Body Memo 2.i NA2019

MEMORANDUM OF UNDERSTANDING: Reasonable Accommodation for the Deaf and Hard of Hearing

MANAGEMENT'S RESPONSIBILITY
Management has an obligation to reasonably accommodate impaired employees and applicants who request assistance in communicating with or understanding others in work related situations, such as:

1. During investigatory interviews which may lead to discipline, discussions with a supervisor on job performance or conduct, or presentation of a grievance.
2. During some aspects of training, including formal classroom instruction.
3. During portions of EAP programs and EEO counselings.
4. In critical elements of the selection process such as during testing and interviews.
5. During employee orientations and safety talks, CFC and Savings Bond Kickoff meetings.
6. During the filing or meetings concerning an employee's OWCP claim.

IMPLEMENTATION
This obligation is met by selecting an appropriate resource from the variety of resources available. In selecting a resource, the following, among others, should be considered, as appropriate:

• The ability of the deaf and hard of hearing employee to understand various methods of communication and the ability of others to understand the deaf and hard of hearing employee.
• The importance of the situation as it relates to work requirements, job rights, and benefits.
• The availability and cost of the alternative resources under consideration.
• Whether the situation requires confidentiality.

Available resources which should be considered include:

1. Installation heads are authorized to pay for certified interpreters. Every effort will be made to provide certified interpreters when deemed necessary by an application of the principles set forth herein.
2. In some states, the Division of Vocational Rehabilitation (DVR) provides interpreters at no charge.
3. Volunteer interpreters or individuals skilled in signing may be obtained from the work force or from the community.
4. In some situations, written communications may be appropriate.
5. Supervisors, training specialists, EAP, and EEO counselors may be trained in sign language.
6. Deaf and hard of hearing applicants should normally be scheduled for a specific examination time when an interpreter will be available.

Management will provide the following assistance for deaf and hard of hearing employees.

1. All films or videotapes designed for the training or instruction of regular work force employees developed on or after October 1, 1987, shall be opened or closed captioned. To the extent practicable, existing films or videotapes developed nationally that will continue to be used by the deaf and hard of hearing with some frequency, will be opened or closed captioned.
2. Special telecommunications devices for the deaf and hard of hearing will be installed in all postal installations employing deaf and hard of hearing employees in the regular work force. These devices will be available to deaf and hard of hearing employees for official business and in the case of personal emergencies. As appropriate, Management will provide training to staff on the use of these special telecommunication devices.
3. A visual alarm will be installed on all moving powered industrial equipment in all postal installations employing deaf and hard of hearing employees in the regular work force.
4. Visual fire alarms will be installed in all new postal installations (installations for which the U.S. Postal Service, as of the effective date of this agreement, has not awarded a contract for the design of the building) where the Postal Service installs audible fire alarms. The parties will discuss and seek to agree at the local level about the installation in such other facilities as may be appropriate.

JOINT LABOR-MANAGEMENT MEETINGS
Discussion of problem areas with regard to the use of certified sign interpreters, enhancement of job opportunities for the deaf and hard of hearing, type of special telecommunications devices to be installed, and installation of visual alarms at other than new postal installations are appropriate matters for considerations at Joint Labor-Management meetings. Discussion of such matters at Labor-Management meetings is not a prerequisite to the filing or processing of a grievance.