UC gave its campuses an evacuation chair checklist — a year later, one had finished

No. Not the California Building Code, not the International Building Code, not NFPA 101, and not the ADA. The only treatment of evacuation chairs in an official federal source is a placement caution from the US Access Board, which notes that it is important that evacuation chairs be located so that they do not obstruct a required means of egress. The Department of Justice's own Title II emergency management checklist does not mention evacuation chairs at all.

That surprises people, and it is worth sitting with, because the absence runs the other way from what you would expect. Two code provisions remove the alternatives. Elevators are recalled under ASME A17.1 Phase I when a fire alarm actuates — the cars travel to a designated level and stay there under firefighter control, which is a life-safety feature and also means the elevator is not an exit. And California Building Code section 1009.3.3 exempts a building equipped throughout with an automatic sprinkler system from providing an area of refuge at the exit stairway, along with Group R-2 residential occupancies.

Put those together for a sprinklered academic building — which is most of them — and a person who cannot descend stairs has no elevator and no code-required refuge. What remains is a plan, or nothing.

One authority, and it is not the one most campuses cite. The California Fire Code requires procedures for assisted rescue for persons unable to use the general means of egress unassisted, and it requires named personnel assigned to perform that rescue. It requires accessible egress routes and assisted-rescue locations to appear on the floor plans. It requires employee training on assisted rescue to be reviewed at intervals not exceeding three months. And it requires drill records.

The authorities campuses usually name are thinner than they sound. The Clery Act requires an annual test of emergency response and evacuation procedures and requires documenting, for each test, a description of the exercise, the date, the time and whether it was announced or unannounced — but it never mentions disability or accessibility anywhere in that provision, a tabletop exercise satisfies the definition of a test, and nothing requires recording whether the people who would need assistance were accounted for. California's Cal/OSHA emergency action plan rule requires a written plan with evacuation procedures and exit route assignments, and it too is silent on anyone who cannot self-evacuate.

The ADA and Section 504 do bind, but they bind differently. The Department of Education's Office for Civil Rights has put it plainly: Title II and Section 504 do not contain specific provisions that set out what must be included in emergency evacuation plans. The enforceable test is the general nondiscrimination duty, applied case by case — whether evacuation was equal to and as effective as what nondisabled people received. Which is why every higher-education OCR matter we could find turned on the absence of a documented plan rather than the absence of equipment.

On March 19, 2024, UC President Michael V. Drake wrote to the Chancellors with a two-page letter and a three-page Emergency Preparedness and Evacuation Checklist. It is worth being precise about its force, because it is widely described as a mandate and it is not phrased as one. The operative sentence reads: I am requesting that you designate a responsible representative and complete the checklist by June 30, 2024. Conformance was to be verified quarterly until achieved, then annually.

The chair requirements are graduated, and the section containing them is captioned Emergency Evacuation Chairs (Where Provided). One requirement is unconditional: each multi-story building in campus housing must have a minimum of one emergency evacuation chair. High-traffic multi-story buildings — libraries, student centers, sports venues, high-occupancy classroom buildings — get a minimum of one, and campuses should endeavor to provide one per building elsewhere. Beyond that, chairs are provided on request through an individualized plan.

The more demanding half of the checklist is not equipment at all. Campuses are to maintain a list of individuals responsible for managing, accessing and deploying the chairs; provide and maintain records of proper and regular training to those individuals; provide and maintain records of ongoing maintenance; and build and maintain a list of the location — building, floor, stairwell — of every evacuation chair on campus. The Campus Fire Marshal and Building Official are to confirm placement. And individualized plans are to be tested during all building evacuation drills.

There is also a procurement instruction inside the checklist that rarely gets read as one. Campuses must develop the processes to ensure funding for chairs upon request, timely purchase and installation of chairs, and clear communication with the requesting individual about the time to deployment. In other words, UC told its campuses that being able to buy a chair quickly is itself part of the program.

UC answered that itself. In a discussion item prepared for the Board of Regents meeting of March 19, 2025 — exactly a year after the letter — the recommendation to create a disability-inclusive emergency evacuation plan and train key staff was scored: 1 Campus has Completed, 9 Campuses are In Progress. The same document confirms that all ten locations had designated a trained representative, so the first step was done everywhere. It was the program that stalled.

Two caveats belong on that number. It is self-certification to the Office of the President rather than an external audit, and there is no published consequence for non-conformance. And it is the most recent scorecard we could find, which means the figure describes March 2025, not today.

Money was not the obstacle. The same report records $8 million in one-time funding allocated by the President with campus matching, plus $1.5 million ongoing from the Budget Act of 2023, also matched. Evacuation is listed among the uses, though it is not broken out.

