The small cruise ship was built in the late 1980s and carries about 120 passengers in 60 passenger guest rooms. The vessel has an overall length of about 302 feet and breadth of about 50 feet, and has six decks. Decks two through six are passenger decks. With a draught of about 14 feet, the vessel travels to ports and areas of the world not navigable to larger vessels. Decks two through six are entry decks.
Figure 1. Outboard Profile – Original Design
Figure 2. Second Deck — Original Design
Figure 3. Third Deck — Original Design
Figure 4. Fourth Deck — Original Design
Figure 5. Fifth Deck — Original Design
Figure 6. Sixth Deck — Original Design
In providing estimates on the costs of implementing (in new construction situations) the provisions of the 2006 draft passenger vessel accessibility guidelines, vessels selected for case studies needed to be of recent construction. Since newer vessels incorporate more access features as part of industry practices, such vessels provide a clearer picture of the impacts the draft guidelines would have on current new construction practices. Because the number of existing newer small cruise ships is low and the willingness of vessel ownership to participate in this study is even lower, it was found necessary to use a small cruise ship built in the late 1980s. Although the vessel is a foreign flagged vessel, the case study evaluated the impacts also based on the vessel being a US flagged vessel subject to international requirements.
Since the vessel was designed and constructed before the Americans with Disabilities Act (ADA) went into effect, there was concern that if the original designs of this vessel were used in the case study, the draft guidelines would produce greater impact than if the cruise ship had been constructed in the 2000s. However, maybe because the vessel was constructed for a clientele which expected more luxury, many of the provided features are at least consistent with current practices. Nevertheless, in three places (number of mobility guest rooms, number with balconies, and public toilet rooms), the cruise representative believes the features did not represent current practices and the applicable impacts were adjusted to reflect outcomes modified by current practices.
To determine the impact, the analysis went through three steps:
Step 1 – A representative of the Access Board reviewed the original general arrangement drawings of the vessel with a representative1 of the cruise company to identify passenger features that would not meet the 2006 draft passenger vessel accessibility guidelines2.
Step 2 – The cruise representative proposed new designs complying with the draft guidelines. However, the designs only showed how the impacted features were changed and the effect on surrounding spaces, but the surrounding spaces themselves were not in most cases further adjusted (for example, the enlarged elevator overlaps the adjacent stair, but the stair was not repositioned). In most situations, the adjustment of bulkheads (walls) to provide necessary clearances for access were determined to not increase the cost of a new vessel, but did create noteworthy space (and operational) impacts summarized below and resolved in Step 3. The issue numbers below correspond to the issues (and actions) discussed in more detail in the section titled “Impacts and Other Outcomes”.
Step 3 – From a review of the space impacts, the cruise representative provided an estimate on how much the size of the original vessel must be increased to restore the space characteristics to that of the original vessel. Also, the cruise representatives provided estimates on applicable cost increases and comments on other outcomes.
Enlarged Vessel (Step 3 Results) – The cruise representative estimated that the original cruise ship would cost approximately $60 million to $70 million to construct in 2008. For a vessel enlarged to restore space characteristics, the cruise representative estimated that the new enlarged vessel would have to be 310 feet long, an eight foot increase. This increase in size would add from $1.8 million to $2.1 million to the vessel’s construction cost. In addition, the enlarged elevator ($2,500), assistive listening system ($4,000 to $5,000), two ramp structures ($38,000), visible alarms ($40,000 to $50,000), and platform lift from the third deck to the tender boarding platform ($25,000) increased costs. Therefore, the case study estimated the cost of the vessel would increase by $1.91 million to $2.23 million, or an increase of approximately 2.7 to 3.7 percent.
Below, the case study provides more details on the impacts and other outcomes.
The cruise ship has 60 passenger guest rooms. No rooms were designated as “ADA” guest rooms. The draft guidelines require that four passenger guest rooms be equipped with mobility features (mobility guest rooms) and at least one be equipped with a roll-in shower. V224.2. The draft guidelines also require these four mobility guest rooms3 to be dispersed among the types of guest rooms provided. V224.5.
