5.1 Findings

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:

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: