Discussion of Provisions: Second Draft

The following discussion does not address every provision in this draft but addresses those provisions which differ substantially from the provisions in the 2004 draft, received significant public comment but were not changed, or are still under review.

Chapter 1: Application and Administration

This draft modifies chapter 1 in the following areas:

  • The title of section V104 was changed from “Conventions” to “Standard Practices” to avoid confusion over international conventions which apply to some passenger vessels.
  • The reference to the International Convention for the Safety of Life at Sea (SOLAS) was removed from V105.2 because SOLAS is not a standard but an international convention (and the SOLAS references in V207 and V410 were moved to advisory notes).
  • The reference to the National Fire Protection Association’s National Fire Alarm Code (NFPA 72) was removed from V105.2 because compliance with that document is no longer required.
  • Section V106.3 was changed in that it requires US Coast Guard regulations to be used to define terms not defined in this draft or defined in regulations issued by DOT and the Department of Justice (DOJ).
  • Section V106.5 was modified by removing the definition for accessible means of escape and passenger areas, adding definitions for ferries and tenders, and amending the definitions for evacuation station, gangway, and occupancy load. The definition for ferries came from US Coast Guard regulations found in 46 CFR 114.400. The definition for tender includes vessels that are used for both emergency and non-emergency purposes to transport passengers between passenger vessels and shore side facilities.

Chapter 2: Scoping Requirements

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

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

Although the charging statement at the beginning of V201.1 applies the draft to all areas of a passenger vessel, various provisions in the draft limit the application. For example, section V203.2 exempts areas used exclusively by employees. Therefore, only passenger areas are subject to this draft. Within passenger areas, for example, V224 only requires a certain number of passenger guest rooms to comply with this draft.

Comment on the 2004 draft and the ANPRM on smaller vessels generally supported either not addressing small vessels at all or first addressing large vessels and then addressing smaller vessels. Although many tenders and ferries carry 150 or fewer passengers, because of the critical transportation function they perform, these types of vessels are being addressed in this draft. Water taxis are not included unless they are classified as ferries by the Coast Guard. For water taxis and other small passenger vessels, the Board plans to develop guidelines to address these vessels after this rulemaking is complete.

V201.4 Passenger Amenities. This section is unchanged in this draft. However, the Board is still evaluating the section’s impact on vessels not required to have vertical access between decks by an exception in V206.2.1. An advisory note has been included with this section.

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

A commenter noted that vessel designers or builders may choose for good reasons to exceed the regulatory minimums regarding structural integrity or fire resistance of a Class A or B bulkhead or deck surface. Therefore, in the commenter’s opinion, in the alteration of existing vessels, the 2004 draft should not reduce safety to the regulatory minimums and should contain the exception developed by the advisory committee. Exception 3(c) was modified to parallel the advisory committee recommendation.

Other key alteration concerns raised by commenters are discussed below.

  • Concern that the alteration provisions require immediate changes in existing passenger vessels.

Under these draft guidelines, accessibility improvements are only required when alterations are performed in existing vessels. The Board does not have jurisdiction over requirements for existing facilities that are otherwise not being altered, except for certain types of transit stations (key stations and intercity rail stations). Under the ADA, regulations issued by DOJ and DOT effectively govern requirements that apply to existing facilities. How, and to what extent, the Board’s guidelines are used for purposes of retrofit, including removal of barriers and provision of program access, is wholly within the purview of these departments.

Many exceptions in this draft which relate to the alteration of existing vessels have been rewritten to clarify their application. For example, in the 2004 draft, the exception in V407.2.1 stated that “existing elevators shall be permitted to have recessed call button”. In this draft, the exception states that “in alterations, existing elevators shall be permitted to have recessed call buttons”.

  • Concern about what actions constitute an alteration and what degree of access improvement is required.

Minor alterations do not trigger extensive retrofitting of existing vessels. To help the passenger vessel industry understand the alteration requirements of this draft, the Board plans to develop a question and answer format on alterations when it issues the NPRM.

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

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

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

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

V203 General Exceptions. This draft adds general exception V203.2 and states that areas of passenger vessels which are exclusively used by employees are not required to comply with this draft. An advisory note is also included which provides further clarification on what is a space exclusively used by employees. Also, for consistency with V203.2, throughout this draft the term “employees” replaces the terms “crew” and “service personnel” where used in the 2004 draft.

