Access for 9-1-1 and Telephone Emergency Services
I. Introduction
Dialing 9-1-1 is the most familiar and effective way Americans have of finding help in an emergency.
The Americans with Disabilities Act (ADA) requires all Public Safety Answering Points (PSAPs) to
provide direct, equal access to their services for people with disabilities who use teletypewriters
(TTYs), which are also known as "telecommunications devices for the deaf (TDDs)."
This document is part of a technical assistance program to provide State and local governments and
persons with disabilities with information about the requirements of the ADA for direct, equal access
to
9-1-1 for persons with disabilities who use TTYs. This guidance is an updated version of the
Department of Justice's earlier guidance entitled, "Commonly Asked Questions Regarding Telephone
Emergency Services." It explains in practical terms how the ADA's requirements apply to 9-1-1
services, including equipment, standard operating procedures, and training, and should be useful to
9-1-1 service providers, equipment vendors, participating telephone companies, and individuals with
disabilities.
Different emergency providers may have different capabilities and features. For instance, some larger
providers have "Enhanced 9-1-1" or "E9-1-1," which automatically identifies for 9-1-1 call takers
the telephone number and/or address of callers. Some providers have call distribution systems,
which place incoming calls in a queue and distribute them to the next available call taker. Other,
smaller providers, may not have these capabilities. This guidance can be useful to all types of
telephone emergency providers, both small and large.
A. ADA Coverage of Telephone Emergency Services
Title II of the ADA covers telephone emergency service providers and other State and local
government entities and instrumentalities. The Department's regulation is published at 28 C.F.R. Part
35. To obtain a copy of the ADA or its implementing regulations, or if you have questions about the
ADA, contact the Department of Justice ADA Information Line at (800) 514-0301 (voice), or
(800) 514-0383 (TTY), or access the Department's ADA Home Page at
http://www.usdoj.gov/crt/ada/adahom1.htm
Q: What types of telephone emergency services are covered by Title II of the ADA?
A: The phrase "telephone emergency services" applies to basic emergency service --
police, fire, and ambulance -- that are provided by public safety agencies, including
9-1-1 (or, in some cases, seven-digit) systems. Direct, equal access must be provided
to all services included in the system, including services such as emergency poison
control information.
Q: In areas without 9-1-1 services, are PSAPs still required to provide access for
TTY users to the telephone emergency services?
A: Yes. Where 9-1-1 is not available and a PSAP provides emergency services via a
seven-digit number, it still must provide direct, equal access to TTY callers. It may do
so either by having one line for both voice and TTY calls, or it may provide two
separate lines -- one for voice calls, and another for TTY calls. Requiring TTY callers
to call a separate seven-digit number is not allowed in areas where 9-1-1 is offered,
because having to dial a seven-digit number is not equal to the ease of having to dial the
simple, familiar 9-1-1.
As with 9-1-1, services for TTY calls on seven-digit numbers must be as effective as
those offered for voice calls in terms of time of response, hours of operation, and other
features. Also, PSAPs must ensure that TTY numbers are publicized as effectively as
voice numbers and displayed as prominently as voice numbers wherever telephone
emergency numbers are listed.
Separate Telephone Lines for TTY Users
Q: Can a PSAP dedicate a separate seven-digit line for TTY calls?
A: Yes, but TTY users must also have direct, equal access to all call-taking positions
on 9-1-1 lines. A PSAP cannot require TTY users to call a seven-digit number when
voice callers may dial the more familiar 9-1-1.
B. TTYs & Telephone Relay Services
A TTY is a device that is used in conjunction with a telephone to communicate with persons who are
deaf, who are hard of hearing, or who have speech impairments, by typing and reading text. To
communicate by TTY, a person types his or her conversation, which is read on a TTY display by the
person who receives the call. Both parties must have TTYs to communicate. When typing on a TTY,
each letter is transmitted by an electronic code called Baudot, which is sent from the TTY on the
sending end of the call through the telephone line in the form of tones to the TTY on the receiving
end of the call, the same way voiced communications occur between two parties. The receiving TTY
transforms the tones back to letters on a small display screen.
Communication between two persons using standard TTYs can only occur in one direction at a time.
