Part I Coast Guard CFR and SOLAS provisions which conflict with provisions in the ADAAG Review Advisory Committee Report (ADAAG-R).
Part II ADAAG-R provisions which may be problematic if applied to passenger vessels due to similar CFR or SOLAS provisions.
Part III Other subcommittee comments.
Index Completion of Coast Guard's initial review. References Part I through Part III.
The following sections from the Coast Guard's CFR, subchapters H and K, and SOLAS conflict with sections from the ADAAG Review Advisory Committee report (ADAAG-R).
Conflict 1 EGRESS ELEVATORS - ADAAG-R 207.2 requires that in certain situations at least one accessible means of egress shall be an elevator. In subchapter H, CFR 72.10-5(b) does not allow elevators to be used as a required means of escape. This conflict does not appear in subchapter K.
Coast Guard CFR Section
Subpart 72.10 Means of Escape
72.10-5 Two means required.
(a) There shall be at least two means of escape from all general areas accessible to the passengers or where the crew may be quartered or normally employed. At least one of these two means of escape shall be independent of watertight doors. For stairway continuity and general requirements for stairways see Sec.72.05-20.
(b) Elevators shall not be considered as one of the required means of escape.
(c) Stairways serving only a space and a balcony to a space shall not be considered as one of the required means of escape.
II-2-28.1.2 Means of Escape - Above the bulkhead deck there shall be at least two means of escape from each main vertical zone or similarly restricted space or group of spaces at least one of which shall give access to a stairway forming a vertical escape.
II-2-28.4 In no case shall lifts be considered as forming one of the required means of escape.
ADAAG Review Report Section
207 Accessible Means of Egress
207.1 General. All accessible spaces shall be provided with not less than one accessible means of egress. Where more than one means of egress is required from any accessible space, each accessible portion of the space shall be served by not less than two accessible means of egress. Accessible means of egress shall comply with 409.
EXCEPTIONS. 1. Areas of refuge are not required in buildings or facilities protected throughout by a supervised automatic sprinkler system.
2. Areas of refuge are not required in open parking garages.
3. Accessible means of egress and areas of refuge are not required in alterations to existing buildings.
207.2 Elevators. In buildings where a required accessible floor is four or more stories above or below a level of exit discharge, at least one required accessible means of egress shall be an elevator complying with 409.3.
207.3 Signs. At exit stairways and elevators serving a required accessible space, but not serving as an accessible means of egress, directional signs indicating the location of accessible means of egress shall be provided. Such signs shall comply with 703.4.
Conflict 2 COAMING - 46 CFR 116.1160(d) and 171.122(f) set coaming heights at 3 to 6 inches at some exterior doors. ADAAG-R 404.2.5 limits thresholds at doors required to be accessible to 1/2 inches high maximum, and 303.4 requires changes in level greater than 1/2 to be ramped.
Coast Guard CFR Sections
116.1160 Watertight integrity.
(d) A weathertight door must be provided for each opening located in a deck house or companionway. Permanent watertight coamings must be provided as follows:
(1) On a vessel on an exposed or partially protected route, a watertight coaming with a height of at least 150 millimeters (6 inches) must be provided under each weathertight door in a cockpit or a well, or on the main deck of a flush deck vessel.
(2) On a vessel on a protected route, a watertight coaming with a height of at least 75 millimeters (3 inches) must be provided under each weathertight door in a cockpit or a well.
(3) The height of the watertight coaming for a hinged watertight door, need only be sufficient to accommodate the door.
171.122 Watertight integrity above the margin line in a vessel of 100 gross tons or more.
(f) Each opening in an exposed weather deck must--
(1) Have a coaming that complies with the height requirements in table 171.124(d); and
(2) Have a means for closing it weathertight.
|Route||Height of coaming|
|Exposed or partially protected||6 inches (15.2 centimeters|
|Protected||3 inches (7.6 centimeters|
II - 1-20.2 All openings in the exposed weather deck shall have coamings of ample height and strength and shall be provided with efficient means for expeditiously closing them weathertight.
ADAAG Review Report Sections
206.5 Doors and Doorways. Accessible doors and doorways shall be provided in accordance with 206.5.1 and 206.5.2 and shall comply with 404.
206.5.1 Accessible Entrances. Each accessible entrance to a building or facility shall have at least one accessible door or doorway.
206.5.2 Accessible Rooms and Spaces. Within a building or facility, at least one door or doorway serving each accessible room or space shall be accessible.
