MR. FRIER: Mr. Chairman, Board members, I
would like to thank you for this opportunity to
speak this afternoon. My name is Jeff Frier. I'm a
naval architect, and I work for a group called Carnival Corporate Shipbuilding, and that is based
in South Hampton on the south coast of England.
One of the points that came through very clearly during a trip on the Island Princess was the fact that we needed to focus on the issues that were causing us concern, the areas where we thought there were problems in the proposed guidelines. So following Ted's presentation, I would like to summarize our main points, clarify why we have an issue with some of these proposed sections, and then suggest alternatives that may be considered to maintain the intent of accessibility.
Point Number 1 is the on/off issue. This has been discussed at some detail, both with the smaller vessels and Ted's presentation. So I would briefly like to say that the wide variety of ship designs and port facilities are the responsibility between the vessel and the landside and it causes a great raft of different concerns and issues, so we feel a pragmatic approach is needed. One size one solution doesn't fit all, so we suggest that the performance standard should be introduced similar to the UK Marine Guidelines, which we have in the UK. So a copy of that is available and if any Board members wish to be provided with further copies, then I can make sure you receive it.
Point Number 2 goes on to the communication technology. Ted mentioned the TTY, but also visual alarms. Vessels have emergency procedures, which are drilled with the ship's crew, and we certainly believe that developments in communication technology should be allowed. So we feel that there should be an acknowledgement in the proposals that new technology and on-board procedures can provide an equivalent standard.
Number 3, again this issue has been raised on a number of occasions already, about the commune sill mines. In certain parts of the vessel we are required by the load line convention, that's an international requirement, to provide a protection to abide water ingress into the hull itself and minimal vertical height is needed to maintain weather-tightness on external doors, particularly on upper decks where we have the vessel rolling and we can have considerable quantities of water moving around the deck.
There was a suggestion for watertight doors, but these are basically very heavy, hydraulically driven structures and this is not an option for safety in passenger areas. Our proposal is to allow vertical sills on external doors to maintain weather tightness.
Point Number 4 is regarding swimming pool access. Swimming pools on cruise ships are generally quite small. They're high up on the ship and the weight has a considerable effect on the stability of the vessel. Therefore, it requires an enclosed beach area to contain the swell. When the ship is moving around, the surface of the pool water tends to slop out the side and we need to enclose that with a beach. This means there's limited deck area to prevent the use of ramps and lifts, maybe not the best solution on a moving flat form. So our proposal is to allow alternative arrangements that can provide a dignified means of access.
Five, emergency signage. There are some new proposals which indicate duration of signage for people with impaired vision. This is something that we simply could not fit on ships. There is concern about actually making or directing people towards danger. This issue has been discussed previously with cruise ships for location lighting and that means there's no arrows or indication direction provided -- it's very important we nominate where the emergency exits are but just that.
Additional onboard procedures will help in the event of something going wrong and assist passengers making sure that they are able to follow the correct route to the master stations. So we consider that the standard should be developed that reflects current practice.
Point Number 6 relates to scoping. I was a bit surprised to hear the story of the unfortunate experience with the lady earlier, but one of the issues with cabins is that to have an accessible cabin, we need to have certain elements within that space, at least to a larger footprint. And most of the cabins on board our modern vessel are standard, prefabricated module.
Having an accessible cabin means we need 50 percent greater area. The cruise ships are not basically a hotel where somebody is going to drop in. Arrangements will be made weeks, if not months, in advance of a cruise. And in this case the correct information should be passed on to the passenger. We believe the requirement should be based on the industry statistics and we have some data that indicates the capacity that we have is sufficient for the projected growth in the next 40 years. So we believe that the scoping requirement should reflect expected growth.
Point 7 relates to the bathroom components. The proposals clearly indicate the arrangements are separate elements, but these reflects what we have on land-based facilities. We feel that the separate elements should be brought together as we have on a cabin on a ship, and included detail such as the toilet flush, which on the vacuum system that we have on modern cruise ships is positioned behind the seat for safety reasons. So again, we suggest that guidelines should be developed to reflect modern cabin bathroom designs.
Point Number 8 relates to the dispersion of seating in public areas. We have certain limitations because of the structural arrangements. We have pillars. We have physical constraints of the breadth of the ship and so we have a limited size. Providing accessible seating to all areas and all tiers is not feasible. So we suggest providing reasonable access to all entry levels.
Item Number 9 relates to elevators. We have structural limitations on size. We just cannot make these as big as possible. And existing marine arrangements appear to be adequate. There is also an issue with increased weight, which again, the drive gear at the top of ship may create stability problems. Indeed one of the examples that was used in the Volpe report indicated that the modified ship was unable to meet the damage stability standards.
The final point, final comment, 10, is definition of a new ship. Cruise ships are often ordered in a series and may include future option. Cruise ship design will take years to develop and substantial structural modifications are not feasible once the design has been completed and approved by the relevant bodies. So a new ship should relate to new design.
