Review of DPTAC Guidance: Large Passenger Ships and Passenger Infrastructure (final report)
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2.2 Accessibility assessments of ships and ports
2.2.1 How were ships and ports selected?
2.2.2 How was port and ship access assessed?
2.3 Brochure and website assessments
2.3.1 Brochure assessment
2.3.2 Website assessment
2.4 Interviews with port and ship operators
2.5 Interviews with naval architects
2.6 Study of disabled people's experiences of large passenger ship travel
2.6.1 How were disabled passengers recruited?
2.6.2 How was the data collected?
2.7 Presentation of findings
2.7.1 Assessment criteria score
3.1 Access to the terminals
3.1.1 Arrival by public transport
3.1.2 Courtesy buses
3.1.3 Approach on foot
3.1.4 Cycle routes
3.1.5 Approach by car
3.1.6 Car parking
3.1.7 Entrance to the terminal buildings
3.2 Facilities within terminal buildings
3.2.1 Reception, ticket office and check-in
3.2.2 Waiting areas
3.2.4 Baby-care facilities
3.2.5 Retail Sales Areas
3.2.6 Restaurants and catering
3.2.8 Information systems
3.2.9 Provision for assistance dogs
3.2.10 Routes through the terminal
3.2.11 Decorative finish
3.2.13 General lighting
3.2.15 Access to upper levels
3.2.16 Lifts within the terminal
3.2.17 Steps and stairs within the terminal
3.2.18 Ramps within the terminal
3.2.19 Emergency egress
3.3 Shore to vessel transition
3.3.1 Arrangements for foot passengers
3.3.2 Arrangements for disabled foot passengers
3.3.3 Arrangements for car passengers
3.3.4 Weather Protection
3.3.5 Queue rails
3.3.6 Pedestrian Crossing Points
3.3.7 Pedestrian route or passageway
3.3.10 Steps and stairs
3.3.11 Overall accessibility of ports
3.4 On board accommodation
3.4.1 Access via passenger gangway
3.4.2 Access via car deck
3.4.3 Lifts on board ship
3.4.4 Steps and stairs on board
3.4.6 General Lighting
3.4.8 Emergency egress
3.4.9 Overall access onto the passenger ship
3.5 Facilities on board the ships
3.5.2 Baby-care facilities
3.5.3 Retail sales areas
3.5.4 Restaurants, cafeterias and other service counters
3.5.5 Induction Loops
3.5.7 First Aid
3.5.8 Safety announcements
3.5.13 Carriage of assistance dogs
3.5.14 Overall accessibility of ships
3.6 Management and training
3.6.1 Awareness of the guidance
3.6.2 Company policies
3.6.3 Design of vessel or terminal
3.6.4 Disability awareness training
3.6.5 Staff assistance
3.7 Discussion and conclusions
4.1 Design of large passenger ships
4.1.1 Responsibility for design of new ships
4.1.2 Design of the ships included in the accessibility assessments
4.1.3 Use of guidance by naval architects
4.2 Design of ports and port infrastructure
4.2.1 Investment in port infrastructure
4.2.2 Design of the ports included in the assessments
5.1 Changes in patronage
5.2 Disabled passengers' experiences of large passenger ship travel
5.2.1 Potential passengers and non-travellers
5.2.2 Research and planning
5.2.3 Booking by telephone
5.2.4 On-line booking
5.2.5 Provision of information in different formats
5.2.6 Declaring disability and requesting assistance
5.2.8 Access to terminal buildings
5.2.9 Foot access onto the ship
5.2.10 Boarding with a car
5.2.11 Car deck access
5.2.12 Wheelchair access
5.2.13 Access to toilets
5.2.17 Emergency evacuation procedures
5.2.18 Safety Announcements
5.3 Discussion and conclusions
6.1 Publicity of accessible services
6.2 Promotion of accessible services
6.2.1 General Travel Information
6.2.2 Provision of information in alternative formats
6.2.3 Assessment of brochures
6.2.4 Assessment of large passenger ship operator websites
6.3 Discussion and conclusions
Glossary of terms and acronyms
ACS - Assessment Critiera Score. This score is the percentage of relevant assessment criteria which were met during the assessment.
Bobby - A commercially available accessibility checker for web pages.
BSL - British Sign Language.
BSL Signer - A person who communicates with a deaf person using British Sign Language.
Coamings - high door sills which help keep the ship watertight.
Crossfalls - the gradient on a pavement which assists drainage.
DDA 1995 - Disability Discrimination Act 1995.
DDA 2005 - Disability Discrimination Act 2005.
DRC - Disability Rights Commission.
