Guiding Principles, Approved 11-28-2007

The Passenger Vessel Emergency Alarms Advisory Committee will use the following principles to guide its efforts to reach consensus regarding recommendations for addressing the following issues:

  • Whether current emergency alarm system designs and practices on passenger vessels meet the access needs of individuals with hearing loss or deafness.
  • Alternative designs or technologies for emergency alarm systems that meet the access needs of individuals with hearing loss or deafness.
  • Contents of proposed accessibility guidelines for passenger vessels related to emergency alarm systems.

Specifically, recommendations made by the Advisory Committee should reflect the guiding principles set out below.

Recognize safety as fundamental responsibility of the crew.

  • Recognize and reflect the overarching, fundamental, and primary responsibility of the vessel’s crew to ensure the safety and security of all passengers and crew in an emergency.
  • Recognize the responsibility of passenger vessels to issue and implement safety protocols, procedures, and practices that comply with international (e.g., SOLAS and STCW) and domestic (Coast Guard) rules.
  • Recognize emergencies may entail evacuations (e.g., fire) as well as lock-downs/staying in place (e.g., hostages).
  • Not propose recommendations that have the effect of forcing passenger vessels to make fundamental changes to standard operating safety policies/practices/protocols or result in placing an undue administrative burden on the crew in the context of responding to an emergency.

Recognize the responsibility to provide effective communication.

  • Ensure that emergency-related communication on passenger vessels to persons who are deaf and hard of hearing is as effective as that provided to other passengers.
  • Effective communication to passengers who are deaf and hard of hearing includes, but is not limited to:
    • The delivery and receipt of the same information provided to others, and;
    • The provision of the information directly to the individual in a timely, accurate, and understandable manner that facilitates an informed, appropriate response to the emergency situation.

Differentiate between overnight and non-overnight passenger vessels.

  • Recognize that cruise ships (overnight vessels) and other passenger vessels (e.g., ferries, dinner boats, charter fishing boats) adopt and implement different safety policies, practices and procedures regarding:For example, there may be no education about emergency procedures on short excursion passenger vessels. In contrast, cruise ships have education sessions at the beginning of the cruise, sound alarms, and provide detailed instructions once passengers get to muster stations. Further, there may be no opportunity on short excursions for persons who are deaf or hard of hearing to self-identify.
    • Educating passengers about what to do in case of an emergency;
    • Getting passengers’ attention that an emergency exists (alarms, public address announcements), and;
    • Communicating detailed instructions on how to respond after getting their attention.
  • Provide for education and training of crew members about the heterogeneity of the population and how to meet functional needs.

Recognize heterogeneity of population.

  • Recognize the heterogeneity of the population of persons who are deaf and hard of hearing by providing for redundancies in alerts within and across modalities, and with respect to the education and detailed instructions provided (to the extent such alerts, education and instruction are provided to others).
  • Respond to the functional needs of individual passengers who are deaf and hard of hearing; response should not be based on labels or categories.
  • Recognize that any alarm system designed should reduce to the extent possible the risks of adverse effects that alarm systems can cause to people with disabilities, including persons with epilepsy.

Balance flexibility and certainty.

  • Provide a balance between recommendations that provide flexible standards (e.g., allow for alternative means of compliance based on advancements in technology) and the need to provide standards that are measurable, demonstrable, and enforceable.
  • Vessel owners should not be prohibited from doing more than what is required.

Recognize authority of Access Board and DOT.

  • Recognize the legal constraints under which the Access Board and DOT function regarding the nature and scope of their respective authority to regulate passenger vessels.