BRUCE P. HILLAM, PH.D.
[address] • LA VERNE, CA • 91750-1401
[home and ofice phone]
[email address]
July 25, 2005
US Access Board
Attn: Draft PVAG
1331 F Street, NW, Room 1000,
Washington, DC, 20004-1111.
Dear Sir/madam:
First, I wish to thank the Board for allowing me to comment on cruise ship access and compliance. I am writing this letter for two reasons:
1. To inform you of my experience (a physically disabled person) as a passenger on of the leading cruise lines
2. To suggest improvements in cruise line services to the elderly and the disabled.
With our aging population, advancement in medical science leading to longer life span, my wife and I anticipate that the demand for handicapped/wheelchair access facilities will increase greatly over the next few decades. In order that disabled people like myself will be able to book and enjoy cruises (in some ways the best form of traveling for our population) without the present frustrations and inconvenience that we experienced, we believe that the cruise industries need to be more aware of the needs of people with various disabilities.
Before I go into detail, let me provide you with some background about myself. Because of a disability, I am a spinal cord injured quadriplegic 6 feet 5 inches tall with weight proportional to my height, I am paralyzed from the shoulders down with limited use of my arms and hands. I have not been able to walk or stand for over forty years. For mobility I use a battery powered wheelchair. This wheelchair is not one of the lightweight three-wheel scooters that you often see people with bad knees or hips using. With its two large batteries the chair weighs about two hundred pounds, and I weigh about the same. On trips my wife helps me with my personal care. We have a routine that allows us to maximize our enjoyment on travel, whether it is for business or pleasure.
My wife and I have completed two cruises, both on ships of the Holland America Line. One cruise was to Alaska and one was from Fort Lauderdale to Los Angeles via the Panama Canal. Our Alaskan experience was without incident. The comments below are based on the experiences of my wife and I on these two cruises. For informational purposes our Panama Cruise was on the M.S.Zaandam which I understand had just gone through a period of refurbishment.
For purposes of my testimony, I believe the cruise experience has four components: the booking experience, the shipboard experience, the shore experience and the excursion experience. In both of our cruises, the shipboard experience was first class, but the booking, shore and excursion experiences were far from even being moderately acceptable.
Booking any cruise has been a challenge. My wife and I have attempted to book about ten cruises. The story typically is that the limited umber of handicapped cabins have been booked even though there are large numbers of other available cabins. If truly disabled patrons are reserving early, then it’s my procrastination in booking that is to blame, but one disabled friend reported that some travel agencies book and hold. Some hotels and ships, and I believe a cruise liner is just a floating resort hotel, now have ‘handicapped rooms’ and ‘wheelchair rooms.’ A handicapped room has a bathroom with a regular shower/bathtub with grab bars while a wheelchair room has a roll in shower. On a ship I would suspect that there is a four to six inch water barrier or threshold in the handicapped room but no such barrier in the wheelchair room. If both handicapped and wheelchair rooms are lumped into one group, then people like myself would only be able to use the wheelchair room, making booking an even greater problem.
Once booked, other problems surface. In our Holland America booking, once reservations were made and a deposit put down, we had to deal with Holland America’s “Access and Compliance Department.” They were concerned about the size and weight of my battery powered wheelchair, and they wanted to make sure that I understood that Holland America would not provide any ‘personal care.’ They also wanted to know about my wheelchair. Their chair recommendations are that a chair should be “no wider than 23” and no more than 100 lbs without batteries.” (See attached of letter from Holland America) The 23” is because, I think, that is how far apart furniture in state rooms is. On both our cruises we found it necessary to have housekeeping remove a couch and shift the beds in order to allow access and a place in the cabin where my wheelchair could turn around. My chair is about 25” wide and it is a ‘standard adult” width. The reason for the suggested 100 lb weight limit is so the crew can lift the chair, I think. Many power wheelchairs for Spinal Cord Injured quadriplegics can weigh several hundred pounds because of posturing and tilt back systems built into the chair. The wheelchair weight and size becomes a critical issue when ship and port access is discussed further down in this letter. My powered wheelchair is of a common design with some accommodations made to my height. To require strict limitations on size and design of wheelchairs is a form of discrimination against the mobility impaired disabled.
I might add that I now receive regular promotions telling me I will automatically be upgraded two or three levels if I book now. With the limited number of rooms how is this possible?
