5 Summary and Actions (Phase 2)

5.1 Findings

  • The investigation into safety regulations and access standards for weathertight doors revealed the nature and details of the fundamental conflict between the two: coamings keep water out and provide structure for weathertight doors, but raise a barrier to access for the mobility-impaired.
  • Designers, shipbuilders and the Coast Guard have in some cases found alternative solutions providing improved access, but these have not been formally recorded as “equivalents” meeting the intent of the watertight integrity regulations.
  • The Coast Guard’s inspectors have in those cases been using a common sense risk management approach without the use of a formalized methodology.
  • Naval architects and operators have welcomed the idea of the risk management methodology.
  • Several naval architects have reviewed and agreed with the particulars of the methodology.
  • Applying the methodology to as built designs produces largely similar door design and access results, with some noted exceptions for larger vessels.
  • Applying the methodology to reconfigure doors and other design elements can work effectively to provide improved access between the passenger cabin and weather decks.

5.2 Course of Action
The Passenger Vessels Association (PVA) and the Coast Guard’s "Partnership Action Team" (PAT) expressed support for the risk methodology at its January 2005 meeting, and agreed to undertake a formal peer review process, offering technical and operational insights to improve the tool. The PAT intends to put the risk methodology reports into the current Department of Transportation (DOT) docket for the rulemaking “Nondiscrimination on the Basis of Disability: Passenger Vessels”, docket number OST-2004-19700. At the time of this report’s completion, the PAT had agreed to prepare a charter identifying the course of action and had asked PVA members to help by providing:

  • Examples where alternative doorway designs give enhanced access from the weather decks to passenger accommodation spaces; and
  • Comments on the practicality of the proposed methodology and the particulars of the risk scoring regime; and
  • Knowledge of vessel casualties where weathertight doors and coamings (or lack of same) were contributing factors.

5.3 Issues
There are several significant questions at the time of this report’s completion. The first concerns the technical particulars as they may be affected by the future PAT review and the public’s response after the report is placed in the DOT docket.

The second question is the eventual disposition of the risk-based methodology. The Coast Guard, industry, and the author agree that it should not become part of the Coast Guard’s or the Access Board’s regulations. One possible outcome is its publication as a Coast Guard “Navigation and Vessel Inspection Circular” (NVIC). NVICs function as technical guidance to industry and have proven a very useful tool for many safety and environmental protection matters in the past.

Finally, there is a set of questions concerning the prospective designs of weathertight and watertight doors providing enhanced access, that is, in conjunction with reduced height coamings and short ramps. These address the enhanced access solutions offered in the risk-based methodology and the extent to which marine door manufacturers can respond to the need for accessible doors. The questions are:

  • Are there manual weathertight and watertight doors currently in the market that comply with 4.13, “Doors, Doorways, and Gates”, of the ADAAG? For doors required to be accessible, do any of the provisions in 4.13 add space or features or present design challenges of providing conforming doors?
  • On the subject of proper sealing of door gaskets:
    • Can manual weathertight doors properly seal against a sloped surface or do they require a vertical surface at the top of the sloped surface? If such doors cannot be properly sealed, would interior deck drains satisfy any leakage concerns and does the installation of such drains create a design challenge or cost concern?
    • Can manual watertight doors properly seal against a ¼ inch vertical surface or a ½ inch vertical rise sloped surface? If not, what is the minimum height required for proper sealing and are such doors commercially available?