Discussion of Provisions

The draft guidelines are formatted similar to ADAAG, but some renumbering of sections was necessary.  To distinguish sections in the vessel guidelines from sections in ADAAG, the letter “V” is placed at the beginning of each section.  Only two figures (which are not in ADAAG) have been included in this draft.  In the proposed rule, these figures (as well as others incorporated from ADAAG) will be placed within the text of the guidelines along with appropriate advisory notes.  The following discussion does not address every provision in the draft or every recommendation made by PVAAC.  The full text of the Board’s draft guidelines follows the discussion.

Chapter 1: Application and Administration

This chapter provides general principles that recognize the purpose of the draft guidelines (V101), provisions for adults and children (V102), equivalent facilitation (V103), conventions (V104), referenced standards (V105), and definitions (V106).

V104 Conventions

Section V104.1 notes that all dimensions not stated as a maximum or minimum are absolute and that all dimensions are subject to conventional industry tolerances (V104.1.1), except where the requirement is stated as a range with specific Aminimum@ and Amaximum@ end points.  Conventional industry tolerances recognized by this provision include those for field conditions and those that may be a necessary consequence of a particular manufacturing process, but not design.  For example, acrylic molded plumbing fixtures, such as shower stalls, often have a slight draft or taper so that they can be drawn from their molds.  This slight taper does not adversely affect accessibility and is a necessary consequence of this particular manufacturing process. 

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.  Trim is the difference between the draft of a vessel at the bow and stern; heel is the side to side difference.  The draft guidelines use provisions similar to ADAAG for calculating percentages (V104.2) and clarifying that figures are provided for informational purposes only, unless specifically stated otherwise (V104.3).

Chapter 2: Scoping Requirements

This chapter provides scoping criteria on passenger vessels for facilities, spaces, and elements required to be accessible in new construction and alterations.

V201.1 Scope

This section applies the passenger vessel accessibility guidelines to all passenger areas of newly designed and constructed passenger vessels permitted to carry more than 150 passengers or more than 49 overnight passengers.  The Board’s draft guidelines would also apply the technical provisions to altered portions of existing passenger vessels.  The draft guidelines would only apply to passenger areas.  For passenger vessels which carry 150 or fewer passengers or 49 or fewer overnight passengers, the Board is publishing a separate notice to solicit comment on how to address access on smaller passenger vessels. 

With respect to foreign-flag cruise ships, the Federal courts of appeal are in conflict as to the application of the ADA.  The United States Court of Appeals for the Eleventh Circuit has held that a foreign-flag ship sailing in United States waters is not considered “extraterritorial” and therefore the Act applies.  See Stevens v. Premier Cruises, Inc., 215 F. 3d 1237, (11th Cir. 2000).  Citing a lack of Congressional intent, the United States Court of Appeals for the Fifth Circuit held directly opposite in finding that the ADA does not apply to foreign-flagged cruise ships.  See Spector v. Norwegian Cruise Line Ltd., 356 F. 3d 641, (5th Cir. 2004).  The Board anticipates that the issue of the application of the ADA to foreign-flagged vessels will ultimately be resolved by the courts.

The advisory committee applied its recommendations to passenger vessels which are subject to U.S. Coast Guard regulations found at 46 CFR Subchapters H or K, and smaller passenger vessels subject to Subchapters C or T.  Determining which Subchapter applies to a passenger vessel is based on the number of passengers a vessel is permitted to carry and the volume tonnage of a vessel.  Because determining the tonnage of a passenger vessel is a complicated process and because many large foreign-flagged passenger vessels are not subject to the Subchapters, the Board’s draft guidelines uses passenger numbers to determine coverage.  The numbers were derived from Subchapter K and are used to distinguish Subchapter K passenger vessels from (generally smaller) Subchapter T passenger vessels.  It is possible for some Subchapter H passenger vessels to have fewer than these passenger numbers. 

V201.4 Passenger Amenities

This section specifies that at least one of each type of element, space, and facility used by passengers shall be on an entry deck or be connected by an onboard accessible route to an entry deck.  An entry deck is defined in V106.5 as a deck which contains passenger entry and departure points which allow passengers to embark or disembark a vessel from fixed piers, floating piers, or the land in non-emergency conditions.  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.  In addition to V201.4, sections V221.2.3.2, V221.2.4, and V224.6 require 100 percent of certain elements and spaces to be located on decks complying with V201.4.

V202.2 Additions

This section requires that each addition on existing passenger vessels conform to the applicable new construction requirements in chapter 2.  Also, each addition that affects or could affect the usability of an area containing a primary function must also comply with V202.4.  For example, if a passenger vessel is lengthened by adding a new mid-section, the new mid-section must conform to the new construction requirements.  If the new mid-section is a primary function area, the path of travel requirements in V202.4 may apply to the existing portions of the vessel.

V202.3 Alterations

This section requires that each alteration to elements and spaces in existing passenger vessels comply with the applicable provisions in chapter 2.  This section does not require that alterations be performed, but when an alteration to a passenger vessel is conducted, this section requires accessibility improvements to be made to the maximum extent feasible based on the degree of alteration performed.  For example, if nonconforming carpet is replaced in a space which is required to be accessible because the carpet is worn out, conforming carpet would be required to be installed as part of this carpet replacement project.  The term Aalteration@ is defined in V106.5 and may carry a broader meaning than how it is used in the marine industry.  Therefore, 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.

Section V202.3 includes a third exception which also addresses when some alterations may be technically infeasible.  In alterations, where compliance with applicable provisions is technically infeasible, the exception requires accessibility to the maximum extent feasible. 

V202.4 Alterations Affecting Primary Function Areas

This section specifies the requirements that apply when alterations are performed in a primary function area.  These requirements are in addition to those required by V202.3.  In general, when alterations are performed in a primary function area, additional accessibility improvements are required to the path of travel to the altered area, and rest rooms, public telephones, and drinking fountains serving the altered primary function area.  The Department of Justice (DOJ) has established specific criteria for this type of alteration in 28 CFR 36.403.  Because criteria for this type of alteration are determined by DOJ, the PVAAC recommendations were not included.

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.  Section V307 establishes minimum vertical clearances along circulation paths and maximum projections into such paths.

Consistent with ADAAG, the Board’s draft guidelines apply V307 to all circulation paths in rooms and spaces which are required to be accessible.  This is primarily because persons with vision impairments will not know which paths have protruding objects and which do not, even if signage alerts other users.  Section V307 does not apply to circulation paths in spaces which are not required to be accessible (for example, guest rooms which are not required to comply with V806.2 and V806.3).

V206 Onboard Accessible Routes

This section specifies the required number of onboard accessible routes (V206.2) and their location (V206.3) and addresses the scoping of elements that are components of accessible routes: vessel entry and departure points (V206.4), doors (V206.5), elevators (V206.6), platform lifts (V206.7), and security barriers (V206.8). 