Thus, both persons who are conversing cannot type to each other at the same time; they must take
turns sending and receiving. A person sending a communication by TTY indicates that he or she has
finished transmitting by typing the letters "GA," which stand for "go ahead."
A person can also use a computer with a TTY modem and related software to communicate with
someone who has a TTY or who has a computer with TTY software and a modem. Computers
generally operate in American Standard Code for Information Interexchange (ASCII), an electronic
"language." A person who uses ASCII must use an ASCII/Baudot modem and related software to
convert the ASCII code into Baudot code, in order to communicate with another person who is
using a Baudot-based system. Similarly, a person who is using a Baudot-based TTY must utilize
conversion software to communicate with a person using an ASCII-based computer.
Telephone relay services are provided by States, as required by Title IV of the ADA, and are
regulated by the Federal Communications Commission. Relay services involve a communications
assistant who uses both a standard telephone and a TTY to type voice communication to a TTY
user and read a TTY user's typed communication to a voice telephone user. Telephone relay
services are not as effective for emergencies, because they are far more time-consuming than calls
between two TTYs.
Q: Does Title II require that telephone emergency service systems be compatible with
all codes used for TTY communications?
A: No. At present, telephone emergency services must only be compatible with the
Baudot format. Until it can be technically proven that communications in another format
can operate in a reliable and compatible manner in a given telephone emergency
environment, a State or local government agency is not required to provide direct
access to computer modems using formats other than Baudot.
Q: Can PSAPs rely on State relay services to answer emergency calls from persons
who are deaf, hard of hearing, or who have speech impairments?
A: No. The Title II regulation specifically prohibits emergency telephone service
providers from relying on relay services. Relay services do not provide "direct access,"
because they require the services of a third party and are far more time-consuming than
direct TTY calls. However, if a person placing a call to a PSAP voluntarily chooses to
rely on a telephone relay service, the PSAP must answer and respond appropriately to
such a call.
II. Direct, Equal TTY Access
A. General Requirements for Telephone Emergency Service Providers
The ADA regulation requires 9-1-1 or other telephone emergency service providers to provide TTY
users with:
direct access; and
an opportunity to benefit from the emergency services that is equal to the opportunity afforded
others.
Direct access means that PSAPs can directly receive TTY calls without relying on an outside relay
service or third-party services.
Equal access means that the telephone emergency services provided for TTY users are as effective
as those provided for persons who make voice calls, in terms of:
response time;
response quality;
hours of operation; and
all other features offered (e.g., automatic number identification, automatic location
identification, automatic call distribution).
Direct, equal access requires PSAPs to have the appropriate equipment to communicate with people
who use TTYs. It also requires them to use the proper procedures and practices when TTY calls are
received.
B. Equipment
Number of TTYs
In order to afford equal access to TTY users, every call-taking position within a PSAP
must have its own TTY or TTY-compatible equipment. PSAPs must have systems that
enable call takers to handle TTY calls as properly, promptly, and reliably as voice calls.
Every call-taking position needs its own TTY equipment because experience has
shown that:
With TTY or TTY-compatible equipment at each call-taking position, call takers
can handle TTY calls as effectively as voice calls.
Call takers at PSAPs that had only one TTY per center had significant difficulties
handling TTY calls within their standard answering time.
Sharing a TTY among several call takers may result in undue delay in obtaining
the TTY and connecting it to the answering position.
Transferring a TTY call from a non-TTY-capable answering position to a
TTY-dedicated position may result in the call being disconnected or undue delay
in answering the call. In some cases, transfers may result in the loss of enhanced
features, such as automatic number identification and automatic location
identification information.
Each call taker needs to query every silent, open line call as a potential TTY call,
as described in Section D, below. Because most PSAPs receive many silent,
open line calls, often more than one at a time, each calltaker must have his or her
own TTY equipment to be able to query all of those calls with a TTY.
Thus, PSAPs may not provide TTY equipment at only a limited number of positions,
such as, at only a supervisor's position, or at only one dedicated call taker's line.
PSAPs must have systems that respond to TTY calls as promptly and reliably as they
respond to voice calls. Call takers cannot be required to transfer TTY calls to specific
phone lines or locations, unless voice calls are also transferred under the same
circumstances. Transfers consume critical time, greatly increase the risk that the call will
be disconnected, and may result in the loss of enhanced features, such as automatic
number identification and automatic location identification information.