As I mentioned in the first paragraph, our shipboard experience was first rate. However this does bring up an issue. Does my cruise experience start the moment I board the ship, or the moment I begin the trip. My wife and I opted to let Holland America arrange our transportation from Los Angeles to Fort Lauderdale, the port of embarkation. We paid Holland America Lines an extra fee to cover the cost of our transportation from Los Angeles to Fort Lauderdale. The airline chosen by Holland American was American Airlines. Our experience with American was not first rate but that is another issue. As I noted above, the on board experience was first rate. Many of the shipboard requirements suggested in the new regulations were already completed on the Zaandam
To have a shore experience, you need to be able to go ashore easily and safely. This requires an individual to be able to easily leave and re-board the ship. There was no problem doing this at the cruise ship terminals in Fort Lauderdale and Los Angeles, but at every other port-of-call on this cruise it was near impossible to leave and re-board the ship if you were mobility impaired, especially if your mobility requires the use of a battery powered wheelchair. The issue here is whether the proposed regulations cover ship access at foreign ports. Remember, I started and finished the Panama Cruise in American ports but in-between the ship stopped at many non-American ports. Does selling me a ticket in the United States guarantee me that I can get on and off the ship in all, or most ports of call? Again, using the Zaandam as an example, the problem is the small gangway carried internally on board the Zaandam used at ports where there were very basic facilities, usually just a pier. (A picture of this ‘portable’ gangway is attached) Not knowing what to expect, when the Zaandam arrived in La Romana, Dominican Republic, our first port of call, my wife and I decided to get off he ship and check out the nearby shore-based amenities and hopefully find a wheelchair accessible taxi. Let me describe my odyssey. Getting off the Zaandam turned out to be a three step process. Each of the three steps became a shared adventure for my wife, the crew, and I. You must first get on the gangway, then you must get down the gangway, and finally you must get off the gangway. Sounds simple, doesn’t it. When the crew first saw me at the head of the gangway, they suggested that if I could just walk, with their assistance as needed, to the end of the gangway, then they would bring the wheelchair to the pier and I could get back in the chair and go on my way. This is the procedure that someone with bad knees or hips and who uses a scooter but not a quadriplegic, might use. I told him I was not able to stand or walk. (I almost told him that if he could get me walking down the gangway, then thousands would come and worship at his feet because, medically, the miracle would be of Biblical proportions but I didn’t.) After clarifying that it was impossible for me to walk or get out of my wheelchair, we proceeded to the first exit obstacle.
The first problem was getting on the gangway. There is about a one foot high lip from the deck floor of the lower deck to the bottom of the door where the gangway is placed. The Zaandan crew placed a small ramp about two or three feet long here from the floor to the lip of the door. My wheelchair’s footrests hit this mini-ramp before my chair’s front wheels did. This steep mini-ramp is, for people who use wheelchairs like mine, a wall. The solution, using an inside bit of gimp humor, is to use the ‘arm-strong’ method. Four strong guys pick up the wheelchair, lift the wheelchair over the first mini-ramp, and place it on the gangway. Oddly enough, wheelchairs, and power wheelchairs particularly, are not designed to be picked up. It is just not safe, especially if still occupied. The armrests and footrests of most power wheelchairs, like mine, are detachable. They are not lifting points. As I pointed out previously, wheelchair with batteries and Dr. Hillam weigh more than four hundred pounds. Lifting like that is not a comfortable situation to all concerned. Remember everything has to be done in reverse when I re-board. Now on to the second stage of my adventure in exiting the ship.
The second problem is navigating the gangway. There are several problems from a wheelchair point of view with the Zaandam’s portable gangway. (Again note picture of portable gangway enclosed) Depending on tide height, and the relative position of the pier to the ship, the slope of the gangway could range anywhere from level or zero slope to a steep slope equal to about 1 which is achieved when the gangplank is at a forty five degree angle. The ramp at forty five degrees is steep even for a mountain goat much less a senior citizen or a wheelchair user. Another problem is that the Zaandam’s mini-gangway has little steps built into the middle of it. My guess is that the purpose of these mini-steps is to help people climb or descend the gangway when there is a moderate to steep slope. Unfortunately these mini-steps poke up high enough to hang up on the battery case under my wheelchair. If these steps went downward into the ramp and became toeholds or weren’t as high, then there would be no hang-up. Now that my wheelchair battery base was caught on these mini-steps, the chair had to be manhandled down the gangway one mini-step at a time. This had to be done from the front and rear of the chair because the gangway was too narrow for crew to get along the side of the wheelchair for lifting and support while the wheelchair is on the gangway. I think the gangway is thirty inches wide and my wheelchair is 24 inches wide. The result was that there was no room along the side of the gangway for people to help. It took over ten minutes to get me down that portion of the gangway. Even able-bodied passengers were tripping over the mini-steps. I heard a rumor that some one actually tripped, fell, and broke their arm, but I don’t know this for a fact. In summary, often too steep, too narrow and too bumpy. Several people commented to me that they also found using this gangway unnerving. I believe the gangway was about twelve feet in length but this is a visual estimate.
The third problem is getting off the gangway. The end of the gangway is about eight inches off the pier, so a little wooden ramp was put at the end gangway. Unfortunately ship motion was constantly moving the gangway around and the little wooden ramp was not always properly positioned. The front wheel of my wheelchair got caught in the space between the gangway end and the ramp and slide into the space between the ramp and gangway, but again four stout crew lifted me out of that crevice.