The term “onboard” was added to the phrase “accessible routes” to make it clear that accessible routes required by V206 must be provided onboard passenger vessels.  For example, a new ferry with two passenger decks could not use a means of vertical access at a landside facility to connect its two passenger decks.  The new ferry must have the accessible connection onboard the vessel.  However, in alterations to existing vessels, such an access solution may be all that is feasible where it is technically infeasible to install vertical access in an existing vessel (see V202.3).

V206.2 Accessible Routes

Section V206.2.1 specifies deck-to-deck and deck-to-mezzanine onboard accessible routes, and requires that at least one accessible route connect each passenger deck and mezzanine in multi-deck passenger vessels.  This section also requires each entry deck to be connected in passenger vessels with multiple entry decks (see V106.5 for entry deck definition).  Five exceptions are included which modify this vertical access requirement.  However, in the first three, the exceptions cannot be used to eliminate the requirement to connect entry decks. 

Section 303 of Title III of the ADA addresses “New Construction and Alterations in Public Accommodations and Commercial Facilities”.  Paragraph (b) provides that elevators are not required in facilities that are less than three stories or have less than 3,000 square feet per story unless the building is a shopping center, a shopping mall, or the professional office of a health care provider or unless the Attorney General determines that a particular category of such facilities requires the installation of elevators based on the usage of such facilities.  Because it is not uncommon for passengers to board on one level and disembark on another, the Department of Justice has indicated its intention toseek comment from the public on whether to include passenger vessels covered by title III of the ADA as a type of public accommodation which requires the installation of elevators for purposes of embarking and disembarking.  Accordingly, in these draft guidelines, the first three exceptions in V206.2.1 note that the entry decks on passenger vessels are required to be on an accessible route.  The Board’s draft guidelines seek to ensure that where passengers embark a vessel on one deck and disembark from another deck, vertical access between entry decks is provided.

Although the exceptions eliminate the requirement in V206.2.1 for vertical access between certain decks, the exceptions do not eliminate the requirements for access on those decks.  Therefore, if a public toilet room is provided on a deck not required to be connected to an accessible route, the toilet room must still be accessible (where required by V213), and it must be connected by an accessible route to other accessible elements and spaces on that deck (where required by V206.2.2).

In addition, the five exceptions do not modify the “one of each type” requirement in V201.4.  This means that in passenger vessels which are not required to have vertical access to some or all passenger decks, at least one of each type of passenger facility, space, and element provided on unconnected decks must be provided on an entry deck or on a deck connected by an accessible route to an entry deck.

Exception 1

This exception specifies that on passenger vessels that have fewer than three decks or that have less than 3,000 square feet per deck, an accessible route shall not be required to connect passenger decks that are not entry decks.

Exception 2

This exception specifies that decks, other than entry decks, that have less than 300 square feet are not required to be connected to an onboard accessible route.  When PVAAC developed its recommended vertical access exceptions, the committee started with a simplified exception which paralleled the vertical access exception contained in title III of the ADA.  Section 303(b) of the ADA does not require the installation of an elevator for facilities that are less than three stories or have less than 3,000 square feet per story unless the building is a shopping center, a shopping mall, or the professional office of a health care provider or unless the Attorney General determines that a particular category of such facilities requires the installation of elevators based on the usage of such facilities.  From the simplified exception, the committee determined that two additional vertical access exceptions were needed, one for high speed ferries with only two passenger decks and another for decks less than 300 square feet in size.  PVAAC recommended that both public and private entities be eligible to use these last two exceptions.

The Board’s draft guidelines include the first exception from the PVAAC report, but apply the exception to both private and public entities.  However, the exception was modified to indicate that it applies only to the connection of decks which are not entry decks.  This exception would include passenger decks without enclosed spaces (for example, a sun deck) in determining if a vessel had less than three decks.  As many passenger vessels subject to these guidelines have more than two decks, aside from the entry deck requirement, such vessels could only use exception 1 if all the passenger decks were less than 3,000 square feet.  A mezzanine is not a deck for purposes of determining eligibility for using the exception.  Because exception 1 may be used by public entities, the high speed ferry exception PVAAC provided was not needed.

The second exception that addresses non-entry decks which are less than 300 square feet was created for very small decks on some passenger vessels where providing access would use up most of the available deck area.  For example, the top of an elevator penthouse or deck cabin may be used as a sunning deck.

Exception 3

This exception specifies that where vehicle lanes for trucks, buses, or other high clearance vehicles divide a higher deck, other than entry decks, into two separate segments and no horizontal circulation is provided between these two segments, only one segment of the divided deck is required to be connected by an accessible route.

Although not addressed by PVAAC, a number of ferries have decks split in half by high clearance vehicle lanes located on lower decks.  Some of these split decks contain parking for vehicles, such as the Tacoma ferry operated by Washington State Ferries.  Others, such as the Machigonne II operated by Casco Bay Lines and the Margaret Chase Smith operated by the Maine State Ferry Service, contain small passenger seating areas on these split decks.  Under V206.2, absent an exception, a newly constructed vessel using this design would be required to have vertical access connecting each side of the split deck with all other accessible passenger decks.  In the cases identified, the services available on one side were identical on the other side and because many of these ferries are quite small, the requirement for two means of vertical access could be burdensome.  Therefore, this exception has been included in the Board’s draft guidelines.  However, as mentioned above, if the passenger services offered on each side are not identical, the “one of each type” requirement in V201.4 would still need to be satisfied.

Exception 4

This exception specifies that decks below the bulkhead deck are not required to be connected to an accessible route.  The bulkhead deck is the uppermost deck to which watertight bulkheads and the watertight shell extend.  Although vertical access may be provided into the area of the watertight shell, the watertight bulkheads which divide the shell into watertight zones would eliminate or severely restrict horizontal movement between zones.  This exception is proposed in these draft guidelines because of the complications in providing horizontal access between watertight zones, and the high likelihood that the passenger spaces tend to be small or similar to those provided elsewhere.

Exception 5

This exception specifies that where exceptions for alterations to qualified historic passenger vessels are permitted by V202.5, an accessible route shall not be required between decks.  This exception is similar to an exception in ADAAG 206.2.3.

V206.3 Location

This section addresses the location of accessible routes required by V206.2.  As recommended by PVAAC, it also requires onboard accessible routes connecting any two points within one or more accessible spaces to not be more than 300 feet longer than the shortest general circulation path connecting the same two points.  This distance is roughly twice the maximum distance between fire bulkheads for main vertical fire zones which are required by the Coast Guard on Subchapter H and K passenger vessels.

V206.4 Entry and Departure Points

This section specifies that each entry and departure point used by passengers shall be on an onboard accessible route.  PVAAC recommended a performance requirement that “in all ports, an accessible route be provided to at least one vessel entry and departure point used by passengers”.  An entry or departure point is the place on a vessel at which a passenger embarks or disembarks the vessel, such as going through an opening in a lifeline, a door in the side of the vessel, or a gate in the bulwark.  Most vessels have a multitude of entry points, generally on both sides of the vessel and some on different decks.  Typically, only one is used by passengers at each site a vessel stops.  The same point is generally used for both embarking and disembarking passengers.  Different entry points may be used at different vessel stops. 