People other than "dedicated" call takers often act as call takers and therefore must
have their own TTY equipment. For instance, dispatchers will often take overflow
emergency calls when all dedicated call takers are busy, and supervisors may take calls
on occasion. Every person who takes emergency calls from the public under any
circumstances must have their own TTY equipment for the same reasons that dedicated
call takers must have their own TTY equipment.
Q: If a PSAP has only received a few TTY calls per month over the past year, why
does it need TTYs at every call-taking position?
A: Most PSAPs receive many silent open line calls, which may be TTY calls. In order
for call takers to know if silent calls are TTY calls, each call taker will need TTY
equipment to query every silent call with a TTY. It is possible that call takers have been
receiving more than a few TTY calls per month, but have treated them as silent lines or
hang-ups rather than TTY calls. This is likely if the call takers have not been querying
all silent lines with TTYs. Some of those silent lines or hang-ups may have been TTY
users waiting for a TTY response.
Historically, many persons who use TTYs have not had confidence in the accessibility
of 9-1-1 services and have not attempted to make direct TTY calls to their PSAP. The
number of TTY calls each PSAP receives is likely to increase in the future, as PSAPs
become more accessible to TTY users, and as TTY users learn of PSAPs' improved
accessibility.
Q: If a PSAP complies with a State law, which requires only one TTY per PSAP, is
that PSAP also in compliance with the ADA?
A: No. Satisfying State law requirements does not mean that a PSAP is also in
compliance with the ADA. Some State laws require only one TTY per PSAP. The
ADA, however, requires direct, equal access, which means that PSAPs must have
enough TTY equipment so that each call-taking position has its own TTY capability.
Also, if a PSAP has extra voice telephone equipment in case of malfunction, which
most do, the ADA would also require them to have back-up TTY equipment.
Therefore, under the ADA, virtually all PSAPs must have two or more TTYs.
Enhanced Features
Many PSAPs have advanced features that facilitate prompt responses to callers. Many
PSAPs have, for example, automatic number identification (ANI) and automatic
location identification (ALI), which tell the call taker the phone number and address
from which a call originates. PSAPs that have these features must ensure that TTY calls
have the same access to enhanced features as do voice telephone calls. TTY calls may
not be required to be transferred to a third line, because those transfers often result in
the loss of the automatic phone number and address information. Another feature
employed by PSAPs is automatic call distribution (ACD), which places incoming calls
into a queue, sends out a programmed message to callers to let them know that their
calls have been received, and distributes calls to the next available call taker. This
feature, if offered, must also be made accessible for TTY calls, with a programmed
TTY message.
Relationship Between Primary and Secondary PSAPs
Primary PSAPs (9-1-1 answering points) often transfer calls to secondary PSAPs
(such as fire or emergency medical services) if they do not dispatch those services
directly from the primary PSAP. In those transfer situations, PSAPs must correctly
transfer TTY calls, as they do voice calls. Secondary PSAPs have the same
responsibilities under the ADA as do primary PSAPs, and they must be able to receive
transferred TTY calls as efficiently and as effectively as voice calls.
C. Other Requirements for TTY Equipment
Maintenance and Back-Up
The ADA regulation contains a specific provision requiring that covered entities
maintain their accessibility features and equipment in operable working condition. In
addition to this specific maintenance requirement, the ADA's equal access requirement
obligates PSAPs to implement equally effective procedures for maintenance and
back-up capability for TTY equipment as they provide for voice telephone equipment.
For example:
TTY equipment must be maintained and tested at least as often as voice
telephone equipment, to ensure that the equipment is operating properly. If
PSAPs check their voice telephone equipment every day to make sure it is
working, they must do so every day for TTY equipment. Similarly, if PSAPs
have contracts with outside companies for maintenance of their voice telephone
equipment, they must employ equally effective methods for TTY equipment.
Most PSAPs have plans for using back-up equipment in case some of its
equipment or telephone lines malfunction, or in case there is a power failure. If a
PSAP has such a plan for voice calls and equipment, it must provide for TTY
calls and equipment in that plan. For instance, PSAPs should keep extra TTY
equipment on hand, in case the primary equipment fails, if they have back-up
voice telephone equipment for such a situation.
