Passenger Vessel Emergency Alarms Advisory Committee
October 14, 2008
On August 13, 2007, the Architectural and Transportation Barriers Compliance Board (Access Board) established an advisory committee to make recommendations on issues related to the effectiveness of emergency alarm systems for passengers who are deaf or hard of hearing on passenger vessels. [72 FR 45200 (August 13, 2007)]. The purpose of this report is to describe the mission and operating protocols of the Committee, the deliberative process used by the Committee to reach a consensus, and the Committee’s recommendations.
- Ms. Hamlin, Community Emergency Preparedness Information Network
- Capt. Thompson, Cruise Lines International Association
- Ms. Tuck, Cruise Lines International Association (alternate)
- Ms. Yannias, Epilepsy Foundation of America
- Dr. Bakke, Gallaudet University
- Ms. Schacter, Hearing Access Program
- Ms. Schacter, Hearing Loss Association of America
- Ms. Raimondo, National Association of the Deaf
- Mr. Richardson, National Fire Protection Association
- Mr. Welch, Passenger Vessel Association
- Mr. Chapman, Society of Naval Architects and Marine Engineers
Committee Mission and Operating Protocols
The establishment, membership and functioning of the Committee were guided by a Charter and Operating Protocols.
Charter and Operating Protocols
The Charter (http://www.access-board.gov/pvaac/alarms/charter.htm) established the “Passenger Vessel Emergency Alarms Advisory Committee” (The Committee). The Committee was required to function in accordance with the Federal Advisory Committee Act (FACA) and the administrative guidelines issued by the General Services Administration’s Committee Management Secretariat.
The Committee was composed of a cross section of organizations representing a variety of interests regarding emergency alarms on passenger vessels, including passenger vessel industry organizations, organizations representing people who are deaf or hard of hearing and other people with disabilities, and technical experts.
With respect to the scope and objectives of the Charter, the Committee was authorized to make recommendations to the Access Board on issues related to emergency alarm systems for proposed accessibility guidelines for passenger vessels subject to the Americans with Disabilities Act (ADA). The Committee acted solely in an advisory capacity to the Access Board.
Consistent with the scope and objectives, the Committee was authorized to make recommendations to the Access Board on issues related to the effectiveness of emergency alarm system design and practices for passengers who are deaf or hard of hearing on passenger vessels. More specifically, the Committee was authorized to make recommendations to the Access Board on:
- Whether current emergency alarm system designs and practices on passenger vessels meet the access needs of passengers who are deaf or hard of hearing;
- Alternative designs or technologies for emergency alarm systems that meet the access needs of passengers who are deaf or hard of hearing; and
- Contents of proposed accessibility guidelines for passenger vessels related to emergency alarm systems.
In the course of considering alternative recommendations that meet the needs of passengers who are deaf or hard of hearing, the Committee recognized the need to take into consideration the potential effect of the recommendations on other passengers with disabilities, including, but not limited to, passengers with epilepsy or photosensitivity.
In accordance with the Operating Protocols, which also were adopted on September 19, 2007 (http://www.access-board.gov/pvaac/alarms/protocols.htm) the Committee meetings were conducted and work performed in a spirit of collegiality and consensus. The goal was to find common ground. A facilitator was employed to help the Committee carry out its mission.
The Committee held four meetings — September 19-20, 2007; November 28-29, 2007; February 12-13, 2008, and August 12-13, 2008. At the end of each meeting, the public was invited to provide input, although many were actively involved in the discussions of the committee throughout all the meetings. During these meetings, the Committee adopted a deliberative process in carrying out its assigned responsibilities. The process included:
- Reaching agreement on a set of principles to guide efforts to reach consensus on recommendations;
- Reviewing various policy frameworks;
- Listening to presentations by key stakeholder groups and technical experts and discussing issues raised; and
- Engaging in focused discussions on alternative approaches and technologies.