One pattern is visible from the outside. Of the ten campuses, two publish an evacuation chair inventory — UC San Diego lists 24 building locations with a named custodian for each, and UC Irvine reported completing 282 stair chairs across 56 buildings in June 2025, a year after the deadline. The rest do not publish one, which is not the same as not having one. But the checklist asks for that list, and the gap between campuses is a documentation gap rather than an equipment gap.

UC Berkeley gives the clearest answer, because it converted the systemwide checklist into binding campus policy — issued December 2, 2024, effective December 31, 2025, owned by its Office of Emergency Management. The language tracks the checklist almost word for word, including the requirement to build and maintain a list of the location of all emergency evacuation chairs. It adds the commitment that makes the rest real: requests for individualized plans are to be addressed within two weeks.

For the training itself, the useful specification is not a manufacturer's. NIST Technical Note 1824 sets out initial classroom instruction plus practical training, with stair practice over at least three floors so that practice on landings can occur, refresher practicals twice a year, a minimum of two operators, more than one assigned assistant per person, and immediate reassignment if an assigned buddy leaves. It also recommends a floating pool of trained operators for visitors, which is the part most programs miss.

Worth knowing how the standards divide. The device is standardized — ANSI/RESNA ED-1:2019 covers design, performance, inspection, installation and maintenance. The operator is not. We could find no accrediting body in the United States or the United Kingdom for evacuation chair operators; training certificates are issued by manufacturers and training providers against their own criteria. Which means the record you keep is the only evidence you will be able to produce.

Then there is frequency. No statute sets an inspection interval; the convergent practice is an annual competent-person inspection with routine visual checks between. The California Fire Code is more demanding on the human side than any standard is on the hardware: assisted-rescue training reviewed at intervals not exceeding three months.

The clearest answer on record comes from a high school rather than a campus, and it is worth reading for that reason — the failure modes are not specific to higher education. In a complaint filed against New Rochelle High School in New York, the US Department of Justice documented what happened on January 31, 2013, when a fire alarm sounded and two students who used wheelchairs were not evacuated.

The chairs existed. Two evacuation chairs were purchased and arrived at NRHS in or around August 2012, the complaint states, but they remained in storage until after the January 31, 2013 incident. At the time, no evacuation chair was available for use in the Main Building. Only two security guards, at most, had been given training on their use. A written protocol directed staff to carry one student down and place him in a wheelchair at the bottom of the steps; his aide stated that a wheelchair had never been placed at that location. Another aide said that before the incident she had had no idea what she would do during an actual evacuation. The school had hired safety consultants in 2011 and 2012 to review its plan, and there were no discussions with these consultants about a plan for evacuating mobility impaired students.

The detail that should trouble anyone who runs drills is this one. It was the policy of the school not to evacuate students with mobility impairments during drills — and one student's aide would be alerted by a security guard before the drill and would take him out of the building using the elevator before the drill began. The drill ran. The record showed a drill. The only thing that would fail in a real fire was never tested.

On the day, both students and their aides waited. There were no further communications, the complaint records. They remained there until the all clear signal was given and were never evacuated.

This is the part of the checklist that defeats good intentions. A student requests an individualized plan; Berkeley's policy says the request is answered within two weeks; the checklist says purchase and installation must be timely. A normal competitive procurement does not run on that clock.

California gives public buyers a faster path, and the University of California's version is the most generous we found anywhere. Under UC's Small Business First program — set out in Presidential Policy BFB-BUS-43 — to purchase goods or services valued between $10,000 and $100,000 annually, the University must only obtain one quote from either a certified small business or a Disabled Veteran Business Enterprise. Between $100,000 and $250,000, at least two quotes are required, which is also what the underlying statute, Public Contract Code section 10508.5, authorizes. Worth noting for anyone who has seen the statute cited for the single-quote rule: it contains no provision below $100,000. The one-quote rule is UC policy.

Two practical cautions. First, departments cannot execute these purchases themselves — delegated departmental signature authority is capped at $10,000 per transaction, which is precisely where Small Business First begins, so every one of these buys routes through the campus procurement office. Second, the policy is in revision: an interim version took effect in January 2026 which softened the operative language and removed the systemwide waiver process, and medical and patient care agreements are an express exemption. Treat it as a program, not a guarantee, and ask your procurement office which agreements already cover the category.

For California state agencies and the CSU system the equivalent mechanism is in the Government Code rather than the Public Contract Code, and it requires quotes from two certified firms rather than one. Either way, the point for a campus is the same: the slow part of complying with the checklist is usually not the decision. It is the paperwork, and there is a legal path built to shorten it.

The campus egress program we build, end to end →