So in conclusion, we strongly believe that land-based standards can't be readily applied to dynamic marine environment. Cruise ships are simply not floating structures, but they include safety procedures and should be considered as a complete system. Guidelines must also relate and acknowledge international maritime standards and regulations.
We would like to offer the Board some realistic cost estimates for the regulatory assessment and these must include figures that reflect large cruise vessels constructed outside the U.S.A. We welcome the opportunity to become part of the process in developing new guidelines and detailed comments of the above will be included in the ICCL submission to the Access Board dockets.
Thank you for your time.
MR. [GARY] TALBOT [BOARD MEMBER]: Thank you very much, Jeff. I have a question for you on pool access. In your comments you said a dignified means of access. Beyond ramped entry or transfer tier or the pool lift that we saw on the Island Princess, what other means of access -- is there another means of access that you folks have looked at?
MR. FRIER: Well, the new proposals -- for the size of the pool that we have, we're very limited in the area that we have, so we're required to provide one primary means of access. And the way the proposals are written at the moment, that is either a ramp or a lifting device.
The ramp is, because of the space that we have available, is difficult to implement, and what we discussed the issue about the lift, which has certain features, which may not be the most dignified approach on pool access. So certainly transfer benches, steps, a combination of steps with ramps. But the point we're trying to make is the way the proposals are written at the moment, it's difficult to maintain a dignified entry.
MR. TALBOT: Thank you. Any other questions?
MR. [W. ROY] GRIZZARD [BOARD MEMBER]: I want to make sure that I understood you correctly on this. Earlier in your testimony did I correctly hear you say that you recommended maintaining the vertical lips on the hatches and doors, particularly the main deck, to ensure watertight integrity? Is that correct?
MR. FRIER: That's correct, yes.
MR. GRIZZARD: Do you have any proposed solution for the egress and exit of wheelchairs off the main deck?
MR. FRIER: We have proposals for minimizing that lift. Essentially the problem we're facing is to prevent the ingress of water to the hull, to the accommodation areas and inside the ship. We need to maintain some sill, silling surface, and we require a minimal height to do that, approximately 20 millimeters, three-quarters of an inch, in most areas.
In the forward part of the ship we are required by the load line convention to provide higher curbing heights, but part of our submission will include details of the minimum height that's required in the forward part of the ship to meet the load line convention, and indeed what our proposals would be elsewhere on the vessel.
MR. TALBOT: Any other questions?
MR. [JAMES] ELEKES [BOARD MEMBER]: Your comments relating to blindness, visual impairment, and you went rather quickly. If you could summarize again because I believe I have a question, but I want to make sure I understand what that point was.
MR. FRIER: This is the issue regarding visual alarms and TTYs and providing equivalent --
MR. ELEKES: I believe you were talking about directional navigation for persons who are blind or visually impaired.
MR. FRIER: This was for emergency signage. The new proposals require that if there is an accessible exit, in the event of that exit not being available, then there should be directional signage to direct you towards the next nearest exit. The problem that we've had on issues like low location lighting is that by providing arrows or directional guidance, you may in the event of a fire or another emergency be directing somebody towards the source of the fire.
MR. ELEKES: Has there been given any consideration for individuals who may be blind or low vision that you would have directional sounding mechanisms to direct them to an alternative location?
MR. FRIER: There has been some discussion on that. It's not been fully developed as far as I'm aware, but in addition to the directional signage that is provided, we have trained crew and operational procedures that will make sure passengers have access to safety.
MR. ELEKES: So if, for example, there's a smoke condition below deck and I wound up in a bulkhead that was locked because of that smoke condition, I would have to rely on faith that someone would have to get to me on time to get me to a safe area with fresh air?
MR. FRIER: You won't have to rely on faith. There would be a group or team, a response team that would actually be assigned to that area and will be responsible for searching that area, making sure that all the corridors, cabins and other spaces are completely clear, as with people that have full use of sight. It's not just the visually impaired passengers that will be searched for and taken to safety.
MR. ELEKES: Unfortunately, without that visual acuity and seeing what's going on, you are leaving it to blind faith, excuse the pun.
MS. [PAMELA] DORWARTH [BOARD MEMBER]: The maritime, is that what you said, that you're a part of that?
MR. FRIER: Yes, it's the UK Maritime Coast Guard Agency.
MS. DORWARTH: And all these comments about signage, is that in there?
MR. FRIER: There are some other guidelines for signage, but the signage, in fact, are not as detailed as the PVAG.
MS. DORWARTH: What is the update on that maritime book?
MR. FRIER: When you say "update," do you mean --
MS. DORWARTH: How old is it?
MR. FRIER: This has recently been published within -- the proposals have been released within the last two to three months. There are some existing proposals for ferries which go back several years, but the latest ones have been released very recently. I am not sure of the exact date, but I could find that.
MS. DORWARTH: Okay.
MR. TALBOT: Any other questions? Thank you very much, Jeff. We appreciate it.