CLIA Annotations and Comments
On the Passenger Vessel Emergency Alarms Advisory Committee
Draft Consensus Document (March 19, 2008)

Note: Anotations in this document which highlighted individual member changes that modified the February 22 and March 13, 2008 versions to create the March 19 version have been removed to reduce confusion regarding CLIA’s comments.

Premise and Definitions: Alarm practices and systems on ships are different than alarm practices and systems on land. The term visible alarms may include other appropriate visible signaling methods to communicate the general emergency alarm and local smoke detector alarm that do not trigger seizures in individuals who have epilepsy.

Recommendation #1 – Applies to general emergency alarms in public spaces which summon passengers to designated muster stations. Cabins (guest rooms) are addressed in recommendation #2 below.

Example: Prior to getting underway or in the course of getting underway, the crew of a vessel instructs the passengers are provided with information on what actions the passengers must are expected to take when the general emergency alarm is activated (e.g., seven short sound blasts on the ships whistle, siren or similar tones and one long sound blast or tone). The instruction 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 of 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 automatically head are expected to proceed to their muster stations where they await further direction or instruction by crew members. Although crew members may be are typically present and may to provide direction to muster stations and other assistance, the alarm system communicates a message independent of crew actions. This alarm system produces an automatic is intended to result in a predetermined action in by passengers which is similar to how building occupants respond to fire alarms.

CLIA note: We recommend deleting “which is similar to how building occupants respond to fire alarms because in a building, occupants leave the building. On a ship this is not the case.

There is consensus:

  1. There is consensus To provide a visible indication of the general emergency alarms in [interior] public spaces. to communicate the message of the general emergency alarm.

    CLIA Partially Agrees: We are not aware or convinced that exterior visible elements have been developed or have been demonstrated to be effective.

  2. That the visible system should be reliable, effective,and integrated into the ship’s general alarm system.
    1. “Reliable” means the visible alarms are activated with no meaningful delay whenever the general emergency alarm is activated.
    2. “Effective” means the visible alarms will should alert individuals with hearing loss or deafness and does not is designed so as to minimize the possibility to trigger of triggering seizures in individuals who have epilepsy.
    3. “Integrated into the ship’s alarm system” means that the activation of the visible element to the general alarm is essentially simultaneous to the activation of the ship’s audible general alarm. one outcome, audible and visible (e.g., one button).
  3. That technical standards need to be developed for visible alarms on vessels meeting the above three twofactors for interior and exterior (daylight) public spaces.

    CLIA Partially Agrees: While technical standards for visual notification appliances in interior spaces can be developed based upon guidance from similar standards such as those issued by NFPA, CLIA is concerned that the standards developed for buildings may not be effective in a cruise ship and marine environment. This is particularly true for our exterior spaces. Deployment of fixed notification devices should not be required until they are shown to be effective. Technical standards should be developed by IMO with input from flag states, industry and appropriate systems experts.

    We are also concerned that technical standards will be overtaken as technology progresses. CLIA recommends that performance standards be developed versus prescriptive requirements that we have seen through experience to be outdated as new technologies are developed.

    1. Recognize existing standards (NFPA 72, UL 1971) as current best thinking for visible alarms (notification appliances) in interior spaces but may need to be adapted for vessels.

      CLIA note: While we do not disagree that the NFPA standards should be modified (versus adapted) for vessels, it should be recognized that NFPA must be the organization that is responsible for editing or modifying their own standards.

    2. In developing standards (either technical or performance) Review other national standards (e.g., UK, Australia, Canada) should be reviewed and taken into account.
  4. That thefollowing process be used for developing technical standards (need support from other countries for b, c & d):

    Short Range

    1. Request that CLIA/PVA to develop an industry standard guideline which could be recognized by Access Board as best practice/safe harbor.

      CLIA Partially Concurs: While CLIA could develop an industry guideline, there are several reasons why development of an industry standard for a system of visual alarms integrated into the ship’s general alarm system is not appropriate;

      Request The US Coast Guard supported by CLIA should propose to the International Maritime Organization (IMO) that the Maritime Safety Committee (MSC) adopt a work program item to develop and issue a circular/guidelines on with regard to a visual element to the general alarms. based on CLIA/PVA document.
      • We have already discussed that a visual element integrated with the ship’s general alarm system would have to be done at IMO and adopted as an international standard. This has been confirmed by the USCG and by the Secretary General of IMO as the appropriate process. Accordingly, an industry standard as a stand alone would not accomplish much.
      • We have been informed that development of a standard where none exists invites liability issues that the industry may not be willing or able to undertake.