As the cruise representative believes that at least one ADA mobility guest room would have been provided based on current industry practices (if the vessel was constructed in the early 2000s), the impact evaluation is based on the need to provide three additional ADA guest rooms, one with a roll-in shower.
|Figure 7. Mobility Guest Room Impact.|
Another industry practice was raised which concerned the number of guest rooms with balconies. Currently 15 guest rooms (on the fifth and sixth decks) have balconies, but industry practice would have much more. The case study calculated its impacts assuming 11 of the 15 guest rooms on the fourth deck have balconies and the critical exterior jogging track which encircles the deck would be provided elsewhere in the enlarged version of the vessel (Step 3), probably on a seventh deck. This increased the number of balconies by 11 which provides a total of 26 guest rooms with balconies. Balconies were not provided on the port side aft of the center stair tower because this portion of the jogging track is part of a means of (emergency) escape to the stern of the vessel.
The cruise representative proposed in Step 2 to provide one mobility guest room with a balcony on decks four through six (for a total of three guest rooms). The fourth mobility guest room required by the draft guidelines is assumed in this case study to already exist on deck two or three.
Deck four is proposed to have the guest room with a roll-in shower, and decks five and six will have transfer showers (36 inches by 36 inches). In making the three bath rooms comply with the draft guidelines, the size of the bath rooms increased from around 32 square feet to around 52 square feet for the transfer shower bath rooms (62 percent increase) and around 57 square feet for the roll-in shower bath room (78 percent increase).
Combined with needs for maneuvering clearances at the mobility guest room entry doors (which moved the room closet forward) and keeping the amenities and space needs the same as other similar guest rooms, the increase in bath room size necessitated over a 10 percent increase in the interior area of the guest rooms.
Figure 8. New Bath Room Layouts — Transfer Shower and Roll-in Shower4
These actions are estimated in Step 2, for each of the three mobility guest room, to reduce the size of one adjacent guest room by an average of about 25 square feet5. The use of drainage systems at the three balcony doors is discussed below, in the door threshold section (issue #4 below).
The cruise ship has a small hospital with one patient sleeping room containing one bunk bed and one single bed. A bath room with a tub serves the patient sleeping room. The hospital also has an examination room with a portable examination table and a small waiting room. The hospital area wraps around a stair tower which connects decks one through six. Officer cabins are located forward of the hospital and passenger state rooms are located aft and on the starboard side. The vessel is required to have three beds should passengers need isolation due to infectious diseases. The draft guidelines require that one bed have a clear deck space on both sides (36 inches wide) and a turning space be provided in the room. V223, V805.2, and V805.3. In addition, the bath room (and tub) must be accessible. V805.4.
The double-leaf doors which connect the outside passageway to the waiting room, to the exam room, to the sleeping room, have a clear opening of about 48 inches wide. The active leaf of each door has a clear opening of about 30 inches and the inactive leaf a clear opening of about 18 inches. The door to the bath room has a clear opening of about 27 inches. The draft guidelines require all four doors to be accessible and have a clear opening of at least 32 inches at the active leafs (plus have maneuvering clearances on both sides). V206.5, V404.2.2, V404.2.3, and V404.2.4.
The cruise representative proposed in the new designs to have the hospital comply with the draft guidelines. This action is estimated in Step 2 to cause the loss of about 40 square feet from one officer cabin (26 percent reduction) as shown below in the figure. The majority of the increase in the size of the hospital was due to the sleeping room needing one bed with clear deck space (36 inches by 48 inches) on both sides of a bed (the bunk was selected) and the enlargement of the bath room.
Figure 9. Hospital Impact — Original Designs and New Designs (stair unchanged)
|Figure 10. Hospital Impact
New Design and New Stair Layout
However, because the adjacent stair needed to be adjusted to provide a maneuvering clearance on the pull side of the entry door, the stair tower had to be lengthened by about 20 inches. This action no longer allowed the bath room to be placed on the port side of the stair (as shown above) which required the cruise representative to propose a new hospital layout (see figure 10). This new layout, in Step 2, caused the loss of about 110 square feet from two adjacent office cabins which have a total area of about 270 square feet (40 percent reduction). As the side of the vessel curves, the bath room could not be positioned adjacent to the port side bulkhead (wall).
