Passenger Vessels Access Advisory Committee
Chapter 3 Egress
*Standards and sections from the ADAAG Review Report referenced in this report that have not been reviewed or approved by the committee.
Note: This chapter only applies to passenger vessels subject to subchapters K or H, except where sections are referenced by chapter 12 which addresses subchapters C and T vessels.
In producing its report, the committee applied sections 207, 409, and 410 of the ADAAG Review Advisory Committee Report (ADAAG-R) to passenger vessels inspected under Coast Guard regulations contained in subchapters K and H. A number of committee report provisions are only triggered when a requirement (not related to accessibility) is mandated by the Coast Guard. The committee realizes that not all passenger vessels fall under Coast Guard jurisdiction, however, due to time limitations the committee selected to only develop recommendations for subchapter K and H Coast Guard inspected vessels. However, the small passenger vessel subcommittee has adopted 207.2 and its exception for application to subchapter C and subchapter T vessels under 100 tons.
Because of the reference to Coast Guard requirements, a number of ADAAG-R terms have been replaced with Coast Guard terms or changed for clarity reasons. For example, the ADAAG-R term “Accessible Means of Egress” was changed to “Accessible Means of Escape.” Likewise, the ADAAG-R term “Area of Refuge” was changed to “Area of Temporary Refuge.”
Advisory - Both the US Coast Guard regulations and the regulations found in the International Convention for the Safety of Life at Sea (SOLAS) (1974 as amended), require safety systems that provide an equivalent level of safety to the areas of safe refuge and the means of escape required by these recommendations.
These safety systems can include: supervised and monitored sprinkler systems in all public and crew accommodations throughout the ship; segregated multiple fire zones; supervised smoke detectors with centralized alarm centers; protected routes of egress from muster stations to lifeboats; ventilation system dampers to prevent the spread of smoke and fire; limited use of combustibles in construction; and limitations on the combustible loading in each space.
Therefore, it is deemed that passenger vessels that comply with the requirements of SOLAS and/or with US Coast Guard regulations 46 CFR subchapters H and K, fully comply with these recommendations.
Note: Several recommendations incorporate engineering standards published by ASME, ANSI, BHMA and other engineering standards setting organizations. The committee did not review these standards, which were included by reference. Therefore, the committee recommends that the competent regulatory drafting authorities and others specifically review all referenced industry standards to determine their suitability in designing equipment for use onboard ships in the marine environment.
Note: The committee recognizes that these recommendations may apply to vessels not built or constructed in U.S. shipyards, and to systems not manufactured in the United States. Therefore, the committee recommends that the final regulations recognize and accept the use of other equivalent standards, such as the International Standards Organization standards and recommendations, International Electro-Technical Commission Engineering standards and recommendations, Japan Engineering Standards, etc.
106.5 Defined Terms
Area of Temporary Refuge. An area where people who are unable to use stairs may remain temporarily to await further instructions or assistance during emergency evacuation.
Comment: Under Coast Guard regulations, an area of refuge is a large fire protected space which could hold hundreds of passengers, similar to a horizontal exit in the building environment. However, the area of refuge required by ADAAG-R would typically be a space capable of holding one or two wheelchairs. To avoid confusion between the Coast Guard’s “area of refuge” and ADAAG-R’s “area of refuge” and still retain the access objective of ADAAG-R, the committee changed the ADAAG-R term to “Areas of Temporary Refuge” and kept the ADAAG-R definition for areas of refuge found in section 106.5.\
207 Accessible Means of Escape
Comment: Section title changed from “Accessible Means of Egress” to Accessible Means of Escape” for consistency with Coast Guard terminology.
Summary of Coast Guard Requirements: Note: Some regulations which may apply to specific cases have been omitted for simplicity, and some minor interpretations have been made. Refer questions to Kevin Kiefer, 202-267-0144, U.S. Coast Guard.
