Recommended Approprate Access for People Who are Deaf or Hard of Hearing

In order for Passenger Vessels (PV) to have full and consistent access for people who are deaf or hard of hearing, the following three types of access must be offered whenever there is sound output (voice or audio):

In addition, there must be appropriate staff training and signage.

These three services can be implemented on a PV as follows:

A- Theaters

The ADA Guidelines for theaters on land require ALDs (Headsets.) Currently, hearing-aid compatible devices or neck loops are awaiting the Department of Justice’s approval. Neck loops should be available since headsets do not work for people who wear behind-the-ear (BTE) hearing aids and some people who have more than a mild hearing loss. For some people, the volume control is not strong enough on the receivers. Neck loops allow the person’s own hearing aid to regulate the volume. All theaters that are places of public accommodation with 50 or more fixed seats are, currently, required to have an assistive listening system. (The elimination of the fixed seat requirement is awaiting the Justice Department's approval.)

The ALDs receive the sound via a sound system called and assisitive listening system. There are currently three types of systems that are available:

There are several factors that would determine which system would be appropriate for each site. The Kennedy Center’s Guide to Assistive Listening Systems for Theaters is a useful tool to aid in assessing which system is appropriate for each venue.

ALDs (headsets or neck loops) enable visitors to receive sound directly in their ears. There are different styles of receivers. Some ALDs fit directly into the ear and some require headphones or neck loops to be plugged into the output jack of the receiver that is the size of a deck of playing cards. The type of ALS selected is based on the person’s degree of hearing loss, whether they use a hearing aid or cochlear implant, the age the person lost their hearing, the level of auditory training they received and their current age. A signal is sent from the system to the receiver.

If an Induction Loop System were utilized then only someone without a T-coil would need to wear a receiver. Anyone with a T-coil would just activate the T-coil on his or her hearing aid to hear the sound. ALDs allow someone to increase the volume and receive the sound directly in their ear without disturbing anyone else. A Population Chart detailing the degrees of hearing loss and what type of accommodation needed is attached. [See Exhibit1] Also, a FAQ Sheet on neck loops and T-coils is attached. [See Exhibit 2] The League for the Hard of Hearing prepared the FAQ sheet.

When installing the system, it is important to ensure the appropriate number of receivers is available at any given place of assembly. The requirements are detailed in the ADA Accessibility Guidelines (“ADAAG”). ADAAG can be found at www.access-board.gov. For your reference, I have attached some Technical Support for Assistive Listening Systems. [See Exhibit 3]

2- Captioning

Unfortunately, not all people can utilize the ALDs due to the severity of their hearing loss or choose not to use an ALD because of the stigma associated with it. [See Chart 1] In addition to the assistive listening system, PVs should offer captioning for all films. There are two methods of captioning, open and closed. Open is when the captioning is always on and either appears on the film screen or a data strip below the screen. Closed captioning is when it is either turned on and off or selectively seen by only those who need it.

We recommend that open captioning should be offered. Open captioning is easiest since there is nothing to maintain and nothing to turn on and off. Therefore, it saves the staff time. It is also always visible. Open captioning allows people to participate without feeling any stigma they may perceive is attached to hearing loss. Therefore, if the event is a film, then a captioned version of the film should be ordered. We suggest inserting a clause in all PV contracts that all films must be captioned. The National Park Service has mandated that all videos be shown open-captioned. (See Exhibit 4)

For closed captioning, it can be either seen on the screen only when someone turns on the captions or when a special data panel is affixed to the seat. Please be aware that these data panels need to be cleaned and maintained. No one can read captions through other people’s fingerprints.

If, however, the event is a lecture then Computer Assisted Real Time Captioning (“CART”) should be offered for specifically scheduled lectures, presentations or when requested. CART provides access for people whose hearing loss is more profound and cannot use the assistive listening system or will not use an ALD. It is the exact translation, which is similar to a court reporter transcribing a statement of a witness except it includes additional details such as descriptions of sounds when there are not actual words.

Qualified interpretation (ASL, Oral, Transliteration or Cued Speech) needs to be offered in the appropriate format that is tailored to the individual to achieve effective communication. ASL is not English. ASL is a visual language with its own syntax and grammar that is quite different from the English language. For example, instead of saying, "There goes the blue car,” ASL would sign, "car, blue." For some people who communicate primarily using ASL, a qualified interpreter will be necessary to ensure effective communication. For some people who are hard of hearing or deaf and do not use ASL, captioning may be necessary to ensure effective communication. It is critical that the interpreter is certified.

