1. 2019 CRO REFRESHER

2. T and D Consulting Solutions
Objectives
Reviewing Acceptance of Service and Emotional Support Dogs
Reviewing Seating Requirements
Reviewing Acceptance of Assistive Devices Including Dialysis Machines
Safety Assistants
DOT Interpretation
Reviewing when to contact the CRO
Emergency situations
Quiz
6/30/2019
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3. ACCEPTING SERVICE AND EMOTIONAL SUPPORT DOGS

4. Accepting Service and Emotional Support Dogs
The best way to determine if a dog is a legitimate service or emotional support dog is to eliminate “the noise”.
“Noise” is something like the guest intentionally or unintentionally oversharing with you about why they need the dog or perhaps other issues related to their trip.
6/30/2019
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5. Accepting Service and Emotional Support Dogs
A legitimate SERVICE DOG is one that has been individually trained to assist a person with a disability with his/her disability:
Ask “How does the dog help you?”
Look for physical indicators such as a harness or a vest that says this is a service dog
6/30/2019
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6. Accepting Service and Emotional Support Dogs
Observe the behavior
The dog will sit, stand or lie quietly next to the guest usually on the left side
The dog will not pace, jump, approach others, bark or otherwise misbehave in the terminal or on the airplane
The dog will not “do it’s ‘business’ ” inside the terminal.
6/30/2019
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7. T and D Consulting Solutions
6/30/2019
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8. Accepting Service and Emotional Support Dogs
Remember only legitimate Service Dogs and Emotional Support Dogs should be accepted on board the aircraft with no charge regardless how the guest refers to the animal
6/30/2019
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9. T and D Consulting Solutions
SEATING REQUIREMENTS
6/30/2019
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10. T and D Consulting Solutions
Seating Requirements
Airlines are required to provide specific seating accommodation in only 4 cases:
A person requires the use of an aisle chair to get to their seat. The guest must be seated in a row with a moveable armrest but may be seated in any seat in that row
When a person is traveling with a guest with a disability and will assist that guest with the disability during the flight with their disability, they must be seated next to each other
A guest traveling with a service dog, the guest and the dog must be seated in the bulkhead or any seat other than the bulkhead of the guest’s choice provided the dog can fit under the seat in front of the guest without blocking the row or the aisle
When a guest has an immobilized leg, the guest must be seated in the bulkhead or any aisle seat that can accommodate the leg on the aisle
6/30/2019
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11. T and D Consulting Solutions
Seating Requirements
Airlines are NOT required to provide seating accommodation for family members traveling with a person with a disability.
SCENARIO
A person with a service dog is seated in the bulkhead. They are traveling with a spouse and 2 children aged 11 and 14 years. The spouse says that he/she also assists the person with the disability with eating and taking medication and so the entire family must be seated in the emergency exit row.
How do you handle this?
You would want to seat 1 child in the bulkhead with the person who has a disability and the spouse and other child as close as possible, preferably in the row behind if possible. This way they can move and change seats amongst themselves s needed.
6/30/2019
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12. T and D Consulting Solutions
Seating Requirements
If the guest with a disability has a request for a specific seat type, but does not fall into any one of the 4 cases where a specific seating accommodation is required, airlines must try to accommodate the request, if they can do so without changing the seat of another guest If a guest without a disability chooses not to sit next to a guest with a disability, generally because of an allergy, the guest making the request should be re-accommodated, if possible, as far away from the guest with the disability
6/30/2019
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13. ACCEPTING ASSISTIVE DEVICES

14. Accepting Assistive Devices
Airlines are required to accept WCHRs, other mobility aids including scooters and Segways or other assistive devices in the hold if they do not fit in the cabin. This acceptance is contingent on the devices meeting safety and security requirements including size and weight. These items have priority over all other baggage and cargo. If you must off-load other guests’ baggage, the airline must use it’s best efforts to forward the off-loaded baggage on the next flight to the guest’s destination. This might involve sending the baggage by an indirect route.
6/30/2019
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15. Accepting Assistive Devices
There have been questions regarding the acceptance of portable dialysis machines. They are considered assistive devices by DOT. Airlines are also required to accept a “reasonable” amount of supplies. The acceptance of dialysis machines is on a case-by-case basis due to their possible size/weight. In general, DOT believes that machines of up to 100 lbs. (45 kgs.) or slightly more, including the case, to be appropriate. DOT also believes that a 1-2 day amount supplies is an appropriate amount of dialysis liquid for an airline to accept in addition to medications and syringes. Airlines may prohibit guests from using a dialysis machine in flight.
6/30/2019
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16. SAFETY ASSISTANTS