The Board’s draft guidelines do not use a performance standard because vessel uses and areas of operation may change over the life of the vessel.  The draft guidelines seek to ensure that persons with disabilities will be able to depart a vessel not just at the current landside facilities a new vessel may stop at but at landside facilities the vessel may stop at in the future.  Although an onboard accessible route must connect each entry and departure point, this section does not address the connection to the landside facility nor does it require each entry and departure point to be connected to a landside facility (see V208 for passenger boarding system scoping).

V206.6 Elevators

This section requires all passenger elevators to comply with the technical provisions for elevators and determines when a limited-use/limited-application (LULA) elevator may be used as a component in an accessible route.  The Board’s draft guidelines simplify the exceptions regarding use of LULA elevators recommended by PVAAC and allows vessels less than 10,000 ITC tons to use LULA elevators.  ITC tons refers to a measurement system used in the International Convention on Tonnage Measurement of Ships. 

V207 Accessible Means of Escape

This section provides scoping criteria that determines how many accessible means of escape (V207.2) are required from an accessible passenger space.  It also determines when an elevator must be provided for accessible escape purposes from a deck (V207.3).  Because ADAAG references the International Building Code (IBC) for most of its means of egress requirements, the draft guidelines generally combines the recommendations of PVAAC (see chapter 3 of its report) and the access principles present in IBC (2000) 1003.2.13.

V207.3 Elevators

This section requires at least one elevator complying with V206.6 and V411.3 on certain multi-deck vessels to serve each passenger deck as an accessible means of escape.  The provision allows LULA elevators to be used as part of an accessible means of escape, where permitted by V206.6.

During emergencies, the elevator required by V207.3 would be crew operated and would be used to assist the movement of persons with disabilities between decks.  PVAAC had expressed concern that the Coast Guard would not allow such elevator usage in an emergency.  In response to this concern, the Coast Guard has communicated to the Board that it would allow crew members to operate elevators as a means of escape in an emergency to transport persons with disabilities only.  Also, the Marine Safety Committee Circular 846 of the International Maritime Organization provides that in emergencies, lifts (elevators) may be used as an additional means of escape provided that they are controlled by the assigned member of the crew and are supplied from the ship=s emergency source of power. 

V208 Passenger Vessel Boarding

This section requires at least one passenger boarding system to be provided that complies with V412 and connects an entry deck to fixed piers, floating piers, or land.  An exception is included which provides that where a boarding system complying with V412 is on a pier, a vessel carried boarding system is not required.

The Board’s draft guidelines require that for new passenger vessels, the vessel itself must be accessible and the vessel must also have at least one accessible connection to landside facilities when embarking and disembarking passengers.  The components which make up the accessible connection (see V412) may either be carried by the vessel (such as a stage or gangway on a riverboat) or be provided at the landside facilities from which the vessel boards passengers.

When the Board publishes the proposed rule, the rule will also include proposed amendments to ADAAG.  These amendments will include landside requirements which apply to getting passengers on and off passenger vessels at new and altered landside facilities that serve passenger vessels.  The Board intends to include a similar exception in the landside requirements which would allow the boarding system to be carried on the vessel instead of provided on the land.

As established in regulations issued by the Department of Transportation and the Department of Justice, both the vessel operator and the pier operator are subject to the ADA’s requirement that they not discriminate against individuals with disabilities in the operation of their programs.  Therefore, vessel operators and pier operators may find it beneficial to work together to negotiate an allocation of responsibility for compliance with V208 and for operating procedures that ensure that both entities meet their obligation to provide access to people with disabilities in the vessel boarding process.

PVAAC had recommended, similar to ADAAG, that this section address scoping for accessible parking spaces.  Parking is not addressed in the Board’s draft guidelines because parking on most ferries is a highly controlled activity as opposed to the undirected parking which normally occurs in a landside parking lot.  Unlike landside parking lots, vehicles typically queue up in preparation to enter a ferry at a set time, with space generally provided on a first-come-first-serve basis.  Vehicles entering the ferry are often directed to a particular lane and are required to fill the lane starting at the front of the ferry.  Depending on the number of vehicles loaded and each vehicle=s weight, vehicles may be directed to certain areas to reduce the weight impact on the stability of the ferry.  High top vehicles may also be directed to particular lanes to ensure that sufficient vertical clearance is provided. 

When ferry demand is high, crew members ensure the spacing between vehicles is at a minimum, thereby maximizing the carrying capacity of the ferry.  Because of these factors, individual parking spaces are not designated on a ferry as in a landside parking lot.  Although lane markings are generally provided to assist drivers and crew members in aligning the vehicles, parking lanes are not further demarcated into individual parking spaces.  This is because vehicle lengths vary and unused space is not desirable during times of high demand. 

PVAAC recommended (in chapter 8 of its report) that a certain number of rectangular shaped boxes be marked on vehicle decks to serve as accessible parking spaces.  These boxes contained the space for a vehicle and its associated access aisle.  Spaces varied in size depending on whether the box served van parking or car parking.  Technical provisions for bus parking spaces were also included in the PVAAC report, but no recommendation on scoping was included.  Both van spaces and bus spaces were provided with vertical clearance minimums. 

Although PVAAC provided these recommendations, it noted that an effective parking management plan was also necessary to ensure accessible parking was available to persons with disabilities.  In discussions with PVAAC members about ferry operations, it was clear that having an effective parking management plan is of primary importance.  If the need is not identified before the parking areas near the elevator (or other passenger service areas) are filled up, providing a marked accessible parking area near such desirable facilities will have little value.  Marking primarily assists crew members in positioning vehicles and ensuring access aisles and connecting accessible routes remain unobstructed. 

Depending on the degree of crew training and the complexity of the loading process, marking schemes will vary to assist crew members in meeting accessible parking demand.  Depending on when a vehicle appears in the queue line, general ADA non-discrimination requirements may require operators to accommodate accessible parking needs regardless of how many accessible "parking spaces" are provided.  For example, if a ferry provides three marked parking boxes, but four vehicles needing accessibility features (e.g., access aisles and accessible routes) were loaded, the operator may have to ensure additional space is left unobstructed to service the fourth vehicle. Likewise, if a lift-equipped bus carrying persons with disabilities entered the ferry, the operator may have to ensure space is left unobstructed to deploy the lift and that additional space is unobstructed to provide the accessible route to the areas of the vessel where goods and services are provided to passengers.  Also, if a vehicle needing accessibility features arrived at the last minute of the loading process on a full ferry, some unobstructed space may still be necessary even though such space would not necessarily connect to all areas where passenger services are provided.  For these reasons, these draft guidelines do not propose marking accessible parking spaces or access aisles. 

As no ferry has been identified which did not have a high clearance lane, the PVAAC recommendation regarding vertical clearance provisions is not necessary.

