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The Public Right-of-Way Accessibility Guidelines (PROWAG) rulemaking has concluded. The PROWAG final rule has been published in the Federal Register. Please visit the Access Board’s PROWAG page for the guidelines.

ADA Access to Passenger Vessels: Finding Safety Equivalence Solutions for Weathertight Doors with Coamings

1.1 Background
The aim of this project is to find possible approaches to provide for both marine safety and disability access at doors into passenger accommodation spaces on U.S. passenger vessels. The sponsoring organization is the Architectural and Transportation Barriers Compliance Board (“the Board”, or ATBCB), an independent Federal agency, whose mission is to improve accessibility for people with disabilities. The Board’s objective was to assist designers, operators, and inspectors in improving disability access without compromising the vessel safety provisions of the coamings at weathertight doors, whose purpose is to prevent the entry of water into the passenger spaces served.

“Phase 1” preceded this report, and examined the following:

  1. The need for and application of the current governing safety regulations;
  2. The application of access provisions in the Americans with Disabilities Act Accessibility Guidelines (ADAAG) to doors on passenger vessels; and
  3. Brief technical case studies examining the design and regulatory review of existing weathertight doors on K and T boats.

The focus of this study is on two of the smaller sized classes of regulated U.S. passenger vessels, known as Subchapter T and Subchapter K boats, named after the relevant sections in Title 46 (“Shipping”) of the Code of Federal Regulations (CFR). These boats generally are less than 100 gross tons and carry more than six passengers. T and K boats make up the overwhelming majority of passenger ferries and excursion vessels, such as dinner boats and whalewatchers, which are available to the general public.

1.2 Purpose
The purpose of Phase 2 was to develop new technical guidance and design solutions for weathertight doors meeting both the U.S. Coast Guard’s (“Coast Guard”) stability regulations and the Access Board’s accessibility design standards. The Access Board specified development of two types of access solutions:

  • Door design solution. Development of manual door design guidance templates to replace coaming equipped doors with doors complying with ADAAG threshold and maneuvering space requirements while providing an equivalent level of safety as achieved with coamings, which eliminate or minimize water entry.
  • Reconfiguration solution. Development of guidance for designers, operators, and inspection personnel in the arrangement of doorways and accommodation spaces to reduce the need for coamings. The basis of the guidance is a characterization of the hazards and risks addressed by the coaming regulations, resulting in adjusted layouts that eliminate the coaming requirement for at least one door, providing the desired access to passenger accommodation areas. This approach addresses manual doors only and does not include the access solutions suggested by the Passenger Vessel Access Advisory Committee (PVAAC).

1.3 Organization of Report
Chapter 2 describes the general approach to the problem. Chapter 3 presents the risk-based methodology in detail. Chapter 4 shows the results of applying the methodology to the reconfiguration of doors on three passenger boats. Chapter 5 is a summary of findings and recommendations.