Public Comment on Draft Guidelines and Notices for Passenger Vessels

Access Board Docket 2004-1
Americans with Disabilities Act (ADA)
Accessibility Guidelines for Passenger Vessels
Comments by
International Council of Cruise Lines

The International Council of Cruise Lines (ICCL) is a non-profit trade association that represents the interests of 161 of the largest cruise lines operating in the North American cruise market and over 90 Associate Member companies that are cruise industry business partners and suppliers. ICCL member cruise lines serve major ports in the United States and call at over 70 ports in the United States and at more than 600 ports around the world. Last year, ICCL’s member lines carried more than 11.2 million passengers on approximately 120 vessels. On November 28, 2006 ICCL is expected to merge with the Cruise Lines International Association. The resulting association will be named the Cruise Lines International Association (CLIA). We will retain our current level of contact and activity with the U.S. Access Board.

These proposed guidelines are of critical significance to ICCL members, as will be the operational and other issues that are to be addressed by DOT. The following submission reflects the comments of our members and is structured as follows:

As you will see from our comments, despite the hard work on the part of all involved, there are numerous issues needing further study and refinement as well as sections requiring clarification and redrafting.

ICCL has contracted for a professional economic impact analysis to be performed with regards to the scoping requirements for accessible cabins and other access elements. We had expected that this study would be completed and included together with these comments. Unfortunately, as discussed with the Board, due to a personal emergency on the part of the individual finalizing the report, the study is not yet ready for submission. We will submit the report as soon as circumstances allow, and appreciate in advance your consideration of the analysis.

Additionally, we are conducting a detailed comparison of the signage required by SOLAS versus that in the Guidelines. We believe that this is a critical issue and while international safety regulations must prevail, it is imperative that we know if there are serious conflicts and just what and where those may be. The results of this detailed examination are also not complete and we would also appreciate your consideration of those results and accompanying comments when available.

ICCL appreciates the opportunity to comment on this most important matter. We look forward to working with the US Access Board in developing the final guidelines for access onboard passenger vessels.

T.E. Thompson
Executive Vice President

1 ICCL member lines include: Carnival Cruise Lines, Celebrity Cruises, Costa Cruise Lines N.V., Crystal Cruises, Cunard Line, Disney Cruise Line, Holland America Line, NCL America, Norwegian Cruise Line, Princess Cruises, Regent Seven Seas Cruises, Royal Caribbean International, Seabourn Cruise Line, SeaDream Yacht Club, Silversea Cruises and Windstar Cruises.

Attachments:
Annex 1: General Comments on Issues for Further Analysis and Refinement
Annex 2: Detailed Comments on PVAG proposals
Annex 3: Supplemental Discussion of Engineering Standards
Annex 4: Diagram of Stateroom

International Council of Cruise Lines
2111 Wilson Boulevard
8th Floor Arlington, VA 22201
Phone (703) 522-8463 ◊ Fax (703) 522-3811
E-mail: info@iccl.org ◊ www.iccl.org

ANNEX 1
Access Board Docket 2004-1
General Comments on Issues
for Further Analysis and Refinement

1. ON/OFF – V208.1

Gangways and boarding systems owned and carried by the ship shall comply with V412 and V413 in providing an accessible path to the shore provided boarding facilities.

The requirement for passenger boarding systems is typically the responsibility of the Port. The ship or ship operator should not be held responsible for shoreside systems unless that ship or ship operator is the owner or manager of the shoreside system/pier, etc. This remains as a critical issue and our comments which were submitted on July 28, 2005 remain applicable.

The ship operator shall make a reasonable effort to embark and disembark all passengers under all circumstances at each port when safe to do so. All passengers are offered or receive assistance in getting on and off the ship. This is an operational and safety necessity.

The operator and ship master will make an assessment of transfer conditions, embarkation and disembarkation, considering safety of the passenger, the crew and the ship, taking into account such items as tidal conditions, weather, and the physical condition of the structures involved.

These guidelines apply to a ship in a static condition which is embarking and disembarking passengers to a shoreside facility.

ON/OFF regarding Tendering Vessels:

Chapter 11 has been added. The definition of “Tender” however must be refined to indicate that these guidelines apply only to tender vessels carried by the ship and not those that are provided at a port by independent third parties. ICCL has offered draft wording in this regard.

2. Date of application – V201
The only flexibility provided in application of new regulations for the ship owner, is before the contract for construction is signed. V201.1 should be redrafted to state:

V201.1 Scope: A new ship is defined by the date of contract for construction of that ship. New ships contracted eighteen months after the date of publication of the final regulation adopting the guidelines, shall comply.

3. Scoping for Accessible Cabins - V224

ICCL notes that the scoping for accessible cabins remains at 3%. ICCL has contracted for an independent analysis of the economic impact of this scoping requirement. Early indications from the economic impact study, which analyzes actual and projected use of accessible cabins and other access elements by persons with disabilities requiring such accommodation, indicates that the currently drafted scoping is far in excess of that needed to meet the actual needs. While this study is nearly complete, its submittal has been delayed by circumstances beyond our control. This study will be submitted as soon as possible.

4. Question 4 introduced the concept of requiring all elevators and lifts to be available in an emergency and requested comment.

This would require ALL elevators and lifts to be on the emergency power system. This concept is unreasonable. As an example, a recently constructed ship has 17 elevators for passenger use and an additional 11 for crew use. The impact would be that all elevators would have to be placed on the emergency generator distribution system. This would accordingly require massive increase in the emergency generating power requiring additional emergency generators impacting the weight and stability of the ship, fuel tankage/capacity requirements, and structural elements as these generators must be located apart from the engine room and meet additional regulatory requirements. This is not a matter of just providing an alternative protected electrical source as it would be in a shore side building. ICCL has previously indicated that this would not be reasonable or achievable.
Typically in an emergency that does not impact the main electrical supply, elevators will remain operable. In these cases, crew will positively operate the elevators to assure the safe mustering and movement of passengers and crew.

In public buildings ashore, elevators are not accessible during an emergency. It is unreasonable to implement a more excessive requirement at sea where crew are trained and assigned to assist in an emergency.
Further comment is provided in main document text.

5. Administrative Authority – V106.5 and various other sections

It is critical that the concept of administrative authority be adequately addressed. In V106.5, ICCL recommends that the governmental agency(s) that adopt or enforce regulations and guidelines for the design, construction, or alteration of passenger vessels be recognized as the administrative authority.

6. Reference to US Engineering Standards – V105 and various other sections

ICCL recommends that a section V105.3 be included that states as follows:

“V105.3: Ships built in non-U.S. shipyards and that are constructed to comply with international requirements and the laws, regulations, industry standards or other related requirements of other nations shall not be required to comply with engineering standards referenced in the Passenger Vessel Accessibility Guidelines and Supplementary Information..”

These guidelines purport to apply US engineering standards of ANSI, BHMA, and AMSE, ASTM and NFPA to establish accessibility in the design and construction of cruise ships in foreign nations. Aside from the obvious jurisdictional problems of mandating compliance with US engineering standards for design and construction occurring outside the territory of the United States, these standards may conflict with the existing or future standards promulgated by the vessels’ flag states or the nations where the ships are designed or constructed.

7. General Discussion – DOT Rulemaking - Precedence of International Conventions over US Laws and guidelines

It should be recognized and stated that International Conventions and other international legal obligations must take precedence. These standards address safety of the passengers, crew and ship and matters of safety cannot be compromised. This is expressly indicated in Spector which states: “Surely a barrier removal requirement under Title III that would bring a vessel into noncompliance with the International Convention for the Safety of Life at Sea (SOLAS)… or any other international legal obligation, would create serious difficulties for the vessel and would have a substantial impact on its operation, and thus would not be “readily achievable.”

8. Dispersion of accessible seating in theaters and other “assembly” areas – V221.2.3

Given the difference between ship construction and shore-side theater, stadium, or building construction, such as the maximum permitted length and area of fire zones and beam of the ship, full dispersion of seats horizontally and on all vertical levels, is not feasible.

The current PVAG draft does not address the comment previously made. We reiterate that providing accessible seating to points of entry levels (usually found at top, middle or bottom levels of the shipboard theaters) along an accessible passenger route allows adequate sightlines and access to the activities occurring in the theater and minimizes the loss of overall seating capacity.

9. Pool Access – V234.2

Of the two options given, only one may be feasible for shipboard use. The use of ramps as a main means of entry would be impractical onboard a ship given the space restrictions for pools and surrounding decks. Additionally, such ramps would result in forming a pathway for water sloshing out of the pool creating safety and stability problems. Thus this option is not feasible and will never be used. We recommend that the Board conduct additional research into other practical methods that can be used safely onboard ship.

10. Alterations – V106.5 and Question 1

As we stated in our comments of July 28, 2005, ships are not as easily altered as buildings due to the integrated structure of a ship and associated safety systems, weight restrictions and the impact on stability. Therefore, alterations which involve change to or rearrangement of structural parts or elements or a rearrangement in the plan configuration of bulkheads and partitions should be expected to comply to the extent feasible. However, changes that are limited to remodeling, renovation, rehabilitation, reconstruction, and historic restoration, and which do not involve the changes or rearrangement in the structural parts or elements should not be considered as being alterations.

11. V-216.4 and 216.4.3 – signage and directional signage

This remains a critical issue as SOLAS and ISO provide detailed standards, including signage standards, for orderly evacuation and escape. These and other international standards already provide that crew assist and direct passengers in the event of an emergency. As a result, crew members perform a significant role in evacuating passengers both with and without disabilities. SOLAS has requirements pertaining to Low Location Lighting (LLL) which along with crew members are designed to direct passengers in the event of an emergency and we must comply with these. Adding signs such as that required by the current draft will only slow down an evacuation by people taking the time to locate and read them, when crew are already trained and stationed to provide direction. These signs could also confuse passengers by leading them to exit doors, as opposed to the proper assembly station.

Additionally, we are conducting a detailed comparison of the signage required by SOLAS versus that in the Guidelines. We believe that this is a critical issue and while international safety regulations must prevail, ir is imperative that we know if there are serious conflicts and just what and where those may be. The results of this detailed examination are also not complete and we would also appreciate your consideration of those results and accompanying comments when available.

12. Telephones – V217

This requirement is clearly in excess of shore side facility requirements as stated in the new ADAAG. No persuasive rationale has been offered for requiring significantly greater scoping of TTY’s onboard vessels. No persuasive rationale has been offered for requiring significantly greater scoping of TTY’s onboard vessels. For private/non-government facilities, revised ADAAG requires that only one TTY be provided per floor, level or phone bank where public phones are otherwise provided. Additionally, statistical information regarding the use of TTY’s onboard the ICCL member cruise line vessels demonstrate that the majority of available TTY technology goes unused. This requirement, as stated above, is excessive and unreasonable. The Board should restate V217.2 to maintain the wheelchair accessible provision and eliminate the TTY requirement.

13. Assistive listening systems – V219

The collective experience of ICCL members is that receivers currently available on voyages are significantly underutilized. The minimum number of receivers in the current draft is excessive. The guideline should not be based on a percentage of the cumulative number of seats in assembly areas as the total number of seats can very well exceed the maximum number of passengers the vessel can carry.

14. Thresholds - V404.2.5 - Weathertight door coamings and hard surface closure

This appears to have been passed to the “administrative authority.” This is listed as an issue that is still under review by the Board and is thus recognized as a critical issue needing additional attention. Furthermore, we are concerned that the Board remains under the impression that a weathertight door with a sill/coaming can be replaced by using a watertight door with a non-beveled threshold of 1 ¼ inches.

Additionally, and at the risk of restating the obvious, ships are not buildings. Where water leakage in a building from a storm may ruin a carpet every now and then, ships are built to be in a wet, marine environment. Cumulative weight of water leakage on upper decks from leaking doors creates a safety issue in terms of added weight which is added high on the ship and possible accumulation of water creating a free surface effect - both of these conditions adversely impact stability and therefore ship safety. Additional safety issues are related to a wet surface include the possibility of electrical fault, slip and fall hazards which are multiplied by the ship motions, and health issues related to mold/mildew. It is therefore necessary to maintain a ship weathertight even at the upper decks where exposed to the elements.

15. Ramps in restricted areas - V405.2

Slope limits for minor differences in deck height are necessary because of shipboard arrangements such as corridor widths that limit the length of the run. The obvious solution would be to add width to the corridors or decks. However, what may be perceived to be a minor adjustment, will have a substantial, cumulative, and negative effect on the design of the ship. For example, adding to the ramp run will increase the total corridor width in order to maintain the minimum clear width mandated by SOLAS. This issue also relates to cabin balcony access.