V213 Toilet Facilities and Bathing Facilities

This section provides scoping criteria for public toilet facilities and bathing facilities.  PVAAC had recommended that 5 percent, but not less than one, of single user toilet rooms in a cluster be accessible.  For consistency with ADAAG, 50 percent of clustered single user toilet facilities are required to be accessible.

V217 Telephones

This section provides scoping criteria for public telephones and TTYs and has been modified from what ADAAG 217 requires.  Because few public telephones are provided on passenger vessels, the draft guidelines propose that at each location containing public telephones, at least one shall be wheelchair accessible and at least one shall have a TTY.  This section does not apply to telephones provided in passenger guest rooms. 

Where public telephones are provided, the telephones may allow communication off the vessel when underway but primarily only allow communication within the vessel.  For example, a courtesy telephone near a cruise ship restaurant or concierge=s desk is provided to allow passengers to call other passengers in their guest rooms. 

As these draft guidelines only apply to the design, construction, and alteration of passenger vessels, the draft does not address whether third party relay systems must be provided by vessel operators.  Such relay systems allow persons who use TTYs to contact vessel services and guest rooms not equipped with TTYs.  Questions regarding auxiliary communication aids and services for TTY users should be directed to the Department of Justice.

V219 Assistive Listening Systems

This section provides scoping criteria for assistive listening systems where communication through audio amplification is provided and is integral to the use of a space.  Similar to ADAAG, this section addresses assistive listening systems in assembly areas, but unlike ADAAG, the section also addresses assistive listening systems in public seating areas (see V221 regarding public seating areas).

Section V219.3 provides criteria for determining the number of receivers needed.  The section has been modified from what ADAAG requires and uses the total number of seats in the vessel to determine the number of receivers needed instead of the number of seats in each area.

V221 Assembly Areas and Public Seating Areas

This section specifies the number of wheelchair spaces, companion seats, and aisle seats required in assembly areas and public seating areas with fixed seating used by passengers.  The assembly area provisions are consistent with ADAAG, except that provisions for box and lawn seating were removed. 

The draft guidelines also depart from ADAAG in that provisions for “public seating areas” are included in the draft.  In a number of visits to passenger vessels by the Board, it was noted that some fixed seating areas do not contain dining and work surfaces and therefore are not subject to V226.  Also, these areas may not be assembly areas.  An assembly area is defined as a passenger vessel, or portion thereof, used for the purpose of entertainment, educational, or civic gatherings or similar purposes.  Because some seating areas may not be addressed by that definition, the public seating area provisions were included in these draft guidelines.  Public seating areas are essentially any fixed seating areas where V226 does not apply and the areas are not assembly areas.  To incorporate the addition of public seating area provisions, as discussed below, a number of changes have been made to V221.

Section V221.2 specifies the number of wheelchair spaces required.  As in ADAAG, table V221.2.1.1 is applied to each assembly area to determine the number of wheelchair spaces required in each area.  However, for public seating areas, the total number of seats in the vessel which are located in public seating areas are used.  From this total, the total number of wheelchair spaces required in public seating areas of the vessel is determined.  For example, if a vessel has two public seating areas and each area has 150 fixed seats, the vessel would have a total of 300 seats and would be required to provide five wheelchair spaces.  This section requires that wheelchair spaces in assembly areas and public seating areas be an integral part of the seating plan (see V221.2.2).  In general, because there is no specific area where the attention of seated passengers is focused, the lines of sight and dispersion requirements for assembly areas were not applied to public seating areas.

Since it is possible under table V221.2.1.1 that not every public seating area would have one or more wheelchair space, section V221.2.4 was added to address wheelchair space dispersion in public seating areas.  As some passenger vessels may be eligible to use the vertical access exceptions in V206.2.1, vessels without vertical access between decks must disperse all their wheelchair spaces in the public seating areas on the decks complying with V201.4.  There is a similar dispersal requirement for wheelchair spaces in assembly areas.

Section V221.3 specifies that at least one companion seat must be provided for each wheelchair space.  This section applies to assembly areas and public seating areas.  Technical requirements for the companion seat are located in V802.3.

Section V221.4 specifies the scoping for designated aisle seats in assembly areas.  Aisle seats in public seating areas are not subject to this provision.  Technical requirements for these aisle seats are located in V802.4.

V224 Passenger Guest Rooms

This section provides scoping criteria for passenger guest rooms (known as staterooms in the PVAAC report).  A passenger guest room could be provided for overnight berthing accommodations or simply for day use only.

One of the major issues discussed by PVAAC was whether doors to inaccessible guest rooms should be required to be 32 inches wide.  Because of the social interaction and visitation that often occurs in landside lodging facilities, ADAAG 224.1.2 requires doors to and within guest rooms that are not required to provide mobility features to have a 32 inch clear opening width.  As this same interaction and visitation occurs on passenger vessels, some PVAAC members were interested in applying this same provision to guest rooms in passenger vessels.

On many overnight passenger vessels, most guest rooms are smaller than those in lodging facilities on land, and the space in the inaccessible passenger guest rooms is not available to include doors with 32-inch clear opening widths.  To provide such doors, many guest rooms would have to be made wider, which may then reduce the number of guest rooms available on the vessel, or closet space and other amenity items may have to be removed to provide the additional space.  In some room configurations, even if the doors were made wider, further access within the rooms would be limited due to the small size of the guest rooms.  In designing new overnight passenger vessels, owners establish the minimum number of guest rooms needed on the vessel to help ensure profitability for the market the vessel owners plan to reach.  Although passenger vessels over the years have steadily increased in size, not every new vessel can be made larger to allow for bigger guest rooms.  For example, even large overnight vessels are limited in size if the vessel uses the Panama Canal.  Increased size may also impact vessel drafts which may reduce the number of ports the vessel may enter and the river systems on which the vessels may operate. Bridges and power lines can block vessel movements if vessels are too large to pass beneath them.

Recognizing that it may not be possible to require all guest room doors to be 32 inches wide, PVAAC developed (in chapter 7 of its report) an exception which modified the door clearance requirement in some cases where hospitality rooms and guest room connector doors were provided.  The exception required that each accessible hospitality room have the same size and many of the same features found in accessible guest rooms, although sleeping facilities were not required.  In addition, the exception required that the hospitality rooms be only available to passengers with mobility disabilities who are unable to enter inaccessible guest rooms or be made available to those non-disabled passengers unable to invite passengers with mobility disabilities into their inaccessible guest rooms.  The committee recommended that passenger vessel operators provide a means of entry to the accessible hospitality rooms that ensures passengers with mobility disabilities have similar spontaneous social experiences that they would get if the inaccessible guest rooms were accessible.  For practicability reasons, the draft guidelines do not require such hospitality rooms.

Section V224.2 specifies the number of accessible guest rooms and the number equipped with roll-in showers.  The section is consistent with ADAAG, except that in table V224.2, the second column was changed. 

