I hope you will accept these comments, I know I am past the deadline.
Sincerely:
Carol MaherUS Access Board Draft Passenger Vessel Accessibility Guidelines
ABOUT THIS RULEMAKING
The Board is developing guidelines under the ADA for access to ferries, cruise ships, excursion boats, and other passenger vessels. These guidelines will supplement the Board’s ADA Accessibility Guidelines for Transportation Vehicles. The Board has released draft guidelines for large vessels for public comment based on recommendations it received from the Passenger Vessel Access Advisory Committee. It also issued a notice concerning guidelines for small vessels and information on a cost assessment of the guidelines being developed.
Draft Passenger Vessel Accessibility Guidelines and Supplementary Information
The guidelines would not require alterations to existing passenger vessels, but would apply where an element, space, or facility on a passenger vessel is altered as part of a planned project. The Board ¡s draft guidelines are intended to provide a better understanding of what accessibility requirements would apply to passenger vessels.
V104 Conventions
Section V104.1 notes that all dimensions not stated as a maximum or minimum are absolute.
Because vessels are subject to six types of motion (rolling, pitching, swaying, etc.), section V104.1.2 was added and provides that all slopes are measured when the passenger vessel is in a static condition with design trim and heel.
Draft Passenger Vessel Accessibility Guidelines
V201.4 Passenger Amenities Section V201.4 seeks to ensure that amenities, provided to passengers on decks not connected to a means of vertical access, are available to passengers with disabilities who cannot climb stairs.
Comments: Part of Program access – on new large vessels vertical access should be available to all areas.
V202.2 Additions V202.3 Alterations These sections requires that each addition or remodel on existing passenger vessels conform to the applicable new construction requirements in chapter 2. Also, each addition or remodel that affects or could affect the usability of an area containing a primary function must also comply with V202.4. some actions classified as repair or maintenance in the marine industry may be considered alterations under these guidelines, and therefore trigger the requirements of V202.3 and (if the alteration was done within a primary function. area) V202.4.
Comments: Technically infeasible should not include cost on State Vessels. Important: 202.3.1 Prohibited Reduction in Access. An alteration can not decrease or have the effect of decreasing the accessibility of a vessel below the requirements for new construction. (Example: a platform just because a person is in a wheelchair, does not mean the person can’t sing or play instrument.) V202.5 Alterations to Qualified Historic Passenger Vessels. Features such as access to the boat should be required if at all possible, if no way, then a video of the boat should be available.
V 203.4 Raised Refereeing, Judging, and Scoring Areas. Raised structures used solely for refereeing, judging, or scoring a sport shall not be required to comply with these requirements or to be on an onboard accessible route
Comments: People used to think only males could judge an event, this section makes it look like a person w/ a disability could not be capable, eliminate this section. Would Christopher Reeves have been incapable of judging?
V204 Protruding Objects This section requires that all circulation paths (not just accessible routes) used by passengers comply with the protruding object requirements in V307.
Comments: The 80 inch clearance is not just important to people with low vision, tall people who see hit their heads. Keep Vertical range of =<27 to >80”
V205.1 General. Operable parts on accessible elements, onboard accessible routes, and in accessible rooms and spaces shall comply with V309. EXCEPTIONS: 1. Operable parts that are intended for use only by crew, or service or maintenance personnel shall not be required to comply with V309. 7. Exercise machines shall not be required to comply with V309.
Comments: A crew member can have arthritis and still function, why not a lever handle to reduce pain in opening door? 7. Just because a passenger can’t twist a knob, does not mean they don’t want to use the equipment.
V206.2.1 Multi-Deck Passenger Vessels 4.Decks below the bulkhead deck are not required to be connected to an onboard accessible route.
Comments: Decks that have passenger cabins, below bulkhead deck should have an accessible route to at least one area. These are often the less expensive areas.
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. EXCEPTIONS: 1. In passenger vessels not required to provide an onboard accessible route between decks, an onboard accessible route shall not be required to a mezzanine area where the mezzanine contains less than 25% of the total combined area for seating and dining and where the same decor & services are provided in the accessible area.
Comments: Add: 25% of the total combined area for seating and dining and where the same décor, services and views. are provided in the accessible area. Mezzanine’s and platforms often block views, this should not be allowed.
V208 Passenger Vessel Boarding. V215 Emergency Alarm Systems V215.1 General. Where emergency alarm systems provide audible alarm coverage to alert passengers, alarms shall comply with V215. EXCEPTION: In existing passenger vessels, visible alarms shall not be required except where an existing alarm system is upgraded or replaced, or a new alarm system is installed.
Comments: Require: Before a remodel require at least a portable Visible alarm in passenger cabins and restrooms that give a deaf person at least a chance of knowing there is an emergency.
V216.1 General. Signs shall be provided in accordance with V216 and shall comply with V703. 2. In parking facilities, signs shall not be required to comply with V216.2, V216.3, and V216.6 thru V216.9.
Comments: EXCEPTIONS: in parking areas should not include size and contrast of signs, these requirements enhance wayfinding for everyone.
V218 Two-Way Communication Systems
Comments: Require 2 way communication in areas of rescue, that connect to emergency system.
V403 Walking Surfaces This section provides technical criteria for walking surfaces and is consistent with ADAAG, except for a provision and exception which address passenger vessels where the largest deck is less than 3,000 square feet.
Comments: Where feasible State owned vessels should comply with ADAAG.