17. T and D Consulting Solutions
Safety Assistants
If an airline decides at check-in it is not safe for a guest to travel unescorted, airlines may require that the guest travel with a companion which will be known as a Safety Assistant. Concern that a guest may not be able to take care of their personal needs such as eating or using the lavatory during the flight is not a reason to require a Safety Assistant. If an airline requires a guest to travel with a Safety Assistant, the airline pays for the Safety Assistant’s transportation.
6/30/2019
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18. Safety Assistants
Airlines may require a Safety Assistant in any one of 4 cases:
The guest is unable to understand and respond appropriately to safety instructions
The guest is traveling on a stretcher (not applicable to DY)
The guest has a mobility disability so severe that they are unable to physically assist in their own evacuation
The guest it BOTH deaf and blind and is unable to communicate with the crew for safety instructions
6/30/2019
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19. INTERPRETING THE REQUIREMENTS
6/30/2019
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20. DOT Philosophy of Consumer Protection
DOT is customer focused. They want airlines to make sure that the guest’s experience is positive
They want airlines to look at situations from the guest’s perspective and to treat each guest as a unique individual person.
They would like airline personnel to handle each situation “on the spot”
Airlines must follow USDOT regulations and their own specific rules and regulations
We must consider each guest’s requests on a case by case basis and provide the requested service, if at all possible
Remember that the division responsible for enforcement is the Consumer Protection Division
6/30/2019
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21. DOT Philosophy of Consumer Protection
Regulatory Language:
MUST = Airlines are REQUIRED to do/not do what that part of the regulation says. This is a legal requirement
SHOULD/MAY = The action specified is OPTIONAL. Airlines have the choice of applying this part of the regulation based on their individual Handling Manuals, but in all situations DOT recommends meeting the guest’s request(s), if at all possible.
6/30/2019
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22. DOT Philosophy of Consumer Protection
US Style
If the part of the regulation doesn’t say the airline MUST NOT do something, then airlines have the option of doing it, if it meets the airline’s policies and procedures.
However, if it is not specifically prohibited by the airline’s rules, DOT recommends doing it, if this is what the guest is requesting and if the airline has the ability to provide the service on the flight.
6/30/2019
T and D Consulting Solutions

23. CONTACTING THE CRO

24. When the CRO becomes involved
Agents MUST make guests aware of the availability of a CRO and then contact the CRO if:
Anyone complains or raises a concern with the agent about discrimination and/or the service a person with a disability is receiving and the agent is unable to immediately resolve the issue to the guest’s satisfaction
If an agent sees an violation in progress or becomes aware that a violation has happened, they should get the CRO to address the issue
6/30/2019
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25. T and D Consulting Solutions
What does the CRO do?
When you, as the CRO, are contacted you must:
Take immediate steps to prevent the situation from becoming a violation
If the violation has actually already happened, you must take steps to reverse the violation if you can do so before the flight has departed
You must also make sure that you inform whomever is responsible to write the dispositive letters the details of the situation so that they can write the appropriate letter within the time limit set out in the regulation.
6/30/2019
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26. Minimizing Violations
Regularly brief your agents and handling company personnel on the requirements of the regulation as it applies to their job responsibilities
Make sure agents are aware that they must inform you any situations that happened with guests with disabilities and how they were resolved
Confirm that all agents and handling company personnel, including WCHR company personnel, have received the required Sensitivity and Awareness initial training and any required refresher training
Ensure that all disability related equipment, e.g. WCHC, is in proper working order
Be observant during your operations to ensure that guests with disabilities are receiving their rights.
Be proactive in correcting potential violations before they become violations
6/30/2019
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27. EMERGENCY SITUATIONS

28. Handling Emergency Situations
Review your airline’s Emergency Response Plan and terminal’s emergency evacuation procedures to see what specifics are in it to assist guests with disabilities
Ensure your agents and handling company personnel know what their responsibilities are in an evacuation especially with respect to guests with disabilities
In the very unlikely situation where you are ever required to implement your airline’s Emergency Response Plan as a result of an incident involving one of your aircraft, keep in mind that you may have to assist people with disabilities. These might be guests who were injured during the incident or a family member who is at your Family Assistance Center (FAC) and you may have to make arrangements to accommodate their specific needs.
6/30/2019
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29. T and D Consulting Solutions
Quiz Now, please proceed to the test that is attached separately. You need to complete the test to be recertified as a CRO.
6/30/2019
T and D Consulting Solutions

30. 2019 CRO refresher quiz