This would also not be achievable from a watertight or weathertight door leading from the deckhouse to an open deck on the side of a smaller ship where the width of external decks can be extremely limited.

16. TTY issues – V224.4

The guidelines as drafted will require a certain number of accessible rooms to be provided with TTY technology. While the cruise industry is not adverse to providing a limited number of TTY kits on board, we believe that the scoping requirement is excessive. Additionally, statistical information regarding the use of TTY’s onboard the ICCL member cruise line vessels, demonstrates that the majority of available TTY technology goes unused. While the study containing this information is nearly complete, its submittal has been delayed by circumstances beyond our control. This study will be submitted as soon as possible.

International Council of Cruise Lines
2111 Wilson Boulevard
8th Floor Arlington, VA 22201
Phone (703) 522-8463 ◊ Fax (703) 522-3811
E-mail: info@iccl.org ◊ www.iccl.org

ANNEX 2
Access Board Docket 2004-1
Detailed Comments on the Revised Draft Passenger Vessel Accessibility Guidelines and Supplementary Information

Please note that we have placed our comments within the text of the Revised Draft PVAG for ease of reading in context. To avoid confusion, we have deleted those portions of the Revised Draft PVAG which have not been the subject of comment or referred to by ICCL comment.

Introduction
Background
General
Summaries
Discussion of Provisions: Second Draft
Passenger Vessel Case Studies
Draft Accessibility Guidelines for Passenger Vessels

The Board is interested in receiving public comments on this entire second draft. Changes made in this draft from the November 26, 2004 draft are summarized below.

Department of Transportation Rulemaking. During the comment period on the 2004 draft, the following issues received comment, but should be addressed by DOT when it publishes its NPRM:

• Who is the administrative authority for US flag and foreign flag passenger vessels (since a number of provisions in the draft relate to determinations by the administrative authority)?
ICCL Comment: ICCL recommends Administrative Authority should be the government agency responsible for approval of ship design and construction. Comment has been drafted in the text of PVAG regarding this recommendation.

• What criteria should be used for determining whether a passenger vessel is considered a new vessel or an existing vessel (e.g., date of keel laying or shipyard contract signing), and what effective date for the standards should be established which provides sufficient advance notice?

The only flexibility provided in application of new regulations for the ship owner, is before the contract for construction is signed. V201.1 should be redrafted to state:

V201.1 Scope: A new ship is defined by the date of contract for construction of that ship. New ships contracted [eighteen months] after the date of publication of the final regulation adopting the guidelines, shall comply.

• What responsibilities do landside facility owners (e.g., pier owners) have in providing accessible passenger boarding systems?

The requirement for passenger boarding systems is typically the responsibility of the Port. The ship or ship operator should not be held responsible for shoreside systems unless that ship or ship operator is the owner or manager of the shoreside system/pier, etc. This remains as a critical issue and our comments which were submitted on July 28, 2005 remain applicable.

While the United States can publish requirements for shoreside access in United States territory, these requirements should be published in a document that addresses these entities and not a document applicable to ships.

• How should conflicts between provisions in this draft and foreign safety and accessibility standards be addressed?

ICCL Comment: Comment has been drafted that international safety rules and foreign rules where a ship is designed, approved and constructed take precedence.

• How should conflicts between provisions in this draft and International Conventions (which the United States is a party) be addressed?

• How should operational issues be addressed which do not fall under the Board’s jurisdiction (examples may include providing service animal relief areas, blockage of passageways with luggage and house keeping carts, accessibility of shore side amenities offered by passenger vessel operators, tours, accessible guest rooms being used by non-disabled passengers, and providing portable shower and pool chairs)?

ICCL Comment: Relief of service animals and the matter of moving or controlling the placement of room servicing carts are operational issues that are the responsibility of each operator as such, should not be addressed by the Board or in formal guidelines or rules.

Shoreside tours in the United States should have to meet whatever requirements for accessibility are applicable to their particular situation. Inclusion of requirements for shoreside tours in guidelines for ships is inappropriate as it is not the ship that operates the shore excursions.

Portable showers and special pool chairs are not provided to any guest. Therefore a requirement to provide a portable shower to a guest with disabilities when an accessible shower is required is inappropriate for these guidelines in-as-much-as the Americans with Disabilities Act is an equal access law and the guidelines already address requirements for accessible rinsing showers where such showers are otherwise provided for guests.

With regard to non-disabled using accessible rooms – it is not currently permitted to require that a guest self-identify nor can an operator second guess a passenger who states a disability and need for an accessible room even when such a need is not obvious (e.g. use of a wheel chair or other mobility aid). However, operators can and do suggest persons with disabilities to self identify so an accommodation can reasonably be made available if requested. In as much as most cruise reservations are made months in advance, it is more likely that an accessible room will be available if requested than at a hotel where a “walk-in” with a request for an accessible room is a more frequent experience. Regardless, when all accessible rooms have been sold to persons requesting them, efforts are made to move declared or noted non-disabled guests to a non-accessible room thus accommodating a late reserving guest with a declared need. However, requiring additional accessible rooms in the scoping is not a solution. Such a mandate will not assure that the additional accessible rooms will not also be utilized by non-disabled persons who want a larger room.

Chapter 2: Scoping Requirements

V201.1 Scope. This draft applies the passenger vessel accessibility guidelines to all areas of newly designed and constructed passenger vessels and altered portions of existing passenger vessels permitted to carry more than 150 passengers or more than 49 overnight passengers. These vessels are labeled as large vessels in this draft (V201.1.1).

In addition, unlike the 2004 draft, this draft applies access provisions to all sizes of ferries (V201.1.2) and certain tenders (V201.1.3). Covered tenders are those which carry 60 or more passengers, and are carried by or used primarily by large passenger vessels (i.e., those subject to V201.1.1). Ferries would have to comply with the same access provisions in chapters 1 through 10 applicable to large passenger vessels and tenders would only use chapters 1 and 11. Three advisory notes have been included with these sections.

ICCL Comment: Regarding the words “carried by or used primarily by large passenger vessels…” Board staff explained that tenders not carried by the ship and that are built for “primary” use as cruise ship tenders would have to comply but that vessels built for other purposes (such as sightseeing) and used occasionally as tender vessels would not have to meet the requirements. ICCL stated that port procured vessels used by cruise ships as tenders would be required to meet access requirements based on their own merit and not the cruise ship’s merit. ICCL offers specific comment with regards to the definition of “tender” to address industry concerns.

V202.3 Alterations. This draft modifies exception 3(c). The exception allows alterations to provide accessibility to the maximum extent feasible where compliance with applicable provisions would result in a reduction in the structural integrity or fire resistance of a Class A or B bulkhead or deck surface. The 2004 draft applied the exception where an alteration would result in a violation of the minimum requirements established by the administrative authority.

Question 1: To assist the Board in developing this question and answer format, what types of alterations are generally performed on passenger vessels? What features of passenger vessels subject to provisions in this draft are typically replaced or rebuilt, and how often do these actions occur? To what degree are new midsections added to passenger vessels and which vessels have received new midsections in the last five years?

• Concern that new construction requirements would apply regardless of the impact when alterations are performed in existing vessels.

Normally, when alterations are performed, section V202.3 would require conformance with the new construction requirements, unless an exception in V202.3 applies. For example, in an alteration where compliance with applicable requirements is technically infeasible, exception 2 allows the alteration to comply to the maximum extent feasible.

However, in some sections, the new construction provisions have exceptions which set out alternative access requirements which are allowed to be used in the alteration of existing passenger vessels. Use of these alternatives is allowed, except where the features being altered already conformed to the new construction requirements. In such cases, section V202.3.1 would prohibit a reduction in access below the new construction requirement.

Question 2: The Board is aware that some passenger vessels have spaces which contain a large number of the same type of fixed elements, such as slot machines. In other sections of the draft guidelines, where multiple elements or spaces of the same type are provided, only a certain number are required to comply. For example, V224 does not require every guest room to be accessible, and V228 does not require every vending machine to comply with V309. Should the Board add an exception to V205 which would address situations where a large number of operable parts of the same type are provided in an accessible space? Should five percent, but not less than one, of each type be used? Besides gambling devices, are there other situations where a large number of operable parts of the same type are provided as part of fixed features of passenger vessels?

ICCL Comment: Yes, such an exception should be included. Other situations may include game arcades.

Question 3: Are entry and departure points provided on passenger vessels which are not used to access piers and other landside structures, or tenders? Should tender platforms which only service smaller tenders (i.e., those not subject to V201.1.3) be required to comply with V206.4? Are some swim, dive, and tender platforms also used as end points in passenger boarding systems which connect passenger vessels to piers and other landside structures (for example, a pier gangway connected to a swim platform)?

Question 4: Although some changes have been made, the Board is still evaluating the AMOE provisions. The Board is aware of situations where the vessel’s emergency plan has employees directing passengers to higher decks where areas of refuge are located when certain emergencies (such as flooding) occur and the vessel is not required to have a means of vertical access. If a newly constructed vessel has an elevator, due to the requirements of V201.4 or V206.2.1, what is the impact of requiring all elevators to comply with V410.3? If platform lifts are provided, what is the impact of requiring all platform lifts to comply with V410.4?

ICCL Comment: This would require ALL elevators and lifts to be available at all times on the emergency power system. This concept is unreasonable. As an example, a recently constructed ship has 17 elevators for passenger use and an additional 11 for crew use. Requiring all of these elevators to be available would far exceed the capacity of the emergency power system. This would accordingly require a massive increase in emergency generating capacity including: additional emergency generators, impacting the weight and stability of the ship, added fuel tankage/capacity requirements and structural elements as these generators must be located apart from the engine room and meet additional regulatory requirements. This is not a matter of just providing an alternative protected electrical source as it would be in a shore side building. ICCL has previously indicated that this would not be reasonable or achievable.

Elevators may be on the emergency source, but can’t be operated continuously. SOLAS II-2/42.2.6.2 requires “emergency arrangements to bring lift cars to deck level for the escape of persons. Lift cars may be brought to deck level sequentially in an emergency.”

Given the extensive fire suppression requirements for the ship (automatic sprinklers), extensive ventilation segregation and other requirements, multiple travel routes between Main Vertical Fire Zones (MVZ’s), crew training and assignments to assist, etc. having one or two elevators for use by crew to assist in mustering and evacuation should be sufficient to assure safety in an emergency situation.

In public buildings ashore, elevators are not accessible during an emergency; it is unreasonable to implement a more excessive requirement at sea where persons trained and assigned to assist in an emergency are a requirement.

V208 Passenger Vessel Boarding. This draft removes the reference to connecting land and replaces the term “land” with the term “landside structures”. The provision applies when embarking and disembarking from fixed piers, floating piers, or landside structures. The terms embarking and disembarking refers to all intermediate stops where passengers leave and reenter the vessel not just the starting point and ending point of a cruise or trip. As in the 2004 draft, an exception allows either the boarding system to be carried by the vessel or to be provided on piers or landside structures.

This draft requires a new vessel to have a conforming connection to piers and landside structures. The draft does not assign responsibility in terms of whether the vessel owner or landside owner is responsible to provide the connection.

ICCL Comment: This statement is very broad and general. It appears to be a catch-all phrase/requirement that will cause enormous difficulty in interpretation and implementation. Once again the statement ignores whether or not such a conforming connection can be provided in all tidal ranges and all weather conditions. It also disregards the question of what is the pier terminal operator’s responsibility versus the ship’s.

Regarding the future ADAAG amendments, the Board is not planning to propose that new piers or landside structures provide accessible boarding systems to all covered passenger vessels. However, where boarding systems are provided by the landside entity, the boarding systems will need to comply with requirements similar to those found in V412. As noted earlier, DOT will be addressing whether boarding systems must be provided as part of a new construction project in its NPRM.

ICCL Comment: If the boarding system is provided by the landside entity, the requirements for that boarding system should be addressed in a regulation that applies to that entity and not addressed in a guideline or regulation that applies to ships.

Aside from replacing the reference to land, the Board has not changed the content of V208, but is still evaluating the components listed in V412 which may be used to provide a conforming passenger boarding system. In the list, a manually powered boarding lift complying with V414 was added.

ICCL Comment: We welcome this expansion to the list for “systems” or elements that may be used for part of the boarding system, just as we welcome any component that will assist in this matter. However, please see our previous comment that discussion of landside requirements is not appropriate in these guidelines.

Question 5: Public seating areas contain fixed seats which are not at fixed tables and are areas not classified as assembly areas (see assembly area definition in V106.5).

ICCL Comment: This appears to apply to ferry type vessels only; thus, ICCL has no comment.

