As a person with Significant hearing loss and a child with hearing loss, who has been a frequent passenger on cruise ships, I welcome this opportunity to respond to the US Access Board’s request for comments to its 2nd Draft to the Americans with Disabilities Act (ADA) Accessibility Guidelines for Passenger Vessels.
Section V703.7.2.1 International Symbol of Accessibility:
That symbol only shows a wheelchair, and it does not represent or give any indication that accommodations for people with hearing loss are being provided. The Disability Access Symbols displayed on the Graphic Artists Guild website (http://www.gag.org/resources/das.php) clearly states:
"The wheelchair symbol should only be used to indicate access for individuals with limited mobility including wheelchair users. For example, the symbol is used to indicate an accessible entrance, bathroom or that a phone is lowered for wheelchair users."
Only displaying a wheelchair logo implies that there is no access for people with hearing loss. If it is supposed to convey access for other disabilities, it promotes the erroneous impression that mobility access is the only disability that is important, or that mobility access is more important than other disabilities. Assistive listening devices and captioning are my "ramps" and should be given equal consideration. I strongly suggest that other logos representing other disabilities be included, and not using that wheelchair logo to imply access for all people with disabilities. In my case, I look for logos that show that Assistive Listening Devices (ALDs) - (logo is an ear with arcs radiating from it) - and Captioning (either OC or CC) are available.
Just having an ear-with-slash logo doesn't give me enough information about the services I need, as described in section V703.7.2.2 Assistive Listening Systems. The logo that has an ear with arcs radiating is the appropriate logo to use - as it specifically tells me there's an assistive listening system available - the type of access that my daughter and I require.
Entertainment:
During the shows particularly the comedians there should be perfered seating for the deaf who lip read since CART is not available so they maybe included.
Movie Captioning:
I don't see any requirement for movies to have captioning. Without captioning on movies, I'm excluded from understanding and enjoying movies. Although showing open captions on the screen is usually preferable, there is current technology - Rear Window Captioning - that allows the captioning to be seen only by the person needing them. It is really frustrating to be excluded from activities on baord because I do not know what is happening in the movie. It is about time that people with hearing loss stop being excluded from attending movies. That is patently discriminatory, especially since the technology now exists to rectify the situation.
Hearing Aid compatible phones and TTY telephones:
I have been on several ships where the phone were not HA compatible which was a significant problem. I also see no requirements for phone accomadations for the ring or for fire. I often miss the fire drill because I can not hear the announcements and there is no alert system for the deaf.
I see no mention of being able to specifically request a TTY in one's stateroom. That telephone equipment is essential for someone who cannot use a regular voice phone. In addition, there needs to be a TTY at a "front desk" that is answered by staff members, so a passenger who needs to call for help or services can do so, just like other passengers can. The logo for TTY phones should be used to convey that these phones are available.
Notification alerting systems:
Since a person with a hearing loss cannot hear loudspeaker announcements, there must be ways to provide this information in locations around a ship. There should be text boards available for people to read what is being said over the loudspeakers. In addition, there should be visual or tactile alerting systems available in a passenger's stateroom.
In the case of emergency alerts, the principles of "Universal Access" should be used. Since many people with hearing loss do not self-identify themselves, but would not be able to hear loudspeaker announcements, it is imperative that this information be provided in text in areas around the ship. Senior citizens would fall into this category, as many have a hearing loss, yet typically do not identify themselves as such.
I appreciate this opportunity to offer my comments. Hearing loss, an invisible disability, is frequently misunderstood, minimized, overlooked and forgotten. It is important to address the needs of this population to insure the optimum safety and enjoyment that is the intention of these ADA guidelines.
Thank you for the opportunity to respond.
Lisa Sheppard MD
[address]
Princeton Jct. NJ 08550