Commenters on this employee area issue generally stated a desire that the Board exempt employee areas or use the employee area provisions from chapter 10 of the advisory committee report. To simplify the rule and lessen its impact on small businesses and small governmental entities, the draft applies the access provisions to passenger areas where most users focused their comments. Although this draft exempts areas exclusively used by employees, for those employers subject to title I of the ADA, employers must still provide reasonable accommodations for employees with disabilities working in such spaces.

In addition, this draft removes the general exceptions for refereeing, judging, and scoring areas, and raised boxing or wrestling rings because such features are not generally provided on passenger vessels or are not for passenger use.

V205 Operable Parts. This section is unchanged in this draft. However, the Board is evaluating the application of this section to situations where a large number of operable parts of the same type are provided in accessible spaces.

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

V206.2.1 Multi-Deck Passenger Vessels (Accessible Routes, Where Required). The content of this section has not changed in this draft, but exception 1 in the 2004 draft was divided into two exceptions for clarity reasons. Exception 1 now addresses passenger vessels which have two passenger decks, and exception 2 addresses passenger vessels where each deck is less than 3,000 square feet. The remaining four exceptions from the 2004 draft have been retained but are renumbered. An advisory note has been added and highlights that the term deck is defined in V106.5 and clarifies how the vertical access exceptions apply to mezzanine access.

One commenter expressed concern that under exception 5, passenger spaces below the bulkhead deck would not be required to be connected to a means of vertical access. The Board has not changed this exception because, if a unique passenger element, space or facility is located below the bulkhead deck, section V201.4 would require that a similar feature be placed on an entry deck or vertical access must be provided down to the feature. As V201.4 is still under evaluation, if changes are made, the Board will reevaluate exception 5.

V206.2.2 Spaces and Elements (Accessible Routes, Where Required). This section is unchanged in this draft. However, the Board is still evaluating the application of onboard accessible routes which must connect accessible features located on vehicle decks of small ferries.

The section addresses onboard accessible routes which connect elements and spaces located within a deck. A deck could contain one or more levels. Under this draft, each level would not be a separate deck, but a change in level within a deck. For example, a tender loading platform is a change in level within a deck. In general, as all passenger areas have to comply with this draft, each change in level is required to be connected by an onboard accessible route. In addition, where an elevator or other means of vertical access is not required by V206.2.1 from an entry deck to another deck, section V206.2.2 still requires that an onboard accessible route connect elements and spaces on that deck which are required to comply with this draft. An advisory note is included which highlights these points.

V206.3 Location. This draft simplifies the 300 foot requirement in V206.3. The section requires that an onboard accessible route connecting any two accessible spaces shall not be more than 300 feet longer than the shortest general circulation path connecting the same two spaces, instead of connecting any two points within the two spaces. A space is not only a room but other definable areas such as clear deck spaces and wheelchair spaces.

V206.4 Entry and Departure Points. This draft adds an exception to V206.4 which only requires one tender boarding platform on the port and starboard side of passenger vessels to be on an accessible route. The exception would not apply to tender boarding platforms provided at the sterns of such vessels. Therefore, if a vessel had two boarding platforms on the starboard side, two on the port side, and one on the stern, one platform on each side and the one on the stern must be connected to an onboard accessible route.

This section does not address embarking or disembarking to piers or other landside structures. It only addresses onboard circulation to these points where someone may enter or depart a vessel depending on which entry or departure point a vessel chooses to use in a particular situation. Section V208 addresses getting on and off a vessel.

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

V206.7 Platform Lifts. This draft adds a condition which allows platform lifts to be used in new construction to access tender boarding platforms. An exception is also included in the section which allows manually powered boarding lifts complying with V414 to be used instead of platform lifts complying with V409. This exception is allowed where platform lifts accessing tender boarding platforms are exposed to waves and the tender boarding platform is less than 300 square feet.