One of the initial tasks completed by the Committee was to reach agreement on a set of principles to guide the efforts to reach consensus regarding recommendations. In general, the Committee agreed that its recommendations should reflect the following guiding principles1:
- Recognize safety as the fundamental responsibility of the crew (e.g., primary responsibility of the vessel’s crew is to ensure safety and security of all passengers and crew in an emergency and issue and implement safety protocols, procedures, and practices that comply with international and domestic rules, where applicable);
- Recognize the responsibility to provide effective communication (e.g., delivery and receipt of the same information provided to others and the provision of information directly to the individual in a timely, accurate, and understandable manner that facilitates informed, appropriate responses to the emergency situation);
- Differentiate between overnight and non-overnight passenger vessels;
- Recognize the heterogeneity of the population, including the need to reduce, to the extent possible, risks of adverse effects that alarm systems can cause to passengers with disabilities, including passengers with epilepsy or photosensitivity;
- Balance flexibility and certainty i.e., balance recommendations that provide flexible standards and the need to provide standards that are measurable, demonstrable, and enforceable; and
- Recognize authority of the Access Board and the Department of Transportation i.e., the legal constraints under which the Access Board and DOT function regarding the nature and scope of their respective authority to regulate passenger vessels.
Review of Policy Frameworks
Several meetings began with a review of aspects of the policy frameworks relating to passenger vessel emergency alarms (e.g., proposed and final regulations, advisory guidelines; domestic and international). This review included a description of the:
- Sections V215, V224.4, and V806.3.1 of the 2006 draft passenger vessel guidelines which generally require that alarms must comply with principles of best practice (http://www.access-board.gov/pvaac/alarms/docs/pvag-draft-2008-excerpts.htm);
- The 2004 draft passenger vessel guidelines (http://www.access-board.gov/pvaac/alarms/docs/pvag-draft-2008-excerpts.htm), which generally required permanently installed audible and visible alarms complying with NFPA 72;
- DOT proposed ADA regulations related to effective communication (Sections 39.57, 39.85, 39.89, and 39.93) (http://www.access-board.gov/pvaac/alarms/docs/dot-nprm-excerpts.htm);
- SOLAS regulations relating to on-board communications and the general emergency alarm summoning passengers and crew to muster stations (audible), muster list and emergency instructions, and emergency training and drills (http://www.access-board.gov/pvaac/alarms/docs/not-us.htm);
- Disability Standards for Accessible Public Transportation in Australia — inclusion of audible and visual alarms (http://www.access-board.gov/pvaac/alarms/docs/not-us.htm);
- Canadian Transportation Code of Practice — Ferry Accessibility for Persons with Disabilities — visual and audible alarms (http://www.access-board.gov/pvaac/alarms/docs/not-us.htm);
- European Union/United Kingdom Directive 2003/24/EC requiring alarm systems “to be accessible by and to alert all passengers with reduced mobility, including persons with sensory disabilities” (audible and visual alarms) (http://www.access-board.gov/pvaac/alarms/docs/not-us.htm);
- U.S. Coast Guard regulations relating to domestic vessels under its jurisdiction (requirements vary by type of vessel) which in general provide for audible emergency alarms (http://www.access-board.gov/pvaac/alarms/docs/usgs-summary.htm);
- Cruise Line International Association (CLIA) Standard regarding local sounding smoke alarms (audible) (http://www.access-board.gov/pvaac/alarms/docs/clia-standard.htm); and
- NFPA 72 National Fire Alarm Code (audible and visible) (http://www.access-board.gov/pvaac/alarms/docs/nfpa72.htm).
Presentations by Stakeholder Groups
Comprehensive presentations were provided by several committee members and by invited guests.