Section V224.4 specifies the number of accessible guest rooms with communication features.  PVAAC had recommended using a table from the ADAAG Review advisory committee report for determining the number of rooms with accessible notification devices which were permitted to be portable.  For visual alarms, PVAAC recommended that all guest rooms be equipped with such alarms where guest rooms are served by audible alarms.  The draft guidelines remain consistent with ADAAG and uses table V224.4 to determine the number of rooms equipped with accessible alarms and notification devices.  The draft does not propose to apply any other accessibility requirement to these communications accessible rooms, except the protruding object requirements (see V204).

Section V224.6 specifies that guest rooms which are required to comply with V806.2 be provided on decks complying with V201.4.  For example, an overnight passenger vessel with two decks but only one entry deck contains 25 passenger guest rooms on each deck.  As this vessel has only one entry deck, exception 1 in V206.2.1 does not require vertical access between the two decks.  To satisfy V224.6, the two guest rooms required by V224.2 must be located on the entry deck.  However, if a complying means of vertical access connected the two decks, these guest rooms would be permitted by V224.6 to be located on any deck.

Chapter 3: Building Blocks

This chapter provides basic technical criteria considered to be the Abuilding blocks@ for accessibility as established by the draft guidelines.  These requirements address deck surfaces (V302), changes in level (V303), turning spaces (V304), clear deck spaces (V305), knee and toe clearances (V306), protruding objects (V307), reach ranges (V308), and operable parts (V309).  They are referenced by the scoping provisions in Chapter 2 and by the requirements in subsequent technical chapters (4 though 10).

V302 Deck Surfaces and V303 Changes in Level

These sections require deck surfaces to be stable, firm, and slip resistant, provide specifications for carpets, surface openings and changes in level in deck surfaces, and are consistent with similar provisions found in ADAAG.  However, an exception in each section is provided to address certain types of vehicle tie-down devices found on some ferries.  These vehicle tie-down devices are attached to flush openings on the deck surface.  The openings would not comply with V302.3 and have depths which are greater than that allowed by the change in level requirements of V303.  These exceptions are permitted only on vehicle deck surfaces which are not part of an accessible route.

V307 Protruding Objects

This section specifies minimum vertical clearances along circulation paths and maximum projections from the side into such paths.  Because sail rigging and other topside features could present a multitude of protruding objects on sailing vessels, PVAAC recommended that V307 not apply to the exterior deck areas of such vessels where the protruding objects did not block the accessible routes. 

The draft guidelines do not include this recommendation because the guidelines only apply to large passenger vessels.  In large passenger sailing vessels, it may be feasible in newly constructed vessels for exterior circulation paths used by passengers to be designed and constructed to meet the requirements of V307.  For existing large sailing vessels, where alterations would require correction of protruding objects on exterior paths, if such corrections were technically infeasible (see V202.3) the corrections would only be required to the maximum extent feasible.

In V307.2, PVAAC had recommended that the vertical range of 27 to 80 inches (within which side protrusions were limited to 4 inches maximum) be reduced to 6 to 80 inches.  For consistency purposes, V307.2 is unchanged from ADAAG.  The protruding objects requirements in this section are based on standard cane techniques used by people with vision impairments.  The techniques allow people to detect low side protrusions.  Two principal detection techniques are used: the touch technique and the diagonal technique.  People are often trained to use both.  The touch technique involves arcing the cane side-to-side to detect points beyond both shoulders and is often used in uncontrolled areas.  The diagonal technique involves holding the cane in a stationary position diagonally across the body with the bottom tip at the ground beyond one shoulder and the grip extending beyond the other shoulder.  This technique is generally used in certain controlled and familiar environments.  The standard sweep of canes allows detection of objects with leading edges up to 27 inches from the deck surface.  Proper cane and service animal techniques allow people to walk along corridors or paths without bumping into walls.  Overhangs that are above cane sweep height (27 inches) may protrude 4 inches maximum without being hazardous.

Section V307.4 specifies a minimum vertical clearance of 80 inches.  Clearances below 80 inches must be provided with guard rails or other barriers to alert persons with vision impairments.  As Subchapter K (46 CFR 116.800(b)) allows a minimum ceiling height of 74 inches, PVAAC was concerned that to increase ceiling heights to 80 inches would require an increase in spacing between decks on some vessels.  This increased deck spacing could impact the stability of some vessels by raising the center of gravity of the vessels.  Therefore, PVAAC recommended that for vessels whose main deck was less than 3,000 square feet, the minimum vertical clearance could be reduced from 80 inches to 78 inches without requiring guard rails or other barriers.

In the draft guidelines, although compliance with the vertical clearance requirements of V307.4 may increase the spacing between some decks, in all sizes of newly constructed large passenger vessels, this increase is reasonable in light of the access needs for persons with vision impairments.  In newly constructed vessels, the stability concerns mentioned above may be addressed in the initial design of the vessels.  For existing large passenger vessels, where alterations would require an increase in the vertical clearances provided along circulations paths, if such increases are technically infeasible (see V202.3), the increase will only be required to the maximum extent feasible.  For example, if an alteration requires an increase in the vertical clearance to 80 inches and it was technically infeasible to provide 80 inches, but 79 inches was feasible, then 79 inches is expected in that alteration. 

Chapter 4: Accessible Routes, Accessible Means of Escape, and Accessible Passenger Boarding Systems

This chapter provides technical criteria for accessible routes (V402) and the various components of such routes, including walking surfaces (V403), doors, doorways and gates (V404), ramps (V405), curb ramps (V406), elevators (V407 and V408), and platform lifts (V409).  In addition, the chapter contains technical criteria for the accessible means of escape and the various components of such escape routes (V410), including areas of temporary refuge (V411).  These two sections do not exist in ADAAG, because ADAAG references sections of the International Building Code (IBC).  The term Ameans of escape@ is used in the draft guidelines instead of the ADAAG term Ameans of egress@ for consistency with terminology used in Coast Guard regulations.  Lastly, the chapter also provides technical criteria for accessible passenger boarding systems and the components of such systems (V412), including gangways (V413).  Many of the components which may be used in an accessible means of escape or an accessible passenger boarding system are the same components used by accessible routes.

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.

V404 Doors, Doorways, and Gates

This section provides technical criteria for both doors, doorways, and gates that are manually operated (V404.2) and those that are automatic (V404.3).  The majority of changes made to the provisions incorporated from ADAAG were made to address door coaming issues.

Under Coast Guard regulations and two international conventions (i.e., Safety of Life at Sea, and Load Lines), certain weathertight 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.  These coamings help protect the operational stability of vessels, for example, by reducing the amount of water that may enter vessels through open exterior doors.  Coamings also improve the survivability of vessels.  When vessels have been damaged due to collision or other hazardous action, the coamings allow a portion of the doorways to be submerged without compromising the reserve buoyancy of the vessels. 

