Paul Beatty
Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
Washington, D.C.
Dear Mr Beatty
I have been in a wheelchair for 10 years and travel extensively by ship.
I moderate a web site with 87 members who all are in wheelchairs and travel by ship. I have reviewed the proposed rules and wish to thank you and the Board for fine work. With a combined wheelchair cruising history of over 900 trips by the members of my web site; I make the following comments. There are several areas which cause me the most problems when traveling and I will concentrate on those.
Ship Boarding: The transition plate to the gangway V405.6 is critical. It is often far to steep and narrow. This plate at the beginning and end of the gangway must be of sufficient width that a standard large size wheelchair has sufficient clearance. I have seen chairs fall and near fall off this plate. My large chair requires 32 inches however, this allows no room for error and the wheels are rolling along the edge of the transition plate. Please require 40 inch wide plates.
Hall Width: Section V403.5 requires 36 inch hall width. While this dimension
allows all chairs to pass it ignores the fact that all halls are being
used by the staff and the companionways are filled with laundry'
food trays etc. While all are movable a 40 inch hall is more practical. Section 403.5.1 allows hall width to be reduced to 32 inches for a
24 inch distance this is not safe. The halls should be 40 with the
exception width being 36 inches.
Muster Station: Current procedures are not safe. All wheelchair passengers should be gathered in one station where their unique needs can be reviewed and one trained crewmen assigned to each wheelchair passenger. One elevator must be designated as the emergency elevator and be provided with a backup generator system in the event of power failure. In the future the location of wheelchair cabins should be placed near the emergency elevator.
Door Width: Section V404.2.3 provides for 32 inch clear door width. This is too narrow it should be 34 inches.
Water Closet: Section V604.9.3 has an 11 inch minimum height this is too low I suggest minimum height of 17 inches.
Thank you for your kind consideration.
William Tuohey
[address]
Fort Lee, New Jersey 07024
[email address]
Web site for Sailingonwheels
http://groups.yahoo.com/group/sailingonwheels