V224 Passenger Guest Rooms. This section is unchanged in this draft. However, the Board is still evaluating the scoping section and the technical provisions applicable to accessible guest rooms.

Commenters generally took opposite positions on the scoping for accessible guest rooms. Industry groups indicated the scoping was beyond the need experienced and should be reduced. Disability organizations and individuals described their experiences and indicated that there are an insufficient number of accessible guest rooms available.

ICCL Comment: This appears to be an asset management issue and is more a perception than a reality. We do not believe that regulations should be based on anecdotal information. Please see the ICCL analysis for detail.

Commenters also said that a guest room equipped with mobility features is generally one and a half times the size of a standard guest room. Therefore, increasing the number of such accessible guest rooms will lead to a reduction in the total number of guest rooms available and related unacceptable revenue loss.

ICCL Comment: This is an oversimplification of the ICCL comment. Please see our previous comments of July 28, 2005.

Question 6: The Board has observed sliding doors (both manually operated and automatic) with tracks greater than ½ inch wide. Are marine sliding doors available which comply with V302.3? Does the location of the sliding door determine the size of the track? Are automatic sliding doors with fold down plates (that cover the track) appropriate for doors used by passengers?

ICCL Comment: There is indeed a difference in the design of a door and the track depending on where the door is located. Watertight doors below the bulkhead deck are massive and have this type of arrangement. We believe here, that the board is primarily focusing on balcony doors. There are several concerns with providing this arrangement on a balcony door. First, the lifting of the plate will create a tripping hazard and second, this will add to the force required to be able to close or open the door. Additionally, we see no such similar requirement or concern with regards to sliding doors shoreside. ICCL members are committed to making balcony doors and indeed all doorways as barrier-free as possible; however, a test design should not be automatically incorporated in a rule until it is proven to be an acceptable solution.

Question 7: The Board has noticed surfaces of gangways with raised narrow slats which are positioned perpendicular to the direction of travel. These slats have been referred to as cleats. Under V413.4, cleats would be prohibited on gangway surfaces. Are these cleats necessary to address slippery conditions?

ICCL Comment: YES. Cleats are an effective system to assure safety under a variety of conditions that involve the slope of the ramp and weather conditions.

Are other methods available to address slippery conditions which do not require cleats or other raised surfaces on the gangways?

ICCL Comment: Yes, articulated stairways and other systems are available but each has its own issues in terms of safety and access under varying circumstances and thus each has its own limited applications.

What are the implications if the Board allowed cleats complying with V303.2 or V303.3?

ICCL suggests that the Board staff contact gangway manufacturers for input. As we recall, there were two such representatives at the Board meeting in New Orleans.

Question 8: This draft includes provisions in V201.1.3 and V1102 through V1104 for tenders that carry 60 or more passengers. These provisions require at least two wheelchair spaces with securement systems; an accessible route to the wheelchair spaces; a method to facilitate boarding passengers with disabilities. Do tenders that have been recently constructed or are under design or construction provide wheelchair spaces with securement systems? What impacts will these provisions have on newly constructed tenders? Should the Board conduct a case study of a tender?

ICCL Comment: Based on tours including a demonstration ride on newer tenders, it appears that the Board is requiring what is currently state of the industry in tender construction. A case study is not needed however, the definition of “Tender” must be refined and ICCL has provided commentary in the text of the guidelines.

Question 9: The Board seeks comments on the sample case studies. The Board is particularly interested in the following:

ICCL Comment: Correlation to these case studies cannot be applied to ICCL members’ vessels.

Chapter 1: Application and Administration
Chapter 2: Scoping Requirements
Chapter 3: Building Blocks
Chapter 4: Accessible Routes, Accessible Means of Escape, and Accessible Passenger Boarding Systems
Chapter 5: General Passenger Vessel Elements
Chapter 6: Plumbing Elements and Facilities
Chapter 7: Communication Elements and Features
Chapter 8: Special Rooms, Spaces, and Elements
Chapter 9: Built-in Elements
Chapter 10: Recreation Facilities and Play Areas
Chapter 11: Tenders

CHAPTER 1: APPLICATION AND ADMINISTRATION
V101 Purpose
V102 Dimensions for Adults and Children
V103 Equivalent Facilitation
V104 Standard Practices
V105 Referenced Standards
V106 Definitions

V101 Purpose

V101.1 General. This document contains scoping and technical requirements for accessibility to passenger vessels by individuals with disabilities. The requirements are to be applied during the design, construction, additions to, and alteration of facilities and elements on passenger vessels to the extent required by regulations issued by Federal agencies under the Americans with Disabilities Act of 1990 (ADA).

ICCL Comment: The term “additions” should be removed as in the maritime industry these are referred to as alterations.

V104 Standard Practices

V104.3 Figures. Unless specifically stated otherwise, figures are provided for informational purposes only.

V105 Referenced Standards

V105 Referenced Standards

ICCL recommends that a section V105.3 be included that states as follows:

Discussion:

These guidelines purport to apply US engineering standards of ANSI, BHMA, and AMSE, ASTM and NFPA to establish accessibility in the design and construction of cruise ships in foreign nations. Aside from the obvious jurisdictional problems of mandating compliance with US engineering standards for design and construction occurring outside the territory of the United States, these standards may conflict with the existing or future standards promulgated by the vessels’ flag states or the nations where the ships are designed or constructed.

The US federal agencies do not have jurisdiction under the ADA to apply design or construction standards outside the U.S., and the existence of any conflicts with foreign standards means the U.S. standards cannot be applied under the reasoning of Spector. The magnitude of this problem is significant, as oceangoing overnight international voyage ships of the type ICCL members operate are built exclusively in non-U.S. shipyards using mostly non-U.S. equipment. [Further discussion is attached at ANNEX 3] As previously noted, foreign countries, shipyards, certifying governments, manufacturers, etc., may not recognize or even accept U.S. standards over their own. For example, German shipyards use DIN or other EU recognized standards and Japanese yards use JIS. This can also negatively impact issuance of a warranty by the manufacturer.

We also reference Advisory V103 which states: “The responsibility for demonstrating equivalent facilitation in the event of a challenge rests with the covered entity. With the exception of transit facilities, which are covered by regulations issued by the Department of Transportation, there is no process for certifying that an alternative design provides equivalent facilitation.” To the extent that this advisory was inserted to address initial comments on V105, it does not adequately address these concerns. It does not eliminate the challenges presented by obligations to comply with conflicting laws, regulations or standards of foreign nations. The above recommended addition should resolve this matter.

These concerns, which were previously raised to the Board, have not been addressed. Promulgating standards where compliance with such standards is known to be infeasible, does not further accessibility and serves no useful purpose. In order to avoid the legal quagmire created by the extraterritorial application of U.S. standards abroad, ICCL proposes at the head of this discussion that V105.3 be added.

V105.1 General. The standards listed in V105.2 are incorporated by reference in this document and are part of the requirements to the prescribed extent of each such reference. The Director of the Federal Register has approved these standards for incorporation by reference in accordance with 5 U.S.C. 552(a) and 1 CFR part 51. Copies of the referenced standards may be inspected at the Architectural and Transportation Barriers Compliance Board, 1331 F Street, NW, Suite 1000, Washington, DC 20004.

V105.2 Referenced Standards. The specific edition of the standards listed below are referenced in this document. Where differences occur between this document and the referenced standards, this document applies.

Advisory V105.2.1 ANSI/BHMA. ANSI/BHMA A156.10-1999 applies to power operated doors for pedestrian use which open automatically when approached by pedestrians. Included are provisions intended to reduce the chance of user injury or entrapment.

ANSI/BHMA A156.19-1997 and A156.19-2002 applies to power assist doors, low energy power operated doors or low energy power open doors for pedestrian use not provided for in ANSI/BHMA A156.10 for Power Operated Pedestrian Doors. Included are provisions intended to reduce the chance of user injury or entrapment.

Advisory V105.2.2 ASME. ASME A17.1-2000 is used for the design, construction, installation, operation, inspection, testing, maintenance, alteration, and repair of elevators and escalators.

V106 Definitions

V106.3 Undefined Terms. The meaning of terms not specifically defined in V106.5 or in regulations issued by the Department of Justice and the Department of Transportation to implement the Americans with Disabilities Act, or in US Coast Guard regulations, or in referenced standards shall be as defined by the current edition of Webster’s unabridged dictionary and in recognized maritime publications.

ICCL Comment: ICCL recommends rewording this section as indicated. American Collegiate dictionaries are not a reliable source for defining terms associated with the maritime industry. The recommended publications will be much more likely to include the terms referenced and are more available to non-U.S. entities that design and construct the majority of cruise ships operating out of U.S. ports. An example of such a publication would be: “The Marine Encyclopedic Dictionary” (Third Edition, Eric Sullivan published by Lloyds of London Press Ltd.

V106.4 Interchangeability. Words, terms and phrases used in the singular include the plural and those used in the plural include the singular.

V106.5 Defined Terms.

Addition. An expansion, extension, or increase in the gross deck area or height of a passenger vessel.

ICCL Comment: This term should be deleted as it is included in the concept of alteration. We also note that under this definition, that an addition to the mast of a vessel to accommodate a new radar or other electronic antennae and which may increase the air draft or “height” of the vessel could be construed as an alteration. We would expect that changing an electronic mast or antenna would not result in having to make access alterations. Therefore, the reference to “height” in the above section is inappropriate.

Administrative Authority. The governmental agency(s) that adopts or enforces regulations and guidelines for the design, construction, or alteration of passenger vessels.

ICCL Comment: In as much as these guidelines apply to non-U.S. Flag ships, this definition is not accurate for these “foreign” vessels and must be modified accordingly. This is problematic. ICCL suggests that the definition of this term be modified as above by deleting the “US Coast Guard or other.”

Alteration. A change to a passenger vessel that affects or could affect the usability of the passenger vessel or portion thereof. Alterations include, but are not limited to, remodeling, renovation, rehabilitation, reconstruction, historic restoration, which involve changes or rearrangement of the structural parts or elements, and changes or rearrangement in the plan configuration of bulkheads and partitions. Normal maintenance, painting or wallpapering, carpet replacement in kind or changes to propulsion, mechanical and electrical systems are not alterations unless they affect the usability of the passenger vessel.

ICCL Note: Carpet replacement in kind is considered to be normal maintenance.

Area of Temporary Refuge. An area where people who are unable to use stairs may remain temporarily to await further instructions or assistance during emergency evacuation.

ICCL Comment: We recommend that this definition be deleted as the term was developed by the PVAAC to address an issue found in small passenger vessels that do not comply with either SOLAS, or USCG Regulations found 46 CFR Subchapters H or K. Also please see our commentary at V411.

Camber. The transverse curvature given to the weather deck surfaces to shed water readily, increase deck surface strength, and increase headroom clearance on the centerline for the deck below. Also known as the rise or crown of a deck.

ICCL Comment: ICCL recommends adding the word “transverse” before the word “curvature” (as shown above) so that the definition is more precise and not confused with “sheer”.

Ground Level. The level within a deck where a play area is located.

ICCL Comment: In as much as ships are not buildings or shoreside facilities, the term “ground level” is misleading, inappropriate, and could be confusing. We recommend the term be changed to “deck level” in keeping with commonly accepted nautical/maritime vocabulary. We see no reason to continue to utilize shore-side terms in a document that is meant for shipboard application.

Ground Level Play Component. A play component that is approached and exited at the ground level.

ICCL Comment: the words “ground level” should be revised to “deck level” wherever used, in accordance with above comment.

Mezzanine. An intermediate level or levels between the deck surface and ceiling of any deck with an aggregate deck surface area of not more than one-third of the area of the room or space in which the level or levels are located. Mezzanines have sufficient elevation that space for human occupancy can be provided on the deck level below. This is also commonly referred to as tweendeck.

ICCL Comment: This should be referred to as a “Tween-deck” to be consistent with nautical terminology. We recommend that a sentence be added indicating that this is also commonly referred to as “tweendeck” as shown above. We do not believe this detracts from the definition and may be of assistance to the ship designer/shipbuilder.

