Department of Transportation
Douglas B. MacDonald
Secretary of Transportation
Washington State Ferries
2911 2nd Avenue
Seattle, WA 98121-1081
Michael G. Thorne
Director and CEO
Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street NW. Ste 1000
Washington DC 20004-1111
Subject: Accessibility Guidelines for Passenger Vessels
Comments by WSF Vessel Engineering
Enclosure: (1) Comments on Passenger Vessel Guidelines
Enclosure (1) contains the comments formulated by Vessel Engineering of Washington State Ferries on the proposed accessibility guidelines.
If you have any questions, please feel free to call Mr. Olof Sander at 206/515-3630.
Very truly yours,
WASHINGTON STATE FERRIES
Olof G. Sander, P.E.
Senior Naval Architect
2911 2nd Ave.
Seattle WA 98121-1012
cc: Laurens Zuidweg
WASHINGTON STATE FERRIES
COMMENTS ON PASSENGER VESSEL ACCESSIBILITY GUIDELINES
1/ On the principle that one picture says more than a thousand words, will examples of, for instance, wheelchair and companion seating in a row seating area be provided, maybe as an attachment to the rules?
Comments on issues applying to WSF, Vessel Engineering
Chapter 2, Scoping Requirements
The Guidelines (GL) apply to new boats and modified areas on existing boats, but only to passenger areas.
V206 Onboard Accessible Routes
On some existing boats we don't meet V206.2.1 which requires that all decks and mezzanine decks have to be accessible.
The new class will be fully accessible. It's not quite clear whether the Upper Vehicle Deck is counted as two separate decks or as a single deck.
All double doors to solariums must be powered (1 leaf each). For signage req. see V216.5 See alsoV404.3
Elevators are required. Exception 2 allows LULA elevator. See V408.
V207.3 Elevators (at least one) has to be part of Accessible means of escape, i.e. connected to the Emergency Generator.
Unclear if 1 WC and 1 urinal are required.
V215 Emergency Alarm Systems
Exception allows existing systems to not have visible components, which are required for new systems by V702.
V216.1 Ex. 3: How is a "Sign" defined. Is a Quick Notice a sign? (Probably not)
V221 Public Seating areas.
The rules mention fixed seating. We have a mix of fixed and movable seating. Should we just design as if all seats were fixed?
V221.3 Companion Seats
Are companion seats to be designated in any way?
V221.4 Designated Aisle Seats in assembly areas.
The definition of assembly areas in V 106.5 does not seem to cover our public seating areas. Is this correct?
Chapter 3 Building Blocks
V304.4 Door Swing
Note: Doors shall be permitted to swing into turning spaces.
V306.2 Toe Clearance, and V306.3 Knee Clearance
It would be very helpful to have a picture here.
V307.4 Vertical Clearance
Unclear. Please provide picture. Does this apply to sloping bulkheads?
Chapter 4 Accessible Routes....
V404.3.6 Brek Out Opening
Please define Break Out Opening.
V405.9.2 Curb or barrier
Does this apply to freeing ports?
V410.2 Exit Stairways
Exception 3: This seems to say that when accesssed from and area of refuge, 48" clearance is not required; but 48 " clearance is required according to V410.2 (a) and is accessed from an area of refuge per V410.2 (b)(ii). This seems contradictory.
Chapter 6: Plumbing Elements and Facilities.
V604.9 Water closets... for Children's use
Is there a requirement to have special facilities for children?
V605.2 Height and depth. How are "stall-type" and "wall-hung" type defined? Does this rule out a "trough-type" urinal, i.e. a long through with room for more than one person simultaneously?
Chapter 8: Special Rooms, Spaces, and Elements.
Are we required to provide aisle seats with movable armrests? See V221.4
Comments provided by Olof Sander
Sr. Naval Architect Washington State Ferries Phone: 206/515-3630