Most people with hearing loss, including many with profound loss, do not use ASL. ASL should still be included as a component of access but it is not a solution for access for the majority of people with hearing loss.

For CART and signing, it is imperative that the quality and accuracy are checked prior to hiring them. There is a wide range in skill level among those who caption and sign. Poor quality captioning or interpretation does not provide appropriate access.

Appropriate seating should be available for those who rely on lip reading. This is very important, because the levels of hearing loss are not clearly defined even though it appears that way on The Population Chart. [See Chart 1] There is overlap between the groups. Some people (like my daughter) who rely on an ALD still miss some of the critical dialogue. Lip reading helps to fill in the gaps. Seat placement is critical for lip reading. The theater attendee must be near the stage and not view the speaker from an odd angle. For this reason, an appropriate number of seats should be made available. This is no different than those patrons who need special seating for wheelchair accommodations or for visual access.

FM systems are ideal for docent tours that are mobile to overcome poor acoustics that even challenge people who do not have a hearing loss.

As mentioned earlier, the ADA requires a certain number of ALDs for theaters. The ADA, however, is not clear on the number of ALDs required for FM-led docent tours. Therefore, to determine the appropriate number of neck loops, we recommend using the same 4% number from the ADA and applying it to the number of FM receivers instead of the number of seats.

Transcripts of the docent tour should be available in regular and large print for those visitors who cannot use ALDs.

Qualified interpretation should be offered for scheduled and/or announced tours and/or upon request with reasonable advance notice.

It is important when installing multiple videos that the acoustics are considered. Many new sites are offering multi-media presentations without understanding how competing sound affects a person's ability to hear and thus learn. Hiring an acoustical engineer is recommended. Some items that museums have utilized to deal with the acoustical issues are the installation of theater curtains and utilizing headsets and neck loops for individual monitors. But again, an acoustical engineer should be consulted.

If a video or film does not have sound then a sign should be posted stating, "Silent". This would inform the visitor who is hard of hearing or deaf not to expect sound or an ALD. If there is just ambient music playing then musical symbols should be posted on the monitor or if there is one type of background sound then it should be clearly identified on a nearby sign.

Both seeing and hearing a film or video provide certain benefits. If an individual who is hard of hearing can receive the same benefits of sound (loud, soft, angry, happy, sad, singing etc.) with a reasonable modification of an ALD, then an ALD is required to be provided for an equal opportunity to effectively participate.

Captioning does not generally work for children below approximately 4th grade who are unable to read quickly enough. As mentioned earlier, the needs of hearing loss vary by age just as they vary based on the degree of loss. One way to meet the needs of young children, who can't read or read quickly enough as well as those who rely heavily on their hearing aids, is to provide an induction loop system around any audio exhibit. In layman's terms, sound is transmitted through a thin wire surrounding the exhibit area via magnetic energy. For your reference, to loop an area could cost as low as $150. In order to learn more about looping, please visit www.hearingloop.org. An alternative to an induction loop system is to install headsets and neck loops adjacent to the monitor or to use a mini-infrared system.

To provide appropriate access for people who are hard of hearing and deaf, all videos need to be captioned. Captioning assists foreign visitors as well. By captioning the videos, not only will they now be accessible to people who are hard of hearing and deaf but also the sound of the video can be lowered which will help with the acoustics

For your reference, to caption a 15-minute video costs approximately $600-750. It is, however, important to select a captioning company based on accuracy of captioning and not based on price alone. Contracts should require that all captioning must be spelled 100% correctly and 100% accurately reflect what is stated. It might seem obvious but sadly, it isn't. Recommended captioning standards are in Exhibit 5.

Personal Digital Assistants (PDAs) are not an acceptable substitute for captioning. It is impossible to read a PDA and watch a video at the same time. For this reason, drivers are not permitted to read a Blackberry while driving.

Qualified interpretation should be offered upon request with reasonable advance notice.

When audio guides are available, it is imperative that neck loops or t-coil compatible audio guides are available and that appropriate signage is posted.

This should be offered for scheduled and/or announced tours and/or upon request with reasonable advance notice.

The announcements and emergency drills on small vessels are difficult to hear for everyone. Shouting into a bullhorn is not appropriate access for people with a hearing loss.

To disseminate clearly the information and emergency drills, the small vessel should have an induction loop system.

LED displays at various places on the boat or transcripts of the announcements and emergency information should be available.

Qualified interpretation should be offered upon request with reasonable advance notice.