Mr. Thompson (a Committee member) made a presentation on behalf of the Cruise Lines International Association (CLIA) concerning emergency alarm systems and operational practices provided on cruise ships subject to International Convention of Safety of Life at Sea (SOLAS). Mr. Brockway (a Committee member) and Mr. Lauridsen (a public participant) discussed with the Committee how smaller US flag cruise ships and other US flag vessels without overnight accommodations (e.g., ferry, dinner, excursion, and gambling vessels) provide emergency alarms and instructions to passengers. Matters highlighted included:
- Many overnight vessels (e.g., cruise ships) hold a practice general emergency alarm drill for passengers when getting underway. Passengers are instructed that when they hear the general emergency alarm they are expected to take specified actions and go to a muster station;
- In many non-overnight vessels (e.g., dinner vessels and ferries), the general emergency alarm gets the attention of passengers but primarily communicates a message to the crew, and then passengers receive directions from crew as to what actions to take;
- Overnight vessels have high crew to passenger ratios (e.g., 1:3), and non-overnight vessels often have lower ratios (e.g., 1:100);
- Cruise ships are not buildings, and are constructed and operate differently from hotels;
- The general emergency alarm is not activated for every emergency, only where there is a threat to the entire passenger vessel, or where there will be a threat to the entire passenger vessel if action is not taken; and
- A goal is to provide a safe and secure on-water experience for everybody.
The Committee also heard from Mr. Richardson (a committee member) who provided the Committee with an overview of NFPA 72. NFPA 72 contains provisions for audible and visible emergency alarms. These provisions were referenced in the Access Board’s 2004 draft PVAG.
The Committee also heard presentations by Dr. Bakke, Ms. Schacter, and Ms. Hamlin (all Committee members) on the needs of passengers who are deaf or hard of hearing. Matters highlighted included:
- Passengers who are deaf or hard of hearing communicate in a variety of ways, therefore information must be presented in both visual and auditory formats;
- It is important to provide redundancy in notification systems;
- Approximately 34,500,000 passengers in the US have some degree of hearing loss;
- Approximately 62 percent of hearing aid users have t-coils, enabling independent access to induction loop assistive listening systems;
- Examples were given of portable alerting devices on the market and how they operate; and
- An example was given of what the US Department of Agriculture is using at some facilities in the Washington, DC area with multiple types of emergency notification systems (e.g., visual alarms, computer screen message pop-ups, and pagers).
The Committee also heard from Ms. Yannias (a committee member) who discussed the need to not only take into consideration the potential effect of adopting emergency alarm standards on passengers who are deaf or hard of hearing but also the potential effect on passengers with other disabilities, including, but not limited to, passengers with epilepsy or photosensitivity. She also highlighted prior successful efforts that addressed these concerns in the promulgation of NFPA 72.
The Committee also had the opportunity to benefit from presentations by guest speakers including a captain of a dinner boat who made a presentation and answered questions about how vessels without designated muster stations use emergency alarms, public address systems, and crew directions to move passengers to safer parts of a vessel (which are not necessarily pre-determined) based on types and locations of emergency situations encountered. The Committee also heard a presentation regarding a chartered cruise held for passengers who are deaf, including a demonstration of the portable emergency alarm/notification devices used during the cruise.
In addition to the presentations, the Committee spent an extensive period of time identifying and discussing various alternative designs and technologies for emergency alarm systems that might meet the access needs of passengers who are deaf or hard of hearing on passenger vessels.
Consistent with the lessons learned from a review of various policy frameworks, presentations, and discussions and the guiding principles agreed to by the Committee, the group reached a consensus on the following set of recommendations presented below.
(1) Recommendations on issues related to the effectiveness of emergency alarm system design and practices on board passenger vessels for passengers who are deaf or hard of hearing should recognize that alarm practices and systems on passenger vessels are different from alarm practices and systems on land.
(2) In addition to the required audible element, alarm systems should include visible, and, where appropriate, tactile or other2 elements.
(3) Visible, tactile or other elements of alarms should provide effective signaling methods to communicate the general emergency alarm and local smoke detector alarm.
