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.
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.
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.
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