DPTAC - Disabled Persons Transport Advisory Committee.
HSC - High Speed Craft. High Speed Craft - are craft capable of a maximum speed in metres per second (m/s) equal to or exceeding: 3.7 0.1667 where = volume of displacement corresponding to the design waterline (m3), excluding craft the hull of which is supported clear above the water surface in non displacement mode by aerodynamic forces generated by ground effect.
IHT - Institute of Highways and Transportation.
Induction Loop - An induction loop is a cable that circles the listening area. It is fed by a current from a loop amplifier. This current produces a magnetic field that can be picked up by hearing aids with a 'T setting'. A loop system helps deaf people who use a hearing aid or loop listener to hear sounds more clearly by reducing or cutting out background noise. A loop can also be set up with a microphone to help hearing aid users hear conversations in noisy places.
Inductive Coupler - This is a very small induction loop. Telephones with an inductive coupler can be used by people with a hearing aid with a 'T' setting. It helps the user hear the sound more clearly and reduces background sound.
IMO - International Maritime Organisation.
Journey life cycle - All the stages a traveller will experience: pre-journey planning, booking a journey, travel and access to terminals, checking in, shore to vessel transfer on embarkation, journey on board vessel, vessel to shore transfer on disembarkation, and travel to terminal exit.
Landside - Port facilities open to public access - i.e. those located before security and passport control.
Large passenger ship - Ships carrying more than 250 passengers and weighing more than 500 tonnes.
Life-line passenger ship - A passenger ship on routes where life-line journeys (see below) are necessary.
Life-line journey /services- A journey that is necessary to undertake, for example, to access critical medical facilities or other vital services not locally available to remote island communities, as opposed to journeys made for pleasure.
MACS - Mobility and Access Committee for Scotland.
MCA - Maritime and Coastguard Agency.
MGN - Marine Guidance Note.
Minicom - Minicom is a widely used brand of textphone.
New passenger ships - Ships registered as passenger ships since 1997.
Older ships/vessels - Vessels registered as passenger ships prior to 1997.
Pet Travel Scheme - The Pet Travel Scheme (PETS), (also known as The Pet Passport). The scheme allows certain animals, including dogs to travel certain routes and on certain carriers (including large passenger ships), without quarantine, provided the animals conform to regulations under the scheme.
Restricted Area - Port facilities located after security and passport control, accessible only to travellers who have cleared those controls.
Ro-Ro ferry - Roll on/roll off car ferry, which you drive onto and off.
Sister-ship - Another ship within the same operator's fleet and of similar capacity and design.
SOLAS - International Convention for the Safety of Life at Sea.
Textphone - Textphones are used by deaf people or those with speech difficulties. Unlike a standard telephone, a textphone has a keyboard and a display screen.
Typetalk - The Typetalk service, run by the RNID, introduces an operator who will relay messages from a textphone user by voice to a standard telephone user and vice versa. Dialling a prefix before the telephone number accesses the service. These services are also available to telephone users wishing to call a textphone user. Again, a Typetalk operator can be automatically included in the conversation by dialling a prefix number to connect a telephone user with a textphone user.
In June 1996 the International Maritime Organisation (IMO) issued guidelines entitled 'Recommendation on the Design and Operation of Passenger Ships to Respond to Elderly and Disabled Persons' Needs'. The member states of IMO were asked `to bring the approved Recommendation to the attention of those concerned for action as appropriate' to ensure that these guidelines were used to improve the accessibility of passenger ships. In response the Maritime and Coastguard Agency issued Marine Guidance Note 31 (MGN 31) in 1997. MGN 31 describes the IMO guidelines.
The Disabled Persons Transport Advisory Committee (DPTAC) document "The design of large passenger ships and passenger infrastructure: guidance on meeting the needs of disabled people" was prepared by the DPTAC Ferries Working Group to support and assist all concerned in the interpretation and implementation of the IMO guidelines to address the needs of the wide range of elderly and disabled people using large passenger vessels.
Under the Disability Discrimination Act 1995 (DDA) transport infrastructure - including ports - is Part 3, which gives disabled people a right of access to goods, facilities and services. However, transport vehicles are currently exempted from those Part 3 provisions.
The DDA 2005 has amended the DDA 1995 to make it clear that the exemption from Part 3 only applies in connection with the provision and use of vehicles, and now includes a regulation-making power to enable the Secretary of State to lift the exemption, in whole or in part (and at different times), in respect of transport providers operating certain types of vehicle, including large passenger ships and cruise liners.