(4) The visible elements should minimize the “possibility or risk3” of triggering seizures in passengers who have epilepsy or photosensitivity.
(5) The committee recognizes the vital role of crew assistance during emergencies on passenger vessels. The committee also recognizes that evidence regarding effective means of providing visible emergency alerts (to supplement crew assistance) in outdoor spaces is not readily available. Therefore, it is of the utmost importance that such evidence be identified if it exists, or that a high priority be given to research for establishing such evidence.
Recommendation #1 – Applies to general emergency alarms in public spaces which summon passengers to designated muster stations. Public spaces include places of assembly, dining areas, places of recreation, public rest rooms, retail areas and other such spaces. Cabins (guest rooms) are addressed in recommendation #2 below.
Background: Recommendation #1 applies primarily to passenger vessels with overnight accommodations. In general, prior to getting underway or in the course of getting underway, passengers are provided with information on what actions the passengers are expected to take when the general emergency alarm is activated (e.g., seven short sound blasts on the ship’s whistle, siren, or similar tones and one long blast or tone). The information provided includes the location and route to the muster stations as well as information regarding lifeboats, low-location lighting, retrieving and donning of lifejackets, retrieving medications and dressing warmly. This information is provided by means such as in-cabin reading materials and in-room video with captions. It is also provided by crew lecture at muster stations and response to individual questions at any time.
When the alarm is activated, without waiting for further direction or instruction by the crew, passengers are expected to proceed to their muster stations where they await further direction or instruction by crew. Although crew is typically present to provide direction to muster stations and other assistance, the alarm system communicates a message independent of crew actions. This alarm system is intended to result in a predetermined action by passengers.
There is a consensus that:
(1) The general emergency alarm system in public spaces should include a visible element in addition to the required audible element.
(2) The visible element of the general emergency alarm system should be as effective as the audible element. For purposes of this recommendation, the term “effective” means that whenever the general emergency alarm in public places is activated and the audible element is sounded, the visible element of the general emergency alarm will:
- Alert passengers who are deaf or hard of hearing;
- Be designed so as to minimize the “possibility or risk4“of triggering seizures in passengers who have epilepsy or photosensitivity; and
- Be activated in the same manner and with the same efficacy, immediacy and convenience as the audible element — i.e., the visible element is activated concurrently with the activation of the audible element (e.g., a single action).
(3) Non-US Flag Passenger Vessels – The U.S. Coast Guard (USCG) supported by the Cruise Lines International Association (CLIA) should propose to the International Maritime Organization (IMO) that the Maritime Safety Committee (MSC) at its 86th session adopt a work program item to develop and issue a circular/guideline with regard to a visible element to the general emergency alarm. The paper proposing this work program item should also suggest that the International Standards Organization (ISO) be invited to develop a standard on visible elements to the general emergency alarm, and request the results of any research from member organizations.
(4) US Flag Passenger Vessels – The Access Board should develop guidelines, with input from the USCG and the domestic passenger vessel industry, for visible elements of general emergency alarms on domestic passenger vessels.
(5) In developing guidelines for visible elements of general emergency alarm systems, the guidelines should:
- Meet the criteria in paragraph 2 above for determining effectiveness;
- Take into account existing standards for visible elements (NFPA 72, UL 1971) with an understanding that they may need to be adapted for passenger vessels;
- Take into account other national standards (e.g., UK, Australia, Canada); and
- Reflect current research and state of technology for effectively alerting passengers who are deaf or hard of hearing for use on passenger vessels.
Recommendation #2 – Applies to general emergency alarms and local smoke detector alarms in cabins (guest rooms).
Background: When the general emergency alarm is activated, passengers in cabins are alerted (and awakened if necessary) and are expected to proceed to muster stations without waiting for crew directions or instructions.
When the cabin smoke detector activates a cabin alarm, passengers in that cabin are alerted (and awakened if necessary) and are expected to evacuate the cabin or dial the emergency number without waiting for crew directions or instructions.