CHAPTER 2: SCOPING REQUIREMENTS

V201 Application
V202 Existing Passenger Vessels
V203 General Exceptions
V204 Protruding Objects
V205 Operable Parts
V206 Onboard Accessible Routes
V207 Accessible Means of Escape
V208 Passenger Vessel Boarding
V209 Stairways
V210 Rinsing Showers
V211 Drinking Fountains
V212 Kitchens, Kitchenettes, and Sinks
V213 Toilet Facilities and Bathing Facilities
V214 Washing Machines and Clothes Dryers
V215 Emergency Alarm Systems
V216 Signs
V217 Telephones
V218 Two-Way Communication Systems
V219 Assistive Listening Systems
V220 Automatic Teller Machines and Fare Machines
V221 Assembly Areas and Public Seating Areas
V222 Dressing, Fitting, and Locker Rooms
V223 Medical Care Facilities
V224 Passenger Guest Rooms
V225 Storage
V226 Dining Surfaces and Work Surfaces
V227 Sales and Service
V228 Depositories, Vending Machines, Change Machines, and Mail Boxes
V229 Windows
V230 Exercise Machines and Equipment
V231 Miniature Golf Facilities
V232 Play Areas
V233 Saunas and Steam Rooms
V234 Swimming Pools, Wading Pools, and Spas
V235 Shooting Facilities

V201 Application

V201.1 Scope. All areas of newly designed and newly constructed passenger vessels and altered portions of existing passenger vessels shall comply with this document to the extent required by V201.1.

ICCL Comment: The only flexibility provided in application of new regulations for the ship owner, is before the contract for construction is signed. V201.1 should be redrafted to state:

“V201.1 Scope: A new ship is defined by the date of contract for construction of that ship. New ships contracted eighteen months after the date of publication of the final regulation adopting the guidelines, shall comply.”

V201.1.3 Tenders. Tenders carried by or used primarily by passenger vessels required to comply with V201.1.1 shall comply with Chapters 1 and 11.

ICCL Comment: This is not clear as written for a document applying to ships. We recommend that the section be redrafted as follows:

“V201.1.3 Tenders: Tenders that fit in the davits of, are secured onboard, and which sail with the ship when it sails shall comply with Chapters 1 and 11.

Other U.S. flag vessels utilized as tendering vessels should comply with access regulations, if any, as written for those vessels.”

Advisory V201.1.3 Tenders. Tenders that are carried by or used primarily by large passenger vessels and that carry more than 150 passengers are only required to comply with chapters 1 and 11 and are not considered large vessels subject to V201.1.1.

ICCL Comment: The language “or used primarily by” should be deleted to carry out the comment made to V201.1.3 above.

V201.4 Passenger Amenities. At least one of each type of element, space, and facility required to comply with this document and used by passengers shall be on an entry deck or connected by an onboard accessible route to an entry deck.

Advisory V201.4 Passenger Amenities. Types of elements, spaces, and facilities used by passengers include, but are not limited to, drinking fountains, seating, tables, counters, food service spaces, toilet rooms, and guest rooms.

In addition to the “one of each type” provision in V201.4, section V224.6 requires all passenger guest rooms that are required to comply with V806.2 to be located on the same deck(s) used to satisfy the “one of each type” requirement. Also, sections V221.2.3.2 and V221.2.4 require all wheelchair spaces and companion seats to have a similar location.

ICCL Comment: This is confusing and seems to contradict the actual requirement of V201.4. We recommend that it be deleted.

V202 Existing Passenger Vessels

V202.1 General. Additions and alterations to existing passenger vessels shall comply with V202.

V202.2 Additions. Each addition to an existing passenger vessel shall comply with the requirements for new construction. Each addition that affects or could affect the usability of or access to an area containing a primary function shall comply with V202.4.

ICCL Comment: We continue to recommend that this section be deleted in accordance with our previous comments that an addition is a subset of an alteration.

V203 General Exceptions

V203.2 Employee Areas. Areas of passenger vessels which are exclusively used by employees shall not be required to comply with this document.

Advisory V203.2 Employee Areas. Where an accessible means of escape required by V207 runs through an employee space, only the circulation path in the space containing the accessible means of escape is subject to applicable accessibility requirements because the circulation path is not exclusively used by employees.

ICCL Comment: We recommend adding wording: “this advisory should be considered in conjunction with V410.”

V204 Protruding Objects

V204.1 General. Protruding objects on circulation paths shall comply with V307.

ICCL Comment: Protruding Objects: This requires that all circulation paths (not just accessible routes) used by passengers comply with V307. ICCL recommends that this be changed to read “circulation paths normally meant to be used by passengers.” As currently written, it could be misinterpreted to mean than crew circulation spaces (stairways, service corridors, elevators etc.) not for use by passengers but which could be used by passengers either intentionally (against prohibition) or mistakenly in an emergency, would have to comply with the referenced section.

The previous ICCL comment has not been adequately addressed. Although these guidelines will not apply to crew spaces, the emergency exit provision in V203.2 above and V410 (with exceptions) will require a close evaluation with regard to protruding objects which in this case may be a fire hose station, fire extinguisher etc. This needs careful evaluation as it may have significant impact on secondary escape routes which may be partially through a crew area. These crew areas are often critical to safety functions such as fire fighting. As such necessary firefighting and other safety equipment must be stored in these areas.

V205 Operable Parts

V205.1 General. Operable parts on elements required to comply with this document, on onboard accessible routes, and in rooms or spaces required to comply with this document shall comply with V309.

ICCL Comment: We recommend that the term “kitchen” be defined in the definitions section and that the definition also refer to the fact that these are often referred to as a “pantry” onboard ship. This is particularly relevant because of the regulatory limitation on the heat output of appliances in these particular areas. Additionally, the term “pantry” in the dictionary (Webster’s Unabridged or the American Collegiate) is defined as a small room where COLD food is prepared. This is in keeping with the SOLAS restrictions. Additionally, the Marine Encyclopedic Dictionary: third edition does not actually define a “kitchen” but rather defines the term “galley” as being the “cooking place or kitchen of a ship.”

ICCL therefore recommends that the term “kitchen” as used in these guidelines be replaced by the word “pantry.”

V206 Onboard Accessible Routes

V206.2.3 Restaurants and Cafeterias. In restaurants and cafeterias, at least one onboard accessible route shall be provided to all dining areas, including raised or sunken dining areas, and outdoor dining areas.

Advisory V206.2.3 Restaurants and Cafeterias Exception 2. Examples of “same services” include, but are not limited to, bar service, rooms having smoking and non-smoking sections, lotto and other table games, carry-out, and buffet service. Examples of “same decor” include, but are not limited to, seating at or near windows and railings with views, areas designed with a certain theme, party and banquet rooms, and rooms where entertainment is provided.

ICCL Comment: We renew our previous comment which stated: “Restaurants and Cafeterias: Exception 1 does not require an onboard accessible route on vessels that otherwise are not required to provide onboard vertical access to mezzanine dining areas that contain less than 25% of the total combined dining and seating area, where the same décor and services are provided in the accessible area. Exception 2 does not require an onboard accessible route to raised or sunken dining areas in existing vessels, irrespective of the size of the area or whether the vessel is otherwise required to provide onboard vertical access, again provided the same décor and services are provided in the accessible area and the accessible area is not restricted to use by persons with disabilities.

These exceptions should be extended to raised and/or sunken dining areas on newly constructed cruise vessels as well. Raised dining areas may be created in dining areas for a multitude of design reasons, such as conditions stemming from use of the space below the dining area or even maintaining views through portals or of a focal point in the room. Such levels may not be served by an elevator (particularly if the raised area does not qualify a higher deck or even a tweendeck). Such levels also may not be served by an accessible route, as space constraints in combination with the necessary dining capacity may make stepped access the more viable solution. In such circumstances, where there truly is no difference in the experience being offered on the different levels of the dining area, and the areas have the same décor and service, these exceptions should apply irrespective of whether the vessel is otherwise exempt for the requirements for vertical access or is an existing vessel. It is also significant that in most main dining areas onboard a cruise vessel, passengers are assigned to a specific table and do not get to choose the particular table at which they sit.

V207.3 Elevators. Where an accessible means of escape from any passenger deck travels vertically four or more decks, at least one accessible means of escape from each passenger deck shall contain an elevator complying with V206.6 and V410.3.

ICCL Comment: While we have previously discussed referencing US engineering and building standards, it is worth repeating here that passenger ships engaged in international commerce are required (even by the United States) to comply with SOLAS requirements. In particular SOLAS has specific and extensive requirements for sprinkler systems that must by complied with versus NFPA standards.

V208 Passenger Vessel Boarding.

V208.1 General. Where passenger vessels are embarking or disembarking passengers from fixed piers, floating piers, or landside structures, at least one passenger boarding system complying with V412 shall connect an entry deck to fixed piers, floating piers, or landside structures.

ICCL Comment: The requirement for a shoreside passenger boarding system is typically the responsibility of the Port. We do not believe that the ship or ship operator should be responsible for shoreside systems unless that ship or ship operator is the owner or manager of the shoreside system/pier, etc.

Therefore, V208 should be redrafted to state that each ship is required to provide an accessible path to the shoreside embarkation system.

V210 Rinsing Showers

V210.1 General. Where provided, rinsing showers shall comply with V608.

ICCL Comment: We recommend that this guideline be reworded to state that “Where provided, at least one accessible rinsing shower in each pool area shall comply with V608.” With this rewording, the exception below should be deleted.

V212 Kitchens, Kitchenettes, and Sinks

ICCL Comment: Please see our comments at V205.1

V215 Emergency Alarm Systems

V215.2 Public Areas. Alarms in public areas shall comply with principles of best practice.

V215.3 Guest Rooms. Guest rooms required to comply with V224.4 shall provide alarms complying with principles of best practice.

ICCL Comment: We recommend that an advisory note be added which states:

“Advisory [215.3] – Principles of Best Practice. Compliance with SOLAS requirements for alarms, crew assignment of emergency duties in this regard and crew training constitutes compliance with best practice.”

V216 Signs

ICCL Members are conducting a detailed comparison of the signage required by SOLAS versus that in the Guidelines. We believe that this is a critical issue and while international safety regulations must prevail, it is imperative that we know if there are serious conflicts and just what and where those may be. The results of this detailed examination are also not complete and will be submitted as soon as possible.

V216.1 General. Signs shall be provided in accordance with V216 and shall comply with V703.

V216.2 Designations. Interior and exterior signs identifying permanent rooms and spaces shall comply with V703.1, V703.2, and V703.5. Where pictograms are provided as designations of permanent interior rooms and spaces, the pictograms shall comply with V703.6 and shall have text descriptors complying with V703.2 and V703.5.

Advisory V216.2 Designations. Section V216.2 applies to signs that provide designations, labels, or names for rooms or spaces where the sign is not likely to change over time. Examples include signs labeling restrooms, room and deck numbers or letters, and room names. Tactile text descriptors are required for pictograms that are provided to label or identify a permanent room or space. Pictograms that provide information about a room or space, such as “no smoking,” occupant logos, and the International Symbol of Accessibility, are not required to have text descriptors.

V216.3 Directional and Informational Signs. Signs that provide direction to or information about spaces and facilities of the passenger vessel shall comply with V703.5.

Advisory V216.3 Directional and Informational Signs. Information about interior spaces and facilities includes rules of conduct, occupant load, and similar signs. Signs providing direction to rooms or spaces include those that identify escape routes.

V216.4 Means of Escape. Signs for means of escape shall comply with V216.4.

ICCL Comment: SOLAS and ISO provide detailed standards, including signage standards, for orderly evacuation and escape. These and other international standards already provide that crew assist and direct passengers in the event of an emergency. As a result, crew members perform a significant role in evacuating passengers both with and without disabilities. SOLAS has requirements pertaining to Low Location Lighting (LLL) which along with crew members are designed to direct passengers in the event of an emergency and we must comply with these. Adding signs such as that required by the current draft will only slow down an evacuation by people taking the time to locate and read them, when crew are already trained and stationed to provide direction. These signs could also confuse passengers by leading them to exit doors, as opposed to the proper assembly station.

V216.4.1 Exit Doors. Exit doors identified with illuminated exit signs shall be identified by tactile signs complying with V703.1, V703.2, and V703.5.

V216.4.2 Areas of Temporary Refuge. Areas of temporary refuge shall comply with V216.4.2.

ICCL Comment: This section should be deleted together with all subsections discussing requirements for an area of temporary refuge as it is not applicable to ships impacted by these guidelines. We note that Areas of Temporary Refuge are referred to above this section and those areas should be deleted also.

The term “Area of Temporary Refuge” was developed by the PVAAC so as to allow protection of sheltering in place in the event of a fire in order to address an issue found in small passenger vessels that do not comply with either SOLAS, or USCG Regulations. Also see this comment at V411.

V216.4.2.1 Identification. Each door providing access to an area of temporary refuge from an adjacent deck area shall be identified by a sign complying with V703.5, stating “AREA OF TEMPORARY REFUGE”, and the sign shall include the International Symbol of Accessibility complying with V703.7.2.1. Where exit sign illumination is required by the administrative authority, the area of temporary refuge sign shall be illuminated. Additionally, a tactile sign complying with V703.2 shall be located at each door to an area of temporary refuge.