      CLIA is willing however to develop an industry guideline for in-room portable kits. (Recommendation 2 below)

      Long Range

    2. CLIA Concurs: Such a request to the MSC would have to be put forward by one or more IMO member states. In this particular case, because this is a US Access Board matter, it would appear that the US Coast Guard would be the most appropriate to propose this work item. The Coast Guard could be supported in this effort by CLIA. PVA has no standing at IMO and would not be able to formally support this proposal. CLIA and PVA would then work with IMO to develop appropriate guidance.

    3. Request International Standards Organization (ISO) to develop an ISO standard on visual alarms.

      CLIA Partially concurs: If the US wants ISO to develop the standard then this route should be recommended to IMO in their paper asking for such a work program item. Normally, when such a work item request is received by IMO, they would ask ISO to develop the matter if that is what is recommended and accepted by the Committee. To ask that these two items be separately undertaken may cause confusion (remember this is an international community of many member states). The most straight forward and typically used methods are the quickest and most easily implemented.

      Additionally, when ISO is asked to undertake a project such as this, they immediately ask for a sponsor to coordinate, act as the secretariat and to fund the effort. Is the US government willing to do this? The US Coast Guard has acted in this capacity in the past.

      The Coast Guard should be consulted before agreeing to this recommendation.

    4. Request International Maritime Organization (IMO) adopt ISO standard as an International Convention of Safety of Life at Sea (SOLAS) requirement.

      CLIA Disagrees: This is part of the process and would be included in the wording of the requested work item. This advisory committee has no standing to direct the IMO in its deliberative process and if done properly in the first place, this step will not be necessary.

  5. Who should be involved in the CLIA/PVA process? That CLIA should be invited and encouraged to consult with technical experts; deaf and hard of hearing individuals or individuals representing deaf and hard of hearing advocacy groups; and government regulators.

    CLIA Partially Agrees: If CLIA undertakes to develop an industry guideline with regard to portable room kits, it may choose to consult with individual experts or persons with disabilities. CLIA opposes any mandate to undertake such a project in what would essentially be a public forum if the Access Board and advocacy groups were to be directly involved.

    That technical standards should be acceptable to and not conflict with requirements of the vessel’s administrative authority (USCG, foreign flag administration).
    1. Technical experts on ship design and alarms.
    2. Individuals with expertise in the needs of persons with hearing loss, deafness, and epilepsy.
    3. Access Board.

Recommendation #2 – Applies to general emergency alarms and local smoke detector alarms in cabins (guest rooms).

Example 1: The general alarm is activated thus activating the portable visual general alarm kit in the cabin, and passengers in the cabins are alerted (and awaken if necessary) and automatically head are expected to proceed to the muster stations without waiting for crew directions or instructions.

CLIA Agrees: This scenario is relatively straight forward. The GA is activated, portable room kits also activate the bed shaker, flashing light and any other elements as agreed and the occupants behave in a manner consistent with response to the general alarm.

Example 2: The cabin smoke detector activates a locally sounding alarm in a cabin alarm, and passengers in that cabin are alerted (and awaken if necessary) and automatically leave the cabin without waiting for crew directions or instructions.

CLIA note: The locally sounding smoke alarm and in this case visual alert and shaking of the bed are intended to alert the cabin occupants to the possibility of smoke in the cabin. In this case, the locally sounding alarm may be one that is installed on a existing ship in accordance with the CLIA recommendation resulting from the NTSB recommendation (in which case the ships smoke detector has probably also activated on the bridge) or a locally sounding alarm from the ships system that also alerted the bridge (in accordance with new SOLAS regulations),

In any event, the sounding of the locally sounding smoke alarm is not equated to the activation of the general alarm. Accordingly, in accordance with IMO expectations that passengers are to be trained to recognize and respond to only one alarm – the general alarm, passengers are not instructed with regards to actions to take in the event of a locally sounding smoke alarm. Cabin occupants are expected to react as they would at home, that is, if there is smoke, get out of the cabin and if not, to dial 911 or other designated emergency number.