The cruise ship is subject to means of escape requirements from the International Convention of Safety of Life at Sea (SOLAS) and, for purposes of this case study, US Coast Guard (USCG) regulations. In general, these requirements mandate at least two means of escape (MOE) paths from each passenger deck to the primary area of refuge (mustering station) in the third deck lecture lounge and to the secondary area of refuge at the open stern area on the fourth deck. From these two locations, two MOE paths are required to the primary life boat embarkation area at the side exterior walkways located near the stern of the fourth deck and to the secondary embarkation area at the side exterior walkways near the stern of the fifth deck. Stairs are the components in the MOE paths which connect the decks.
The draft guidelines require that two accessible means of escape (AMOE) also connect the areas of refuge and embarkation areas. V207. The draft guidelines allow stairs to be components in an AMOE path. V410.1.2(e). As this vessel is protected by an automatic sprinkler system complying with SOLAS, the stairs which are part of the AMOE path are not required to comply with the stair technical requirements in the guidelines. V410.2 Exception 2. However, the doors to the stairs which are part of the AMOE must be accessible. V410.1.2(b). The AMOE impacts principally relate to door threshold and maneuvering clearance issues and are discussed below in more detail.
The cruise ship operates in international waters and, for purposes of this case study, is also subject to USCG requirements. Therefore under the International Convention of Load Lines and USCG requirements, certain exterior doors must have coamings (e.g., high thresholds).
The draft guidelines require doors which are part of an onboard accessible route or part of an AMOE to have conforming (beveled) thresholds ½ inch high maximum. V206.5 and V404.2.5. However, where doors are required to have coamings, the draft guidelines allow higher thresholds for the coamings if ramps are provided. V404.2.5 Exception 3 and V404.2.5.2.
Door Coamings – Coamings are only required on decks two and three. To meet the requirements of the draft guidelines, the cruise representative proposed the following actions.
Figure 11. 2nd Deck – Restaurant Ramp to External Stair
Figure 12. 3rd Deck – Lecture Lounge
Drainage – Coamings are not required on decks four through six, but the cruise representative was concerned about water from rain, sea spray and storm waves entering the exterior doors (including balcony doors) with low thresholds due to ship movements and creating maintenance and safety problems inside the vessel. To address this concern, the cruise representative proposed in the new designs to add drainage systems to the outside of the exterior doors which are required to be accessible on these decks and also to have thresholds which do not exceed a height of ½” beveled. These actions are estimated to have an insignificant impact on the cost of a new enlarged vessel (Step 3) and do not create head clearance issues on the decks below the drainage systems.
The passageways are at least 36 inches wide and have overheads which are 82 inches high with doors having 78.5 inch vertical clearances. Public doors along the passageways have at least 32 inch clear openings. However, many doors which would be part of an accessible route to public spaces or are part of an AMOE do not have sufficient maneuvering clearances, and some passageway doors are in series with other doors (which may only be fire doors held open by magnets) and may not have sufficient space between the in-series doors.
|Figure 13. Sample Maneuvering Clearance Impacts|
The draft guidelines require that each door used as part of a required onboard accessible route or an AMOE be conforming. V206.5, V207.2, and V410.1.2. Complying doors must have maneuvering clearances (unless automatic) and comply with the doors in series provision. V404.2.4 and V404.2.6.
The cruise representative proposed in the new designs to provide the necessary maneuvering clearances at the public doors which created minor space impacts on adjacent spaces in Step 2. However, the doors in the center stair tower (see Figure 10) created the greatest difficulty as maneuvering clearances were not provided on the side of the doors inside the tower. To provide these clearances, the tower needed to be widened by a few inches on the fourth, fifth and sixth decks, and increased in depth by about 20 inches on the second and third decks. In Step 2, the case study recognizes that additional refinement in the stair tower layout may be necessary to ensure clearances are provided and are factored into the Step 3 results. Providing maneuvering clearances at the stair enclosure at the forward end of the second deck also significantly impacted surrounding spaces in Step 2, as the stair enclosure had to be enlarged which blocked entry to adjacent crew cabins.
At the forward end of the elevator lobby, on the second through fourth decks and sixth deck, doors in series were proposed to be further separated in Step 2. At these locations, light weight lobby doors (with no latches which swing in both directions) separate the lobbies from the forward passageways. Pass these doors, toward the bow, magnetically held open fire doors (more than 36 inches wide) are provided. Separating the doors to provide 48 inches between the lobby doors and the swing of the fire doors had significant impacts on the adjacent spaces in Step 2, as the new location of the fire doors blocked the entry to spaces on one side of the passageways. Maneuvering clearances however, created minor space impacts in adjacent guest rooms and crew cabins. On the sixth deck, also, the series doors to the hair dressers room were replaced with one door.