V216.4.2.2 Instructions. In each area of temporary refuge provided with a two-way communication system, instructional signage on the use of the area under emergency conditions shall be posted under the communications system and shall comply with V703.5. The instructions shall include all of the following:

V216.4.3 Directional Signs. At exit doors and elevators serving a space required to comply with this document but not serving as an accessible means of escape, signage complying with V703.5 shall be provided indicating the location of the nearest accessible means of escape.

ICCL Comment: This paragraph should be deleted as we believe that providing the signs as indicated in this section could actually lead a person into danger.

Whereas the purpose of ADA is to ensure independent access, in an emergency onboard ship, safe egress is not an individual or independent function. The safety of ALL passengers onboard dictates that ALL will be assisted. The location of the safe means of escape will depend upon the circumstances of the emergency. Thus, the concept of directional signs onboard a ship to designate the direction of safe egress is inappropriate and such signs could easily misguide a person into danger rather than away from it.

Safe escape from any space onboard ship is a complex matter. For this reason, maritime experts such as the USCG and IMO are charged with assuring the safety of crew and passengers. Given current regulatory signage requirements, shipboard safety systems, and crew emergency procedures, the proposed signage will be counterproductive and may very well promote confusion. Moreover, SOLAS specifically prohibits the use of directional low location lighting. See SOLAS Chapter II-1 Regulation 13.3.2.5 – Marking of Escape Routes and associated guidance. This indicates that IMO recognizes the danger of directional signs.

V216.6 Elevators. In alterations, where existing elevators do not comply with V407, elevators complying with V407 shall be clearly identified with the International Symbol of Accessibility complying with V703.7.2.1.

ICCL Comment: In existing vessels, a change in elevator cab size is not technically feasible. Thus, unless new elevators are added, such as in a mid-body extension, elevators on an altered vessel will still not comply with these requirements. Thus, this section should state that where elevators in compliance with V407 have been installed these signs would be required. Otherwise, this section would imply that a complying elevator must be installed for any alteration

V216.8 Assistive Listening Systems. Each assembly area and public seating area required by V219 to provide assistive listening systems shall provide signs informing patrons of the availability of the assistive listening system. Assistive listening signs shall comply with V703.5 and shall include the International Symbol of Access for Hearing Loss complying with V703.7.2.2.

ICCL Comment: We recommend an exception similar to that currently in the Access Board’s latest edition of ADAAG be included here. The definition of assembly area makes it impractical to post signage in each of those areas on the ship, and the main Guest Services Desk is a well recognized location for guest inquiries of this nature. Further, cruise lines readily make information concerning assistive listening devices available to guests in a variety of ways, including materials provided in advance of the departure date and in guest rooms onboard the ship, thereby diminishing the need for such signage.

Exception: Signs shall not be required at each assembly and public seating area, provided that signage is displayed at the main shipboard Guest Services Desk informing patrons of the availability of the assisted listening systems.

V217 Telephones

V217.1 General. Where coin-operated pay telephones, coinless pay telephones, closed-circuit telephones, courtesy telephones, or other types of public telephones are provided, public telephones shall be provided in accordance with V217 for each type of public telephone provided.

Advisory V217.1 General. These requirements apply to all types of public telephones, including courtesy phones provided at passenger vessel restaurants or concierge desks that provide free direct connections to passenger guest rooms or guest services.

V217.2 Minimum Number. No fewer than two public telephones shall be provided at each location containing telephones. At least one shall be a wheelchair accessible public telephone complying with V704.2 and at least one shall be a public TTY complying with V704.4.

ICCL Comment: Our previous comment has not been adequately addressed. This requirement is clearly in excess of shore side facility requirements as stated in the new ADAAG. No persuasive rationale has been offered for requiring significantly greater scoping of TTY’s onboard vessels. For private/non-government facilities, revised ADAAG requires that only one TTY be provided per floor, level or phone bank where public phones are otherwise provided. Additionally, statistical information regarding the use of TTY’s onboard the ICCL member cruise line vessels demonstrate that the majority of available TTY technology goes unused. This requirement, as stated above, is excessive and unreasonable. The Board should restate V217.2 to maintain the wheelchair accessible provision and eliminate the TTY requirement.

V219.3 Receivers. Receivers complying with V706.3 shall be provided for assistive listening systems in the largest assembly areas and public seating areas in accordance with Table V219.3 and calculated according to the total number of seats in the vessel required to comply with V219.2. Twenty-five percent minimum of receivers provided, but no fewer than two, shall be hearing-aid compatible in accordance with V706.4.
EXCEPTION: Where all seats in an assembly area or public seating area are served by an induction loop assistive listening system, the minimum number of receivers required by Table V219.3 to be hearing-aid compatible shall not be required to be provided.

ICCL Comment: The collective experience of ICCL members is that receivers currently available on voyages are significantly underutilized. The minimum number of receivers in the current draft is excessive. The guideline should not be based on a percentage of the cumulative number of seats in assembly areas as the total number of seats can very well exceed the maximum number of passengers the vessel can carry. A more appropriate guideline would be to require on each voyage an amount equal to .5% of the number of seats in the vessel’s single largest assembly area, but not less than two receivers. As an example, under ICCL’s proposal Royal Caribbean International’s Freedom of the Seas would be required to carry seven devices as that vessel’s largest assembly area seats 1320 passengers.

To the extent the demands of the marketplace change and dictate an increased need for receivers, vessel operators will naturally offer more receivers to remain competitive. However, to keep excess receivers on board when they are not used, unnecessarily diminishes storage space, which is already limited on vessels.

Capacity of Seating	Minimum Numberof Required Receivers	Minimum Number of Required ReceiversRequired to be Hearing-Aid Compatible
50 or less	2	2
51 to 200	2, plus 1 per 25 seats over 50 seats¹	2
201 to 500	2, plus 1 per 25 seats over 50 seats¹	1 per 4 receivers¹
501 to 1000	20, plus 1 per 33 seats over 500 seats¹	1 per 4 receivers¹
1001 to 2000	35, plus 1 per 50 seats over 1000 seats¹	1 per 4 recievers¹
2001 and over	55, plus 1 per 100 seats over 2000 seats¹	1 per 4 receivers¹

V221 Assembly Areas and Public Seating Areas

V221.1 General. Assembly areas shall provide wheelchair spaces, companion seats, and designated aisle seats complying with V221 and V802. Public seating areas shall provide wheelchair spaces and companion seats complying with V221, V802.1 and V802.3.

V221.2 Wheelchair Spaces. Wheelchair spaces complying with V221.2 shall be provided in assembly areas and public seating areas with fixed seating.

V221.2.1 Number. The number of wheelchair spaces shall be provided in accordance with V221.2.1.

V221.2.1.1 Assembly Areas. Wheelchair spaces shall be provided in each assembly area in accordance with Table V221.2.1.1.

V221.2.1.2 Public Seating Areas. The number of wheelchair spaces for public seating areas shall be calculated according to the total number of fixed seats provided in public seating areas of the passenger vessel in accordance with Table V221.2.1.1.

Number of Seats	Minimum Number of Required Wheelchair Spaces
4 to 25	1
26 to 50	2
51 to 150	4
151 to 300	5
301 to 500	6
501 to 5000	6, plus 1 for each 150, or fraction thereof, between 501 through 5000
5001 and over	36, plus 1 for each 200, or fraction thereof, over 5000

V221.2.2 Integration. Wheelchair spaces shall be an integral part of the seating plan.

Advisory V221.2.2 Integration. The requirement that wheelchair spaces be an “integral part of the seating plan” means that wheelchair spaces must be placed within the footprint of the seating area. Wheelchair spaces cannot be segregated from seating areas. For example, it would be unacceptable to place only the wheelchair spaces, or only the wheelchair spaces and their associated companion seats, outside the seating areas defined by risers in an assembly area or public seating area.

V221.2.3 Lines of Sight and Dispersion in Assembly Areas. Wheelchair spaces in assembly areas shall provide lines of sight complying with V802.2 and shall comply with V221.2.3. In providing lines of sight, wheelchair spaces shall be dispersed. Wheelchair spaces shall provide spectators with choices of seating locations and viewing angles that are substantially equivalent to, or better than, the choices of seating locations and viewing angles available to all other spectators. When the number of wheelchair spaces required by V221.2.1 has been met, further dispersion shall not be required.

ICCL Comment: Given the difference between ship construction and shore-side theater, stadium, or building construction, such as the maximum permitted length and area of fire zones and beam of the ship, full dispersion of seats horizontally and on all vertical levels is not feasible.

Even the largest cruise ships feature theaters that are steeply sloped relative to slopes found in land-based theaters. Given the steepness of the slope, ramps that would be required to provide full vertical dispersion of wheelchair accessible and companion seats would be exceptionally long, to provide a maximum ramp slope of 1:12. Long ramps would mean excessive loss of seating overall in the areas covered by ramps.

The current PVAG draft does not address the comment previously made. We reiterate that providing accessible seating to points of entry levels (usually found at top, middle or bottom levels of the shipboard theaters) along an accessible passenger route allows adequate sightlines and access to the activities occurring in the theater and minimizes the loss of overall seating capacity.

Advisory V221.2.3 Lines of Sight and Dispersion in Assembly Areas. Consistent with the overall intent of the ADA, individuals who use wheelchairs must be provided equal access so that their experience is substantially equivalent to that of other members of the audience. Thus, while individuals who use wheelchairs need not be provided with the best seats in the house, neither may they be relegated to the worst.

V221.2.3.1 Horizontal Dispersion. Wheelchair spaces shall be dispersed horizontally.

Advisory V221.2.3.1 Horizontal Dispersion. Horizontal dispersion of wheelchair spaces is the placement of spaces in an assembly facility seating area from side-to-side.

V221.2.3.2 Vertical Dispersion. Wheelchair spaces shall be dispersed vertically at varying distances from the screen, or performance area. In addition, wheelchair spaces shall be located in each balcony or mezzanine that is located on an onboard accessible route.

This provision is ambiguous as it implies that vertical dispersion is required on all levels of all such areas, including balconies and mezzanines, even though not all levels of those areas are located onboard an accessible route.

V224 Passenger Guest Rooms

V224.1 General. Passenger vessels shall provide guest rooms in accordance with

V224.2 Guest Rooms with Mobility Features. Guest rooms with mobility features complying with V806.2 shall be provided in accordance with Table V224.2.

ICCL Comment: ICCL has contracted for an economic impact study with regards to scoping of guest rooms with mobility features. This study will look at actual usage as well as projected usage by persons needing this feature. While we expected the study and ICCL comments to be ready for submittal with this set of comments, events beyond our control have delayed completion and submission.

Table V224.2 Guest Rooms with Mobility Features

Total Number of Guest Rooms Provided	Minimum Required Number of Rooms With Tubs or Showers	Minimum Number of Required Rooms With Roll-In Showers	Total Number of Required Rooms
1 to 25	1	0	1
26 to 50	2	0	2
51 to 75	3	1	4
76 to 100	4	1	5
101 to 150	5	2	7
151 to 200	6	2	8
201 to 300	7	3	10
301 to 400	8	4	12
401 to 500	9	4	13
501 to 1000	2 percent of total	1 percent of total	3 percent of total
1001 and over	20, plus 1 for each 100, or fraction thereof, over 1000	10, plus 1 for each 100, or fraction thereof, over 1000	30, plus 2 for each 100, or fraction thereof, over 1000

V224.6 Location. Guest rooms required to comply with V806.2 shall be provided on the decks complying with V201.4.

ICCL Comment: Please see our comment regarding Advisory V201.4

V226 Dining Surfaces and Work Surfaces

V226.1 General. Where dining surfaces are provided for the consumption of food or drink, at least 5 percent of the seating spaces and standing spaces at the dining surfaces shall comply with V902. In addition, where work surfaces are provided for use by other than employees, at least 5 percent shall comply with V902.

ICCL Comment: An additional exception should be drafted for tables, drink holders etc. which do not provide knee clearance for anyone.

In show lounges and entertainments areas, lounges etc., small cocktail tables are provided. These tables are not intended to provide knee clearance or approach. These tables should be included in the exception under V226.1. This section currently requires an element that is not provided even for persons without disability. We note that no discussion was presented regarding the ICCL comment and renew our statement that accommodation should not be required for the disabled community where no accommodation is made for the non-disabled community.

V232.2 Play Components. Where provided, play components shall comply with V232.2 and V1004.