Comments on platform lifts focused primarily on operational matters and included questions regarding employee assistance in using a platform lift and when platform lifts could be locked or the power turned off. The draft requires a platform lift to be capable of independent entry, operation, and exit. This means that passengers must not have to wait for employees to arrive and unlock the lift or activate its power. However, where a platform lift is used to access a space which is not always open to passengers, such as a performing area, it would be acceptable to turn off the power or lock the platform lift when the space in question was not open to passengers. Lifts must not be installed which require employee assistance to use. However, operators are permitted to have employees available to assist all users of a platform lift (when assistance is requested).

V207 Accessible Means of Escape. This draft modifies V207 in the following areas:

  • The definition for accessible means of escape (AMOE) was removed from V106.5 and incorporated into V207.1.
  • Where more than one means of escape is required by the administrative authority from a space required to comply with this document, section V207.2 was changed to require the space to be served by at least two AMOE, instead of each accessible portion of the space to be served by at least two AMOE. This change was to make the provision consistent where only one AMOE is required.
  • The reference in V207.3 which allows sprinkler systems complying with SOLAS to be used in exceptions 1 and 2 was moved to an advisory note.
  • Advisory notes were added to V207.2 and V207.3.

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

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

Commenters objected to requiring a conforming connection regardless of what pier a new vessel may use, imposing this requirement on both the vessel owners and pier owners, or requiring a conforming connection to vessels subject to this draft when new piers are built or existing piers are altered. Other commenters pointed out difficulties in connecting undeveloped land, or specific problems where steep gangways exist or very long gangways are required.

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

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

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

V213.2 Toilet Rooms and Bathing Rooms. This draft clarifies exception 1, in response to a commenter concern that the exception in the 2004 draft was possibly introducing a new standard for technical infeasibility. Exception 1 now states that “in alterations, where it is technically infeasible to comply with V603, the existing toilet rooms or bathing rooms shall comply to the maximum extent feasible in accordance with V202.3 exception 2, or provide a single unisex toilet room or bathing room complying with V213.2.1 that is located in the same area and on the same deck as existing inaccessible toilet or bathing rooms”.

V213.2.1 Unisex (Single-Use or Family) Toilet and Unisex Bathing Rooms. In response to a commenter concern, this draft clarifies how many water closets and urinals are required in unisex toilet and bathing rooms required by V213.2 to be accessible.

V215 Emergency Alarms. This draft modifies V215 by requiring emergency alarm systems which are provided to alert passengers to comply with principles of best practice. This is similar to a provision in ADAAG for medical care facilities which permits fire alarm systems in medical care facilities to be provided in accordance with industry practice. The 2004 draft required emergency alarm systems (both audible and visible) to be permanently installed and to comply with NFPA 72.

Commenters primarily focused on the desire to allow portable systems with enhanced capabilities as an alternative to requiring permanently installed visible alarms in public areas and in guest rooms required by V224.4 to have communication features. Aside from problems in interfacing visible alarm systems with public address systems over which audible alarms operate, these commenters noted benefits in using portable systems. Portable systems would allow technological advances to be more rapidly adopted which could provide better information during emergencies than permanently installed visible alarms. Portable systems would also allow more guest rooms to be covered than the two percent proposed in the 2004 draft. The same portable systems could also be used to communicate more effectively other information about shipboard activities to people who are deaf or hard of hearing.

The Board is also aware of how employees on passenger vessels play an important role in providing directions and addressing passenger needs during emergencies. This heightened role is more analogous to how hospitals notify its patients and is completely different from most other facilities on land.

As technology in this area is rapidly changing, this draft proposes that alarm systems comply with principles of best practice to alert passengers. Alarm systems which are in accordance with principles of best practice may contain capabilities which are more than just flashing lights and better meet the emergency needs of persons who are deaf or hard of hearing.

V219 Assistive Listening Systems. This section is unchanged in this draft. Some commenters may have been confused between the requirements of this section and the requirements for audible and visible alarms in V215. Section V219 requires, in certain assembly areas and public seating areas, that permanently installed assistive listening systems be provided. Where audio amplification is provided and is integral to the use of the space, such as in movie theaters, assistive listening systems will transmit the audio signal to a headset or other receiver to assist people who are hard of hearing in understanding the audio signal received by others through typical room sound systems. The permanent installation applies to the transmitters not the receivers.