Means of escape (MOE) from areas accessible to passengers or where crew may be quartered or normally employed to the embarkation point (place where passengers/crew disembark the vessel in an emergency). This route includes any intermediate evacuation areas if the location of muster stations or refuge areas differs from the location of embarkation areas. The two exits should be as widely separated so as to minimize the possibility of one incident blocking both escapes.
Vessel Type - Subchapter H (46CFR72.10)
Total MOE - 2
- At least one MOE must be: 1. independent of watertight doors (72.10-5(a)), 2. a protected stairway (72.05-20(e)).
- MOE can be: 1. normal exits; 2. emergency exits; 3. passageways/corridors; 4. stairways.
- MOE cannot be: 1. elevators (72.10-5(b)); 2. stairways serving only a space and a balcony to a space (72.10-5(c)); 3. vertical ladders; 4. deck scuttles. Note - A vertical ladder/scuttle may be used as the secondary MOE for crew only, where it can be demonstrated that the installation of a stairway would be impractical (72.10-15(a)).
Vessel Type - Subchapter K (46CFR116.500)
Total MOE - 2
- At least one MOE must be: 1. independent of watertight doors (116.500(a)); 2. a protected stairway if it spans more than two deck levels (116.438(m)) or if carrying more than 600 passengers (more than 49 overnight) (116.438(a)).
- MOE can be: 1. normal exits (116.500(c)); 2. emergency exits; 3. passageways/corridors; 4. stairways; 5. ladders; 6. deck scuttles; 7. windows.
- MOE cannot be: 1. elevators; 2. stairways serving only a space and a balcony to a space (116.438(l)).
Vessel Type - Subchapter T (46CFR177.500)
Total MOE - 2
- At least one MOE must be: 1. independent of watertight doors (117.500(a)).
- MOE can be: 1. normal exits (177.500(c)); 2. emergency exits; 3. passageways/corridors; 4. stairways; 5. ladders; 6. deck scuttles; 7. windows.
- MOE cannot be: 1. elevators.
Vessel Type - SOLAS (II-2 reg. 28).
Total MOE - 2.
- At least one MOE must be: 1. independent of watertight doors (II-2/28.1.1); 2. a protected stairway (II-2/28.1.5).
- MOE can be: 1. normal exits; 2. emergency exits; 3. passageways/corridors; 4. stairways; 5. ladders in machinery spaces only. Note: A steel ladder providing a continuous fire shelter may be used in machinery spaces (II-2/184.108.40.206).
- MOE cannot be: 1. elevators; 2. stairways serving only a space and a balcony to a space (II-2/28.1.7).
207.1 General. Accessible means of escape shall be provided in accordance with 207.
207.2 Number Required. All spaces required to be accessible shall be provided with not less than one accessible means of escape complying with Coast Guard requirements. Where more than one means of escape is required by the Coast Guard from any accessible space, each accessible space shall be served by not less than two accessible means of escape. Each required accessible means of escape shall comply with 409 and shall be a continuous and unobstructed way of exit travel to an area of refuge complying with Coast Guard requirements, then, if applicable, to mustering and lifeboat embarkation locations, or alternatively to the point of disembarking the vessel.
EXCEPTION: Where a required means of escape is permitted by the Coast Guard to include a ladder, go through a window, or go through a deck scuttle, the corresponding accessible means of escape is not required.
Comment: ADAAG-R section 207.1 is titled “General” and determines the required number of accessible means of egress. For clarity, the committee added a charging statement to section 207.1, similar to what is found in ADAAG-R section 206.1 which addresses accessible routes, and kept the title as “General.” A second section, 207.2, titled “Required Number” was added, and it determines how many accessible means of escape (MOE) are required from a space required to be accessible. The committee was uncomfortable with the words “each accessible portion of the space” in the phrase “each accessible portion of the space shall be served by not less than two accessible MOE.” Therefore, the words “portion of the” was removed.
