October 14, 2008
On August 13, 2007, the Architectural and Transportation Barriers Compliance Board (Access Board) established an advisory committee to make recommendations on issues related to the effectiveness of emergency alarm systems for passengers who are deaf or hard of hearing on passenger vessels. [72 FR 45200 (August 13, 2007)]. The purpose of this report is to describe the mission and operating protocols of the Committee, the deliberative process used by the Committee to reach a consensus, and the Committee’s recommendations.
The establishment, membership and functioning of the Committee were guided by a Charter and Operating Protocols.
The Charter (http://www.access-board.gov/pvaac/alarms/charter.htm) established the “Passenger Vessel Emergency Alarms Advisory Committee” (The Committee). The Committee was required to function in accordance with the Federal Advisory Committee Act (FACA) and the administrative guidelines issued by the General Services Administration’s Committee Management Secretariat.
The Committee was composed of a cross section of organizations representing a variety of interests regarding emergency alarms on passenger vessels, including passenger vessel industry organizations, organizations representing people who are deaf or hard of hearing and other people with disabilities, and technical experts.
With respect to the scope and objectives of the Charter, the Committee was authorized to make recommendations to the Access Board on issues related to emergency alarm systems for proposed accessibility guidelines for passenger vessels subject to the Americans with Disabilities Act (ADA). The Committee acted solely in an advisory capacity to the Access Board.
Consistent with the scope and objectives, the Committee was authorized to make recommendations to the Access Board on issues related to the effectiveness of emergency alarm system design and practices for passengers who are deaf or hard of hearing on passenger vessels. More specifically, the Committee was authorized to make recommendations to the Access Board on:
In the course of considering alternative recommendations that meet the needs of passengers who are deaf or hard of hearing, the Committee recognized the need to take into consideration the potential effect of the recommendations on other passengers with disabilities, including, but not limited to, passengers with epilepsy or photosensitivity.
In accordance with the Operating Protocols, which also were adopted on September 19, 2007 (http://www.access-board.gov/pvaac/alarms/protocols.htm) the Committee meetings were conducted and work performed in a spirit of collegiality and consensus. The goal was to find common ground. A facilitator was employed to help the Committee carry out its mission.
The Committee held four meetings — September 19-20, 2007; November 28-29, 2007; February 12-13, 2008, and August 12-13, 2008. At the end of each meeting, the public was invited to provide input, although many were actively involved in the discussions of the committee throughout all the meetings. During these meetings, the Committee adopted a deliberative process in carrying out its assigned responsibilities. The process included:
One of the initial tasks completed by the Committee was to reach agreement on a set of principles to guide the efforts to reach consensus regarding recommendations. In general, the Committee agreed that its recommendations should reflect the following guiding principles1:
Several meetings began with a review of aspects of the policy frameworks relating to passenger vessel emergency alarms (e.g., proposed and final regulations, advisory guidelines; domestic and international). This review included a description of the:
Comprehensive presentations were provided by several committee members and by invited guests.
Mr. Thompson (a Committee member) made a presentation on behalf of the Cruise Lines International Association (CLIA) concerning emergency alarm systems and operational practices provided on cruise ships subject to International Convention of Safety of Life at Sea (SOLAS). Mr. Brockway (a Committee member) and Mr. Lauridsen (a public participant) discussed with the Committee how smaller US flag cruise ships and other US flag vessels without overnight accommodations (e.g., ferry, dinner, excursion, and gambling vessels) provide emergency alarms and instructions to passengers. Matters highlighted included:
The Committee also heard from Mr. Richardson (a committee member) who provided the Committee with an overview of NFPA 72. NFPA 72 contains provisions for audible and visible emergency alarms. These provisions were referenced in the Access Board’s 2004 draft PVAG.
The Committee also heard presentations by Dr. Bakke, Ms. Schacter, and Ms. Hamlin (all Committee members) on the needs of passengers who are deaf or hard of hearing. Matters highlighted included:
The Committee also heard from Ms. Yannias (a committee member) who discussed the need to not only take into consideration the potential effect of adopting emergency alarm standards on passengers who are deaf or hard of hearing but also the potential effect on passengers with other disabilities, including, but not limited to, passengers with epilepsy or photosensitivity. She also highlighted prior successful efforts that addressed these concerns in the promulgation of NFPA 72.
