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

1.1 Purpose of Report
The purpose of this report is to examine 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 Architecture 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 here is to assist designers and operators in improving disability access without compromising the vessel safety provisions of the high sills at some doorways. The high sills are known as coamings in marine parlance and their purpose is to prevent the entry of water into the passenger spaces served.

This report includes the results of “Phase 1” of the project, which are:

  1. The need for and application of the current governing safety regulations; and

  2. Brief technical case studies examining the design and regulatory review of weathertight doors on K and T boats.

Phase 2 is to follow and will be a research project to develop Americans with Disability Act (ADA) Access Guidelines for complying manual door designs which provide an equivalent coaming protection.

The focus of this study is on the small-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. Other sections of Title 46 regulate smaller boats carrying up to six passengers and larger vessels of greater than 100 gross tons. 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, and are the focus of this study. Vessels operating in international waters and subject to international marine safety codes are not included in the study.

1.2 Organization of Report
Chapter 2 is a brief description of the relevant safety regulations and the underlying safety philosophy and the ADA Accessibility Guidelines mobility-impaired access guidelines, as well as the current practice in the U.S. passenger fleet. Chapter 3 presents the case studies on passenger vessels with weathertight doors having no coamings. Chapter 4 is a summary of findings and recommendations.