Where a portable sound system is provided, section V219 does not apply. However, it may still be useful in helping entities meet their ADA obligations to provide auxiliary aids and services. Two advisory notes have been added to the technical provisions in V706 and provide more detail on the types of transmitters and receivers.

V221 Assembly Areas and Public Seating Areas. This section is unchanged in this draft. However, the Board is still evaluating the dispersion requirement in V221.2.3 and its application to large assembly spaces. Some commenters noted that unlike many large assembly spaces on land, passenger vessels have size constraints and meeting the dispersal requirements could cause an unacceptable loss in seating.

Question 5: Public seating areas contain fixed seats which are not at fixed tables and are areas not classified as assembly areas (see assembly area definition in V106.5). Such seats would typically be found on passenger vessels, such as ferries, which primarily provide a transportation service similar to a city bus or commuter rail vehicle. In the Board’s guidelines for transportation vehicles which apply to buses, vans, light rail, commuter rail and rapid rail, no companion seats are required and the number of wheelchair spaces is generally set at two. The Board seeks information regarding the impact in using table V221.2.1.1 to determine the number of wheelchair spaces required in public seating areas of ferries (particularly small ferries). In addition, regarding public seating areas, the Board seeks information regarding the impact of providing each wheelchair space with an adjacent companion seat that is positioned for shoulder to shoulder alignment, while ensuring the wheelchair spaces are an integral part of the seating plan and dispersed throughout the public seating areas of the vessel.

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

Commenters generally took opposite positions on the scoping for accessible guest rooms. Industry groups indicated the scoping was beyond the need experienced and should be reduced. Disability organizations and individuals described their experiences and indicated that there is an insufficient number of accessible guest rooms available. Commenters also said that a guest room equipped with mobility features is generally one and a half times the size of a standard guest room. Therefore, increasing the number of such accessible guest rooms will lead to a reduction in the total number of guest rooms available and related unacceptable revenue loss. Some commenters noted the need for wider doors at all guest rooms, not just accessible guest rooms.

V230 Detention Facilities. This draft removes the provisions concerning detention facilities which appeared in section V230 of the 2004 draft because such spaces are seldom provided in passenger vessels. With this change, the remaining sections of chapter 2 were renumbered and other references to detention facilities were removed from this draft.

V234.2 Swimming Pools. This draft simplifies the swimming pool access provisions in the following ways and reduces the number of exceptions from four to two:

  • As no swimming pool on a passenger vessel has been identified with 300 or more linear feet of pool wall, this draft simplifies the text and requires at least one accessible means of entry into each swimming pool, and the means will be either a pool lift or sloped entry.
  • An exception was removed which addressed situations where user access to a pool is limited to one area, because the exception is not applicable to swimming pools provided on passenger vessels.
  • An exception regarding clustered swimming pools was modified to include a “one of each type” condition. Therefore, where swimming pools are clustered, at least one of each type of pool needs to have a means of entry which is either a pool lift or sloped entry.

Comments from industry groups recommended allowing transfer systems to access swimming pools instead of pool lifts. As pool lifts provide access for a broader range of the population, as compared to transfer systems, the Board has not modified the requirement. Although the 2004 draft allowed sloped entries to be used instead of pool lifts, industry groups have indicated that due to space limitations on cruise ships, sloped entries would not be provided. This draft has retained the sloped entry option as newer vessel designs may allow their installation.

Concern was also raised about the arms of pool lifts (while subject to vessel motions) extending out over wide (shallow water) beach areas of the pool to reach deeper water. As observed in some existing vessels, this may be resolved by locating the deeper water near the forward or after ends of new pools. Pool wave action may also be less at the ends and may allow designs with no beach, as compared to the sides of the pools where wider beach areas may be needed.

A commenter also raised concern that different types of pools would not be required to have a pool lift or sloped entry. In this draft, exception 2 was modified to include a “one of each type” condition which did not exist in the 2004 draft.

Chapter 3: Building Blocks

V302.3 Openings (Deck Surfaces). This draft adds an exception that allows larger openings needed for deck drainage where the administrative authority determines that they are necessary. Openings not located within an accessible route shall be permitted to be increased, provided the size does not allow passage of a sphere more than ¾ inch in diameter.