Comment: The committee was concerned that because an accessible means of escape may not coincide with a means of escape required by the Coast Guard, the degree of protection would not be the same. To rectify this problem, the committee added at the end of the first sentence a requirement that the accessible means of escape comply with Coast Guard requirements.
Comment: In the last sentence of 207.2, the committee added a phrasing which identifies the point to which the accessible means of escape must connect – an area of refuge (AOR) complying with Coast Guard requirements. The committee realized that a Coast Guard required MOE may continue beyond an AOR to a point where passengers could disembark the vessel in an emergency and therefore believed that the accessible MOE should also connect to such a point. In some cases, the point of emergency embarkation is clearly designated, such as a life boat station. In other cases, the point of emergency embarkation is not specifically designated and may be anywhere along the sides of the vessel.
Comment: The exceptions that existed under ADAAG-R 207.1 were moved to other sections or deleted for clarity reasons. A new exception under 207.2 was added to address situations where the committee felt it was unreasonable to require an accessible MOE where the Coast Guard’s required MOE went through a major barrier.
Example: A passenger vessel inspected by the Coast Guard under subchapter K has a central passageway running nearly the length of the vessel. Passenger cabins, for two occupants each, are provided on both sides of the passageway and an enclosed stairway connecting the main deck above is located at both ends. An accessible elevator, which does not conform to 409.3, provides vertical access to the main deck and opens to the passageway at its midpoint. Two cabins are accessible and are located at the forward and after end of the passageway. For purposes of this example, except for these cabins, no other spaces on this deck are accessible. Under 46 CFR 116.500, the Coast Guard requires that each cabin along this passageway (including the accessible cabins) be provided with two MOE. Thus, for each cabin, one MOE starting at the cabin doors uses the forward stairway and the second MOE starting at the cabin doors uses the after stairway. Therefore, under 207.2, two accessible MOE must be provided from each accessible cabin and connect to an area of refuge complying with Coast Guard requirements. From the area of refuge, the two accessible MOE must connect to mustering and lifeboat embarkation locations, if such locations are provided, or to a point of disembarking the vessel per a Coast Guard approved emergency evacuation plan. The two accessible MOE may connect to the same AOR, but these two accessible MOE should be as widely separated so as to minimize the possibility of one incident blocking both escape paths.
Comment: The committee considered requiring the accessible MOE to coincide with the Coast Guard required MOE. In some situations, the accessible MOE may have to deviate from the Coast Guard MOE, for example, when accessing an accessible evacuation elevator complying with 407 and 409.3. The committee decided to indicate in its report that the two paths should coincide where feasible.
207.3 Elevators. Where an accessible means of escape, from a space required to be accessible, travels vertically four or more decks, at least one accessible means of escape shall contain an elevator complying with 407 and 409.3.
EXCEPTION: This section does not apply where a means of vertical access is not required.
Comment: Excluding the exception, the committee basically adopted the language from ADAAG-R section 207.2. Note: Access Board staff and Coast Guard support staff investigating whether the Coast Guard would allow an accessible MOE to be an elevator. The committee developed its recommendations based on the assumption that an elevator will be allowed to be used as an accessible MOE.
207.4 Signs. At exit stairways and elevators serving a required accessible space, but not serving as an accessible means of escape, directional signs indicating the location of the accessible means of escape shall be provided. Such signs shall comply with 703.4*.\
409 Accessible Means of Escape
409.1 General. Each required accessible means of escape shall be a continuous and unobstructed way of exit travel to an area of refuge complying with Coast Guard requirements, then, if applicable, to mustering and lifeboat embarkation locations, or alternatively to the point of disembarking the vessel, and shall consist of one or more of the following components:
a. walking surfaces complying with 403;
b. doors and doorways complying with 404;
c. ramps complying with 405;
d. curb ramps complying with 406;
e. exit stairways complying with 409.2; and
f. elevators complying with 407 and 409.3.
Comment: New 409.1 basically follows ADAAG-R section 409.1. Subsections were added for clarity reasons. In addition, language has been included which is similar to 207.2 regarding the emergency embarkation point.