Phone receivers need to have volume control and be hearing-aid (T-coil) compatible (HAC). There also needs to be prominent signage (Please see www.hearingloop.org) indicating that the receivers are usable by individuals with hearing aids and cochlear implants equipped with T-coils. If the phones are out of order, there needs to be a sign stating they are out of order so the visitor knows they are broken and not to expect sound.

Qualified interpretation should be offered upon request with reasonable advance notice.

Exhibits with ambient sound alone (e.g. bird coos in an exhibit on birds) are difficult for someone with hearing loss. There are no facial cues available for the person to augment their hearing if they have residual hearing. If a person does not have residual hearing, there is no possibility to understand what is happening within the exhibit.

A sign, an LED screen or a printed transcript in both regular and large print should be available.

Qualified interpretation should be offered upon reasonable request with advance notice.

All audio devices should be T-coil compatible and volume control. We recommend requesting documentation from the company to ensure the device is compatible. Any accessible device should post the ear symbol with the “T.” This symbol can be found on www.hearingloop.org.

An LED screen or a printed transcript in both regular and large print should be available.

Qualified interpretation should be offered upon request with reasonable advance notice.

All Service Desks (e.g. tour, maitre d’, spa, pursers desks) and classrooms should have an induction loop system installed. This allows someone with a hearing loss to ask a question and hear the answer. People do not ask questions if they think they cannot hear the answer.

A piece of paper and pen should be for people to write their questions down and receive answers to their questions.

Qualified interpretation should be offered. All personnel who are certified sign interpretation should have the ASL symbol on their nametag. This identifies appropriate staff that can assist a visitor when needed.

All staff should understand that service animals are not just for the blind but are used by people with other disabilities as well. Service animals, however, must be clearly identified.

A system must be in place for emergencies. Both sound amplification with low frequencies and visual or tactile alarms must be used. These need to be both inside as well as outside the PV. All employees should also realize that someone who is hard of hearing or deaf might not always be able to hear emergency warnings even if they can hear during the day. Many people who wear hearing aids cannot hear anything when they take their hearing aids out to take a shower or go to sleep/nap.

Therefore, appropriate emergency warnings should utilize tactile warnings and visual strobes that do not impact people with epilepsy. The system needs to be part of the central system and not a plug-in style.

All telephones on the PV need to be hearing aid compatible and have volume control just as they are on land. A person with hearing loss should not be restricted to which phone they can use. Also, a person does not know when and where an emergency will happen and where they will need to make or receive a call.

Any passenger that indicates that they have a hearing loss should be asked what type of phone they require. A passenger who indicates a hearing loss should not automatically be given a TTY. The type of communication equipment that a person requires will depend on the degree of hearing loss. While TTYs have started to fall out of favor on land, they are still critical on PVs since relay service is not possible at this time.

M- Signage, Advertisements, Brochures, Mailings and Websites.

All of the steps I have outlined mean little if visitors are not aware of them. Therefore, the appropriate symbols (e.g. assistive listening devices, captioning, American Sign Language interpretation) and information must be posted wherever access is available e.g. outside the theater, by the purser’s desk.

The phrase, “headset or neck loop are available” or “T-coil or hearing aid compatible” should be included under the symbol so that patrons will know specifically what type of equipment is available. An alternative T-coil compatible symbol is available at www.hearingloop.org.

The symbols also need to be listed in the brochures, mailings, advertisements and on the website. Some excellent examples of web sites are:

The methodology recommended and is utilized on all of these web sites. The "Access" or "Accessibility” information is located under "Visit Us". All of the information is then grouped by disability. The symbols should appear on the left and the appropriate information on the right. We would be happy to review the information prior to posting it on the web.

For your reference, the following website has all the access symbols formatted for easy downloading.

An on-going training program for all personnel is needed so that everyone is aware of what options are available at the PV. All the money spent on access and all the appropriate access is worthless unless the staff is appropriately trained, knowledgeable and welcoming about what accommodations are available.

There also needs to be an Access Coordinator who is a point person for access information and complaints. There is an enormous amount of turnover on a ship and an Access Coordinator ensures continuity.

Access training participation should be a mandatory part of an employee’s annual review. An Access Guide should be available at the Purser’s desk. There should be a separate page for each type of disability and the type of accommodations available. The Access Coordinator’s contact information should be listed on the inside cover.

SUMMARY:

Passenger Vessels need to be accessible to everyone. With these proposals and adequate training, the PV can offer consistent access for passengers who are deaf or hard of hearing so that they too can enjoy the cruising experience.