There is consensus:
(1) To provide appropriate visible, tactile or other elements, in addition to the required audible elements, to notify passengers in cabins when they are awake or asleep.
(2) The visible, tactile or other elements of alarm systems should be as effective as the audible element. For purposes of this recommendation, the term “effective” means that whenever the alarms are activated and the audible elements are sounded, the visible, tactile or other elements will:
- Alert and awaken passengers who are deaf or hard of hearing;
- Be designed (visible elements only) so as to minimize the “possibility or risk5“of triggering seizures in passengers who have epilepsy or photosensitivity;
- Be activated in the same manner and with the same efficacy, immediacy and convenience as the audible elements — i.e., the visible, tactile or other elements are activated concurrently with the activation of the passenger vessel’s or cabin’s audible elements; and
(3) Portable devices/systems should be permitted, consistent with the criteria below:
- Effective criteria in paragraph (2);
- As reliable as the general emergency alarm or local smoke detector alarm with regards to sensitivity (i.e., activates every time the audible elements are activated) and specificity (i.e., does not activate if general emergency alarm or local smoke detector alarm does not activate); and
- Capable of activating all elements.
(4) CLIA should develop guidelines for the performance, carriage, availability, and crew installation of portable devices/systems.
- CLIA should consult experts and passengers who are deaf or hard of hearing or their representatives;
- Portable devices/systems should be validated by taking into consideration age and degree of hearing loss of passengers who may be using these devices/systems;
- Guidelines should reflect current research and state of technology for effectively alerting and awakening passengers who are deaf or hard of hearing for use in cabins;
- Information should be provided to notify passengers of the availability of portable devices/systems, such as, but not limited to, advertisements, brochures, signage, and web sites; and
- Portable devices/systems should be acceptable to the passenger vessel’s administrative authority (e.g., USCG for US Flag passenger vessels), and installed in the cabin per manufacturer’s specifications.
Recommendation #3 – Applies to general emergency alarms (audible alarm or voice alert) in public spaces on passenger vessels without designated muster stations to notify or alert passengers, followed by crew instructions on how to respond.
Background: Recommendation #3 applies primarily to passenger vessels without overnight accommodations. A general emergency alarm is activated over the passenger vessel public address system, or an announcement is made about an emergency condition (like a fire in the galley). Although passengers are alerted that some type of emergency condition exists on the passenger vessel, passengers require additional information from crew to respond appropriately.
A) Safety Briefing Upon Boarding
New Construction Design Elements: There is consensus that:
- Where an audio amplification system (e.g., public address system) is provided for a safety briefing the amplification system should include the ability to transmit the audio signal to at least one type of assistive listening system (ALS) (e.g., Induction loop, FM, and Infra-red);
- The ALS should be capable of coupling acoustically to the ears and provide for a hearing aid compatible device; and
- The receiver scoping in section V219 of the final PVAG should be applicable to this recommendation.
Operational Elements: If audible instruction is provided, visual auxiliary aids and services should be provided per 28 CFR part 35.160 (DOJ title II regulations), 28 CFR part 36.303 (DOJ title III regulations), and 49 CFR part 37.5(f) (DOT regulations), which may include computers, data screens, illustrative instructions (pictures), LCD TVs, wall mounted or hand carried placards, and white boards. Industry should evaluate how to better provide safety information upon boarding to passengers who are deaf or hard of hearing.
B) Emergency Alert
New Construction Design Elements: There is consensus visible elements should be provided for emergency alerts. See recommendation #1 on development of guidelines for visible elements.
Operational Elements: No Recommendations.
C) Emergency Instructions
New Construction Design Elements: There is consensus that:
- Where an audio amplification system (e.g., public address system) is provided for emergency instructions the amplification system should include the ability to transmit the audio signal to at least one type of assistive listening system (ALS) (e.g., Induction loop, FM, and Infra-red);
- The ALS should be capable of coupling acoustically to the ears and provide for a hearing aid compatible device; and
- The receiver scoping in section V219 of the final PVAG should be applicable to this recommendation.