A small elevator is provided which serves all five passenger decks (decks two through six) with a travel distance of about 36 feet. The elevator car size is estimated to be 53 inches in depth and 45 inches wide.
In this new construction situation, two options were evaluated. Either use two limited-use/limited-access elevators (LULA8) or one standard elevator to connect decks two through six. Although the guidelines recommend that elevators comply with ASME A17.1, the case study assumes the US Coast Guard would require ASME use in US Flag vessels. Therefore, a LULA is restricted by ASME to a vertical travel distance of 25 feet, thereby requiring that two LULAs be provided to connect the 36 feet travel distance between the five decks. ASME does not restrict a standard elevator to a 25 feet maximum travel distance. The guidelines allow standard elevators to use a number of different dimensional sizes that include a minimum size of 60 inches by 60 inches, and 80 inch depth by 54 inch width. V206.6 and V407.4.1. The LULA is allowed to be smaller (e.g., 54 inches by 42 inches). V206.6 Exception 2 and V408.4.1.
The cruise representative proposed in the new designs to use a standard elevator which is 60 inches by 60 inches to connect decks two through six. This action in Step 2 would cause the footprint of the elevator to increase by 10 square feet and overlap the adjacent stair and lobby area by less than a foot. In Step 3, the stair would have to be moved outside the footprint of the new elevator. The larger elevator is estimated to increase the cost of the new enlarged vessel by $2,500.
At the stern of the second deck a tender boarding platform is provided. The platform is about 24 to 30 inches below the main level of the second deck. A small stair of five or more steps connects these two levels. As discussed above, on the second deck level, two exterior doors with 24 inch high required coamings connect the stern area with the restaurant. As the doors are for emergency use, passengers embarking or disembarking the tenders use the exterior stair which connects the second deck stern area with the third deck.
The draft guidelines require that an onboard accessible route connect the boarding platform (which functions as an entry point). V206.4. The draft guidelines allow a platform lift to be used to connect the boarding platform. V206.7.7. As a platform lift would be exposed to waves, the draft also allows use of a manually powered boarding lift to connect the boarding platform. V206.7.7 Exception. The cruise representative evaluated three options in providing access to the tender boarding platform. All options will experience maintenance difficulties due to potential storm wave actions in following seas at the exposed stern location and create complications and obstructions for crew in operating the tender boarding platform and operating mooring equipment and running mooring lines.
|Figure 14. Tender Boarding Platform
Onboard Accessible Route
Option 1 (54 Inch High Platform Lift) — A hydraulically operated platform lift (36 inches by 60 inches), approached from the side, would connect an onboard accessible route by an elevated walkway to the restaurant’s 24 inch high coaming door at the base of the stair to the third deck. This option is estimated to increase the cost of the enlarged new vessel designs (Step 3) by $12,000 to $22,0009. As the 24 inch high raised walkway cuts across the mooring equipment area and needs guardrails, it creates an obstruction to crew member use of the mooring equipment and some operations related to the tender boarding platform. Also, a second small stair would be needed for passengers (who would not be using the platform lift) to provide a path from the raised walkway down to the other small stair.
In an enlarged vessel design (Step 3), a grated deck surface at the height of the 24 inch coamings could be provided with raised mooring equipment. This would remove the need for the raised walkway and the 24 inch coamings would still protect the doors to the restaurant, but the drop-off to the tender platform would increase and therefore increase the size of the small stair.
Option 2 (144 Inch High Platform Lift) — A hydraulically operated platform lift would be provided running from the third deck down to the tender boarding platform. As the lift platform and most of the operating mechanisms can be stored on the third deck, the platform lift has less exposure to waves, but the lift and the onboard accessible route occupies spaces on the third deck used for inflatable tender storage. However, the raised walkway (elevated accessible route) from the restaurant’s 24 inch high coaming door to the platform lift is not required and the elevated maneuvering clearance on the outside of the coaming door is less of an obstruction for crew members working in the stern area of the second deck. In this option, although there is no platform lift shaft, the structure to support the lift’s decent from the third deck could interfere with mooring operations and some tender operations. This option is estimated to increase the cost of the enlarged new vessel designs (Step 3) by $25,000 with hydraulic power coming from the mooring equipment hydraulic power source.