Prepared and copyright protected by The Hearing Access Program, 9/07
Janice Schacter 212-988-8099 Jschacter@nyc.rr.com

POPULATION CHART

Nature of Loss	Potential Accommodation
Mild to Moderate	Assistive Listening Device: Headset Captioning
Moderate to Severe	Hearing-Aid Compatible Assistive Listening Device or Induction Loop System Captioning
Profound to Deaf	Captioning Qualified Interpreter

What is an induction receiver/neck loop?
While you may already be familiar with the headset or stethoscope type of infrared receiver used at this theater, there is another type of receiver that is known as an induction or neck loop receiver. It will receive the infrared signal that is transmitted in this theater but, unlike the headset type of receiver, cannot be used alone but must be used with hearing aids. In addition, the hearing aids MUST be equipped with TELEPHONE SWITCHES.

How is this receiver used?
The receiver is hung around your neck using the attached cord and the neck loop is placed over your head. Make sure the plastic lens faces outward. Turn your TELEPHONE switches to the “T” position; turn the induction receiver on using the rotary knob that also serves as the volume control. You can also adjust the volume by using the volume controls, if present, on your hearing aids.

How do I know if I need an induction receiver?
While most people with a mild to moderate hearing loss can use the standard headset receivers, those individuals with a more extensive hearing loss, that is, severe to profound, may find it advantageous to use an induction receiver. The induction receiver can provide a number of advantages over the standard headset receiver that are:
1) You do not have to remove your hearing aids but merely switch them to the "T" position in order to use the induction type receiver.
2) You can most likely get higher volume, if needed than with the headset.
3) If you are using the headset receiver and find it necessary to turn up the volume to the maximum or near maximum level, you may be inadvertently disturbing audience members sitting next to or close to you because some of the sound from your headset can leak out causing an unpleasant echo.
Again, in order to use an induction or neck loop receiver, your hearing aids MUST HAVE TELEPHONE SWITCHES

What exactly is a telephone switch “T” (also known as a telephone coil)?
A telephone switch enables a hearing aid user to pick up the signal coming from the earpiece of a telephone handset be means of a small coil of wire which is sensitive to the magnetic field being emitted from the telephone earpiece. This will make it easier for many (but not necessarily all) hearing aid users to use the telephone. It turns out that this technology, although originally developed for telephone use, has other applications and can be used to enable a hearing aid to directly pick up other signals such as those emitted by an infrared induction receiver.

How do I know if I have a telephone switch?
On some hearing aids, there may be a switch labeled O-T-M or M-T. On other hearing aids, there may be a switch with other labeling or no labeling at all. On some newer hearing aids, there may be no visual indication that the telephone switch is present - it may be activated by pressing in on the aid in a certain spot or remote control or by just holding a telephone over the hearing aid. In general, the smallest types of hearing aids such as the CIC (completely in the canal) do not have telephone switches. If you are not sure whether or not your hearing aids have a telephone switch, you can check with your audiologist or hearing aid specialist.

Technical Support for Assistive Listening Systems

The assistive listening device (“ALD”) distributors need to be trained to test the equipment before it is given to the patron. According to Josh Gendel, Director of Technology at The League for the Hard of Hearing, two inexpensive pieces of equipment from Radio Shack are needed. The Radio Shack Mini-Audio Amplifier #277-1008 for approximately $11.99 and the Telephone Bug #44-533 for approximately $3.99 are needed. Placing the Bug next to the neck loop can quickly test the neck loop. Any sound the neck loop receives will be heard through the Mini-Audio Amplifier.

Not only is it important to ensure that the equipment is working but it is also important to confirm that the equipment is working in the attendee's seat prior to the start of the show. On many occasions, my daughter heard only static through her neck loop. This meant the signal wasn't strong enough and either there were not enough infrared emitters or the emitter was moved during a performance. None of which could easily be remedied. The only solution was to change seats. Unfortunately, on these occasions, it was too late to change seats since we did not realize this problem until after the event began. This problem could have been avoided if the theater had a pre-show sound test.

The pre-show sound test is accomplished by having a CD/tape playing prior to the start of the show but run only through the assistive listening system. The audience cannot hear the sound unless they are wearing the ALD. By having the sound on while patrons are arriving, anyone whose seat is not receiving the signal or whose neck loop/headset is not working would be able to make appropriate arrangements prior to the start of the event. This alleviates disturbances during the event. In the end, the customer is satisfied rather than disappointed.

