36 CFR Parts 1195
[Docket No. 2004-1]
Americans with Disabilities Act (ADA) Accessibility Guidelines for Passenger Vessels
Ampetronic is the world leader in Audio Induction Loop systems, and has developed new techniques which are recognised as setting advanced standards so that people with (often significant) hearing loss are helped to re-connect with their outside world. We operate worldwide, including the USA.
In many countries, most hearing aids are fitted with Telecoil capability. In the European environment, often more than 90% of aids are so equipped, hence the dominance of Induction Loop facilities in this area. A large part of the international cruise market, involving passenger vessels as covered by this document, is run by USA businesses, but a significant proportion of their clients are not USA based.
Furthermore, in the USA, based on recent research at Ohio State University, which has been published, more than 50% of aids supplied now have the telecoil fitted, and the major deaf associations are pushing for this to be made universal, because of the immense advantages of this facility, which enables listening to hear clean sound whenever an induction loop system is installed, without the often unwanted wearing of very obvious receivers.
It is sometimes claimed that the metal structure of these vessels makes induction loops impossible. As a company, we have done extensive research in this area, and are fully familiar with the potential solutions. RF systems can be extremely difficult due to the reflection of the signal from the metal surfaces. It also needs selecting frequencies whenever a person moves from one area to another and this can be a serious problem for some people. Infrared (IR) cannot be used where significant daylight, especially sunshine, is present. Both RF and IR are essentially unuseable at service counters, etc.
Hearing loss is an “unseen” disability which affects many people, who often feel cut-off from their surrounding world by this loss.
Apart from what we have written, we would totally support Janice L Schacter in her submission (http://www.access-board.gov/pvaac/comments-rev/schacter.htm <http://www.access-board.gov/pvaac/comments-rev/schacter.htm> ), as well as David Myers.
We will comment upon some of the sections.
V215 Wherever a voice based alarm system is installed, the signal from that system should also be available on an ALS. Because a majority of users always have their hearing aid fitted, an Induction Loop system is the outstanding advantage. It is an established fact that when an emergency announcement is made, the ambient noise level increases significantly, and people with average hearing loss, or hearing aid users, are unable to understand the content of the message, except when they receive a clean signal in their hearing aids. This was made very obvious less than 2 years ago during a serious fire on board a ferry in the Baltic, where even people with normal hearing had problems with understanding the PA system due to the noise level caused by many people reacting with fear.
V216 Internationally approved signs exist for the Hard-of-hearing. This is accepted in V703.7.2.2
V216-8 This list should be extended to cover information points & desks, service counters (as referred to under V227 & V904), etc. This is also true for Two-way communication systems as listed under V218-1. Essentially, anywhere on a vessel where passengers listen to sound which is part of the information provision or the entertainment provision, including cabins. Induction loops will increase the enjoyment and benefit of the sound to the passenger.
V219.3 In the light of the information about the percentage of aids having the telecoil, the middle column needs revising downwards when induction loop systems are installed. We believe this has already been noted for the basic ADA standards.
V407 & V408 Elevators: All elevators use by passengers should have an induction loop fitted, to ensure that the information from the communication system can be heard. This should not be restricted to a small area of the elevator, due to mobility constraints when several people are in the vehicle. New European rules cover this.
V411.6 This has been mentioned earlier in our comments under V216-8
V706.1 All installed induction loops MUST comply with IEC 60118-4, which specifies magnetic field intensity, variation of this across an area, and also, very important, the required and measured frequency response. This is vital as the metal used in passenger vessels has a significant effect upon this requirement. A new version of this standard has just been accepted by the IEC secretariat, and will be published soon.
Similar standards should be applied to other Assistive technologies, to guarantee a satisfactory level of intelligibility.
Leon. A. Pieters
Newark, Notts. NG24 2ET