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

V305.7 Maneuvering Clearance (Clear Deck Spaces). This draft removes the term “alcoves” from this section. In addition, it adds an exception concerning manually powered boarding lifts (see V414 discussion).

V309.4 Operation (Operable Parts). This draft adds an exception that allows the administrative authority to establish a maximum force for hardware on fire doors, watertight doors, or other doors where forces greater than 5 pounds are necessary.

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

V403.6 Handrails (Walking Surfaces). This draft adds an exception which does not require rails (like guard rails) provided along walking surfaces for edge protection to comply with V403.6. An advisory note points out that rails installed for edge protection on passenger vessels may provide gripping surfaces but are not considered handrails.

V404.2.5 Thresholds (Manual Doors, Doorways, and Manual Gates). This draft adds exception 4 which allows weathertight doors to have non-beveled thresholds no higher than ¾ inch on the sealing side of the doors, where required by the administrative authority to meet weathertight door sealing requirements. To use the exception, the thresholds are required to contrast visually with adjacent deck surfaces either light-on-dark or dark-on-light.

The exception was added to address concerns from commenters that manually operated weathertight doors cannot properly seal against a sloped surface (whether a ramped surface or a beveled surface at 1:2) and a vertical sealing surface of ¾ inch is needed. As weathertight doors are often required where coamings are present, under this exception, this sealing surface would be allowed at the top of the ramps used at coaming equipped doors with double and single ramp access.

Although exception 4 has been included in this draft, the Board is evaluating, with the help of the Coast Guard, the scope of this exception, the degree weathertight doors may leak and not compromise vessel safety, and the second and third configuration of access set out in this draft. An advisory note has been included to explain the three configurations of access and how exception 4 applies in the first and second configuration (see also figures in V404.2.5 and V404.2.5.2). The Board is exploring whether certain manually operated weathertight hinged doors could be sliding doors and whether such weathertight sliding doors need a ¾ inch sealing threshold.

V404.2.9 Door and Gate Opening Force (Manual Doors, Doorways, and Manual Gates). This draft clarifies this section by removing the text regarding retractable latch bolts. This draft also adds exception 2 which includes the provision regarding fire doors and watertight doors from the 2004 draft and allows the administrative authority to make similar force opening determinations for other doors on passenger vessels. This allows higher force opening requirements to be established by the administrative authority to address unique vessel situations, such as closing doors or keeping doors shut due to the motion of a vessel.

V404.3 Automatic and Power-Assisted Doors and Gates. This draft clarifies how door clear openings apply to door leaves where breakout openings are required. In addition, it applies the break out requirements to doors which are part of an accessible means of escape, instead of doors which are part of a means of escape as in the 2004 draft. An advisory note is included which explains the purpose of breakout openings.

V405.2 Slope (Ramps). This draft adds exception 3 (see V414 discussion). Some commenters wanted the Board to use the ramp slopes in the advisory committee report which recommended steeper slopes for shorter ramps. The Board has not made that change.

V405.7.3 Length (Ramp Landings). This draft adds exception 2 (see V414 discussion).

V407 Elevators. This section is unchanged in this draft. However, the Board is still evaluating the elevator car size requirements. Comment was received requesting that the Board include all six car sizes provided in the advisory committee report. Four of the six were included in the 2004 draft and are in this draft.

V409.1 General (Platform Lifts). This draft adds a requirement that the design load of the platform lifts shall be at least 600 pounds. An advisory note is also included which recommends that the provisions in ASME A18.1, Safety Standard for Platform Lifts and Stairway Chairlifts, be used where applicable in the marine environment. ASME A18.1 is not directly referenced because A18.1 does not contain specific provisions for shipboard platform lifts.

V410 Accessible Means of Escape. This draft reformatted the provisions in V410.1 (General) and V410.2 (Exit Stairways) and is unchanged from the 2004 draft, except in the following four areas:

  • An advisory note was added to V410.1.1 to address requirements applied by the administrative authority to the accessible means of escape (AMOE).
  • An option to use a manually powered boarding lift was added to V410.1.2, as an AMOE may be routed to a tender boarding platform. The boarding lift may only be used where permitted by V206.7.
  • The same SOLAS clarifications made in V207 were made in V410.2 Exception 2 and V410.3 Exception 2.
  • The term “open” was clarified to apply to “stairways open to the weather” in V410.2 Exception 3 and “are accessed from areas open to the weather” in V410.2.2 Exception and V410.3 Exception 1. Covered areas can be considered open to the weather. An advisory note was added to V410.2.2 to explain the difference between areas of refuge and areas of temporary refuge.