Switching Between Voice and TTY Modes
All call takers must have the capability to switch back and forth easily from TTY mode
to voice mode during the same call. This capability is necessary especially for silent
calls, since call takers are required to first query the line by voice and then quickly
switch to query the line by TTY. This capability is also necessary for VCO and HCO,
which are described below. VCO and HCO shorten the lengths of calls that would
otherwise be conducted exclusively by typing. Call takers who use stand-alone TTYs
can switch from TTY mode back to voice mode simply by removing the telephone
handset from the TTY couplers. TTY-compatible consoles for call takers should have
built-in switching capability.
Q: What is VCO? Who uses it?
A: VCO is voice carryover. It is a communication hybrid of TTY and voice. VCO
allows a person with hearing loss to speak directly to the call taker and read the
response that is typed back. Many persons who became deaf or hard of hearing later
in life prefer to speak instead of type. They use what is called voice carryover (VCO).
With VCO, the caller speaks directly into the phone, and the call taker types back via
TTY to the caller. VCO can be accomplished with standard stand-alone TTY
equipment simply by having the call taker alternate between listening on the handset
when the caller is speaking and placing the handset in the TTY couplers to type a
response.
Q: What is HCO? Who uses it?
A: HCO is hearing carryover. People with speech impairments who are not deaf or
hard of hearing often prefer HCO. HCO allows them to type their words on a TTY to
call takers and hear call takers' spoken responses through their handset. HCO can be
accomplished by a call taker using standard stand-alone TTY equipment by alternating
speaking into the handset and placing the handset in the TTY when the caller types a
response.
D. Procedures for Handling TTY Calls
In addition to proper equipment, direct, equal access for TTY calls requires that PSAPs use
effective procedures for recognizing and responding to TTY calls.
Recognizing TTY Calls/Treating Silent, Open Lines as Potential TTY Calls
All call takers must be able to recognize and handle TTY calls properly. There are
three types of TTY calls a call taker may receive. Some TTYs emit a recorded spoken
announcement to the call taker that a TTY call is being placed, such as "HEARING
IMPAIRED CALLER. USE TTY." Other times, TTY callers may press TTY keys to
emit audible tones and more quickly notify the call taker that a TTY call is being
placed. Most often, however, a person using a TTY will make a call that is perceived
by the call taker as a silent, open line call. This is because the caller's equipment does
not recognize that the call has been answered until the call taker sends a TTY response.
The only way for PSAPs to properly identify all TTY calls is for call takers to recognize
TTY tones and to query every silent, open line call with a TTY to determine if it is a
TTY call after it has been queried by voice.
Requiring Callers Using TTYs to Press a Key
In the past, some PSAPs have required callers using TTYs to press the space bar or
other keys after they call, to emit tones and notify call takers that it is a TTY call. This
requirement violates the ADA. Requiring TTY callers to press keys repeatedly until
recognized is unfamiliar to most TTY callers, and callers cannot be relied on to perform
such unfamiliar tasks, especially in emergency situations. Further, in many emergency
situations there may not be time or opportunity to press keys repeatedly until
recognized.
ILLUSTRATION: A 9-1-1 call taker answers a call, responds with a
standard spoken greeting, and expects to hear a spoken response. If the
call taker receives a silent, open line, the call taker should query the line
verbally a second time, and then query the line using a TTY to determine
if the call is from a TTY user.
TTY Detection Equipment
Q: If a PSAP uses TTY detection equipment, does it still have to query every silent call
with a TTY?
A: Yes. Some PSAPs have installed equipment that detects TTY calls and produces a
voice announcement to the call taker that a TTY call has come in. TTY detection
equipment, however, only recognizes TTY calls that transmit tones, such as when
callers press keys to emit tones. This equipment will not recognize TTY calls when the
caller does not emit tones and instead waits for a TTY response before transmitting.
Thus, TTY detection equipment does not eliminate the need for call takers to query
every silent line with a TTY.
Dispatching Police to Origin of Silent Calls
It is not sufficient merely to dispatch police to the origins of all silent, open lines, in lieu
of querying the lines with a TTY. Precious time may be lost by sending the police if the
caller needs another type of response, such as fire or emergency medical services. All
silent, open lines must be queried with a TTY to assess the basis for the call and to
dispatch the appropriate emergency equipment and personnel.
