ADA Evacuation Planning Essentials: Accessible Routes, Areas of Refuge, PEEPs and Two-Way Communication

The Americans with Disabilities Act of 1990 and its 2010 Standards for Accessible Design require that places of public accommodation, commercial facilities and government buildings be accessible to people with disabilities. For evacuation planning, this means: accessible means of egress (under IBC Chapter 10 and the 2010 ADA Standards Section 207), areas of refuge for mobility-impaired occupants who cannot use stairs (IBC Section 1009.6), accessible signage including tactile signs (ADA Section 703), accessible warning notification (visual strobes for hearing-impaired, audible alarms for visually impaired), and accessible assembly points (path to the assembly point must be wheelchair-accessible, the assembly point itself must be on a level firm surface). The ADA does not directly mandate PEEPs (Personal Emergency Evacuation Plans), but the practical implementation of accessible evacuation requires PEEPs for each mobility-impaired, visually impaired, hearing-impaired or cognitively impaired occupant. OSHA 29 CFR 1910.38 (Emergency Action Plans) requires the EAP to include procedures for assisting employees with disabilities, which functionally requires PEEPs.

IBC Chapter 10 Section 1009 (Accessible Means of Egress) requires that accessible means of egress be provided from any accessible space in the building. The accessible means of egress can be: (1) An accessible route through a horizontal exit (a fire-rated wall separating two parts of the same building at the same level), (2) An accessible route through a stair that includes areas of refuge at each level above the discharge level, (3) An accessible route through an elevator that meets specific standby-power and fire-protection requirements, (4) An accessible route through a smoke-protected enclosed exterior balcony in some configurations. The accessible means of egress must serve every accessible space; multi-story accessible buildings without accessible elevators must include areas of refuge as the accessible means of egress for floors above the discharge level. The accessible route must be at least 36 inches wide clear and must include all clear-width, slope and surface requirements of an accessible route. The posted plan should depict the accessible egress route with a distinct line style or color so that mobility-impaired occupants can identify the route they should use.

An area of refuge is a fire-rated space within a building where mobility-impaired occupants can wait for assisted evacuation by responders or by trained building staff. Areas of refuge are required under IBC Section 1009.6 in multi-story accessible buildings as part of the accessible means of egress, unless other accommodations are made (horizontal exits, accessible elevators with standby power). Configuration: the area of refuge is typically a smoke-protected lobby or stair landing with at least 30 inches by 48 inches of clear floor space per wheelchair, one wheelchair space for every 200 occupants of accessible spaces served, two-way communication to a constantly-attended location (security desk, fire command center), signage including AREA OF REFUGE text and the international symbol of accessibility, and instructions for use of the two-way communication system. The area of refuge must be on the accessible route from the served spaces and must connect to an exit stair or other means of egress for the occupant's eventual evacuation. NFPA 101 Section 7.2.12 has substantially similar requirements. The posted plan must mark every area of refuge with the international symbol of accessibility and the location.

A Personal Emergency Evacuation Plan (PEEP) is an individualized written plan for the evacuation of a specific occupant who needs assistance during an emergency. PEEPs are not directly required by U.S. federal law but are universal best practice and are required in many U.K. and other jurisdictions. The PEEP includes: the occupant's name and work location, the type of impairment (mobility, visual, hearing, cognitive, temporary impairment such as pregnancy or post-surgery), the specific assistance the occupant needs (evacuation chair, sighted guide, sign-language interpreter, simplified verbal instructions), the names of designated assistants (typically two — primary and backup — who are trained on the procedure and who work in the same area as the occupant), the assigned area of refuge or alternate accessible route, the communication method to alert the assistants and the responders, and the procedure for relocating the occupant from the area of refuge to a final safe location. PEEPs are confidential under disability privacy law (ADA Section 504, GDPR in Europe) and are shared only with the designated assistants, the emergency response leadership and (under controlled access) the responding fire department.

IBC Section 1009.8 requires a two-way communication system at each area of refuge connecting the refuge to a constantly-attended location (typically the security desk, fire command center or central monitoring station). The two-way system allows the occupant in the refuge to communicate their location and status to the attended location, and allows the attended location to provide instructions and reassurance during the wait for assisted evacuation. The system must be hardwired (not cellular) to ensure availability during loss of cell service, must include both audible and visible signaling (so the occupant can communicate even if their phone or other personal device is lost), must include backup power for the same 90-minute duration as emergency lighting, and must include signage explaining how to use the system (visible signs and tactile signs with Braille). Many systems are now augmented with video so the attended location can see the occupant in the refuge — useful for confirming identity, status and number of persons waiting. The posted evacuation plan does not need to depict the two-way system in detail but should mark the areas of refuge so occupants know where to wait for communication.

Designated assistants — typically co-workers in the same area as the occupant needing assistance — must be trained on the specific assistance procedure. Training topics include: how to recognize the alarm and respond, how to verify the occupant's location and needs, how to operate an evacuation chair if one is used, how to escort the occupant to the area of refuge or alternate accessible route, how to operate the two-way communication system in the area of refuge, when to leave the occupant in the area of refuge and proceed to safety themselves vs when to wait, how to coordinate with arriving responders. The two-assistant model — primary and backup — ensures that the occupant has assistance even if the primary assistant is unavailable on the day of the event. Training is repeated annually and after any change of personnel, area assignment or building configuration. Some facilities run annual PEEP-specific drills focused on the area-of-refuge procedure and the assisted-evacuation execution. PEEPs are reviewed at least annually and whenever the occupant's needs change.

EvacPlan Generator (www.evacplangenerator.com) supports ADA evacuation planning through: (1) Accessible egress routes drawn as a distinct color or line style (typically a dashed green-and-blue line) so that mobility-impaired occupants can identify their route. (2) Area of refuge icons (the international symbol of accessibility on a green field) placed at each refuge location, with text annotations identifying the refuge by name (Area of Refuge - Stair A Landing - Floor 3). (3) Accessible assembly point icons placed at the designated accessible muster point, which may differ from the general muster point if the accessible point provides better surface and shelter. (4) Two-way communication icon (a stylized handset symbol) placed at each area of refuge to indicate the system. (5) The MAP KEY automatically includes all ADA-related symbols once placed, providing a complete legend for accessibility features. The plan can be produced in multiple sizes — large posted plans at building exits and reduced 8.5x11 plans for inclusion in the PEEP documents — using the same source. ADA evacuation planning is one of the most rewarding applications of a well-designed posted plan because the plan is the lifeline for occupants whose evacuation depends on others knowing where they are.