Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street NW., Suite 1000
Washington DC 20004-1111
My Comments on Draft Guidelines for Passenger Vessels:
I believe there needs to be an increase in the ADA rules in general to make all doorways a minimum of 36-inches for ships, planes and land-based business since this will accommodate "most" wheelchairs (manual and electric and electric scooters) as well as those on the larger side of life. Heck most airplane restrooms barely are wide enough for a skinny person now add a person over weight or disabled....sigh
In this day and age there are many disabled people that are on the larger side of life and they use what is called a bariatric chair or heavy duty chair and most have an overall width around 36 inches. Bariatric seat widths average 22-30 inches; now add wheels and they can get as wide as 48 inches, but the average seems to fall at 35.5-36 inches so you can get through a standard front door.
All entry doorway clearances on all guestrooms (not just the accessible
guestrooms) should be at least 36-inches wide. I feel this is an essential part of the ADAAG and I strongly encourage the Access Board to incorporate a similar provision in the final guidelines for passenger vessels.
Staterooms with balconies need to be accessible. I sailed July 2004 on Carnival Pride and had a disabled room with a balcony. I could not get onto the balcony because there was what I call a submarine door with a step out to the balcony. When I sailed on the Grand Princess in March 2001 the disabled room with a balcony had sliding glass doors and were accessible. Carnival Pride did NOTHING when I complained of booking me in "disabled room with a balcony" that I couldn't access and refused to issue any refund. Carnival sticks when it comes to customer service and those disabled. (They blocked the ramp to the showroom with their portrait backdrops and the list goes on and on).
I feel cruise ships could be properly design so that all state rooms would better serve seniors and those that have problems walking distances, have knee problems, use walkers or are on the larger side of life. If all bathrooms had raised toilets, grab bars and an area a scooter/wheelchair/walker could be stored in the cabin you would cut down on folks asking for disabled rooms leaving them for those that really need them. Designers can incorporate these essential measures into every stateroom with simple things like relocating the closets adding a few feet in width to the room. Having a closet on the balcony that could store a wheelchair/scooter or luggage. Sure the design would have to be changed a bit, but as the baby boomers get older you will have a lot more seniors cruising and needing these helpful features.
Designers need to better design the roll in showers. The drains NEVER seem to be where the water runs and leaves half inch of water on the floor making it a slippery and dangerous surface for anyone with a walker or even a non-disabled person walking in and slipping. It would be pretty easy to make a quarter inch slope towards the drain and have a drain strip at least 3 feet long and 4 inches wide.
I also urge the Access Board to address the tours and make them accessible as well.
There should be no different access to times and availability of tendering services for those with mobility disabilities than for those who are able-bodied and someone with mobility disability should never be told it's too dangerous or not safe for them. If it's not safe for them it's not safe for able-bodied either! EQUALITY FOR ALL.
Boarding ramps need to be widen to 36 inches as well and not have stairs or a rise larger than 1.5 inches to enter and exit the ramp and the slope needs to be 1 to 30.
All ships should be required to have life preservers that will hold a persons shoulders, neck and head above water. People with tracheotomies and larengectomies for example need that type of life preserver. Life boats also need to be accessible for someone in a wheelchair or scooter. There needs to be at least one elevator designated as an emergency elevator for wheelchair/scooter users and their family and it should have a backup generator system in the event of power failure. New built boats might consider disabled staterooms be placed within 100 feet (10 cabins) of the emergency elevator.
The showrooms need to have disabled seating, it can be accomplished pretty easy by having an area at both ends of all the rows allowing disabled people to sit with non-disabled members of their party.
The dining rooms need to have at least a 36 inch wide aisle and not have "areas" for wheelchairs, a person should be able to sit anywhere in the dining room and not feel like a second class citizen or one sitting at the kiddie table at Christmas. Any raised area should have access (not limited to the dining room but the entire ship).
Also some couples need to have a child or a personal attendant in an accessible cabin. Some ships still have no accessible cabins allowing a third or fourth person but have many in the regular cabins in all categories. Accessible cabins should be found in each cabin category and should not be blocked view as is commonplace. A person that is disabled likes a view just like everyone else! Again equal for all.
There must be access to ALL of the ship not just some areas as is common currently. In all public areas of the ship, there should be wheelchair accessible paths of travel to all bars, theaters and showrooms, etc. and these paths should allow access to all areas of such areas. Ramps to these areas should comply with existing ADA ramp specifications (this if often not the case).
There also should be at least one deck that encircles the ship and have fully accessible paths of travel without stairs use required.
Ships should have disabled push button automatic powered door openers. Doors are often very heavy with very high pull force, which is only worsened by wind or sea action, someone in a wheelchair/scooter or a senior with walker or can have great difficulty opening doors.
Shops on the ship often do not have clear path of travel for a wheelchair/scooter between clothing racks and shelving. This should be required for all ship stores and shops.
There should be at least one pool and one hot tub with either a ramp or lift (accessible for all ages). If there is an adult only pool there should be a life/ramp there as well.
Hallways should not be allowed to be blocked by housekeeping carts. A person traveling alone by wheelchair/scooter can't get past and are blocked and can't turn around to go another way. This could easily be remedied with carts that allow at least a 38" path of travel on the side of the cart (don't forget to allow for hand rail protrusion into the space). The carpet should also be designed and marked for luggage placement for disembarkation or any item to be in hallways (laundry bags, food trays, etc) so they do not block wheelchair/scooter access at any time.
If the ship has wheelchair/scooter lifts- Should have minimum weight capacity of 750 lbs and be capable of sustaining a static load of at least 1.5 times the rated load. A person that weighs 300 lbs and a electric wheel chair or electric scooter on the lift and a 500 lb capacity will be barely enough to get them up or down. Getting stuck on a lift is highly embarrassing to the disabled person. The lift should also be at least 36 inches wide and long enough to accommodate an electric scooter (minimum 55 inches). Having a lift that uses a universal key will be very helpful and a key should be given to anyone in a wheelchair/scooter for them to use while on the cruise and not cause the disabled person to wait for someone to find the key to operate the lift. (This is commonly done in casinos)
Floor surfaces do impact wheelchair movement so great consideration to type of floor surface should be taken.
It would be extremely good if the ship designated certain elevators as
“wheelchair or scooter (and their family) use only” Also
wheelchair/scooter (and family) check in and check out only lines.
Accessible restroom- make them large enough to easily turn/maneuver a wheelchair/scooter. Think about corners, angles, and aisle/path width. Scooters and wheelchairs can require as much as 58 inches for turning. There should be at least 2 disabled restroom per deck (one on each end at a minimum).
Cruise ships also often provide shuttle services from airports to their ships (sometimes free, sometimes for a charge) but often do not provide equivalent accessible transportation for wheelchair users and those that do provide it I have yet to see them have the transportation available when they KNOW your arrival. I have had to wait hours for the accessible transportation that NEVER arrived.
I oppose asking for someone disabled to provide documentation so they can get the services they need. Not everyone has a disability that would have documentation. Someone who has trouble walking or knees problems or are over weight are just a few examples of someone that can't use a normal
shower/tub. I hate those that make the claim "Those who are truly disabled
and who truly need a handicapped room should not be offended." Equality does not mean one has to prove their disability and yes I am offended someone would suggest I prove I am disabled.
I urge the Access Board to facilitate the above changes and make cruise ships more accessible to everyone skinny, fat, young and old. Remember one day you may be old and a slow walker or need the use of a walker, cane, wheelchair or scooter. Wouldn't it be nice to be able to get around and not struggle like most of us currently do?
Santa Clara, CA 95055