Although required at some doors by regulation and convention, PVAAC recognized the coamings were barriers for persons with disabilities.  They recommended using a Adouble ramp access@ or Asingle ramp access@ method to cross the coamings.  Both methods of access were recommended by PVAAC where coamings were required by an administrative authority or just provided as part of good design practice.  The two methods are used in the draft guidelines (with some changes) and are discussed in section V404.2.5.2 below.

PVAAC recommended that the provisions which implement the double and single ramp access methods be placed in a separate section (V404.4), but in this draft they have been included as exceptions to provisions located throughout V404.2 and V405.  No exceptions are needed in V404.3 (automatic doors) because the affected sections in V404.3 reference modified sections of V404.2 (manual doors).  To address door coamings, the draft guidelines set out three configurations of access. 

First Configuration of Access

The first configuration of access requires compliance with threshold (V404.2.5) and maneuvering clearance requirements (V404.2.4) similar to those found in ADAAG.  PVAAC believed that some doors which were required to have coamings could be designed to meet ADAAG requirements on both sides and still provide a level of vessel protection equivalent to that provided by coamings.  For this reason, PVAAC had recommended (in chapter 1, section 206.5.3, of its report) that where the main deck of a vessel is greater than 3,000 square feet, at least one exterior door on each accessible weather deck have thresholds that are a maximum of 2 inch high and comply with V302 and V303, except where prohibited by the administrative authority having jurisdiction.  This first configuration of access implements the PVAAC recommendation that both sides of the doors be fully accessible. 

Second Configuration of Access

In V404.2.5, three exceptions allow departure from the threshold requirements and represent the second configuration of access.  Exception 1 allows thresholds to be any height if the coamings are readily removable by crew and other passenger use conditions are met.  This exception allows flexibility in those circumstances where the administrative authority (e.g., the U.S. Coast Guard) permits the coamings to be removed when the vessel is in port but requires them to be reinstalled when the vessel is underway.  Also included in the second configuration of access, exceptions 2 and 3 set out conditions which allow use of a single ramp or double ramp method of access at doors required to have coamings.  One condition (exception 2) is based on the largest deck of the vessel being less than 3,000 square feet.  The other (exception 3) is based on a determination by the administrative authority that compliance with V404.2.5.1 is not feasible. This exception parallels the methodology used in V202.5 to address historic preservation issues.  Both exceptions 2 and 3 were influenced by the PVAAC 206.5.3 recommendation discussed above.

Within V404.2.5, two sections are provided.  Section V404.2.5.1 contains the threshold requirements found in ADAAG, and the ADAAG exception which allows existing thresholds to have a slightly higher beveled height.  Section V404.2.5.2 contains the threshold requirements for the double ramp and single ramp access methods.  Provisions in this section may only be used where allowed by exceptions 2 or 3 in V404.2.5.

The double ramp access method involves providing ramps on both sides of doors which connect at the top of the coamings.  As recommended by PVAAC, the provision notes that this method of access may only be used where the door is automatic.  Therefore, compliance with V404.3 (automatic doors) would also be required where double ramp access is used. 

The single ramp access method involves having a ramp on one side of the doors which connects the top of the coamings.  Exception 2 of V405.2 allows the ramp in the single ramp access method to use the running slope provisions in Table V405.2.  Table V405.2 sets the maximum slope at 1:8 for a 3 inch rise which is less than the 1:4 recommended by PVAAC.  Only one side of the coaming equipped doors could have a ramp.  The other side would be required to comply with threshold requirements similar to those found in ADAAG.  Also, PVAAC recommended that when using the single ramp access method, the non-ramp side would have maneuvering clearances consistent with ADAAG, except the maneuvering clearances were not required to be more than 48 inches in length measured perpendicular to the doorway.  The draft guidelines only allow the 48 inch limitation where the largest deck is less than 3,000 square feet (see exception 3 in V404.2.4). 

Other exceptions in the maneuvering clearance provisions of V404.2.4 and V404.2.4.4 and ramp provisions of V405.2 and V405.7 permit modification of some requirements to allow installation of either the double or single ramp access methods.  Figures V404.2.5.2.1 and V404.2.5.2.2 (which are included in the draft guidelines) provide section views of the single and double ramp access methods and contain references to the applicable sections and exceptions.

Figure V404.2.5.2.1 Doors with Double Ramp Access allowed by V404.2.5 exceptions 2 and 3.  The figure shows an elevation view of a door with a high sill, known as a coaming, at the bottom.  Two ramps, one on each side of the coaming, slopes up and join at the top of the coaming -- forming an inverted shallow V.  Three statements are located within the figure which indicates where in the guidelines various provisions and exceptions allow installation of these double ramps.  The first states that no landings are required at the top of the double ramps (V405.7 exception).  The second states that these doors are required to be automatic (V404.2.5.2.1).  The third states that maneuvering clearances are allowed to be slope (V404.2.4.4. exception 1).  An addition statement is provided in the figure to remind readers that the maximum slope for the ramps is 1:12 (V405.2).

Figure V404.2.5.2.2 Doors with Single Ramp Access allowed by V404.2.5 exceptions 2 and 3.”  The figure shows an elevation view of a door with a high sill, known as a coaming, at the bottom.  On one side of the coaming, a ramp slopes up to the top of the coaming.  Three statements are provided which indicate where in the guidelines provisions and exceptions allow installation of this single ramp on one side of the door.  The first states that no landing is required at the top of the ramp (V405.7 exception), and the second states that maneuvering clearance on the ramp side of the coaming is permitted to be sloped (V404.2.4.4 exception 2).  The third states that the slope is permitted to be 1:8 maximum for a 3 inch maximum rise and 1:10 maximum slope for a 6 inch maximum rise (V405.2 exception 2).  On the other side, a 48 inch minimum maneuvering clearance is shown connecting to the top of the coaming.  From that maneuvering clearance, a ramp slopes down away from the maneuvering clearance and door.  Two statements are provided on this side of the door.  The first states that if the largest deck is less than 3,000 square feet, the maneuvering clearance is allowed to be 48 inches minimum (V404.2.4 exception 3).  The second states the maximum slope for the ramp shown on the side of the door with a maneuvering clearance is 1:12 (V405.2).

Third Configuration of Access

An exception in V404.2.5.2 implements the third configuration of access.  The exception allows the thresholds to have a non-beveled height of 1-1/4 inches maximum on one side of the doors where the administrative authority determines that due to space limitations it is not feasible to install the single ramp or double ramp access methods. 

The exception is included to support a Coast Guard provision (see 46 CFR 116.1160(d)(3)) which allows watertight doors with limited thresholds to be used instead of weathertight doors with three to six inch coamings.  To install a watertight door, the threshold would need to be only high enough to provide a watertight seal at the base of the door.  From discussions with marine door manufacturers, a minimum 1-1/4 inch vertical height was identified as necessary.  This height allows the doors to swing over the deck surface and provides a sufficient vertical surface at the base of the doorways to allow the watertight doors to form a watertight seal against the doorways.  This exception only applies to the side of the door threshold which comes in contact with the door seals.  The other side must comply with all door access requirements similar to what is found in the first configuration of access.