Conducting TTY Calls
After TTY calls are recognized, call takers must effectively communicate with callers
during the calls. Effective communication by TTY will require call takers to be familiar
with the use of TTY equipment and TTY protocols.
E. Training
PSAPs must train their call takers to effectively recognize and process TTY calls. Call takers must
be trained in the use of TTY equipment and supplied with information about communication protocol
with individuals who are deaf or hard of hearing, or who have speech impairments. For instance,
callers who use American Sign Language use a syntax that is different from spoken English. In
addition, in TTY communication, certain accepted abbreviations are frequently used. A list of some
of those abbreviations is attached to this document.
The ADA does not specify how call takers must be trained, but the Department believes that the
following are essential to proper training:
Training should be mandatory for all personnel who may have contact with individuals
from the public who are deaf, hard of hearing, or who have speech impairments.
PSAPs should require or offer refresher training at least as often as they require or offer
training for voice calls, but at a minimum, every six months.
Comprehensive training should include:
Information about the requirements of the ADA and Section 504 of the Rehabilitation
Act for telephone emergency service providers;
Information about communication issues regarding individuals who are deaf or hard of
hearing, or who have speech impairments, including information about American Sign
Language;
Practical instruction on identifying and processing TTY calls, including the importance
of recognizing silent TTY calls, using proper syntax, abbreviations, and protocol when
responding to TTY calls and relayed calls; and
Hands-on experience in TTY communications, especially for new call takers, as part of
their initial training orientation.
To ensure the effectiveness of training, PSAPs may want to consult the Emergency Access
Self-Evaluation program, published as a manual by Telecommunications for the Deaf, Inc., under a
Department of Justice grant. The EASE manual, which was reviewed by the Department, can be
obtained for a fee by calling TDI at (301) 589-3786 (voice), (301) 589-3006 (TTY), or (301)
589-3797 (FAX).
F. Testing
The Department believes that frequent testing is essential to ensure direct, equal access. Testing call
takers and their equipment is also the one of the most effective ways to ensure compliance with the
ADA's requirement that accessibility features are maintained in operable working condition. The
ADA does not specify how testing is to be conducted. We believe, however, that PSAPs should
conduct an internal testing program in which they conduct random TTY test calls of each call-taking
position. The tests should be designed to ascertain whether TTY equipment functions properly and
whether personnel have been adequately trained to recognize TTY calls quickly, to operate TTY
equipment, and to conduct TTY conversations. The Department recommends the following for an
effective testing program:
To test whether call takers have been trained adequately to recognize TTY calls, a
PSAP should conduct two types of test calls--silent, open line calls in which no tones
are emitted and calls in which the caller introduces the call by transmitting TTY tones.
Tests should be unannounced.
It is best for PSAPs to keep records of the results of all test calls, including, at a
minimum: the date and time of each test call; identification of the call taker and
call-taking position; whether each call was silent or transmitted tones; whether the caller
received a TTY response and the content of the TTY response; the time elapsed and
number of rings from the initiation of the TTY call until the call taker responded by
TTY; and whether the call was processed according to the PSAP's standard operating
procedures. The testing program should cover each call taker and each position.
Some Helpful TTY Abbreviations
ASAP - As soon as possible
CD or CLD - Could
GA - Go ahead, your turn to talk
GA or SK - Go ahead or Goodbye
HCO (Hearing Carry Over) - TTY user will use his/her hearing during call
HD or HLD - Hold, Please
MSG - Message
NBR or NU - Number
PLS - Please
Q or QQ - Question mark
R - Are
SHD - Should
SKSK - Stop Keying, means end of conversation
TMW - Tomorrow
TTY - Teletypewriter
U - You
UR - Your
VCO - (Voice Carry Over) TTY user will use his/her voice during the call
XXXX - Error, Erase
This document is available in the following formats for persons with disabilities --
- Braille
- Large print
- Audiocassette
- Electronic file on computer disk and electronic bulletin board, (202) 514-6193
To obtain these documents in alternate formats, call the Department of Justice ADA Information
Line, (800) 514-0301 (voice), (800) 514-0383 (TDD).
Note: Reproduction of this document is encouraged.
July 15, 1998
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