Operational Elements: If audible instruction is provided, there is consensus that visual auxiliary aids and services should be provided per 28 CFR part 35.160 (DOJ title II regulations), 28 CFR part 36.303 (DOJ title III regulations), and 49 CFR part 37.5(f) (DOT regulations), which may include computers, data screens, illustrative instructions (pictures), LCD TVs, wall mounted or hand carried placards, and white boards.
Recommendation #4 – There is consensus that the areas below should be further reviewed and researched.
(1) Availability and efficacy of personal notification devices in emergencies for use in alerting adults and children who are deaf or hard of hearing.
(2) Elements of alarms to ensure their effectiveness for their intended purposes of alerting and awaking passengers who are deaf or hard of hearing, while minimizing the “possibility or risk6” of triggering seizures in passengers who have epilepsy or photosensitivity. Areas of review and research include:
- Strobes to awaken passengers who are deaf;
- Rotating beacons to alert or awaken passengers;
- Flashing lights in portable devices/systems to alert or awaken passengers;
- Visible elements outdoors to alert passengers;
- Tactile elements to awaken passengers; and
- Broader bands for audible elements, including 520 Hz square wave, to awaken passengers.
(3) Effective text and visual gestural communications for use by crew in emergencies.
(4) Best and promising practices for soliciting self-identification information and encouraging passengers who are deaf or hard of hearing to respond.
Recommendation #5 – There is consensus that the Access Board should pass on the recommendation below to the Department of Transportation (DOT).
After DOT issues final regulations on passenger vessels, DOT should develop policy guidance to supplement the regulations on effective communication in emergencies.
- Methods of providing effective communications, including qualified interpretation, emerging technologies, personal display devices, portable ALS, which couple acoustically to the ears and provide for a hearing aid compatible device.
- Training of crew in regards to use and maintenance of emergency related auxiliary aids and services and interactions with passengers who are deaf or hard of hearing.
- Best and promising practices for soliciting self-identification information and encouraging passengers who are deaf or hard of hearing to respond.
- Emphasize use of auxiliary aids and services in emergency alerting in outdoor areas.
- Distribution and information signage related to ALS receivers used in emergencies.
1 The complete set of Guiding Principles is set out at http://www.access-board.gov/pvaac/alarms/docs/ principles.htm.
2 Recently, the NFPA 72 committee has proposed to amend NFPA 72 (for the 2010 version) to have a low frequency alarm signal in certain sleeping rooms for the purpose of awakening those with mild to severe hearing loss. The alarm signal would have a square wave or equivalent awakening ability. The wave would have a fundamental frequency of 520 Hz +/- 10%, and the minimum sound level at the pillow would be 75 dBA, or 15 dB above the ambient noise level, whichever is greater.
3 Note: After the final committee meeting (August 12-13, 2008), the Epilepsy Foundation (which was not present at the August meeting) believed that use of the word “possibility” when used in the context of minimizing the triggering of seizures, took the language in the draft consensus report (March 13, 2008) “down to a very minimal level of minimizing the possibility of seizures”. Accordingly, the Epilepsy Foundation wanted the phrase “minimize the risk of triggering seizures” used instead of “minimize the possibility of triggering seizures” here and in three other parts of the report where the term was used. The Cruise Lines International Association (which was present at the August 12-13, 2008 meeting) objected to using the term “risk”, and expressed concern that use of the term “risk” implies conducting a risk assessment and noted that there are not standards or guidelines for either conducting such an assessment or as to what would constitute an acceptable risk. In CLIA’s view, this was specifically discussed at the committee and was not the committee’s intent. The term “possibility or risk” is used throughout the report to highlight this issue. This was the only issue where complete consensus was not achieved.
4 See footnote number 3.
5 See footnote number 3.
6 See footnote number 3.