Other changes made to provisions in V404 incorporated from ADAAG include:

  • Modifying the exception in 404.1 to address doors only operated by crew;
  • Adding exception 2 to V404.2.4 to not require maneuvering clearances on the outboard side of doors and gates at entry and departure points;
  • Treating watertight doors like fire doors in terms of applying the force opening requirements in V404.2.9;
  • Adding an exception to V404.2.9 which indicates the section does not apply to doors on sailing vessels.

V405 Ramps

This section provides technical criteria for ramps and is consistent with ADAAG.  However, exceptions have been included which address door coamings and implement reduced clearance requirements where the largest deck of a passenger vessel is less than 3,000 square feet in size.

V406 Curb Ramps

This 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.

V407 Elevators

This section provides technical criteria for elevators and is consistent with ADAAG, except for two issues.  ADAAG requires hoistway designations and a symbol on car control buttons to orient users to the main entry floor of a building.  As vessel entry decks may change based on the port in which the vessel is embarking or disembarking passengers, using the ADAAG orientation provisions may lead to confusion if the vessel has more than one main entry deck based on its different ports of call.  In V407.2.3.1 and V407.4.7.1.3, changes have been made to apply the orientation requirements to vessels with only one entry deck. 

The second change concerns section V407.4.10 which does not exist in ADAAG.  The section requires handrails provided in elevators to comply with V503.  The section allows handrails to overlap the clearances required in elevators provided the handrails comply with the protruding object requirements in V307.2.

Although PVAAC provided a number of recommendations regarding elevators, most are not included in these draft guidelines to keep the requirements consistent with ADAAG elevator provisions.  PVAAC recommendations included requiring: visible signals at hall call and car control buttons to consist of white lights to improve visibility for persons with vision impairments; where a hall call or car control button is flush, a tactile distinction be placed on the button to differentiate it from the surrounding surface; no protruding objects located within the space beneath the hall call buttons so service animals could activate the button; audible signal or verbal annunciators readings to be measured at the annunciator instead of the call button; the handset used in emergency communications to be hearing-aid compatible.

PVAAC also recommended two additional sizes for elevator cars besides the four already provided.  A car with a side to side dimension of 65 inches and front to back dimension of 54 inches was recommended.  This car was reportedly used in a number of foreign flagged cruise ships.  The recommendation was not included in the draft guidelines for consistency with ADAAG.  It is noted that for existing elevators, the exception under V407.4.1 would allow the car dimensions recommended above.  Therefore, the draft guidelines would not require such existing elevators to be changed when alterations were performed. 

The second recommendation included an elevator car 54 inches side to side and 65 inches front to back, and was reportedly needed to address casing problems on vehicle ferries.  On a number of vehicle ferries, a narrow central casing is located between vehicle lanes provided on the sides of the ferry.  Within the casing, stairs and narrow elevators connect the decks above.  The casing also contains exhaust ducts and ventilation ducts for engine rooms and other spaces located below the vehicle deck.  If a wider elevator is required, casings must be made wider which in turn may require the entire vessel to be wider because portions of the casing should not project into vehicle lanes.  The recommendation was not included, because one of the other four choices from ADAAG already contained an elevator with the same 54 inch width.  Although, this type of elevator has a front to back dimension of 80 inches, the Board questions if 15 additional inches are that critical in the casing of large vehicle ferries.  Also, in ferries less than 10,000 ITC tons, section V206.6 allows use of LULA elevators which have car dimensions that are less than what is contained in the PVAAC recommendation (see V408.4).

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.  Neither exception has been included in the draft guidelines because V206.7 allows platform lifts to be used in new construction to access decks less than 3,000 square feet.  As platform lifts may be 36 inches wide, no additional exception is needed in V408 to allow narrower LULA elevators for passenger vessels of less than 1,000 ITC tons.

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.  Secondly, section V409.6 is included and requires that where handrails are provided on platform lifts, the handrails conform to V503.  The section allows handrails complying with V307.2 to overlap clearances for platform lifts where handrail supports do not project into the clear deck space required by V409.3.

V410 Means of Escape

This section provides technical criteria for each accessible means of escape required by V207. Section V410 does not exist in ADAAG because the International Building Code (IBC) is referenced for the technical requirements for means of egress.  As the IBC is not appropriate for application on passenger vessels, section V410 was created based on the IBC provisions and PVAAC recommendations.

Common changes made to the IBC provisions that appear throughout V410 include changing the term Aarea of refuge@ to Aarea of temporary refuge@.  In Coast Guard regulations and guidance (46 CFR 114.400 and Navigation and Vessel Inspection Circular 8-93), areas of refuge (or qualified refuge areas) tend to be large fire protected spaces which may hold hundreds of passengers (similar to a horizontal exit in the building environment).  Areas of refuge are often located in the vicinity of an evacuation station, and in some cases, they may be located within an evacuation station.  In the International Convention for the Safety of Life at Sea (SOLAS), Aareas of refuge@ are known as muster stations and assembly stations.  However, in the IBC, the term Aarea of refuge@ refers to spaces which are generally of a size that can hold a few occupants who are waiting for assistance.  As recommended by PVAAC, the above smaller spaces are referred to in these draft guidelines as Aareas of temporary refuge@ to avoid confusion with the Coast Guard=s Aareas of refuge@.

In addition, the draft guidelines replace the IBC term Ahorizontal exit@ with Aarea of refuge@.  As mentioned above, the Coast Guard Aareas of refuge@ are similar to horizontal exits in the building environment.  In the various sections of V410, exceptions often allow departures from the requirements where areas of refuge are used and they comply with Coast Guard safety requirements.  Also, the draft replaces the IBC term Astandby power@ with Aemergency power@ which is a more recognized marine industry term.  Lastly, where the IBC provisions for automatic sprinkler systems are called out, the draft guidelines reference automatic sprinkler requirements contained in National Fire Protection Association (NFPA) 13 or SOLAS II-2.  Both documents are approved for use by the Coast Guard. 

Section V410.1 lists the various components which may be used to provide an accessible means of escape.  Many of the components are identical to the components used in accessible routes.  The components are walking surfaces (V403), doors, doorways and gates (V404), ramps (V405), and curb ramps (V406), but also include exit stairways (V410.2), elevators (V410.3), and platform lifts (V410.4).  Section V410.1 uses V206.6 to determine whether elevators or LULA elevators may be used as a component, and V206.7 to determine whether platform lifts are allowed to be used as a component. 

In addition, V410.1 requires that each accessible means of escape comply with the administrative authority requirements applicable to the corresponding required means of escape from that space. As discussed in V207, the administrative authority requires most passenger spaces of a passenger vessel to have at least one means of escape from the spaces.  Section V207 requires an accessible means of escape for each means of escape required by the administrative authority.  Although the accessible means of escape required by these draft guidelines is not required to follow the same path as the required means of escape, section V410.1 requires the accessible means of escape to comply with the same safety requirements (e.g., fire and smoke protection) established by the administrative authority applicable to the required means of escape.