The aim of this project was, therefore, to review the effectiveness of the IMO and DPTAC guidance in order to help the DPTAC to advise the Government on whether the voluntary approach is working satisfactorily or whether it should consider using the powers within the DDA 2004, to ensure the needs of disabled people travelling by sea are met.
The study investigated the use, usefulness and effectiveness of the guidance. In particular, it aimed to find out how effective it has been in influencing the design of new ships and investment in infrastructure, and the impact it has had on existing service provision. The publicity given to the promotion of accessible services was also assessed. Overall, the aim was to evaluate the degree to which the shipping industry was complying with the voluntary guidance.
The project consisted of a number of tasks undertaken to investigate the influence of the guidance on ports and large passenger ships. These included accessibility assessments of ships and ports, an assessment of ship operator brochures and websites, interviews with port and ship operators, interviews with naval architects, and interviews and observations with disabled passengers.
The key findings were:
- The IMO and DPTAC guidance has to some extent influenced the design of new ships and investment in the infrastructure. However, the voluntary guidance recommendations are not being addressed fully at the detailed level. For instance, the angle on some ramps was too steep for a wheelchair user to use easily without assistance, and toilets where the toilet door handles were not of the recommended profile could make them inaccessible to people with arthritic conditions.
- Overall, the ships met between only 57% and 77% of the DPTAC guidance recommendations for the facilities they provide, and the ports met between 51% and 80% of the recommendations. This means that the DPTAC recommendations means have been only partially effective in ensuring that ships and ports are designed and operated in a way that makes them fully accessible to disabled people, despite the fact that most of the physical and service facilities that older and disabled travellers asked for at ports and on board ship are included in the DPTAC guidance. This indicates that accessibility needs would have been met more comprehensively if ship designers and operators had followed the DPTAC guidance's recommendations more closely.
- Disabled passengers indicated that their main concern related to the boarding of ships, particularly older vessels. Passengers generally reported favourably on access to the main facilities once they were on board, such as appropriate seating, toilets and cabins. Physical access appears to be better addressed than aspects affecting the design of facilities and interior fittings. Differences in the physical design and service provision between different ports means accessibility is often dependent on local practice and local knowledge of the services available, for example, the option of having a friend drive the disabled person on board, leave them and take the car off the ship.
- An important finding relates to an 'accessibility gap' between the level of service offered and that required to meet the advice and recommendations set out in the DPTAC guidance for the design of the ship, port or service. This gap was typically overcome by good customer care and assistance by staff, whose attitude and competence was often the deciding factor in whether large passenger ship travel was possible, practicable and comfortable for older and disabled passengers. However, most staff had not had relevant disability awareness training, which should have further improved the quality and consistency of the services offered. This need of training is also indicated by some operational lapses even where appropriate facilities were provided.
- There was a lack of awareness and knowledge of the DPTAC guidance among ship and port managers, naval architects and designers that may explain why the DPTAC guidance has not been followed comprehensively. Naval architects and ship operators were more familiar with the IMO guidance and regulations, in particular safety regulations that they are required to follow. These regulations were adhered to more closely than the recommendations within the DPTAC guidance. Some parts of the industry, even those responsible for operational issues, did not realise that the DPTAC guidance applied to them.
- A key problem concerns boarding ships, which can be particularly problematic for disabled people because they often need special facilities. However, provision for these often cuts across the responsibilities of port and ship authorities. Making the transition from shore to ship requires closer collaboration between ship and port operators, so that proper consideration can be given to meeting the needs to disabled travellers.
- Journeys by disabled passengers could involve travelling through areas where their access is legislated or regulated by a large number of different UK, European and International Organisations, all of which produce sources of information that need to be referred to by the ship or port operator or designer. Having up-to-date advice on these diverse sources is therefore important.
- Port and ferry operators need to take into account a wider range of passenger requirements in order to improve accessibility for elderly and disabled people at all stages of a journey. For instance, the needs of wheelchair passengers appear to be widely understood, but there is less awareness of the requirements of people with visual or hearing and learning or mental health impairments. Some disabled people travel with a carer, but others want to travel alone and may need extra assistance.
- A failure to provide passengers with relevant information in an appropriate manner through websites and printed information has resulted in the shipping industry losing some business. This is because disabled people are uncertain about the tasks that they would have to undertake in order to travel or the availability of services that could have eased their journey (e.g. courtesy buses, complementary wheelchairs, and personal assistance services). Poor information makes it more difficult for first time users, who have particular difficulty in predicting their needs in relation to the facilities that are actually offered.
