Alexander Graham Bell Association
for the Deaf and and Hard of Hearing
3417 Volta Place, NW
Washington, DC 20007
November 13, 2006
Office of Technical and Information Services Architectural And Transportation Barriers Compliance Board
1331 F. Street NW, Suite 1000
Washington, DC 20004-1111
The Alexander Graham Bell Association for the Deaf and Hard of Hearing (AG Bell) welcomes the opportunity to submit comments to the Access Board's request for comments on the Revised Draft Passenger Vessel Accessibility Guidelines and Supplemental Information.
AG Bell is the world’s oldest and largest consumer membership organization promoting the use of spoken language and hearing technology by children and adults with hearing loss. The Association is a life long resource, support network and advocate for listening, learning, talking and living independently with hearing loss. Members include parents of children with hearing loss, adults who are deaf or hard of hearing, educators, audiologists, speech-language pathologists, physicians, and other professionals in fields related to hearing loss and deafness. Through advocacy initiatives and programs, AG Bell promotes its mission: Advocating Independence through Listening and Talking!
Our comments submitted today support the comments filed by Janice A. Schacter, Chair of the Hearing Technology Program and a parent member of AG Bell who has a daughter with hearing loss and direct experience in the inaccessibility of information and activities on cruise ships. Her comments focus specifically on issues in sections identified under the drafted guidelines that will promote accessibility for children and adults who are deaf or hard of hearing. It is important that the guidelines address, contain and provide accessibility for all people with disabilities, not only people with physical disabilities or other disabilities that require environmental structural accommodations or other types of modifications. It is also important that accessibility applies to the arts, cultural venues and entertainment and leisure type activities that are enjoyed by all persons. Our comments are also directed to provisions that enhance communication access to adults and children who communicate by listening and speaking as their primary mode of communication, using advanced hearing technology, hearing aids and cochlear implants.
Specifically, addressed is the need to remove the exception for assistive listening devices for assembly areas in Section V219.2. Under Section V215 & /V806.3.1: emergency alarm systems, consider wording that will include rapid changes in technology and not limit the definition. In addition, define best practice in a way to rely on the the latest research in technology, e.g. when considering equipment and/or modifications. The International Symbol of Accessibility defines disability in terms of mobility issues only and does not represent people with hearing loss, visual impairments or the community of person with disabilities at large. All telephones need to be hearing aid compatible Section V704. We support the additional recommendations made by Ms. Schacter the sections not listed and addressed in these comments.
Other areas that must be addressed to provide access to people with hearing loss must include captioning for movies and videos shown on the vessel. In addition, televisions must be equipped with captioning decoder chips, programming and shipboard announcements must be captioned and must be available in a visual format and via an assisted listening devices. Real time captioning should be made available when requested, audioguides must be made accessible with neck loops or hearing aid compatible and appropriate signage must be implemented. Most importantly appropriate training must be provided for staff and vessel personnel on guidelines, equipment usage and accommodations that are necessary for communication access.
We respectively request that these recommendations and the recommendations submitted by Janice A. Schacter, be implemented in the final guidelines. Thank you for your consideration.
Respectively submitted,
Gerri A. Hanna
Senior Director of Advocacy & Policy
Alexander Graham Bell Association
for the Deaf and Hard of Hearing
3417 Volta Place NW
Washington, DC 20007
Office: 202-337-5220
Direct: 202-204-4686
Fax: 202-337-5087