I recently spent an uncomfortable afternoon in Washington, D.C., listening to comments from representatives of the disabled community and the passenger vessel industry to members of the federal government’s Architectural and Transportation Barriers Compliance Board, commonly called the Access Board.
I was somewhat surprised by the questions and comments from the board members after hearing the public statements. The board displayed a minimal understanding of the complexities involved in making design modifications to small vessels in order to make them more accessible. It was surprising since this dialog has been going on for at least seven years.
The Americans with Disabilities Act became law in 1990 to ensure that facilities and vehicles are readily accessible and usable by disabled individuals. Unlike other modes, there were no rules established to specify the details for new construction of passenger vessels. Eight years later, the Access Board established a 21-member Passenger Vessel Access Advisory Committee to make recommendations to the board. The committee membership included disabled organizations, industry trade groups, government agencies, and passenger vessel operators. PVAAC met nine times between September 1998 and September 2000 and submitted a final report to the board, “Recommendations for Accessibility Guidelines for Passenger Vessels,” which can be found at http://www.access-board.gov/pvaac/ commrept/index.htm.
Unfortunately for the industry, it took four years for the board to review the report and develop a proposed rule that allows only four months for comments. This is not nearly enough time. Speakers at the D.C. hearing requested an extension of at least 90 days to submit comments and called for additional public hearings at other locations. Comments can be submitted at http://www.access-board.gov/pvaac/ anprm.htm.
Due to the lengthy delay in the process, the makeup of the board has changed appreciably, and much of the knowledge gained during the numerous meetings and hearings over seven years has been lost.
Hopefully, board members will use the extended time to learn about the complexities, variations, and regulatory limitations that affect passenger vessel design and construction.