409.2 Exit Stairways. An exit stairway to be considered part of an accessible means of escape:
a. shall be enclosed, where at least one of the corresponding means of escape from the accessible space is required by the Coast Guard to be enclosed;
b. shall have stairs complying with 504* and shall have a clear width of 48 inches (1220 mm) minimum between handrails; and
c. shall either incorporate an area of temporary refuge complying with 410 within an enlarged deck-level landing, accessed either from an area of temporary refuge complying with 410, or accessed from an area of refuge complying with Coast Guard requirements.
EXCEPTION 1. This requirement shall not apply to exit stairways serving only one stateroom.
EXCEPTION 2. This requirement shall not apply to exit stairways in vessels protected by a Coast Guard approved sprinkler system, or having a fire load of less than 3 lbs. per sq. ft.
EXCEPTION 3. The clear width of 48 inches (1220 mm) between handrails is not required for exit stairways accessed from an area of refuge complying with Coast Guard requirements.
EXCEPTION 4. This requirement shall not apply to exit stairways serving open decks.
EXCEPTION 5. Subchapter K vessels shall be permitted to have exit stairways with a clear width of 36 inches (915 mm) minimum between handrails.
Comment regarding Subsection (a): In subchapter H, the Coast Guard requires at least one MOE to be a protected stairway (see summary). In subchapter K, at least one protected stairway is required if it spans more than two deck levels or if carrying more than 600 passengers or more than 49 overnight passengers. Therefore, where the Coast Guard requires a MOE to travel through a protected stairway, subsection (a) requires that at least one accessible MOE serving an accessible space also travel through a protected stairway. Because the second Coast Guard MOE is permitted to travel through an open stairway, subsection (a) permits the second accessible MOE to also travel through an open stairway.
This provision did not exist in ADAAG-R 409.2 because in the building environment “exit stairways” are typically enclosed. Since the Coast Guard does not require all exit stairways to be enclosed, the committee added this subsection to indicate when an accessible MOE stairway must be enclosed. Although an open stair may be permitted, areas of temporary refuge may still be required – see section 409.2 regarding technical provisions for exit stairways and associated areas of temporary refuge.
Comment: Subsection (b) is consistent with a similar requirement in ADAAG-R 409.2. The committee notes that ADAAG-R section 504 needs to be reviewed.
Comment: Subsection (c) is consistent with similar requirements in ADAAG-R 409.2. A Coast Guard “area of refuge” is similar to a “horizontal exit” in the building environment.
Comment: Exception 1 is consistent with ADAAG-R 409.2 Exception 1.
Comment Exception 2: In Coast Guard inspected vessels, fire alarms sound at a central control station, generally the bridge, whereupon crew investigates the cause of the alarm and activates (if needed) sprinkler systems. The committee believes that the degree of protection provided by a Coast Guard approved sprinkler system is similar to the supervised automatic sprinkler systems found in the building environment. The word “throughout” was removed because of the confusion over the meaning of “throughout” a vessel. The committee also added a fire load provision, believing that if the fire load was less than 3 lbs per square feet, an equivalent level of fire protection exists as provided with a sprinkler system. The 3 lbs fire load value is from 46 CFR 116.427 which applies to low risk spaces.
Comment: Exception 3 is consistent with similar requirements in ADAAG-R 409.2 Exception 3. A Coast Guard “area of refuge” is similar to a “horizontal exit” in the building environment.
Comment: Exception 4 is modified to refer to open decks instead of open parking garages. The committee believes that the same degree of fire protection is present on open decks of passenger vessels as in open parking garages.
409.3 Elevators. An elevator to be considered part of an accessible means of escape shall comply with the requirements of Rule 211* of ASME/ANSI A17.1, or an equivalent marine standard, and emergency power shall be provided. The elevators shall be accessed from either an area of temporary refuge complying with 410 or an area of refuge complying with Coast Guard requirements.
