Reasonable accommodation for hearing loss

Reasonable accommodation is "the necessary and appropriate modification and adjustments, as well as assistive devices and technology, not imposing a situation, where needed in a particular case, to ensure persons with disabilities the enjoyment or exercise on an equal basis with others of all human rights and fundamental freedoms. Reasonable accommodation ensures that persons with disabilities enjoy, on an equal basis with others, all human rights and fundamental freedoms"

-White Paper on the Rights of Persons with Disabilities, 2015

The “denial of reasonable accommodation” can be seen as a form of unfair discrimination. 

Reasonable accommodation support is individual and impairment specific. It includes measures to:

• Make the physical environment accessible

• Provide persons with disabilities with access to information and communication

• Reduce stress factors in the environment

• Accommodate specific sensory requirements like light, noise and spatial stimuli

• Improve independence and mobility of persons with disabilities

• Guarantee participation and supported decision-making by persons with disabilities

• Provide access and participation to quality education and work.

Reasonable accommodation measures include -

• assistive devices

• assistive technology

• personal assistance

• adaptations of the built environment

• signage

• captioning

• text available in audio

• loop systems and FM systems

• alerting/alarm systems for evacuation procedures dedicated SMS lines to all emergency service call centres

• adaptation of (for example) work arrangements and the implementation of flexibility within the workplace to accommodate persons with disabilities.

Reasonable Accommodation Measures

Directives from the White Paper

• Develop national minimum norms and standards

  Minimum norms and standards for reasonable accommodation support measures aimed at providing equal access and participation must be developed and promulgated.

• All public and private institutions must ensure equitable access to and participation in programmes and services. This includes the development and publication of reasonable accommodation measures in service charters and standards across the full spectrum of services.

Minimum Standards for reasonable accommodation of persons who are deaf/hearing impaired may vary from case to case, depending on circumstances – in a place of worship, for example, not all the Standards may apply. The UN Convention on the Rights of Persons with Disabilities and the White Paper should be used as guidelines with special reference to reasonable accommodation measures when Minimum Standards are established.

The following accommodations might be applicable and should be seen to in consultation with the relevant specialist in Universal (Inclusive) Access and Design:

(Points 1 to 13: Primarily related to communication aspects and personal approaches towards disabilities)

1. Personal amplification (hearing aid systems, etc.)

2. Favourable seating (one person with slight loss may cope well in sitting in any row, but someone else with slight loss may find it easier to follow proceedings when sitting in the very front)

3. Sensitisation – in the family or workplace

4. Counselling

5. Monitoring in terms of: 

    • safety — monitoring noise levels and implementing appropriate protection in terms of the Health & Safety Act

    • functionality — are the devices/technology used, in a working condition and do the staff responsible for such devices knowledgeable on how to operate these

    • compatibility of what is implemented with the devices used by staff

    • personally monitoring your hearing loss is crucial. It is reasonable for you to request time off work to do so

6. Amplification during lectures/training: make use of a good sound system (in consultation with the supplier and experts in the field of hearing loss) that is fitting to the size of the room and its acoustics. A microphone should be used by the main speaker and at least two roaming mics should be available for use when there are comments from others in the room. The sound system must be compatible with assistive hearing technologies.

7. Telephonic amplification in line with the individual’s needs, the nature of his work and the telephone in use (e.g. cell phone, landline and more) in consultation with suppliers and experts in the field of hearing loss.

8. Ambient noise is controlled in line with applicable legislation and policies, as well as and in consultation with persons with impairments and experts in the field of disability

9. Communication in writing

10. Assistive listening devices like FM Systems, loop systems, etc. (We view a good quality sound system, making use of roaming microphones together with a loop system as a minimum requirement as it services a large number of people; secondly a loop receiver meant for persons who are deaf or hearing impaired and not the ones meant for technicians who are hearing, should be acquired.)

11. Besides the already mentioned devices and methods to support communication, more options can be considered depending on the individual and the situation faced:                            

• Word to text transcriptions: In a one on one session making use of software like Dragon Naturally Speaking, may be beneficial. Software like this converts spoken communication to text.