V232.2.1 Ground Level Play Components. Ground level play components shall be provided in the number and types required by V232.2.1. Ground level play components that are provided to comply with V232.2.1.1 shall be permitted to satisfy the additional number required by V232.2.1.2 if the minimum required types of play components are satisfied. Where two or more required ground level play components are provided, they shall be dispersed throughout the play area and integrated with other play components.

ICCL Comment: In the definitions section, the words “ground level” should be revised to “deck level” wherever used. These changes should be made in all sections where referenced.

V234 Swimming Pools, Wading Pools, and Spas

V234.1 General. Swimming pools, wading pools, and spas shall comply with V234.

V234.2 Swimming Pools. At least one accessible means of entry shall be provided for swimming pools. The accessible means of entry shall be a swimming pool lift complying with V1005.2 or a sloped entry complying with V1005.3.

ICCL Comment: Due to the design of children’s pools, ICCL recommends that the following exception be added.

3. “Children’s pools where access can be provided by a parent or attendant lifting the child into the pool shall not be required to provide a mechanical lift.”

CHAPTER 3: BUILDING BLOCKS

V301 General
V302 Deck Surfaces
V303 Changes in Level
V304 Turning Space
V305 Clear Deck Space
V306 Knee and Toe Clearance V307 Protruding Objects
V308 Reach Ranges
V309 Operable Parts
V301 General

V302.2 Carpet. Carpet or carpet tile shall be securely attached and shall have a firm cushion, pad, or backing or no cushion or pad. Carpet or carpet tile shall have a level loop, textured loop, level cut pile, or level cut/uncut pile texture. Pile height shall be ½ inch (13 mm) maximum. Exposed edges of carpet shall be fastened to deck surfaces and shall have trim on the entire length of the exposed edge. Carpet edge trim shall comply with V303.

Advisory V302.2 Carpet. Carpets and permanently affixed mats can significantly increase the amount of force (roll resistance) needed to propel a wheelchair over a surface. The firmer the carpeting and backing, the lower the roll resistance. A pile thickness up to ½ inch (13 mm) (measured to the backing, cushion, or pad) is allowed, although a lower pile provides easier wheelchair maneuvering. If a backing, cushion or pad is used, it must be firm. Preferably, carpet pad should not be used because the soft padding increases roll resistance.

ICCL Comment: This advisory appears to conflict with the later part of the advisory itself as in one place it states that a firm carpet backing can lower the roll resistance and then states that carpet pad should not be used because it increases roll resistance. Unless the measurement in the advisory is clarified, it is not clear as to weather or not the term pile height is to include backing, pad or cushion. We recommend that the matter be clarified.

CHAPTER 4: ACCESSIBLE ROUTES, ACCESSIBLE MEANS OF ESCAPE, AND ACCESSIBLE PASSENGER BOARDING SYSTEMS

V401 General
V402 Accessible Routes
V403 Walking Surfaces
V404 Doors, Doorways, and Gates
V405 Ramps
V406 Curb Ramps
V407 Elevators
V408 Limited-Use/Limited-Application Elevators V409 Platform Lifts
V410 Accessible Means of Escape
V411 Areas of Temporary Refuge
V412 Passenger Boarding Systems V413 Gangways V414 Manually Powered Boarding Lifts

V403.6 Handrails. Where handrails are provided along walking surfaces with running slopes not steeper than 1:20, handrails shall comply with V503.

Advisory V403.6 Handrails Exception. Rails installed for edge protection on passenger vessels may provide gripping surfaces but are not considered handrails for purposes of applying V403.6.

ICCL Comment: We previously stated: “It should be made clear that this provision does not apply to guard rails installed for safety purposes which are specifically addressed by both SOLAS and USCG regulations.

We do not believe that this Advisory adequately addresses our concern but rather, appears to require dual rails. We do not believe this is what is intended or appropriate. Please clarify.

V404 Doors, Doorways, and Gates

V404.2.5 Thresholds. Thresholds, if provided at doors and doorways, shall comply with V404.2.5.1.

V404.2.5.2 Doors with Coamings. Doors and doorways permitted to comply with V404.2.5.2 shall comply with V404.2.5.2.1 or V404.2.5.2.2.

ICCL Comment: We are concerned that the Board remains under the impression that a weathertight door with a sill/coaming can be replaced by using a watertight door with a non-beveled threshold of 1 ¼ inches. This is not a reasonable or practicable solution. The study that was conducted by the Volpe Transportation Center at the behest of the Board was very limited in its application to a specific type of vessel and route, neither of which are applicable to an ocean going passenger ship or cruise ship.

Additionally, and at the risk of restating the obvious, ships are not buildings. Where water leakage in a building from a storm may ruin a carpet every now and then, ships are built to be in a wet, marine environment. This means that there are frequent storms and a greater likelihood of water impacting a given opening. Even though passenger cruise ships make every effort to avoid major storms, leakage from such a storm will result in much more than just wet carpet. Cumulative weight of water leakage on upper decks creates a safety issue in terms of added weight high on the ship and possible accumulation of water creating a free surface effect - both of these conditions adversely impact stability and ship safety. Additional safety issues are related to a wet surface include the possibility of electrical fault, slip and fall hazards which are multiplied by the ship motions, and health issues related to mold/mildew.

V404.2.5.2.1 Doors with Double Ramp Access. The height of thresholds on both sides of the doors shall be equal to or less than the minimum coaming height allowed by the administrative authority provided the doors are automatic and comply with V404.3.

ICCL Comment: The administrative authority requires coamings to prevent the ingress of water into the ship. It is not clear how the ramp requirements shown in the associated figures will maintain the integrity required. Installing a solid surface ramp on the exterior of a weather door provides a ramp for water to travel into the space. This negates the purpose of the sill. An ICCL member installed grated ramps to avoid this situation and found that they soon needed to be removed for safety purposes. Experience showed that items such as women’s shoe heels and canes became stuck in the holes/slots provided for drainage resulting in twisted ankles, falls, and damaged personal property. Also, individuals not wearing shoes on the main pool deck suffered cut feet.

Additionally, the requirement for automatic doors presents engineering and safety issues in the marine environment and these issues have not been adequately considered or addressed. Automatic doors are not technically feasible in all areas due to a variety of factors including among others: exposure to high winds, boarding seas (water); and dynamic forces resulting from ship motions. Therefore, the inclusion of a requirement for automatic doors must be removed.

V404.2.9 Door and Gate Opening Force. The force for pushing or pulling open interior and exterior sliding and folding doors, and interior hinged doors and gates, shall be no more than 5 pounds (22.2 N) maximum.

ICCL Comment: If the opening force is too light, it could result in doors swinging in heavy weather or wind causing injury.

The wording with regard to the “administrative authority” has been added apparently in response to our concern. We remain doubtful that this will resolve the matter.

Advisory V404.2.9 Door and Gate Opening Force. The maximum force pertains to the continuous application of force necessary to fully open a door, not the initial force needed to overcome the inertia of the door. It does not apply to the force required to retract bolts or to disengage other devices used to keep the door in a closed position.

ICCL Comment: Slope limits for minor differences in deck height are necessary because of shipboard arrangements such as corridor widths that limit the length of the run. The obvious solution would be to add width to the corridors or decks. However, what may be perceived to be a minor adjustment, will have a substantial, cumulative, and negative effect on the design of the ship. For example, adding to the ramp run will increase the total corridor width in order to maintain the minimum clear width mandated by SOLAS. This issue also relates to cabin balcony access.

This would also not be achievable from a watertight or weathertight door leading from the deckhouse to an open deck on the side of a smaller ship where the width of external decks can be extremely limited.

The Board, in their commentary, specifically states that they did not make this change but has not given any reason.

We reiterate our previous comments and recommend that the advice and recommendations of the group of experts brought together as the Passenger Vessel Access Advisory Committee be adopted.

Slope¹	Maximum Rise
Steeper than 1:10 but not steeper than 1:8	3 inches (75 mm)
Steeper than 1:12 but not steeper than 1:10	6 inches (150 mm)

V410 Accessible Means of Escape

V410.2.2 Areas of Refuge and Areas of Temporary Refuge. Exit stairways shall comply with V410.2.2.1, or V410.2.2.2, or V410.2.2.3.

V410.2.2.1 Areas of Refuge. Exit stairways shall be accessed from an area of refuge complying with requirements established by the administrative authority.

V410.2.2.2 Areas of Temporary Refuge and Enlarged Stair Landings. Exit stairways shall incorporate areas of temporary refuge complying with V411 within enlarged deck-level stair landings.

ICCL Comment: Stair towers on ships built to SOLAS are required to be designed as areas of refuge.

V410.2.2.3 Areas of Temporary Refuge in Adjacent Spaces. Exit stairways shall be accessed from areas of temporary refuge in an adjacent space complying with V411.

Advisory V410.2.2 Areas of Refuge and Areas of Temporary Refuge. Areas of refuge (different from areas of temporary refuge) on passenger vessels are typically large spaces that are separated from the effects of fire and flooding where passengers can gather in an emergency, and then if necessary be directed to an evacuation station for disembarking a vessel. In the International Convention for the Safety of Life at Sea (SOLAS), areas of refuge are known as muster stations and assembly stations. Areas of temporary refuge typically would be much smaller spaces where passengers who are unable to use stairs may remain temporarily to await further instructions or assistance during emergency evacuation to an area of refuge or evacuation station.

V410.3 Elevators. Elevators that are part of an accessible means of escape shall comply with the requirements of Section 2.27 of ASME/ANSI A17.1 and shall be provided with emergency power. The elevators shall be accessed from either an area of temporary refuge complying with V411 or an area of refuge complying with requirements established by the administrative authority.

V410.4 Platform Lifts. Platform lifts that are part of an accessible means of escape shall comply with V409 and shall be provided with emergency power.

V411 Areas of Temporary Refuge

ICCL Comment: This section should be deleted together with all subsections discussing requirements for an area of temporary refuge as it is not applicable to ships impacted by these guidelines. We note that Areas of Temporary Refuge are referred to above this section and those areas should be deleted also.

The term “Area of Temporary Refuge” was developed by the PVAAC so as to allow protection of sheltering in place in the event of a fire in order to address an issue found in small passenger vessels that do not comply with either SOLAS, or USCG Regulations.

V411.1 General. Areas of temporary refuge that are part of an accessible means of escape shall comply with V411.

V411.2 Location. Areas of temporary refuge shall be accessed from the space it serves by an accessible means of escape. Every required area of temporary refuge shall have direct access to a stair complying with V410.2 or an elevator complying with V410.3.

V411.3 Size. Areas of temporary refuge shall be sized to accommodate one wheelchair space complying with V305.3 for each 200 occupants or portion thereof, based on the occupant load of the area of temporary refuge and all areas served by the area of temporary refuge. Such wheelchair spaces shall not reduce the required means of escape width established by the administrative authority. Access to any of the required wheelchair spaces in an area of temporary refuge shall not be obstructed by more than one adjoining wheelchair space.

V411.4 Construction. Areas of temporary refuge shall comply with construction requirements established by the administrative authority for areas of refuge applicable to the particular vessel.

V411.5 Smoke Resistance. Areas of temporary refuge shall comply with smoke resistance requirements established by the administrative authority for areas of refuge applicable to the particular vessel.

V411.6 Two-way Communication. Areas of temporary refuge shall be provided with a two-way communication system between the area of temporary refuge and the bridge of the vessel, or a central control station which is manned while passengers are on the vessel. The two-way communication system shall include both audible and visible signals.

V412 Passenger Boarding Systems

V414.2 Design Load. The design load of the lift shall be at least 600 pounds (272 kg). Working parts, such as cables, pulleys, and shafts, which would be expected to wear, and upon which the lift depends for support of the load, shall have a safety factor of at least six, based on the ultimate strength of the material. Nonworking parts, such as platform, frame, and attachment hardware which would not be expected to wear, shall have a safety factor of at least three, based on the ultimate strength of the material.

ICCL Comment: We agree that a working load of 600 lbs. is appropriate; however, safety factors should be in accordance with accepted marine engineering practices.

CHAPTER 5: GENERAL PASSENGER VESSEL ELEMENTS

V601 General
V602 Drinking Fountains
V603 Toilet and Bathing Rooms
V604 Water Closets and Toilet Compartments V605 Urinals
V606 Lavatories and Sinks
V607 Bathtubs
V608 Shower Compartments and Rinsing Showers V609 Grab Bars
V610 Seats
V611 Washing Machines and Clothes Dryers
V612 Saunas and Steam Rooms
V603 Toilet and Bathing Rooms

V603.1 General. Toilet and bathing rooms shall comply with V603.