EXCEPTION 1. Elevators are not required to be accessed from an area of temporary refuge or an area of refuge complying with Coast Guard requirements in open air spaces.
EXCEPTION 2. Elevators are not required to be accessed from an area of temporary refuge or an area of refuge complying with Coast Guard requirements in vessels protected by a Coast Guard approved sprinkler system, or having a fire load of less than 3 lbs per sq. ft.
Comment: As the words “emergency power” are more appropriate for the maritime environment, the committee replaced the words “standby power” with “emergency power”.
410 Areas of Temporary Refuge\
410.1 General. Where areas of temporary refuge are required, they shall comply with 410.
410.2 Location. Each area of temporary refuge shall be accessed from the space it serves by an accessible route which serves as an accessible means of escape. The maximum travel distance to an area of temporary refuge shall not exceed the travel distance permitted for the occupancy by the Coast Guard. Every area of temporary refuge shall have direct access to an exit stairway complying with 409.2 or an elevator complying with 409.3.
410.3 Size. Each area of temporary refuge shall be sized to accommodate one wheelchair space complying with 305.3 for each 200 occupants or portion thereof, based on the occupant load of the area of temporary refuge and all areas served by the area of temporary refuge. Such wheelchair spaces shall not overlap the required means of escape width set by the Coast Guard. Access to any required wheelchair space shall not be through more than one adjoining wheelchair space.
410.4 Construction. Each area of temporary refuge shall comply with Coast Guard construction requirements for an area of refuge.
Comment: The committee believes that Coast Guard construction requirements for an area of refuge provides an equivalent degree of protection as the requirements in 410.4.
410.5 Smoke Resistance. Every area of temporary refuge shall comply with Coast Guard smoke resistance requirements for an area of refuge.
Comment: The committee believes that Coast Guard construction requirements for an area of refuge provides an equivalent degree of protection as the requirements in 410.4. The exceptions were removed due to confusion. Section 410.5.1 was removed because in emergency situations on board Coast Guard inspected vessels, unlike buildings, elevator shafts are not pressurized.
410.6 (Option #1) Communication System. Every area of temporary refuge shall be provided with an accessible two-way communication system between the area of temporary refuge and the bridge or other continuously manned station. The communication system shall have both audible and visible signals.
410.6 (Option #2) Communication System. Every area of temporary refuge shall be provided with a two-way communication system between the area of temporary refuge and the bridge or other continuously manned station. The minimum requirements of this system include:
a. a mechanism to signal from the area of temporary refuge to the central control station that fact that the area of temporary refuge is occupied. The mechanism must operate in one physical motion (i.e., push button or lever handle); and
b. a mechanism to acknowledge from the central control station to the area of temporary refuge the fact that a signal from the area of temporary refuge has been received. This mechanism must result in a visible and audible signal at the area of temporary refuge.
Comment: Two options were provided. One is more detailed than the other.
410.7 Instructions. In each area of temporary refuge provided with a two-way communication system, instructions on the use of the area under emergency conditions shall be posted adjacent to the communications system. The instructions shall include:
1. Directions to other means of escape;
2. Advice that persons able to use the stair towers do so as soon as possible unless they are assisting others;
3. Information on planned availability of assistance in the use of stairs or supervised operation of elevators and how to summon such assistance; and
4. Directions for use of emergency communications system.
Comment: The committee discussed whether such instructions should be in Braille and large/raised print. It was decided that due to the number of words such instructions would contain, and the minimum size requirement of 5/8 inch for the raised letters (see 703.2.3.4), an entire wall may be covered with Braille and raised letters. Such a situation may be unusable for persons who would need these accommodations.
410.8 Identification. Each area of temporary refuge shall be identified by a tactile sign stating “Area of temporary refuge” complying with 703.2* and including the International Symbol of Accessibility complying with *703.7. A sign shall be located at each door providing access to the area of temporary refuge. The sign shall be illuminated as required for exit signs where exit sign illumination is required.