The Committee also had the opportunity to benefit from presentations by guest speakers including a captain of a dinner boat who made a presentation and answered questions about how vessels without designated muster stations use emergency alarms, public address systems, and crew directions to move passengers to safer parts of a vessel (which are not necessarily pre-determined) based on types and locations of emergency situations encountered. The Committee also heard a presentation regarding a chartered cruise held for passengers who are deaf, including a demonstration of the portable emergency alarm/notification devices used during the cruise.
In addition to the presentations, the Committee spent an extensive period of time identifying and discussing various alternative designs and technologies for emergency alarm systems that might meet the access needs of passengers who are deaf or hard of hearing on passenger vessels.
Consistent with the lessons learned from a review of various policy frameworks, presentations, and discussions and the guiding principles agreed to by the Committee, the group reached a consensus on the following set of recommendations presented below.
Premises:
(1) Recommendations on issues related to the effectiveness of emergency alarm system design and practices on board passenger vessels for passengers who are deaf or hard of hearing should recognize that alarm practices and systems on passenger vessels are different from alarm practices and systems on land.
(2) In addition to the required audible element, alarm systems should include visible, and, where appropriate, tactile or other2 elements.
(3) Visible, tactile or other elements of alarms should provide effective signaling methods to communicate the general emergency alarm and local smoke detector alarm.
(4) The visible elements should minimize the “possibility or risk3” of triggering seizures in passengers who have epilepsy or photosensitivity.
(5) The committee recognizes the vital role of crew assistance during emergencies on passenger vessels. The committee also recognizes that evidence regarding effective means of providing visible emergency alerts (to supplement crew assistance) in outdoor spaces is not readily available. Therefore, it is of the utmost importance that such evidence be identified if it exists, or that a high priority be given to research for establishing such evidence.
Recommendation #1 – Applies to general emergency alarms in public spaces which summon passengers to designated muster stations. Public spaces include places of assembly, dining areas, places of recreation, public rest rooms, retail areas and other such spaces. Cabins (guest rooms) are addressed in recommendation #2 below.
Background: Recommendation #1 applies primarily to passenger vessels with overnight accommodations. In general, prior to getting underway or in the course of getting underway, passengers are provided with information on what actions the passengers are expected to take when the general emergency alarm is activated (e.g., seven short sound blasts on the ship’s whistle, siren, or similar tones and one long blast or tone). The 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 such as 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 are expected to proceed to their muster stations where they await further direction or instruction by crew. Although crew is typically present to provide direction to muster stations and other assistance, the alarm system communicates a message independent of crew actions. This alarm system is intended to result in a predetermined action by passengers.
There is a consensus that:
(1) The general emergency alarm system in public spaces should include a visible element in addition to the required audible element.
(2) The visible element of the general emergency alarm system should be as effective as the audible element. For purposes of this recommendation, the term “effective” means that whenever the general emergency alarm in public places is activated and the audible element is sounded, the visible element of the general emergency alarm will:
(3) Non-US Flag Passenger Vessels – The U.S. Coast Guard (USCG) supported by the Cruise Lines International Association (CLIA) should propose to the International Maritime Organization (IMO) that the Maritime Safety Committee (MSC) at its 86th session adopt a work program item to develop and issue a circular/guideline with regard to a visible element to the general emergency alarm. The paper proposing this work program item should also suggest that the International Standards Organization (ISO) be invited to develop a standard on visible elements to the general emergency alarm, and request the results of any research from member organizations.
(4) US Flag Passenger Vessels – The Access Board should develop guidelines, with input from the USCG and the domestic passenger vessel industry, for visible elements of general emergency alarms on domestic passenger vessels.
(5) In developing guidelines for visible elements of general emergency alarm systems, the guidelines should:
Recommendation #2 – Applies to general emergency alarms and local smoke detector alarms in cabins (guest rooms).
Background: When the general emergency alarm is activated, passengers in cabins are alerted (and awakened if necessary) and are expected to proceed to muster stations without waiting for crew directions or instructions.