V603.2 Clearances. Clearances shall comply with V603.2.

V603.2.1 Turning Space. Turning space complying with V304 shall be provided within the room.

V604 Water Closets and Toilet Compartments

V604.3 Clearance. Clearances around water closets and in toilet compartments shall comply with V604.3.

V604.3.2 Overlap. The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, dispensers, sanitary napkin disposal units, coat hooks, shelves, accessible routes, clear deck space and clearances required at other fixtures such as shower spaces, and the turning space. No other fixtures or obstructions shall be located within the required water closet clearance.

ICCL Comment: Per conversations with the Access Board and Staff which indicated that in individual guest room toilet spaces there may be a common turning circle that overlaps the toilet space and the shower space, V604.3.2 should be redrafted as shown above. Please see the diagram at ANNEX 4 with regards to the ICCL comments under this section.

V604.5 Grab Bars. Grab bars for water closets shall comply with V609. Grab bars shall be provided on the side wall closest to the water closet and on the rear wall.

ICCL Comment: The IMO Guidelines specify a rising side bar on the wide or open side of the water closet. This element has also been adopted in the European recommendations. ICCL recommends that a folding/rising grab bar be permitted so that ships can continue in international operation without having to change internal structures when traveling from country to country.

V604.5.1 Side Wall. The side wall grab bar shall be 42 inches (1065 mm) long minimum, located 12 inches (305 mm) maximum from the rear wall and extending 54 inches (1370 mm) minimum from the rear wall.

ICCL Comment: At a meeting with the Board and staff on March 10th, ICCL requested to know the source of the 54 inch dimension and noted that in toilet stalls that the requirement is for 52 inches. Staff agreed to consult with the persons doing research in this regard (Edward Steinfeld, Project Director with Inclusive Design and Environmental Access (IDEA Center), State University of New York at Buffalo.) to see if this dimension is appropriate or if a shorter side bar can be provided without compromising accessibility.

V604.9 Water Closets and Toilet Compartments for Children's Use. Water closets and toilet compartments intended primarily for children's use shall comply with V604.9.

ICCL Comment: Children will use every public restroom on a ship. This should apply only to WC and toilet compartments PRIMARILY for use by children and the guideline should be redrafted accordingly.

V608.3 Grab Bars. Grab bars shall comply with V609 and shall be provided in accordance with V608.3. Where multiple grab bars are used, required horizontal grab bars shall be installed at the same height above the finish deck surface.

V608.3.2 Standard Roll-In Type Shower Compartments. Where a seat is provided in standard roll-in type shower compartments, grab bars shall be provided on the back wall and the side wall opposite the seat. Grab bars shall not be provided above the seat. Where a seat is not provided in standard roll-in type shower compartments, grab bars shall be provided on three walls. Grab bars shall be installed 6 inches (150 mm) maximum from adjacent walls.

ICCL Comment: As a result of a March 10th meeting with the Board and staff, it was agreed that a fold-down grab bar would be appropriate for this type of shower when a third wall is not present. Board staff agreed to draft wording to this effect.

V609 Grab Bars

V609.6 Fittings. Grab bars shall not rotate within their fittings.

V610.3 Shower Compartment Seats. Where a seat is provided in a standard roll-in shower compartment, it shall be a folding type, shall be installed on the side wall adjacent to the controls, and shall extend from the back wall to a point within 3 inches (75 mm) of the compartment entry. Where a seat is hall be installed on the front wall opposite the back wall, and shall extend from the provided in an alternate roll-in type shower compartment, it shall be a folding type, s adjacent side wall to a point within 3 inches (75 mm) of the compartment entry. In transfer type showers, the seat shall extend from the back wall to a point within 3 inches (75 mm) of the compartment entry. The top of the seat shall be 17 inches (430 mm) minimum and 19 inches (485 mm) maximum above the bathroom finish deck surface. Seats shall comply with V610.3.1 or V610.3.2.

ICCL Note: Given that the Board is considering requirements for a fold-down grab bar for showers in certain circumstances, this section should be compatible with whatever is decided and drafted for that other element at V608.3.2.

CHAPTER 7: COMMUNICATION ELEMENTS AND FEATURES

V701 General
V702 Reserved
V703 Signs
V704 Telephones
V705 Two-Way Communication Systems
V706 Assistive Listening Systems
V707 Automatic Teller Machines and Fare Machines

V701 General

V701.1 Scope. The provisions of Chapter 7 shall apply where required by Chapter 2 or where referenced by a requirement in this document.

V702 Reserved

V703 Signs

ICCL Comment: V703.2.4 & .5 – Characters: This needs to be compared to the SOLAS and IMO advisories such at Resolutions, Circulars and Guidelines as well as the ISO standard for shipboard signs that will soon be adopted by IMO.

For example, in V703.5.1. – Finish and Contrast: There appears to be a conflict with the SOLAS requirements for Low Location Lighting signs that may be photoluminescent or photointumescent.

V703.1 General. Signs shall comply with V703. Where both visual and tactile characters are required, either one sign with both visual and tactile characters, or two separate signs, one with visual, and one with tactile characters, shall be provided.

V703.2 Raised Characters. Raised characters shall comply with V703.2 and shall be duplicated in Braille complying with V703.3. Raised characters shall be installed in accordance with V703.4.

Advisory V703.2 Raised Characters. Signs that are designed to be read by touch should not have sharp or abrasive edges.

V703.2.1 Depth. Raised characters shall be 1/32 inch (0.8 mm) minimum above their background.

V703.2.2 Case. Characters shall be uppercase.

V703.2.3 Style. Characters shall be sans serif. Characters shall not be italic, oblique, script, highly decorative, or of other unusual forms.

V703.2.4 Character Proportions. Characters shall be selected from fonts where the width of the uppercase letter "O" is 55 percent minimum and 110 percent maximum of the height of the uppercase letter "I".

V703.2.5 Character Height. Character height measured vertically from the baseline of the character shall be e inch (16 mm) minimum and 2 inches (51 mm) maximum based on the height of the uppercase letter "I".

V703.2.6 Stroke Thickness. Stroke thickness of the uppercase letter "I" shall be 15 percent maximum of the height of the character.

V703.2.7 Character Spacing. Character spacing shall be measured between the two closest points of adjacent raised characters within a message, excluding word spaces. Where characters have rectangular cross sections, spacing between individual raised characters shall be c inch (3.2 mm) minimum and 4 times the raised character stroke width maximum. Where characters have other cross sections, spacing between individual raised characters shall be 1/16 inch (1.6 mm) minimum and 4 times the raised character stroke width maximum at the base of the cross sections, and c inch (3.2 mm) minimum and 4 times the raised character stroke width maximum at the top of the cross sections. Characters shall be separated from raised borders and decorative elements d inch (9.5 mm) minimum.

V703.2.8 Line Spacing. Spacing between the baselines of separate lines of raised characters within a message shall be 135 percent minimum and 170 percent maximum of the raised character height.

V703.3 Braille. Braille shall be contracted (Grade 2) and shall comply with V703.3 and V703.4.

Advisory V703.3 Braille. Contracted (Grade 2) Braille is an abbreviated method of displaying words in Braille. For example, the word "men" is displayed using the Braille symbols for "m" and "en". The word "women" would use the Braille symbols for "w", "o", "m", and "en". Some grouping of letters have no contracted form, such as exit which would appear as "e", "x", "i", and "t". Also, numbers have no contracted form. Numbers in Braille are created by using "a" to "j" for 1 to 0. By putting a “#” sign in front of the letter or letters the reader is told these are numbers not letters. Therefore, #abc means 123 and #aj means 10.

V703.3.1 Dimensions and Capitalization. Braille dots shall have a domed or rounded shape and shall comply with Table V703.3.1. The indication of an uppercase letter or letters shall only be used before the first word of sentences, proper nouns and names, individual letters of the alphabet, initials, and acronyms.

Measurement Range	Minimum in Inches Maximum in Inches
Dot base diameter	0.059 (1.5 mm) to 0.063 (1.6 mm)
Distance between two dots in the same cell¹	0.090 (2.3 mm) to 0.100 (2.5 mm)
Distance between corresponding dots in adjacent cells¹	0.241 (6.1 mm) to 0.300 (7.6 mm)
Dot height	0.025 (0.6 mm) to 0.037 (0.9 mm)
Distance between corresponding dots from one cell directly below¹	0.395 (10 mm) to 0.400 (10.2 mm)

V703.3.2 Position. Braille shall be positioned below the corresponding text. If text is multi-lined, Braille shall be placed below the entire text. Braille shall be separated d inch (9.5 mm) minimum from any other tactile characters and d inch (9.5 mm) minimum from raised borders and decorative elements.

V703.4 Installation Height and Location. Signs with tactile characters shall comply with V703.4.

V703.4.1 Height Above Finish Deck Surface. Tactile characters on signs shall be located 48 inches (1220 mm) minimum above the finish deck surface, measured from the baseline of the lowest tactile character and 60 inches (1525 mm) maximum above the finish deck surface, measured from the baseline of the highest tactile character.

V703.4.2 Location. Where a tactile sign is provided at a door, the sign shall be located alongside the door at the latch side. Where a tactile sign is provided at double doors with one active leaf, the sign shall be located on the inactive leaf. Where a tactile sign is provided at double doors with two active leafs, the sign shall be located to the right of the right hand door. Where there is no wall space at the latch side of a single door or at the right side of double doors, signs shall be located on the nearest adjacent wall. Signs containing tactile characters shall be located so that a clear deck space of 18 inches (455 mm) minimum by 18 inches (455 mm) minimum, centered on the tactile characters, is provided beyond the arc of any door swing between the closed position and 45 degree open position.

V703.5 Visual Characters. Visual characters shall comply with V703.5.
EXCEPTION: Where visual characters comply with V703.2 and are accompanied by Braille complying with V703.3, they shall not be required to comply with V703.5.2 through V703.5.9.

V703.5.1 Finish and Contrast. Characters and their background shall have a non-glare finish. Characters shall contrast with their background with either light characters on a dark background or dark characters on a light background.

V707 Automatic Teller Machines and Fare Machines

V707.8 Braille Instructions. Braille instructions for initiating the speech mode shall be provided. Braille shall comply with V703.3.

ICCL Comment: This section should not go into effect before the new ADAAG where these requirements reflect the new ADAAG because the supporting infrastructure will not be there.

CHAPTER 8: SPECIAL ROOMS, SPACES, AND ELEMENTS

V801 General
V802 Wheelchair Spaces, Companion Seats, and Designated Aisle Seats
V803 Dressing, Fitting, and Locker Rooms
V804 Kitchens and Kitchenettes
V805 Medical Care Facilities
V806 Passenger Guest Rooms
V807 Storage

V801 General

V804 Kitchens and Kitchenettes

ICCL Comment: Please see our previous comment in the definitions with regard to referring to these as “pantries.”

V804.1 General. Kitchens and kitchenettes shall comply with V804.

V804.5.4 Range or Cooktop. Where a forward approach is provided, the clear deck space shall provide knee and toe clearance complying with V306. Where knee and toe space is provided, the underside of the range or cooktop shall be insulated or otherwise configured to prevent burns, abrasions, or electrical shock. The location of controls shall not require reaching across burners.

V804.5.5 Oven. Ovens shall have controls on front panels.

ICCL Comment: We recommend that V804.5.4 and 804.5.5 be deleted as SOLAS does not permit appliances with the heat output of a range, cooktop or oven to be installed in guest rooms.

V805 Medical Care Facilities

V805.4 Toilet and Bathing Rooms. Toilet and bathing rooms that are provided as part of a patient sleeping room that is required to comply with V805 shall comply with V603. Where provided, no fewer than one water closet, one lavatory, and one bathtub or shower shall comply with the applicable requirements of V603 through V610.

ICCL Comment: ICCL recommends redrafting as shown above for clarification.

V806 Passenger Guest Rooms

V806.2.3 Sleeping Areas. At least one sleeping area shall provide a clear deck space complying with V305 on both sides of a bed. The clear deck space shall be positioned for parallel approach to the side of the bed.
EXCEPTION: Where a single clear deck space complying with V305 positioned for parallel approach is provided between two beds, a clear deck space shall not be required on both sides of a bed.

ICCL Comment: The flexible nature of cabin bed configurations permits arranging the bed to provide an accessible route with either a right-side or left-side approach to the bed according to the passenger’s need or preference, thus obviating the need for a permanent accessible route to both sides of a single bed. While we appreciate the exception as providing for the arrangement onboard a cruise ship when the beds are separated, the exception does not recognize the instance when beds are pushed together at the request of the guests. In that instance it is not possible to provide the access from each side of the bed. ICCL proposes that in this instance (when the beds are together to form one double size bed) required access can be provided from either one side or the other by assigning the guests to a cabin on one side of the ship or the other. Please see the attached drawing.