There is consensus

  1. There is consensus To provide appropriate visible and tactile alerts alarms to notify passengers in cabins with regard to an audible smoke alarm activation when they are awake or asleep. Based on research there may be other methods to awaken sleeping hard of hearing passengers.¹

    CLIA note regarding footnote 1: If portable in-room kits are accepted and CLIA agrees to develop an acceptable performance standard for such kits, it may be possible to include the newly proposed low frequency, square wave audible signal. If that signal is approved, it could be incorporated much more quickly than any US regulatory process or IMO process.

    However, for ships, this should have a predetermined minimum sound level as IMO requires the GA to have a certain sound level over background then the two standards would be climbing on each other. Additionally, if this is intended for use in rooms where the occupants can not hear other sounds, then a reasonable level above the general background noise level for that type of space (passenger cabin) would be appropriate.

  2. The visible and tactile alarm systems in cabins should be reliable, effective, and integrated into activate with no meaningful delay upon activation ofthe ship’s general alarm system.Portable systems that meet the above criteria should be permitted. Portable systems should be approved by the vessel’s administrative authority (USCG, foreign flag administration), and installed in the cabin per manufacturer’s specifications. Signage Information should be provided to notify passengers of the availability of portable systems.
    1. “Reliable” means the visible and tactile alarms should work when they are activated with no meaningful delay whenever the general emergency alarm or local smoke detector alarms are activated.
    2. “Effective” means the visible alarms will should alert individuals with hearing loss or deafness and does not is designed so as to minimize the possibility to trigger of triggering seizures in individuals who have epilepsy.
    3. “Integrated into the ship’s alarm system” “Activate with no meaningful delay” means that the system in the cabin and the alarm system in the bridge/safety center will be interconnected by hardwire,radio-frequency, or other effective means.

      CLIA note: If this system must be hardwired, it would then require IMO regulation or guidance, alteration of the emergency generator load requirements and alteration of the emergency switch board and load shedding requirement and guidelines. CLIA does not believe this should be necessary to accomplish the action envisioned by the Advisory Committee.

      CLIA Agrees to portable systems to accomplish the above goals. CLIA can agree to develop guidelines for carriage, availability, and crew installation of these devices as well as developing performance standards. The advantage of using a portable in-room device is that

      1. It is not tied into the ships general alarm system and thus would not require IMO regulation or guidance
      2. It can be placed in any room thus obviating the need for inventory management of specially connected rooms.
      3. Cabins would not have to be specially wired to the emergency generator thus avoiding a myriad of issues.
  3. Technical standards need to be developed for visible and tactile alarm system in cabins. Use same process as under recommendation #1.

Recommendation #3 – Applies to emergency alarms (audible alarm or voice alert) in public spaces to notify/get passenger attention, followed by crew instructions on how to respond.

Example: A general alarm is sounded over the vessel public address system, or an announcement is made about an emergency condition (like a fire in the galley). Although passengers may be aware that the alarm is activated or know some type of emergency condition exists on the vessel, without direction or instruction by the crew, passengers are unsure of where to go in the vessel and how to respond.

A) Safety Briefing Upon Boarding

New Construction Design Elements: If an audio amplification system (e.g., public address system) is provided for a safety briefing, the amplification system must include the ability to transmit the audio signal to at least one type of assistive listening system (ALS) (e.g., Inductive loop, FM, and Infra-red). The ALS will be hearing aid compatible and will include more than one option of hearing aid compatible coupling deviceinclude coupling devices and hearing aid compatibility. Use the 2006 draft vessel accessibility guidelines for determining the number of receivers.

CLIA note: While this is essentially intended to apply to smaller vessels without designated muster stations, we would not agree to use of the 2006 PVAG if it were to ultimately be applied to ships muster stations. We also remain concerned with regards to interference or adverse impact of trying to utilize such a system when surrounded by metal.

Secondly, we note that while this is a recommendation, it is also an area noted for further research. We do not believe that it can be a solid recommendation if further research is needed.