A sound loop explaining the ALD should be developed. This can be done on either a CD or on MP3 player that would cost approximately $300. This system is currently implemented at Disney World, most Broadway theaters and at Avery Fischer Hall.

Prepared and copyright protected by The Hearing Access Program, 9/06
Janice Schacter 212-988-8099 Jschacter@nyc.rr.com

In the followup letter from me to the Chair of the House Subcommittee on National Parks following the Congressional Hearing on Disability Access in the National Parks held in May 2006, the National Park Service (NPS) indicated that it would continue to enhance efforts to provide accessible audio-visual programs for visitors with visual and hearing loss in our parks through a special emphasis initiative using fee revenue dollars in FY 2007. This memorandum has been developed in order to carry through with that commitment.

Recently, a series of official disability rights complaints and testimony received at a Congressional oversight hearing on disability access revealed that the NPS has many audio-visual programs that are not captioned or audio-described; assembly areas that are not equipped with assistive listening systems; and in some cases, captioning systems that are broken and have not been repaired. While the NPS has come a long way in providing structural and non-structural access for our visitors with disabilities over the past several years, there is still much to be done. One of the shortfalls of our past actions is that in many parks Servicewide, the NPS still does not provide accessible audio-visual programs for individuals with visual and hearing loss.

As Director, I believe we can create the opportunity for the NPS to complete one aspect of making the parks accessible. The goal is to complete projects over the next year so that all of the films and audio-visual programs presented in our parks provide three basic services:

With funding from the Recreation Fee Program, this is an attainable goal. Recreation fees have funded more than $11 million in films and audio-visual media at 83 parks over the past several years. Considering on-going and new starts on film projects, recreation fees have the potential to make 68 accessible films over the next year.

In order to reach this goal, all superintendents should evaluate their parks’ existing audio-visual programs and venues to determine if the required services are provided and in working order. In all of their existing programs, in any film project in production, and in any planned in the future, the superintendent should ensure that these three elements are included. Deficiencies in these three basic services should be used to create a Project Management Information System (PMIS) project that requests funding in FY 2007. Parks should use their recreation fee or other revenues where possible. Low revenue and non-collecting parks should identify 20 percent Recreation Fee funds.

The regions should take steps to ensure that each park has conducted these evaluations so that the region can prepare an implementation schedule by December 1, 2006. The regions should assist the parks in identifying needs in PMIS during this Servicewide Comprehensive Call and adjusting ongoing projects to meet this goal. It is the goal of the NPS to have all park units show films that are captioned and audio-described, and all of their assembly areas equipped with assistive listening devices by January 2008.

If you need technical assistance or have contracting questions regarding captioning, audio- description or assistive listening devices, please contact the Harpers Ferry Center at
304/535-5050. Questions on the project development process and funding should be addressed to your Regional Recreation Fee Projects Manager. Questions on accessibility protocols should be addressed to Dave Park, Accessibility Management Program Coordinator, at 202/513-7027.

cc: Associate Regional Directors, Park Operations
Regional Accessibility Coordinators

Captions should not obscure information relevant to understanding or enjoying a program such as but not limited to covering people’s faces, descriptive banners.

The coordinator can supply a list of words to the Captioner that are likely to be used during the event. The presenter should supply their presentation in advance or if not their exact presentation at least a list of topics, names and any points likely to be discussed. This allows the captioner to program the information into their computer and thus lessen the number of potential errors.

This can be either a real or fictitious company produced name. Giving ownership to the captioner will be an incentive to the captioner to work harder to ensure the words are spelled correctly.

Captioning is like any other product or service that a PV bids. The standards should be reviewed annually and as technology changes. Also, price should not be the sole determiner for obtaining a contract. Quality captioning cannot be obtained when captioning contracts are based on price alone.

Prepared and copyright protected by The Hearing Access Program, 9/07
Janice Schacter 212-988-8099 Jschacter@nyc.rr.com

PASSENGER VESSELS

RECOMMENDED APPROPRIATE ACCESS
FOR PEOPLE WHO ARE DEAF OR HARD OF HEARING

SUMMARY:

POPULATION CHART

Technical Support for Assistive Listening Systems

PASSENGER VESSELS

RECOMMENDED APPROPRIATE ACCESSFOR PEOPLE WHO ARE DEAF OR HARD OF HEARING

SUMMARY:

POPULATION CHART

Technical Support for Assistive Listening Systems

RECOMMENDED APPROPRIATE ACCESS
FOR PEOPLE WHO ARE DEAF OR HARD OF HEARING