ICCL recommends that an additional exception be inserted to read:

EXCEPTION: Where a single bed can be repositioned to provide a clear deck space complying with V305 for either a left hand or a right hand parallel approach as requested by a passenger, a clear deck space shall not be required on the opposite side.

V806.2.4.1 Vanity Counter Top Space. If vanity counter top space is provided in non-accessible guest toilet or bathing rooms, comparable vanity counter top space, in terms of size and proximity to the lavatory, shall also be provided in accessible guest toilet or bathing rooms. Comparable vanity counter top space may consist of supplemental shelf and/or storage space within reach range.

ICCL Comment: Due to the limited nature of space onboard a ship and ship construction practices, we recommend that the requirement be clarified as above.

V806.2.7 Doors to Adjacent Guest Rooms. Where provided, doors that connect adjacent guest rooms shall comply with V404.

ICCL Comment: We previously stated: “It should be clarified that accessibility from an accessible cabin into the ADJOINING non-accessible room is to be enter and exit only without maneuvering clearance in the adjoining non-accessible cabin.”

We note that section V404 includes a requirement in V404.2.4 for maneuvering clearances by the doors. It was agreed that maneuvering clearances could be provided in the accessible room while the adjoining room should be enter and exit only without maneuvering clearances. This section should be redrafted to express the above agreed concept.

ICCL Recommends that V806.2.7 be redrafted to state:

V806.2.7 Doors to Adjacent Guest Rooms: Where provided, doors that connect an accessible guest room to a non-accessible guest room shall comply with V404, except for V404.2.4 in the adjoining non-accessible guest room.

CHAPTER 9: BUILT-IN ELEMENTS

V901 General
V902 Dining Surfaces and Work Surfaces
V903 Benches
V904 Sales and Service Counters

V904.4 Sales and Service Counters. Sales counters and service counters shall comply with V904.4.1 or V904.4.2. The accessible portion of the counter top shall extend the same depth as the sales or service counter top.

• ICCL Comment: Sales counters, referred to as “points of sale” within particular retail spaces onboard ship, do not serve separate functions. That is, all merchandise within that store may be purchased at any point of sale within that retail space. At these locations, the counter is the entire selling space. ICCL recommends that one accessible counter be provided at each retail shop with a parallel approach. Alternatively, the use of clipboards or other portable or moveable counters should be allowed. The current proposal is appropriate for other shipboard counters such as at the Pursers desk, shore tour bookings, etc. It should also be noted that cruise ships are cashless and any onboard purchases will be made using the cabin keycard.

V1001 General
V1002 Exercise Machines and Equipment
V1003 Miniature Golf Facilities
V1004 Play Areas
V1005 Swimming Pools, Wading Pools, and Spas
V1006 Shooting Positions

V1005 Swimming Pools, Wading Pools, and Spas

ICCL Comment: Swimming pools on passenger vessels are limited in size due to stability requirements. The proposed guidelines allow either a ramp or a chair lift - given the limitations we already have in size, introducing a ramp will significantly reduce pool area and would introduce safety issues that have already been recognized shoreside. These safety issues would be exacerbated onboard due to ship movements. Additionally this will cause problems with water running up the ramp due to wave action which would result in unsafe conditions. Chair lifts are not the best solution on a moving platform in many instances and therefore ICCL still recommends that the use of transfer benches also be considered as an acceptable means of access. This would allow discrete access on a stable platform that can be extended to include other pool features such as Jacuzzis.

V1005.1 General. Where provided, pool lifts, sloped entries, transfer walls, transfer systems, and pool stairs shall comply with V1005.

V1005.2 Pool Lifts. Pool lifts shall comply with V1005.2.

CHAPTER 11: TENDERS

V1101 General
V1102 Wheelchair Spaces
V1103 Accessible Route
V1104 Boarding Systems

V1101 General. Tenders carried onboard shall comply with the provisions of Chapter 11 where required by V201.1.3.

V1103 Accessible Route. At least one onboard accessible route complying with V402 shall connect each wheelchair space to an entry and departure point of the tender used by passengers in non-emergency conditions.

ICCL Comment: Future designs of ship-borne tenders may include two points of entry. In this case, passenger seating will be provided between the points of entry where the wheelchair spaces and tie downs are provided. In this case, it will not be possible for each entry/departure point to be connected. Realistically, on these small vessels, no one is permitted to be moving about when the boat is in motion and thus the movement of wheelchairs between wheelchair positions would not be permitted as a safety matter. Embarking and disembarking the wheelchairs from each location either at the ship or the port destination is an operational matter. If a wheelchair can only be embarked or disembarked at one tender location either at the ship or at the port, then only one of the tender wheelchair platforms will be able to be utilized at that location.

V1104 Boarding Systems. Where tenders embark or disembark passengers to vessels, fixed piers, floating piers, or landside structures, a method complying with criteria established by the US Department of Transportation shall be provided to facilitate the embarkation and disembarkation of passengers with disabilities.

ICCL Comment: The requirement for passenger boarding systems is typically the responsibility of the Port. The ship or ship operator should not be responsible for shoreside systems unless that ship or ship operator is the owner or manager of the shoreside system/pier, etc. This remains as a critical issue and our previous comments remain applicable. Clearly, the ships tendering vessel can not carry the appropriate gangways or boarding systems.

International Council of Cruise Lines
2111 Wilson Boulevard
8th Floor Arlington, VA 22201
Phone (703) 522-8463 ◊ Fax (703) 522-3811
E-mail: info@iccl.org ◊ www.iccl.org

ANNEX 3
Access Board Docket 2004-1
Supplemental Discussion of Engineering Standards

Submitted by
International Council of Cruise Lines
November 13, 2006

The following information is provided as discussion and further background as to why ICCL does not believe that referencing US engineering standards is appropriate for proposed rules that are intended to apply to non-US flag passenger ships.

With this discussion, ICCL is of the opinion that it would be impossible for ships built in non-US shipyards to comply with rules requiring the use of US engineering standards.

We believe that once again, the Access Board staff has its focus on land based structures built within the United States. This will simply not work in the international maritime industry. At the same time we see no adverse access impact in using the non-US engineering standards. Access Board members, both past and present, seemed quite satisfied with the elevators installed on the ICCL member cruise ships that have been visited. If the size recommendations of the PVAAC report are adopted to recognize installation of elevators in both the transverse and longitudinal axis on board ships as well as other design requirements, we believe that these will provide fully accessible maritime elevators.

Canada:

ICCL members do not have ships currently building in Canada. However, if Canada decided to unilaterally apply their standards to non Canada ship, their elevator standard is CAN/CSA-B44-M. We have not compared this to the ANSI 17.1.

European Union:

The European Parliament and Council Directive 95/16/EC of 29 June 1995 on the approximation of the laws of the Member States relating to lifts establishes European legal requirements for the design, installation and placing on the market of new lifts. It also sets out the conformity assessment procedures to be followed by lift installers to ensure conformity with these requirements. The provisions of the Directive are implemented in the national law of each Member State of the European Union.

An additional directive is: Directive 97/23/EC of the European Parliament and of the Council of 29 June 1995 on the approximation of the laws of the Member States relating to lifts.

Further the European Standards Organization (ESO) under the auspices of the European Committee for Standardization (CEN) has listed a number of Standards for lifts. These include:

ESO	Standard reference	Titles	First publication OJ (*)
CEN	EN 81-1:1998	Safety rules for the construction and installation of lifts - Part 1: electric lifts	1999-03-31
CEN	EN 81-2:1998	Safety rules for the construction and installation of lifts - Part 2: hydraulic lifts	1999-03-31
CEN	EN 81-28:2003	Safety rules for the construction and installation of lifts - Lifts for the transport of persons and goods - Part 28: Remote alarm on passenger and goods passenger lifts	2004-02-10
CEN	EN 81-58:2003	Safety rules for the construction and installation of lifts - Part 58: Lift landing doors - Fire resistance testing	2004-02-10
CEN	EN 81-72:2003	Safety rules for the construction and installation of lifts- Particular applications for passenger and goods passenger lifts - Part 72: Firefighters lifts	2004-02-10
CEN	EN 12016:1998	Electromagnetic compatibility - Product family standard for lifts, escalators and passenger conveyors - Immunity	1999-03-31
CEN	EN 13015:2001	Maintenance for lifts and escalators - Rules for maintenance instructions	2004-02-10

ICCL would also note: Directive 95/16/EC - Lifts Working Group - Doc.2004.08 rev 2: Accessibility for people with impaired mobility. This directive states in part:

ICCL believes that this illustrates our point quite well showing that there are mandatory EU Standards (which is where most cruise ships are constructed and where most equipment onboard is manufactured) as well as specific requirements for access.

For further information regarding EU lift standards please refer to: http://europa.eu.int/comm/enterprise/mechan_equipment/lifts/

Classification Society Rules:

The major Shipping Classification Societies with which ICCL members build and class their ships include:
United Kingdom: Lloyds Register of Shipping - LR
Norway Det Norske Veritas - DNV
Japan Nippon Kaiji Kyokai - NKK
Italy Registar Italiano Navale - RINA
Germany Germanischer Lloyd – GL
France Bureau Veritas

These shipping classification societies each have their own rules for ship construction and equipment. According to IMO, it is mandatory for a ship receiving a SOLAS certificate to be registered with a recognized shipping classification society. Accordingly, it is mandatory that ships be built to the rules of their class society.

Each shipping classification society requires that certain national standards be used. These may be DIN, JIS standards. European class societies will most likely also reference EU rules where appropriate.

Accordingly, shipyards must demonstrate compliance by adopting standards such as DIN or JIS together with the yard's own build standard. A simple example of how these differ from US standards will be the units (i.e. metric rather than imperial). This would have a bearing on elements such as the proposed standards for the installation of sprinklers and alarms. Where PVAG refers to the National Fire Protection Association, this would not be acceptable as the more local standards would prevail.

International Standards Organization:

Often times, the standards of the ISO are required. Below is an example of these standards.

Document ID:	ISO 4190-1	ISO 4190-2
Title:	Lift (US: Elevator) installation : Part 1 - Class I, II, III and VI lifts	Lift (US: Elevator) installation : Part 2 - Class IV lifts
Author (Corporate Body):	International Organization for Standardization. ISO	International Organization for Standardization. ISO
Parallel Title:	Installations d'ascenseurs	Installation d'ascenseurs : Partie 2 - Ascenseurs de classe IV
Edition:	3rd. ed.	2nd ed.
Place of Publication/Publisher:	Geneva : ISO	Geneva : ISO
Date of Publication:	1999	2001
Shelf Location:	International Organizations - ISO	International Organizations - ISO
Language:	English; French	English; French
Type:	Monograph	Monograph

These may also be paralleled by or even superseded by individual country requirements. The flag state requirements rule and each may be different in content and affect.

Another Example:

Another example, although not directly applicable to access requirements but showing how engineering standards are not interchangeable is for structural steel.

International Council of Cruise Lines
2111 Wilson Boulevard
8th Floor Arlington, VA 22201
Phone (703) 522-8463 ◊ Fax (703) 522-3811
E-mail: info@iccl.org ◊ www.iccl.org

ANNEX 4
Access Board Docket 2004-1
Configuration for One Double Bed or Two Singles

Annex 4 to the ICCL comments shows a plan view of a stateroom designed for persons with mobility impairments. The stateroom is 5720 mm (225 inches) long and 3380 mm (133 inches) wide. The entry door is located on a long wall at the right side of the drawing. The door is between the space containing the bathroom in the lower right hand corner and the area containing two beds in the upper right side of the drawing. The drawing shows how the bed near the entry door is moved upward toward the second bed to create a double bed. The drawing shows a narrow area between the second bed and the wall at the top of the drawing.

[Text description provided by the Access Board:
Annex 4 to the ICCL comments shows a plan view of a stateroom designed for persons with mobility impairments. The stateroom is 5720 mm (225 inches) long and 3380 mm (133 inches) wide. The entry door is located on a long wall at the right side of the drawing. The door is between the space containing the bathroom in the lower right hand corner and the area containing two beds in the upper right side of the drawing. The drawing shows how the bed near the entry door is moved upward toward the second bed to create a double bed. The drawing shows a narrow area between the second bed and the wall at the top of the drawing.]

International Council of Cruise Lines, T.E. Thompson November 13, 2006 [Email]

International Council of Cruise Lines, T.E. Thompson
November 13, 2006 [Email]