For example, a passenger cabin in a U.S. flagged passenger vessel is located on the second deck of a vessel.  From this cabin, the Coast Guard (the administrative authority) requires two means of escape to the first deck where the evacuation stations are located.  The Coast Guard requires at least one path to be a protected stairway, but allows the other to be an open stair.  If this cabin is an accessible cabin, to satisfy V207.1 and V207.2, at least two accessible means of escape must be provided to the first deck.  Because the Coast Guard requires one means of escape to be an enclosed stair, V410.1 then requires that at least one accessible means of escape to be an enclosed stair (if an exit stair is used as a component in the accessible means of escape).  The other accessible means of escape is not required to be an enclosed stair.  Likewise, if the Coast Guard required one of the means of escape to be independent of watertight doors, one of the accessible means of escape must be independent of watertight doors.

Section V410.2 contains the technical requirements for exit stairways which may be used as a component in an accessible means of escape, and is generally consistent with IBC 1003.2.13.2, except for the common changes discussed above and exception 5 in V410.2.  Also, because the Coast Guard does not require every exit stair to be enclosed, the provision in IBC 1003.2.13.1 that requires only stairways within exit enclosures to be used in an accessible means of escape was not included. 

Exception 5 does not exist in the IBC and comes from a PVAAC recommendation.  Due to possible space limitations on Subchapter K vessels, the requirement for 48 inches between handrails on exit stairs would be a problem.  PVAAC allowed Subchapter K vessels to have 36 inches between handrails.  As some Subchapter K vessels can carry over 1,000 passengers, applying the PVAAC exception to all Subchapter K vessels places persons with disabilities at undue risk.  Where Subchapter K vessels can carry more than 600 passengers or more than 49 overnight passengers, the Coast Guard requires (see 46 CFR 116.438(a)) such vessels to meet certain improved safety requirements applicable to Subchapter H vessels.  Taking guidance from the Coast Guard provision, the PVAAC exception was modified to allow vessels with 600 or fewer passengers or 49 or fewer overnight passengers to have exit stairs which are 36 inches wide between handrails.

Section V410.3, in addition to V407 or V408, contains the technical requirements applicable to where an elevator is used as a component in an accessible means of escape.  Where V207.3 applies, at least one elevator complying with V410.3 would be required.

Section V410.4 contains the technical requirements applicable to when platform lifts are used as a component in an accessible means of escape.  The section requires compliance with V409 and that the platform lift shall be provided with emergency power. 

PVAAC and the IBC also address posting instructions and identification signage for areas of temporary refuge.  These requirements are included in V216.4.

V412 Passenger Boarding Systems

This section provides a list of various components which may be used as part of an accessible passenger boarding system where such a system is required by V208.  Many of the components are identical to the components used in accessible routes.  The components are walking surfaces (V403), doors, doorways and gates (V404), ramps (V405), curb ramps (V406), elevators (V407 or V408), platform lifts (V409), and gangways (V413).

V413 Gangways

This section provides technical criteria for gangways.  Gangways are defined in V106.5 as a variable-sloped pedestrian walkway that connects a passenger vessel to a floating pier or to a fixed pier or land where no floating pier is used.  The provisions of this section came from the ramp provisions in V405 but were modified as follows:

  • The exceptions in V405 applicable to the single or double ramp access methods for doors with coamings were not included;
  • The maximum rise requirement in V405.6 and the landing length exception in V405.7.3 were not included;
  • Exceptions 2 through 5 are included in V413.2 to address alterations to existing gangways and running slope requirements;
  • A transition plate requirement is included in V405.6, and exceptions regarding transition plates and handrails are included in V413.7 and V413.8.

Section V413.6 requires gangway transition plates to have a visual contrast with adjacent passenger walkways to alert persons with visual impairments of transitions.  The Board is considering whether such transition plates should also have surfaces which differ from adjoining walkway surfaces in resiliency or sound-on-cane contact.  The Board seeks comment on this issue and what test methods are available to measure resiliency or sound-on-cane contact that provide sufficient notification to persons who are blind about the presence of transition plates. 

Chapter 5: General Passenger Vessel Elements

This chapter provides technical criteria for stairways (V502), and handrails (V503).  An exception is included in V503.4 which addresses conditions where the administrative authority may require guardrails (which are also intended to function as handrails) to be mounted above 38 inches.

Chapter 6: Plumbing Elements and Facilities

This chapter provides technical criteria for plumbing elements and facilities, including drinking fountains (V602), toilet and bathing rooms (V603), water closets and toilet compartments (V604), urinals (V605), lavatories and sinks (V606), bathtubs (V607), shower compartments and rinsing showers (V608), grab bars (V609), tub and shower seats (V610), and laundry equipment (V611).  Provisions for rinsing showers are included in V608.

Chapter 7: Communication Elements

This chapter provides technical criteria for communication elements, including emergency alarm systems (V702), signs (V703), telephones (V704), two-way communication systems (V705), assistive listening systems (V706), and automatic teller machines (V707).

V702 Emergency Alarm Systems

This section provides technical criteria for audible and visual alarms used in emergency alarm systems, and refers to NFPA 72, Chapter 4, for most of its requirements.  PVAAC noted a conflict between sound level requirements in the recommendations and alarm signal requirements in Coast Guard regulations.  After review with the Coast Guard, no conflict was identified.  Section V702 remains consistent with ADAAG.

Chapter 8: Special Rooms, Spaces, and Elements

This chapter provides technical criteria for various types of elements, rooms and spaces, including assembly seating (V802), dressing, fitting, and locker rooms (V803), kitchens and kitchenettes (V804), medical care patient sleeping rooms (V805), passenger guest rooms (V806), detention cells (V807), and storage (V808).

V806 Passenger Guest Rooms

This section provides technical criteria for passenger guest rooms and is consistent with ADAAG except for one change.  Section V806.2.7 requires that doors to adjacent guest rooms comply with V404.  For example, a guest room equipped with mobility features is provided as required by V224.2.  In this room, a door is provided which directly connects the guest room with an adjacent guest room which is not accessible.  Under V806.2.7, the connector door must comply with V404 on both sides.  The section does not require that connector doors be provided, but only applies where such doors are provided in rooms required to be equipped with mobility features.

Chapter 9: Built-In Elements

This chapter provides technical criteria for built-in elements, including dining surfaces and work surfaces (V902), changing benches (V903), and sales and service counters (V904).

Chapter 10: Recreation Facilities and Play Areas

This chapter provides technical criteria for various types of recreation facilities and play areas, including exercise machines (V1002), miniature golf facilities (V1003), play areas (V1004), swimming pools, wading pools, and spas (V1005), and shooting positions (V1006).  Two exceptions are included in the transfer system provisions which may be used when accessing wading pools.