Option 3 (54 Inch High Manually Powered Boarding Lift) — A manually powered boarding lift would be used instead of the hydraulically operated platform lift used in option 1. This option is estimated to increase the cost of the enlarged new vessel (Step 3) by $10,000 to $15,000 but (due to the raised walkway) create the same crew problems as noted in option 1. Added to this expense is the cost of the raised walkway which is estimated to be $7,000, for a total increase of $22,000 for this option.
In evaluating the options, the cruise representative selected option 2, as the raised walkway created a greater obstruction to crew members.
The second, third and fifth decks each have two multi-user toilet rooms (one male and one female) in the elevator lobby. The cruise representative believes that current industry practices would have produced clusters of two single-user (uni-sex) toilet rooms on these three decks with at least one on each deck being accessible. The draft guidelines only require one toilet room in a cluster of two single user (uni-sex) public toilet rooms to be conforming. V213.2 Exception 4. Therefore, as sufficient space is available to convert the multi-user toilet rooms into two single-user (uni-sex) toilet rooms (with space to spare), one of which complies with the draft guidelines, this outcome is determined to have no impact on the enlarged vessel designs (Step 3).
The cruise ship has a lounge in which amplified lectures are held. The lounge has a seating capacity of 110 seats. Because the lecture lounge is an assembly area where amplified communication is integral to the use of the space, the draft guidelines require the lounge to be served by a permanently installed assistive listening system (ALS). V219.2. For a seating capacity of 110 seats, the draft guidelines require five receivers, two of which must be hearing aid compatible. V219.3. It is estimated a permanently installed ALS and the necessary number of receivers would increase the cost of the enlarged vessel design by $4,000 to $5,00010 (Step 3).
When getting underway, the crew instructs the passengers on what actions to automatically take when the general (audible) alarm sounds and passengers are given a practice alarm drill. Therefore, an audible emergency alarm is provided for passenger use and passengers know the meaning of the alarm and take immediate actions without crew direction. The draft guidelines require principles of best practice. V215.2 and V215.3. The cruise representative proposed to provide in the new enlarged designs (Step 3), visible alarms (strobes) complying with NFPA 72 (2007) in the public passenger spaces and in the seven guest rooms required to be equipped with communications features. The vessel will take approximately 110 alarm points to cover the applicable spaces. The total cost of the visible alarm system will be approximately $40,000 to $50,000. There might be some cost savings if the visible alarms were integrated into the SOLAS audible general alarm system11, but that would be hard to quantify. The visible alarm strobes themselves draw about 250 watts. Adding in the alarm control system and monitoring, the total will be on the order of 500 to 1,000 watts. This power need is not estimated to impact the size of the emergency generator. Providing visible alarms is estimated to be not significantly more expensive than just the audible alarms, nor is the power requirement significantly larger.
No storage facilities are provided for passengers outside their guest rooms. Life jacket storage lockers are intended to be used only by crew members, in handing out life jackets to passengers, and are therefore not subject to the guidelines. V203.2.
|Figure 15. Transfer Wall|
The stern area of the fifth deck contains one raised spa (Jacuzzi). The draft guidelines require either a means of entry which is a swimming pool lift, transfer walls, or transfer system. V234.4. The cruise representative proposed in the new designs to provide a transfer wall (see figure 15). This action is estimated to have an insignificant impact on the enlarged new vessel designs (Step 3).
The vessel has four 1000 KW generators. Two run off the vessel’s propeller shaft and two run off motors. One 240 KW emergency generator is provided. The larger elevator12, platform lift, and assistive listening system have an insignificant impact on the normal power supply of the vessel.
For emergency power, the larger elevator has a very similar power draw to the original elevator, within a few horsepower, and is estimated to have an insignificant impact on the emergency power supply. If the platform lift to the tender boarding platform was required to be part of an accessible means of escape, it would need emergency power (see V410.4). Therefore, a separate hydraulic power unit (HPU) on emergency power would be needed (instead of using the larger mooring equipment HPU). This smaller HPU would likely not drive the emergency power over its current limit. In addition, the 500 to 1,000 watts needed for the visible alarm system (issue #12) is estimated to not have a significant impact on the capacity of the emergency generator.