V403.5 Clearances. Walking surfaces EXCEPTIONS: 1.Clear width permitted to be reduced to 32”min. for a length of 24”max, if reduced width segments are separated by 48” x 36” wide min.2. deck of a vessel <3000 sq. ft. permitted to have a clear width of 32”.
Comments: Exception: for deck <3000 sq. ft. should be 36” unless technically infeasible then 32” min. can be used. (32” is a causes scraped knuckles).
V403.6 Handrails. Where handrails are provided along walking surfaces with running slopes not steeper than 1:20 they shall comply with V503.
Comments: Requirements when to provide handrails should be addressed. Example around public room to use in rough weather.
V404 Doors, Doorways, and Gates Under Coast Guard regulations and two international conventions (i.e., Safety of Life at Sea, and Load Lines), certain weather tight doors are required to have raised thresholds (coamings) which are three or more inches in height that form a watertight barrier at the base of the doors.
Comments: Adouble ramp access@ or Asingle ramp access@ use seals that disappear into floor when door is open and raise to seal when doors are shut. These are used on some vessels. Require on State owned vessels.
V404.2.7 Door and Gate Hardware. Handles, pulls, latches, locks, and other operable parts on doors and gates shall comply with V309.4. EXCEPTIONS: 1. Existing locks shall be permitted in any location at existing glazed doors without stiles, existing overhead rolling doors or grilles, and similar existing doors or grilles that are designed with locks that are activated only at the top or bottom rails. 2. Access gates in barrier walls and fences protecting pools, spas, and hot tubs shall be permitted to have operable parts of the release of latch on self-latching devices at 54” max. above the finish deck surface, provided the self-latching devices are not also self-locking devices and operated by means of a key, electronic opener, or integral combination lock.
Comments: Exception: 1. Existing locks until a remodel 2. Self Latch 48 “ max. ( a child can climb and open a latch at 54” , the only people you will keep out with 54” latch is people in wheelchairs and people of small stature.
V404.2.11 Vision Lights EXCEPTION: Vision lights with the lowest part more than 66 inches (1675 mm) from the finish deck surface shall not be required to comply with V404.2.11.
Comments: In new construction why would a vision light be at 66”?
V404.3 Automatic and Power-Assisted Doors and Gates.
Comments: Require: Automatic door anytime opening pressure cannot be reduced to 5lbs.
V406 Curb RampsThis section provides technical criteria for curb ramps. The ADAAG curb ramp sections which address location, diagonal curb ramps, and islands have not been included. PVAAC had indicated that the features addressed by these sections do not exist on passenger vessels which carry vehicles.
Comments: Curb ramps do appear in ferry boats on car decks and transitions to elevators on car decks and should be addressed here.
V407 Elevators V408 Limited-Use/Limited-Application Elevators This section provides technical criteria for LULA elevators. PVAAC had recommended two exceptions for ferries and other passenger vessels which are less than 1,000 ITC tons that would have allowed LULA elevators to have 36 inch clear widths.
Comments: Should address not using LULAs on vertical access covering more than one floor. A elevator on a new ferry with 4 large decks should not be a LULA. They are too small and are not made for constant use.
V409 Platform Lifts This section provides technical criteria for platform lifts and is consistent with ADAAG 410, except in two areas. First, V409 does not require platform lifts to comply with ASME A18.1 because that safety standard does not have provisions for shipboard platform lifts.
Comments: Then a technical standard should be used designed for ships. Example: A home lift with a low weight capacity would not stand up to use on ships.
V410 Means of Escape Aarea of refuge@ to Aarea of temporary refuge@. Exit stairs which are 36 inches wide between handrails.
Comments: In cases where the fire is not near the elevators , the elevator should be allowed to be used to transport people with disabilities, rather than using area of temporary rescue. Areas of refuge:Require 2 way communication in these areas to emergency radios
Chapter 5: General Passenger Vessel Elements
Comments: No comments
Chapter 6: Plumbing Elements and Facilities 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. EXCEPTION: In detention facilities, grab bars shall not be required to be installed in cells that are specially designed without protrusions for purposes of suicide prevention.
Comments: Require: the kind of grab bars, that are not open, we use them in Washington State.
Chapter 7: Communication Elements V702 Emergency Alarm Systems
Comments: No comments at this time (I have a communication specialist reviewing this.)
Chapter 8: Special Rooms, Spaces, and Elements V806 Passenger Guest Rooms; V807 Cells
Comments: Require: All guest room doors shall be 32”, unless technically infeasible. (There are a lot of people that use wheelchairs during the day, but can get around a room. This will save money in the long run, because one would not have to turn away a customer for lack of an accessible room.) Note: In Washington State, we are making all doors in correctional facilities 32-36”.
Chapter 9: Built-In Elements; V903 Benches; V904.5 Food Service Lines
Comments: Add section: Benches shall have arms on at least one side. (Important for transfers and for older people who have trouble standing up from seated position. Food service lines should have a 9 inch toe space to allow for an increased reach range.
AreasV904.6 Security Glazing. Where counters or teller windows have security glazing to separate personnel from the passengers, a method to facilitate voice communication shall be provided. Telephone handset devices, if provided, shall comply with V704.3.
Comments: Require: 6” space at 44” to 50” that does not have glass. Can just be a 6” round opening. This allows a lip reader to read lips of employee.
Chapter 10: Recreation Facilities and Play
Comments: No comments at this time, sent to a person who uses a wheelchair, that works for Interagency committee for recreation.