I used the gangway for one round trip circuit at the first port of call. It took fifteen minutes to get down and five minutes to get back up. At other ports, particularly Costa Rica, I checked to see if things were better. It was always the same set-up. Once up and down this obstacle course was enough. On this sixteen day cruise I only got off the Zaandam once. Modern cruise ships are larger than World War II era aircraft carriers and they displace more tonnage than World War II battleships. Clearly, these modern floating resorts have the capacity to carry something more usable and safer than this type of gangway.
The third problem was shore excursions. These are marketed within the United States. I believe that the possibility of shore excursions assumes that one can get to shore in a dignified matter. I realize that not all shore excursions can be accessible to everyone, but more can be done in several ways. The booklet describing the Alaskan shore excursions stated, as well as the on board excursion director on the Volendam knew, which excursions were or were not accessible. Before we left for our Panama Cruise, I phoned the HAL access and compliance office and asked about accessibility and the possibility of alternative arrangements. I was advised to assume that nothing would be accessible. When we first arrived on board the Zaandam, the shore excursion director did email ahead to various port representatives and did find the possibility of a taxi with wheelchair access only in Costa Rica. My wife, by just asking the local taxi drivers, also found accessible taxi service at two other ports. It surprised my wife and I that the shore excursion office lacked a simple directory of local transportation services for passengers with special needs. When we prepared for this cruise, we booked ahead tours that we thought might be accessible in most ports of call. We ended up canceling all tours that I had purchased. We are very grateful, though, to Holland America for accommodating the cancellation without charge, as they had promised when we booked the tours.
On about the third day of our cruise, the Holland American Lines marketing group gave everyone a brochure of cruises in 2006 and encouraged all passengers to reserve their next year’s dream trips then. Shouldn’t cruises with non-accessible ports be noted as such? In summary, my suggestions for improvement of cruise line access and enjoyment for the disabled are:
1. Cruise line distinguish between passengers who need wheelchair accessible rooms, passengers who need handicap accessible rooms and passengers that need neither. The present practice appears to be that anyone who requests for a handicap or wheelchair accessible room will get one if it is available at the time the reservation is made.
2. If a ship has rooms designated as wheelchair and as handicapped accessible, then the number of designated wheelchair accessible rooms must exceed the number of handicapped accessible rooms. Every wheelchair accessible room is handicapped accessible by definition. Furthermore, the number of such designated rooms be available in all cabin classes in strict proportionality.
3. Cruise ships has a designated place for people using scooters to park and charge their vehicles. (Scooters are generally used by individuals who are still able to walk short distances) These people do not really need a wheelchair accessible room, but they may request for a wheelchair room because such rooms are generally bigger and the wider doorway enable the scooters to pass through. On our last cruise, one passenger had to park her scooter along the corridor because it could not go into her room. She informed us that in future she would book an accessible room like ours.
4. Cruise lines be required to carry gangways that are safe and easy to use by all passengers with little or no assistance from the crew. There should be no step up or step down from this gangway. If the gangway must be ‘pieced’ together, it must be done in a ‘natural’ way..
I hope that you find the information and suggestions in this letter useful. Transiting the Panama Canal was an experience that I will long remember, and I am glad that I did it. I believe that there should be lots of opportunities for other memorable cruises. I believe many of these ships are foreign flagged for convenience but essentially American owned as their shares are traded on major American stock exchanges. They aggressively market in America and should confirm to American standards of hospitality, civility, and accessibility.
Yours truly,
Bruce P. Hillam Ph.D.
Holland America Line Inc.
OFFICE OF THE PRESIDENT
July 6, 2005
Dr. and Mrs. Bruce Hillam {address] La Verne, CA 91750
RE: 6090297
Dear Mr. and Mrs. Hillam,
Thank you for the letter to Mr. Stein Kruse regarding your ms ZAANDAM sailing on April 24, 2005. Mr. Kruse has reviewed your letter in detail and has asked me to respond on his behalf.
We sincerely regret the difficulties you experienced getting on and off the ship. However, as you noted, Dr. Hillam's wheelchair is 24" wide and 200 lbs. In the letter sent from our Access and Compliance Department, we state that any mobility devices should be no wider than 23" and no more than 100 lbs. without the batteries. These specifications are made with our gangway in mind, and particularly for ports outside the United States, where there is no analogue to the Americans with Disabilities Act.
We truly understand your frustration, and Holland America Line has been a leader in the cruise industry in accessibility, as is evident from your onboard experience. However, we cannot influence the nations we visit, and accessibility remains an issue in most of them. We can confirm that in St. Petersburg, all shore excursions that visit the Hermitage do have steps and are not accessible for wheelchair guests. For the Australia and New Zealand cruise, all locations have excursions that are accessible. We believe that should you join us for this cruise, you will have an excellent journey, and have no trouble fully enjoying the ports of call.
Thank you again for taking the time to provide us with your comments. We look forward to serving you again in the very near future.
Very truly yours,
Mr. Gitai Ben-Ammi
Special Advisor
Office of the President
300 Elliott Ave. West
Seattle, WA 98119
206-281-3535
Fax: 206-301-5327