Operational Elements: If audible instruction, there must be a visual auxiliary aids and services 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 could 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 info to persons with hearing loss or deafness upon boarding. Concerns about DOT NPRM include: the use of auxiliary aids and service for effective communication over the full spectrum of hearing loss, including visual and audible.

B) Emergency Alert

New Construction Design Elements: There is consensus to provide visible alarms for emergency alerts. See recommendation #1 above on development of technical standards for visible alarms.

Operational Elements: No Recommendations.

C) Emergency Instructions

New Construction Design Elements: If an a permanently installed audio amplification system is provided for emergency instructions, the amplification system must include the ability to transmit the audio signal to at least one type of ALS (e.g., Inductive loop, FM, and Infra-red). The ALS will be hearing aid compatible and will include more than one option of hearing aid compatible coupling device include coupling devices and hearing aid compatibility. Use the 2006 draft vessel accessibility guidelines for determining the number of receivers. Emergency power must be provided for ALS, if amplification system has emergency power.

CLIA note: CLIA does not concur with the penultimate sentence above about the number of receivers as we have previously objected to these numbers in our comments to the Access Board. Additional review and discussion is needed to determine the right number of devices needed to assist passengers.

Operational Elements: If audible instruction, there must be a visual auxiliary aids and services 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 could include computers, data screens, illustrative instructions (pictures), LCD TVs, wall mounted or hand carried placards, and white boards.

Recommendation #4 – Areas of additional research and recommendations.

  1. Have Research availability of or development of assistive listening system at muster stations that will be hearing aid compatible and will include more than one option of hearing aid compatible coupling device include coupling devices and hearing aid compatibility.

    CLIA note: This is a recommendation for research yet is worded as a recommendation for regulation. CLIA has redrafted accordingly.

  2. Review/Research availability and efficacy of personal notification devices.
  3. Review/Research notification appliances to ensure their effectiveness for their intended purposes for persons who are deaf or hard of hearing, ensuring no effects on persons with epilepsy.Effective text and visual gestural communications.
    • Using strobes to awaken those passengers who are deaf.
    • Rotating beacons to alert or awaken passengers
    • Flashing lights in portable ADA kits to alert or awaken passengers
    • Visible signaling outdoors to alert passengers
    • Tactile notification appliances to awaken passengers
    • Use of broader bands for audible general alarms, including 520 Hz square wave, to awaken passengers.

      CLIA Notes:

      1. What agency is expected to do this research?
      2. It is quite well known that lights, even strobe lights will not reliably awaken a sleeping person. Should additional research be funded through the appropriate governmental agencies so that experts in these fields can determine the best guidance to be applied before standards are developed for 1 & 2?
      3. Hopefully we are talking only about awaking persons who are sleeping in their own beds and not on deck furniture, lounge chairs, other persons cabins etc.
  4. CLIA note: While we do not oppose this as a research suggestion, it appears that the suggestion lacks information and sufficient specifics to take forward. We would suggest rewording.

Recommendation #5 – Supplemental emergency communications by public address system or crew.

  1. Industry and disability organizations desire a want to dialog with DOT on effective emergency communications. DOT rule on effective communications covers all kinds of communications on vessels, including emergency communications.
  2. Methods of providing effective communications, including emerging technologies, personal display devices, portable ALS which will be hearing aid compatible and will include more than one option of hearing aid compatible coupling device include coupling devices and hearing aid compatibility, printed material, and sign language interpreters.
  3. What does effective communication mean in emergencies?
  4. Training of crew in regards to the needs of persons who are deaf or hard of hearing, including learning about hard of hearing and deaf cultures.

    CLIA Comment: This is not an emergency alarm equal access matter, this is a training issue that is being addressed by the DOT NPRM. It should be deleted.

  5. No one should be on a cruise ship without access to emergency info. Industry needs to ask the right questions, and provide customer information on web sites and promotional material, to encourage people to self-ID. If some people don’t self-ID, the ship needs a minimum number onboard devices anyway.

    CLIA Comment: The matter of self identification needs to be considered in the minimum scoping requirements. We object to the current PVAG numbers as they are not reasonable. The matter requires further discussion.

1 Recently, the NFPA 72 committee has proposed (accepted in principle) to amend section 11.3.7 of NFPA 72 (for the 2010 version) to have a low frequency alarm signal in certain sleeping rooms. 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.