  
  

• Note-taking: Note-taking refers to the production of a set of notes for persons who are deaf or hearing impaired, who rely on the notes to follow event proceedings. Note Takers are used in schools, tertiary education settings, at work, on training courses and more. The notes may be taken electronically or manually, depending on the agreement between the service provider and the client.                                                                            

  
  

• Lip speaking: The process wherein a Communication Facilitator referred to as a Lip Speaker (trained to repeat the words a speaker is saying using clear lip patterns) is used to support the lip reader in following proceedings. Lip Speakers can make use of natural gestures and facial expressions.  Lip Speakers are used in situations where it would be difficult for the deaf or hearing impaired person to lip read the actual speaker, for example if the speaker is far off.     

  
  

• Whispered simultaneous interpreting: A Whisper Interpreter interprets directly into the ear of the person who is deaf or hearing impaired or into this person’s assistive device (e.g. an FM system). This form of interpreting may be used in situations like meetings.

  
  

• Sign Language Interpreting:  This is the facilitation of communication between a spoken South African language and South African Sign Language. 

  
  

• Subtitles and subtitling: Subtitles are the text version of audio and is intended for viewers who can hear the audio, but cannot understand the language, for example English text at the bottom of a French movie. Similar to captions, subtitles can also be open or closed.

• Captions and captioning: Captioning is the process of converting the audio content of a television broadcast, film, live event, etc. into text. This text (captions) are then displayed on a screen or monitor. Captions also identify elements like the speaker and sound effects like music, squeaking doors, etc. Captions can be “open” or “closed”. In the case of open captions, the captions are shown on screen and the viewer does not have the option of turning them off. However, with closed captions the viewer has the option to display captions or not. 

  
  

• Live closed captioning refers to the captions that appear at the bottom of the screen during live broadcasting of events (real-time). Stenographers transcribe the audio to text as it happens, with the captions appearing seconds after the audio became available. Voice recognition software may also be used to turn audio into text. As accuracy is a concern, it is best for a Captioner or stenographer to re-speak dialogue into a microphone, after which software like Dragon Naturally Speaking converts it to captions. This way of creating captions is useful when one or more person speaks simultaneously.

  
  

• Stenography: The process of writing in shorthand and transcribing to shorthand on a a typewriter.

  Besides the already mentioned devices and methods to support communication

  
  

  

  
  

(Points 14 to 18: Primarily related to the physical environment)

12. Emotional support: understanding the impact of hearing loss on the individual

e.g. fatigue, anxiety, difficulty in managing stress, depression. Sensitisation

programmes are available and should be utilised.

13. Aural rehabilitation: the individual should be accommodated to attend

rehabilitation services which may include, but is not limited to training on how

to speech read, assertiveness training, assistive hearing technologies and the

use thereof.

14. Emergency alarms to be accessible (light & vibrating)

15. Good signage & pictograms

16. Emergency evacuation procedures to be accessible (e.g. the steps indicated

on the back of hotel room doors)

17. Good lighting & illumination 

18. Good acoustics

The White Paper also defines universal access -

Universal Access refers to the removal of cultural, physical, social and other barriers that prevent people with disabilities from entering, using or benefiting from the various systems of society that are available to other citizens and residents. The absence of accessibility or the denial of access is the loss of opportunities to take part in the community on an equal basis with others.

Closely related hereto is Universal design -

The design of products, environments, programmes and services to be usable by all persons to the greatest extent possible without the need for adaptation or specialised design. Assistive devices and technologies for particular groups of persons with disabilities where these are needed, must also respond to the principles of universal design.

Different approaches or perspectives are accepted when considering disability. The Social Model on disability acknowledges that disability is a social construct and assesses the socio-economic environment and the impact that barriers have on the full participation, inclusion and acceptance of persons with disabilities as part of mainstream society. It is a model that focuses on the abilities of persons with disabilities rather than their differences, that    fosters respect for inability and that recognizes persons with disabilities as equal citizens with full political, social, economic and human rights.

The model does not locate the “problem” within the person with impairment, but acknowledges and emphasizes barriers in the environment which disable the person with the impairment aimed at inclusion rather than exclusion of persons with disabilities from mainstream life. It emphasises the need for broader systemic and attitudinal changes in society, the provision of accessible services and activities, and the mainstreaming of disability to ensure full inclusion of persons with disabilities as equals. The model encourages that persons with disabilities must actively participate in transformation processes that impact on their lives. Also it does not deny the reality of impairment, (an incident of human diversity), nor the impact this may have on the individual.

Source : The White Paper on the Rights of Persons with Disabilities, 2015 Photo credit: Meta AI