United States Access Board
1331 F Street, NW, Suite 1000
Washington, DC 20004-1111
To Whom It May Concern:
RE: Comments on Revised Draft Passenger Vessel Accessibility Guidelines and Supplementary Information Hearing Loss Association is pleased to have the opportunity to respond to the US Access Board’s request for Comments on its Revised Draft Passenger Vessel Accessibility Guidelines. Hearing Loss Association, formerly Self Help for Hard of Hearing People, has played an ongoing active role in expanding communication access for people with hearing loss on passenger vessels. Susan Finisdore, represented us on the Access Board’s Advisory Committee that developed recommended guidelines. But there is still more to be done to reach the level of communications accessibility on passenger vessels that is acceptable.
Hearing Loss Association is the largest organization of people with hearing loss in the US. We represent people who use spoken language and make use of any residual hearing they have through hearing aids, cochlear implants supplemented by speech reading and other visual means. Our mission is to open the world of communication to people with hearing loss through information, education, advocacy, and support.
There are today 31 million Americans with hearing loss, one in ten of the population. The incidence rises to one in three among people over the age of 65 years. This age group tend to have the time, money and inclination to take cruises. At that stage of life they are often facing many physical and or sensory challenges, with hearing loss being the most prevalent. Apart from seniors who love to take cruises, many families find them an ideal way to have everyone together with activities to suit all ages and preferences. It is quite common, for example, for families to plan family reunion cruises. So communication access needs apply to people of all ages from seniors to teens and everyone in between.
We receive many complaints into our office about inaccessible passenger vessels. Not only is it frustrating to spend money and look forward to a cruise vacation only to find that much of the entertainment, relaxation, and information provided is inaccessible to you. But more importantly that safety procedures and phones for staying in touch and making contact are not set up taking your needs into consideration. People expect to be safe or at least know what to do in an emergency, be independent and not have to rely on anyone to make phone calls for them or tell them what is going on, and to enjoy themselves. That is not possible today on many passenger vessels.
A few individuals with hearing loss have already submitted comments about the lack of access. Not as many as we would expect or like given the number of people who have hearing loss and meet inaccessible situations regularly. However, the lack of commenters in one way is not surprising. People with hearing loss have become used to not having access provided for them. They are used to being given a sign language interpreter but no assistive listening devices, CART, or other visual aids and alerting devices that are more appropriate to their needs and many of them have, sadly, come to accept the status quo.
Janice Schacter, for the Hearing Access Program, has documented comments well from her perspective as a frequent traveler on passenger vessels and parent of a teenage daugther with hearing loss. She has gone through the 2nd Draft systematically and noted key areas where access gaps for people with hearing loss currently exist. Hearing Loss Association totally agrees with her observations and wholeheartedly supports them. In summary:
- The "effective communication" standard must be flexible enough to incorporate emerging technologies
- V215 /(a) V806.3.1 Emergency Alarm Systems and Alarms in Guest Rooms. Must incorporate examples of "shall comply with principles of best practice." It is important to pay attention to the latest research that shows that tactile rather than visual strobe alarms are more reliable for waking up individuals with hearing loss. Also that low frequency alarms are more likely to be heard and therefore alert them than high frequency.
- V219.2 Remove the exception for ALS in assembly areas where amplification is not used
- V703.7.2.1 International Symbol of Accessibility is well known as the symbol for people who use wheelchairs and has no relevance for people with hearing loss
- V703.7.2.2 Hearing Loss Association supports the use of the International Symbol of Access to Hearing Loss as long as it specifies what access is being provided e.g. CART; Captioning; ALS: FM, Loop, or Infrared system; TTY so that the type of accessibility being provided is clear to consumers
- V704 All telephones should be hearing aid compatible and have volume control
- V706.1 General. An overview of the advantages and disadvantages of all ALS should be documented including loop systems
- V904 Sales and Service Counters. Need to be made accessible through the use of counter loop systems
- Chapter 11: Tenders. Instructions on departure/embarkation and in emergencies must be conveyed via an assistive listening system and in a visual format
- Tours. Docent systems should be made available and transcripts for those who cannot benefit from any ALS
- Movies/videos shown on the cruise should be captioned
- All on-board televisions should be equipped to display captions
- All ship-board announcements must be given in a visual format and via an ALS
- Audioguides. When offered should be hearing aid compatible or offer neck loops. Also transcripts should be available
- CART and or qualified interpreteration should be available on request prior to embarkation
- There should be back-up portable ALS on board in case of technical breakdowns
- Appropriate signage should be placed outside each room where accessibility is in place
- All accessible events/rooms must be listed on the company's websites, advertisements, daily program and brochures
- Accessibility equipment should be tested and maintained regularly
- All personnel must undergo appropriate training in the accessibility that is provided
Passenger vessels are floating communities and require the same level and type of access as expected in our towns and cities on land. Incorporating these suggestions we believe will lead to safer and more enjoyable cruises for people with hearing loss and we hope the Access Board will look seriously at recommending changes in the guidelines.
Thank you for the opportunity to comment.
Associate Executive Director
Hearing Loss Association