Passenger boarding systems were not addressed in the case study.
The cruise representative estimated that the original cruise ship would cost approximately $60 million to $70 million to construct in 2007. For a vessel enlarged to restore space characteristics (Step 3), the cruise representative estimated that the new enlarged vessel would have to be 310 feet long, an eight foot increase. This increase in size would add from $1.8 million to $2.1 million to the vessel’s construction cost. Plus, the following table summarizes other costs which would add $109,500 to $120,500 to the above amount. Therefore, the case study estimated the cost of the vessel would increase by $1.91 million to $2.23 million, or an increase of approximately 2.7 to 3.7 percent.
Assistive Listening System
$4,000 to $5,000
Restaurant Ramp Structure
Lecture Lounge Ramp and Raised Exterior Walkway
Platform Lift From Third Deck to Tender Boarding Platform
$40,000 to $50,000
$109,500 to 120,500
The cruise representative believes the cost increases due to the draft guidelines to provide a 310 foot vessel (Step 3) are not unreasonable.
The cruise representative does not see as unreasonable that four mobility guest rooms are required for a 60 guest room cruise ship. With the aging of the US population, market forces are creating a greater demand for mobility guest rooms.
The cruise representative sees no problem in selling the four mobility guest rooms as many passengers seek larger accommodations even if they are not disabled.
1 Although the report notes decisions made by the cruise representative, it should be noted that the Access Board hired a consultant (acceptable to the cruise representative) to provide most impact information (including cost estimates) which was used by the cruise representative in the case study decision making process.
2 2006 draft guidelines, as amended by Board action at the 2007 and April 2008 meetings.
3 The draft guidelines V224.4 would also require cruise ships with 51 to 75 guest rooms to have seven guest rooms equipped with communications features (communications guest rooms). Per V224.5, one communications guest room is required to be located in one mobility guest room. The other six communications guest rooms are not permitted to be placed in the “required” mobility guest rooms. Although these six guest rooms are not required to be equipped with any mobility features, such as clearances at doors, water closets, lavatories and beds, the rooms would still have to meet the protruding object requirements in V204. The case study assumes that to provide seven communications guest rooms, the impact would have an insignificant increase on the cost of a new enlarged vessel (Step 3).
4 The plumbing chase was widened to support the shorter grab bar (see V608.3.2 Exception).
5 The case study did not evaluate if furniture layouts were impacted in the mobility guest rooms and corrections may require additional square footage from adjacent guest rooms and are assumed resolved in Step 3.
6 A platform lift could not be used as part of an AMOE from the rear of the restaurant because the AMOE runs up to the third deck and does not run to the tender boarding platform. Therefore, V206.7.7, which is referenced by V410.1.2(h), cannot be used.
7 The cruise representative proposed to not limit the ramped exit door to only emergency use but would use it as part of the onboard accessible route connecting the interior areas of the third deck to the exterior areas. Therefore, an onboard accessible route complying with V206.3 connects the lobby to the exterior areas of the deck and the lobby exterior doors are not required to be accessible.
8 The US Coast Guard informally communicated to the Board that they would interpret ASME A17.1 as not prohibiting shipboard elevators from being LULAs.
9 The platform lift uses the hydraulic power unit used by the mooring equipment which reduces the potential cost of the platform lift which is estimated to be $5,000 to $15,000, and the elevated walk from the restaurant exit door is estimated to be around $7,000.
10 This cost estimate was provided by the Access Board and includes 1 FM transmitter ($750), 3 headsets and receivers ($630), 2 neckloops and receivers ($530), power adapter and antenna kit ($124), receiver carrying case with charger ($405), misc. hardware and parts ($362), and 13 hours engineering and installation ($1515).
11 US Coast Guard has indicated informally that in their reading of SOLAS, SOLAS would not prohibit a visible alarm system from being attached to the SOLAS required general alarm. In addition, the consultant hired to provide impact costs contacted the American Bureau of Shipping and they confirmed that in their opinion SOLAS would not prohibit a visible alarm system from being attached to the SOLAS required general alarm.
12 The consultant noted that the elevator is required to have emergency power for half an hour to bring passengers to a deck. In practice, the elevator will be on emergency power.