When the cabin smoke detector activates a cabin alarm, passengers in that cabin are alerted (and awakened if necessary) and are expected to evacuate the cabin or dial the emergency number without waiting for crew directions or instructions.
There is consensus:
(1) To provide appropriate visible, tactile or other elements, in addition to the required audible elements, to notify passengers in cabins when they are awake or asleep.
(2) The visible, tactile or other elements of alarm systems should be as effective as the audible element. For purposes of this recommendation, the term “effective” means that whenever the alarms are activated and the audible elements are sounded, the visible, tactile or other elements will:
(3) Portable devices/systems should be permitted, consistent with the criteria below:
(4) CLIA should develop guidelines for the performance, carriage, availability, and crew installation of portable devices/systems.
Recommendation #3 – Applies to general emergency alarms (audible alarm or voice alert) in public spaces on passenger vessels without designated muster stations to notify or alert passengers, followed by crew instructions on how to respond.
Background: Recommendation #3 applies primarily to passenger vessels without overnight accommodations. A general emergency alarm is activated over the passenger vessel public address system, or an announcement is made about an emergency condition (like a fire in the galley). Although passengers are alerted that some type of emergency condition exists on the passenger vessel, passengers require additional information from crew to respond appropriately.
New Construction Design Elements: There is consensus that:
Operational Elements: If audible instruction is provided, visual auxiliary aids and services should be provided 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 may 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 information upon boarding to passengers who are deaf or hard of hearing.
New Construction Design Elements: There is consensus visible elements should be provided for emergency alerts. See recommendation #1 on development of guidelines for visible elements.
Operational Elements: No Recommendations.
New Construction Design Elements: There is consensus that:
Operational Elements: If audible instruction is provided, there is consensus that visual auxiliary aids and services should be provided 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 may include computers, data screens, illustrative instructions (pictures), LCD TVs, wall mounted or hand carried placards, and white boards.
Recommendation #4 – There is consensus that the areas below should be further reviewed and researched.
(1) Availability and efficacy of personal notification devices in emergencies for use in alerting adults and children who are deaf or hard of hearing.
(2) Elements of alarms to ensure their effectiveness for their intended purposes of alerting and awaking passengers who are deaf or hard of hearing, while minimizing the “possibility or risk6” of triggering seizures in passengers who have epilepsy or photosensitivity. Areas of review and research include:
(3) Effective text and visual gestural communications for use by crew in emergencies.
(4) Best and promising practices for soliciting self-identification information and encouraging passengers who are deaf or hard of hearing to respond.
Recommendation #5 – There is consensus that the Access Board should pass on the recommendation below to the Department of Transportation (DOT).
After DOT issues final regulations on passenger vessels, DOT should develop policy guidance to supplement the regulations on effective communication in emergencies.
1 The complete set of Guiding Principles is set out at http://www.access-board.gov/pvaac/alarms/docs/ principles.htm.
2 Recently, the NFPA 72 committee has proposed to amend NFPA 72 (for the 2010 version) to have a low frequency alarm signal in certain sleeping rooms for the purpose of awakening those with mild to severe hearing loss. 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.
3 Note: After the final committee meeting (August 12-13, 2008), the Epilepsy Foundation (which was not present at the August meeting) believed that use of the word “possibility” when used in the context of minimizing the triggering of seizures, took the language in the draft consensus report (March 13, 2008) “down to a very minimal level of minimizing the possibility of seizures”. Accordingly, the Epilepsy Foundation wanted the phrase “minimize the risk of triggering seizures” used instead of “minimize the possibility of triggering seizures” here and in three other parts of the report where the term was used. The Cruise Lines International Association (which was present at the August 12-13, 2008 meeting) objected to using the term “risk”, and expressed concern that use of the term “risk” implies conducting a risk assessment and noted that there are not standards or guidelines for either conducting such an assessment or as to what would constitute an acceptable risk. In CLIA’s view, this was specifically discussed at the committee and was not the committee’s intent. The term “possibility or risk” is used throughout the report to highlight this issue. This was the only issue where complete consensus was not achieved.
4 See footnote number 3.
5 See footnote number 3.
6 See footnote number 3.