The findings are that the shipping and port industry has partially met the recommendations of the DPTAC voluntarily. In some cases this partial compliance has meant that some facilities are difficult or impossible for a disabled person to use. It is recognised that, there may be operational reasons or restrictions for not meeting the recommendations that have not been explored in this study. Nonetheless, the evidence from this research indicates that the voluntary approach has not been fully effectively, and should be reviewed.
The following are the main recommendations made by the study team:
Recommendation 1: DPTAC should advise the Government to consider lifting the Part 3 DDA exemption for large passenger ships and consult the industry.
Lifting the Part 3 exemption and introducing regulations should ensure a minimum level of service is provided but it should be noted the DPTAC guidance contains best practice. The research suggests that the shipping industry is more likely to adhere to regulations but if these are not considered reasonable could lead to ships being registered outside of the UK to avoid regulation.
Recommendation 2: The content and structure of the documents should be reviewed.
The content and the structure of the DPTAC guidance are such that it is difficult to identify who the intended audience is. By its use of very different additional documents, the DPTAC guidance mixes best practice and minimum legal requirements without making the distinction clear. The document should highlight which parts operators are required to meet under the DDA.
The DPTAC guidance has to some extent influenced the design of new ships and investment in the infrastructure, but it can be seen that some designers and operators who should be using it are not doing so. One of the reasons for this may be a mismatch between the design structure and presentation of the document and of the needs of the potential users of the document.
DPTAC should consult with the industry to ensure the document appropriately reflects distinctions between new design projects, refurbishment and service issues.
Recommendation 3: The document should be updated in order to remain a creditable resource.
In the five years since publication of the DPTAC guidance, some of the reference material has been updated or changed and new regulations introduced. The document should be updated in order to maintain its authority and credibility for potential users.
Recommendation 4: It is recommended that all opportunities are taken to raise awareness of the DPTAC guidance and different methods of dissemination should be considered.
There is a low level of knowledge of the content of the DPTAC document among appropriate professionals. This is not helped by the title of the document, the fact that it only refers to design, not operation, does not mention ports, and many people in the industry do not know what 'a large passenger ship' is. The DPTAC guidance refers to new large passenger ferries, although it does state that "it is strongly recommended that owners or operators of any passenger vessel should take due account of this guidance when planning refurbishments of vessels or terminals." DPTAC and the Maritime and Coastguard Authority have issued guidance for small passenger ships in connection with implementing European Commission Directive 2003/24/EC - amending safety rules and standards for passenger ships. This should be highlighted in the guidance.
Recommendation 5: Port and ship operators should ensure that all staff receives appropriate disability awareness training at regular intervals.
Although all the staff interviewed were very willing to assist disabled people, this help was not always as useful as it could be, due to a lack of knowledge of the requirements of disabled people. Section 7 (Management and Training) of the DPTAC guidance refers to the provision of disability awareness training to all ship and port staff, but it is clear that this requirement is not being met. It is particularly important that staff who deal with passengers and staff who deal with enquiries or bookings are trained to inform disabled people of any practical difficulties there may be in using their services and how these can be overcome. Designers and naval architects may also benefit from appropriate disability awareness training.
Recommendation 6: Consultation between ship and port operators and disabled people or representative groups should be encouraged.
Involving disabled people in the design stage can mean that their needs are properly taken into account. Representative groups can also help to provide local knowledge, especially for life-line services, and establish priorities for service and facilities.
Good working arrangements exist between some ship and port operators and these should be built upon and extended more widely.
Recommendation 7: Shore to ship transfer and boarding will only be fully resolved by port and ship operators working together to resolve access issues. Revised DPTAC guidance could emphasise the need for this.
The transition from shore to ship is often one of the most difficult for the disabled traveller. It is important that those responsible for new ship design work together with those responsible for the port-side facilities to arrive jointly at accessible boarding arrangements that are fully accessible for all foot passengers.
DPTAC has a very important role to play in this area because it would seem that gangways may not be covered by either building regulations or SOLAS, and whilst it is clear from the Code of Safe Working Practices for Merchant Seaman (Ch.6) that the ships master has the responsibility for safe access and egress, for most RoRo services he cannot fulfil this duty without the full cooperation of the port authority.
Recommendation 8: Port and ship operators need to take into account the needs of older and disabled people at all stages of their information dissemination.
The marketing of ships and ports to potential passengers does not appear to take account of disabled people and the provision of web and print based information does not provide the required information in an accessible format. For instance, on line booking services need to include specific information for people with disabilities and be accessible using screen readers. In addition where facilities for accessibility have been improved, this should be publicised. In addition, ship and port operators should be encouraged to publish their disability policies to promote the accessibility or disabled people. Information at the port and on board the vessel should also be available in alternative formats such as large print.