404 Doors and Doorways
404.2.5 Thresholds. Thresholds if provided at doorways shall be 1/2 inch (13 mm) maximum in height. Raised thresholds and changes in level at doorways shall comply with 302 and 303.
302 Floor or Ground Surfaces
302.1 General. Floor and ground surfaces shall be stable, firm, and slip resistant and shall comply with 302.
302.2 Carpet. Carpet or carpet tile shall be securely attached and shall have a firm cushion, pad, or backing or no cushion or pad. Carpet or carpet tile shall have a level loop, textured loop, level cut pile, or level cut/uncut pile texture. Pile height shall be 1/2 inch (13 mm) maximum. Exposed edges of carpet shall be fastened to floor surfaces and shall have trim along the entire length of the exposed edge. Carpet edge trim shall comply with 303.
302.3 Openings. Openings in floor or ground surfaces shall be of a size that does not permit passage of a 1/2 inch (13 mm) diameter sphere, except as allowed in 407 and 408. Elongated openings shall be placed so that the long dimension is perpendicular to the dominant direction of travel.
303 Changes in Level
303.1 General. Where changes in level are permitted in floor or ground surfaces, they shall comply with 303.
303.2 Vertical. Changes in level of 1/4 inch (6.4 mm) high maximum shall be permitted to be vertical.
303.3 Beveled. Changes in level between 1/4 inch (6.4 mm) high minimum and 1/2 inch (13 mm) high maximum shall be beveled with a slope not steeper than 1:2.
303.4 Ramps. Changes in level greater than 1/2 inch (13 mm) high shall be ramped, and shall comply with 405 or 406
During the review of subchapters H and K of the Coast Guard's CFR and SOLAS, the following sections from the ADAAG Review Advisory Committee report (ADAAG-R) have been identified as being problematic. For example, in some situations, compliance with CFR or SOLAS minimum standards may result in non-compliance with ADAAG-R. The applicable sections have been noted below. In some cases, notes have been provided indicating some of the requirements. Page numbers from the ADAAG-R have also been provided.
1) CFR for Subchapter H and K requires instructions, markings, and alarms (in some cases) for controls of typically crew operated fire fighting systems. Such controls may be located in spaces open to passengers. Mounting heights and operating requirements, signage requirements, and visual and audible alarm requirements of ADAAG-R may be problematic if applied.
2) In some situations, ADAAG-R will require wider openings at doors to stairways, wider stair treads, reduced stair inclinations and higher handrail/mounting heights, than the CFR and SOLAS. Generally, crew-only areas are allowed by the CFR and SOLAS to have narrower doors/stairs and steeper stairs then passenger areas.
3) For wheelchair seating in assembly areas, ADAAG-R will require wider aisle width than the Subchapter K CFR requires for aisle widths when passenger seating is available. Size depends on length of aisle. When seats are in rows, distance from seat front to seat front must not be less than 30".
4) ADAAG-R requirements for Accessible Route, Parking Spaces and Passenger Loading Zones should be considered when Subchapter K CFR requirement states that the Master shall ensure that vehicles are distributed for stability.
5) For Passenger/overnight accommodations for Subchapter K, ADAAG-R requirements for lodging, clear floor or ground space, and maneuvering clearance must be addressed.
6) For Subchapter K vessels, a ladder leading to a deck scuttle may not be used as a means of escape except when a vessel is less than 65' in length. For vessels less than 65' in length, a vertical ladder and deck scuttle or window may be used as one of the means of escape from a passenger accommodation space providing that each ladder is mounted at least 7" from the nearest permanent object in back of the ladder. ADAAG requirements for Accessible Means of Egress (Sec 409) must be addressed for this size vessel.
During the review of the Coast Guard's CFR subchapters H and K, and SOLAS, the following comments were made by subcommittee members.
1) ADAAG-R has specific requirements for handrails and edge protections on stairs and ramps. CFR for subchapters H and K also require guard rails, deck rails and storm rails in certain situations. ADAAG's underlying safety and accessibility issues should be considered when complying with CFR requirements for guard rails, deck rails and storm rails.
2) General alarms and other communication should be accessible for persons who are deaf or have hearing impairments.
3) All critical communications such as posted emergency instructions and warning signs must be available in accessible formats for persons with visual impairments. In addition, all general communication must be accessible as well.
4) ADAAG-R has specific requirements for kitchen, kitchenettes and wet bars. These requirements may apply to cooking equipment requirements for Subchapter K vessels.
ADAAG/Coast Guard Comparison Index