2016 CRO RECURRENT COURSE Objectives Whats new Whats

2016 CRO RECURRENT COURSE

Objectives ■ What’s new ■ What’s coming ■ Current key issues ■ Refresher 4/13/2016 T and D Consulting Solutions 2016 CRO Recurrent Course 2

What’s new ■ No new regulations were added to 14 CFR 382 during 2015 ■ One key component is went into effect in December 2015 – Making airline websites accessible to persons with disabilities with respect to 7 core elements: – Booking and changing a reservation including flight amenities – Web check-in – Accessing personal travel itineraries – Accessing flight status – Accessing personal Frequent Flyer accounts – Accessing flight schedules – Accessing carrier contact information ■ Enforcement of this part of the regulation begins June 2016 ■ The remainder of all other web pages must be accessible to people with disabilities by December 2016. 4/13/2016 T and D Consulting Solutions 2016 CRO Recurrent Course 3

What’s New ■ Kiosk accessibility for passengers with disabilities goes into effect at US airports only in December 2016. It is not required at non-US airports ■ 25% of all new kiosks must be accessible ■ 25% of all kiosks must be accessible by 2023 ■ Passengers who request the use of an accessible kiosk must be given priority to use one, when they are under your control ■ When a passenger with a disability is unable to use a kiosk, airline personnel should provide immediate assistance either at an non-accessible kiosk or at the counters ■ Where kiosks are common use, the airlines and airport authority are severaly liable for compliance 4/13/2016 T and D Consulting Solutions 2016 CRO Recurrent Course 4

What’s coming ■ USDOT has requested comments from airlines, aviation organizations, disability organizations and individuals on the following topics: – Ensuring IFE is accessible to passengers with disabilities – Providing greater access to air travel for passengers dependent on in-flight medical oxygen consistent with DG and security requirements – Determining the appropriate definition of a service animal – Establishing safeguards for airline to reduce the likelihood of passengers claiming their pet is a service animal – Addressing the feasibility of adding accessible lavs on new single aisle aircraft The closing date for these comments is on or about 20 January 2016. 4/13/2016 T and D Consulting Solutions 2016 CRO Recurrent Course 5

What’s coming ■ Additionally, DOT is looking at the feasibility of requiring US airports to provide animal relief areas inside the sterile areas of the terminals ■ Increased enforcement of regulations, especially website accessibility which will be handled by 3 rd party contractors 4/13/2016 T and D Consulting Solutions 2016 CRO Recurrent Course 6

Current key issues ■ Service animal acceptance abuse – What you can do to prevent abuse of the privilege 4/13/2016 ■ Observe the behavior of the animal. Service animals are exceptionally well behaved ■ ■ ■ Look for indicators that the dog is a legitimate service dog, e. g. a harness ■ If you have doubts about the validity of the letter, look at the stationery. Is is printed or a photocopy? Call the phone number on the letterhead. Listen to how they answer the phone or if after hours, what the voice mail says. Do not talk with the person who answers. You can tell if the phone is answered with the professionalism of a medical office or not. Ask “What does the dog do for you? ” For Emotional Support dogs, ask for the letter from a licensed mental health professional that is less than 1 year old, states that the passenger is under the professional’s care, has a recognized mental/emotional disability and needs the animal as an accommodation either during the flight and/or at the destination. The letter also needs to have the date, type and jurisdiction of issue of the professional’s license T and D Consulting Solutions 2016 CRO Recurrent Course 7

Current key issues ■ WCHR usage abuse – What you can do to prevent abuse of the privilege 4/13/2016 ■ Check with your local airport authority. Some cities have laws making it at least a misdemeanor to lie to the authorities. Such laws should be posted at your location giving advanced warning. ■ Because airlines are obligated to assist passengers who cannot carry their luggage, airlines may request credible assurance that each passenger requesting this type of assistance cannot carry the luggage in question. You may deny this service if the passenger using the service cannot provide documentation, This may help to reduce the number of requests for the “passenger’s convenience”. Please note that you may not deny the WCHR if the request is made on the basis of needing mobility assistance. You must provide the WCHR, but do not need to carry the baggage in this case T and D Consulting Solutions 2016 CRO Recurrent Course 8

Current key issues ■ Enforcement – DOT has indicated that they will increase enforcement efforts in 2016. – Steps to improve compliance: ■ ■ ■ Ensure all agents are trained and that you can document this training has occurred Do regular briefings and/or refreshers to remind agents of their responsibilities Remind agents to contact the CRO to handle any situation in which the passenger with a disability, or anyone on their behalf, begins to complain about anything When a violation has occurred, the CRO must correct the situation Remind agents to provide details to the appropriate person in the prescribed manner about the details of any situation in which a person with a disability, or anyone on their behalf, complains so a dispositive letter can be written Make sure the information about these verbal complaints are forwarded immediate to the appropriate person to write the letter ■ REMEMBER, COMPLIANCE DEPENDS ON THE PERFORMANCE OF YOUR TEAMS, NOT TRAINING OR WRITTEN POLICIES AND PROCEDURES ALONE 4/13/2016 T and D Consulting Solutions 2016 CRO Recurrent Course 9

Conclusion ■ Regulations requiring airlines to provide EQUAL access for passengers with disabilities are here to stay ■ Airline personnel are required not only to adhere to the letter of the regulation, but also the intent and spirit of the regulation ■ This means that we must treat each passenger as an individual on a case-bycase basis and not to assume that we know what the passenger needs nor to try and give them services they neither need nor want. 4/13/2016 T and D Consulting Solutions 2016 CRO Recurrent Course 10

Quiz Now, please proceed to the test that is attached separately. You need to complete the test to be recertified as a CRO. 4/13/2016 T and D Consulting Solutions 2016 CRO Recurrent Course 11

2016 CRO REFRESHER QUIZ