V412.2 Components (Passenger Boarding Systems). This draft adds a manually powered boarding lift to the list of components which may be used to provide an accessible passenger boarding system required by V208.

V413.2 Slope (Gangways). This draft modifies exception one and allows gangways having only one run and rises which do not exceed 6 inches to use the running slope values in Table V413.2. The Table allows a maximum 1:8 slope where the maximum rise of a gangway is 3 inches. Exceptions 2 through 5 are unchanged from the 2004 draft. The above modification was made to address situations where short gangways are used to bridge the gap between a pier and vessel.

V413.4 Surfaces (Gangways). This section is unchanged in this draft. However, the Board is evaluating whether cleats should be allowed on gangway surfaces.

Question 7: The Board has noticed surfaces of gangways with raised narrow slats which are positioned perpendicular to the direction of travel. These slats have been referred to as cleats. Under V413.4, cleats would be prohibited on gangway surfaces. Are these cleats necessary to address slippery conditions? Are other methods available to address slippery conditions which do not require cleats or other raised surfaces on the gangways? What are the implications if the Board allowed cleats complying with V303.2 or V303.3?

V414 Manually Powered Boarding Lifts. This draft adds provisions for manually powered boarding lifts. The technical provisions are based on the manual boarding lift provisions developed for intercity rail cars and systems (36 CFR 1992.125), but V414 requires a larger platform, primarily when approached from the side. To maintain consistency with the intercity rail provisions, the following exceptions were added to sections in V305 and V405:

  • The exception to V305.7 allows platforms of boarding lifts to have a minimum width of 56 inches where the clear deck space (the platform) is approached at the long side.
  • Exception 3 to V405.2 allows ramps directly connected to boarding lifts to have a maximum slope of 1:8 provided the rise of the ramps does not exceed 3 inches.
  • Exception 2 to V405.7.3 allows the end of ramps directly connected to platforms of boarding lifts to have landings 48 inches long minimum. This allows boarding lifts to have 48 inch long or wide platforms depending on which side of the platform is connected to a ramp.

In this draft, the manually powered boarding lift is allowed to be used as a component in an accessible passenger boarding system. It is also allowed in accessing a tender boarding platform when platform lifts would be exposed to waves and the tender boarding platform is less than 300 square feet.

Chapter 6: Plumbing Elements and Facilities

V604.6 and V604.9.5 Flush Controls (Water Closets and Toilet Compartments). This draft modifies two sections to address vacuum flush systems.

V608 Shower Compartments and Rinsing Showers. This draft clarifies how V608.5 through V608.8 apply to rinsing showers.

Chapter 7: Communication Elements and Features

V702 Reserved. In the 2004 draft, section V702 referenced NFPA 72 which contains technical specifications for visible and audible emergency alarms. As V215 in this draft requires compliance with principles of best practice, section V702 has been labeled as reserved.

Chapter 10: Recreation Facilities and Play Areas

V1005.2 Pool Lifts. This draft removes the requirement that pool lifts be located where the water level does not exceed 48 inches. This change was made because most shipboard swimming pools do not have levels deep enough to submerge a pool lift yet shallow enough to meet the 48 inch requirement. An advisory note is included which recommends that portions of pools, where pool lifts are located, have water depths that do not exceed 48 inches. This will allow the opportunity for someone to provide assistance from a standing position in the water to assist pool lift users.

Chapter 11: Tenders

This draft adds chapter 11 which contains technical provisions applicable to tenders which principally transport passengers between large vessels and landside facilities, and carry 60 or more passengers. The chapter requires:

  • at least two wheelchair spaces;
  • minimum dimensions for such spaces;
  • securement systems at each space;
  • an accessible route connecting each space with the passenger entry and departure points of the tender; and
  • a method complying with criteria established by the Department of Transportation to facilitate the embarkation and disembarkation of passengers with disabilities.