COMMONLY ASKED QUESTIONS
REGARDING TELEPHONE EMERGENCY SERVICES
Web Posted on: December 18, 1997
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1. Q: What does the ADA require for telephone emergency services?
A: Public safety agencies that provide telephone emergency services must provide "direct access" to individuals who use telecommunications devices for the deaf (TDD) or computer modems for telephone communication. These agencies must ensure that the services for nonvoice calls are as effective as those provided for voice calls.
The applicable Title II regulation at 28 C.F.R. § 35.162 states:
Telephone emergency services, including 911 services, shall provide direct access to individuals who use TDD's and computer modems.
2. Q: What services are covered by telephone emergency services in Title II?
A: The phrase telephone emergency services applies to basic emergency services - police, fire, and ambulance - that are provided by Public Safety Agencies, including 9-1-1 (or, in some cases, seven-digit) systems. Direct access must be provided to all services included in the system, including services such as emergency poison control information. Emergency services that are not provided by public entities are not subject to the requirement for direct access.
3. Q: What is a telecommunications device for the deaf (TDD), and how does it work?
A: A TDD is a machine that is used in conjunction with a telephone to communicate with others who are deaf, hard of hearing, or who have speech impairments, by typing and reading communications. A TDD user types his or her conversation, which is read on a display by the receiver using a TDD. Both parties must have TDD's to communicate.
A TDD is similar to the teletypewriters used by Western Union to "wire" transmissions. When typing on a TDD, each letter is transmitted by an electronic code called Baudot, which is sent through the telephone line to the TDD on the receiving end of the call -- the same way voiced communications occur between two parties. The receiving TDD transforms the tones back to letters on a small display screen.
4. Q: How are computer modems used as TDD's?
A: A person can use a computer modem to place a call and communicate with someone else who has a TDD or who has a computer with TDD 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 software to translate the ASCII code into Baudot code in order to communicate with another person's system that uses Baudot, or vice versa.
5. Q: What is direct access?
A: Direct access means that telephone emergency services can directly receive calls from TDD and computer modem users without relying on State telephone relay services or third party services.
6. Q: Did the rule establish minimum standards of service (e.g., the number and location of TDD's)?
A: No. When issuing the rule, the Department of Justice decided instead to establish a performance standard through the mandate for direct access.
7. Q: Would one TDD per Public Safety Agency be sufficient?
A: As explained above, while the rule does not specify a minimum number of TDD's required, the services to individuals who use TDD's must be as effective as those provided to other telephone users. Therefore, an agency must provide a sufficient number of TDD's to ensure that all TDD calls are answered directly -- not by State telephone relay services -- and that sufficient equipment is available to continue service in the event of emergency, malfunction, or power failure.
8. Q: What is a telephone relay service?
A: Title IV of the ADA (which is enforced by the Federal Communications Commission) requires States to provide telephone relay services. Such services involve a communications assistant who uses both a standard telephone and a TDD to type voiced communication to the TDD user and read the typed communication to the voice telephone user. State and local agencies may use State relay services to meet the ADA requirements to provide equally effective communication to individuals who are deaf, hard of hearing, or who have speech impairments, but relays may not be used as a substitute for direct access to telephone emergency services.
9. Q: If a Public Safety Agency has TDD's in place, is it in compliance with Title II?
A: Not necessarily. Often, an agency has purchased a sufficient number of TDD's but lacks personnel trained in how to use the TDD's. An agency must take all appropriate steps to ensure that the TDD's will be used properly.
10. Q: What kind of training must a Public Safety Agency provide for call takers
A: In order to ensure the proper operation of TDD's and related equipment as well as the effective processing of TDD calls by call takers, the training program should include general information about the communication issues regarding individuals who are deaf, hard of hearing, or who have speech impairments, including information about American Sign Language; and practical instruction on identification and processing of TDD calls, including the handling of relayed calls and the importance of syntax and TDD protocol when responding.
11. Q: What kind of training should a Public Safety Agency provide for the public?
A: Public education is crucial to the effective processing of TDD calls. Providing public education to promote the correct use of telephone emergency services, including 9-1-1 services, by persons who use TDD's is strongly encouraged.
12. Q: Does title II require that telephone emergency service systems be compatible with all formats used for TDD 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, an agecny is not required to provide direct access to computer modems using formats other than Baudot.
13. Q: In areas without 9-1-1 services, are Public Safety Agencies still required to provide direct access to their telephone emergency services?
A: Yes. Where a 9-1-1 line is not available and the PSA provides emergency services by calling a seven-digit number, it may provide two separate lines - one for voice calls, and another for TDD calls - rather than providing direct access for nonvoice calls on the line used for voice calls. In that case, the services for TDD calls must be as effective as those offered for voice calls in terms of time response and hours of operation (i.e., 24-hour). Also, the PSA must ensure that the TDD number is publicized as effectively as the voice number, and is displayed as prominently as the voice number wherever telephone emergency numbers are listed.
14. Q: In areas with 9-1-1 services, is it acceptable to have a dedicated seven-digit TDD line?
A: Yes. A Public Safety Agency may provide a separate seven-digit line for use exclusively by TDD callers in addition to providing direct access for such calls to the 9-1-1 line. Where such a separate line is provided, callers using TDD's or computer modems would have the option of calling either 9-1-1 or the seven-digit number. Where a 9-1-1 telephone line is available, a separate seven-digit telephone line may not be substituted as the sole means for TDD users to access 9-1-1 services.
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