I cruise frequently with my parents as a caregiver for my mother, who has MS and is a full-time wheelchair user. My parents have taken more than 30 cruises, and I have taken more than 15, accompanying them on nearly all of these. I am also a rehabilitation nurse with over 30 years experience working with people with serious disabilities. I would like to make comments and give input to the development of the ADA standards for cruise ships.
In reviewing the standards, I will make the following comments:
Chapter 1: Accessible routes
We often find that there is no wheelchair access to some decks of the ship. This is often an observation deck used for such activities as star gazing or view while underway, or the sports deck, which excludes the wheelchair user from participation in or observation of sports such as tennis, shuffleboard or volleyball. This is not equal access, and it should be required.
Many ships have promenade decks designed to allow exercise and recreation around the ship. Some ships (such as the Grand Princess) include stairs in this route, which excludes the wheelchair user from these forms of recreation and exercise. Promenade decks that encircle the ship should have fully accessible paths of travel.
While nearly all ships have accessible dining areas, in many, wheelchair seating is limited to only a few areas in the dining area, often in areas with no access to windows or the other more preferred seating. There also is often no path of travel available to many tables during mealtimes when tables are occupied. There should be a path of travel available to all seating areas, including raised areas, areas near windows, etc. In addition, in areas where food is served buffet style, there should be wheelchair access to all serving stations.
This is not the case on many ships. Many tables are too low to accomodate wheelchair users as well. A select number of wheelchair accessible tables should be distributed in all areas of the dining area.
In other public areas of the ship, there should be wheelchair accessible paths of travel to all bars, theaters and showrooms, and these paths should allow access to all areas of such areas. Ramps to these areas should comply with existing ADA ramp specifications (this if often not the case). On many ships the wheelchair seating is in a segregated area that does not allow wheelchair users to sit with other members of their party. Often these areas are in the least desirable parts of the room (often in the back and to the side) and often have poor lines of sight that prevent the wheelchair user from seeing the entire show. This may be due to overhanging balconies, mezzanines or lighting fixtures, or more often due to railings set at eye-level for a wheelchair user. Wheelchair seating should be designed to allow the wheelchair user to sit in a wide variety of areas of the showroom (which often is stadium type seating) and allow them to sit with non-disabled members of their party.
Shops on the ship often do not have clear path of travel for a wheelchair between clothing racks and shelving. This should be required for all ship stores and shops.
We have never been on a ship with any signage indicating accessible routes of travel for either safety (access to lifeboats) or in general when stairs were the most commonly available route. This would be helpful for all wheelchair uses as well as for families with children in strollers.
Doors to exterior areas of the ship should either comply with the maximum pull/push force should also be less than 5 lb. or an automatic powered door opener should be provided. These doors are often very heavy with very high pull force, which is only worsened by wind or sea action.
Hallways should not be allowed to be blocked by housekeeping carts. This is a major problem on nearly all ships except for Holland America. HAL uses hand-carried housekeeping trays, not carts, and is an exception to this common problem. The wheelchair user if often forced to have an able-bodied companion with them simply so that person can move the carts as they try to move down a hallways. Carts should be designed to allow at least a 38" path of travel on the side of the cart (allowing for hand rail protrusion into the space). Luggage should not be allowed to be stacked in hallways prior to disembarkation nor linen hampers or bags allowed to be in hallways that block wheelchair access at any time. We often find we cannot get to our cabin the night before disembarkation as luggage may completely block the hallway, requiring us to move many suitcases to get to our room. This would be a safety hazard as well if we had to evacuate our room under such circumstances.
We have frequently found that chair lifts are locked, requiring attendant assistance, and that once an attendant if found, and the key obtained, they have had no training in the use of the lift and area unable to operate it. This should not be allowed as covered in 408.1
Chapter 2:On/Off Accessible Routes
There are frequent problems with embarkation and disembarkation on many ships. If there is a ramp provided, it is often very steep (sometimes up to a 45 degree angle) and often very narrow. There is often a lip more than 1-2" high. Using an 18" standard manual wheelchair, we have had problems with a wheel nearly falling off the edge of the ramp on numerous occasions, risking a fall from the ramp or serious injury. Edge protection is rarely present, or ineffective on these ramps. The ramps should be able to accomodate at least a 20" standard manual wheelchair.
We have often found shore-side elevators which are designed for embarkation or disembarkation require a long walk for access, and are insufficient in number for the number of wheelchair users, requiring long waits. Elevators are often broken as well.
Crew members are also often poorly educated about how to assist the wheelchair user to safely go up or down a steep ramp or how to safely carry an occupied chair. This should be included in safety training for crew involved with these activities.
While we understand that tendering ashore from a cruise ship may need to be limited for those with mobility disabilities for safety reasons, we have found that there are often undue restrictions placed on wheelchair users. Tendering may be announced as "unsafe" or unavailable many days before arriving at a port, when the local conditions on that day could not be known. This is often done because the captain and crew don't want to be bothered having to deal with wheelchair users. Another common problem is that only 1 or 2 tenders may be able to accomodate wheelchairs, and if they decided not to use those lifeboats for tender use, there is no access. We have experienced on several ships being required to give several days notice of our intent to tender, and then being told we would have to wait to go ashore until all able-bodied passengers who wish to disembark have done so. This may reduce by up to 4 hours the amount of time we have in a port. This is not equal access. There so be no different access to times and availability of tendering services for those with mobility disabilities than for those who are able-bodied.
Chapter 3: Egress
We have found that access to life boats for wheelchairs seems to have poor planning. This should be covered at the time of the required life boat drills on each voyage.
Crew should be required to include wheelchair passenger evacuation in their life boat drills. We had a recent experience on the HAL Statendam that brought this point home. Due to heavy seas, when returning from a tender port, we were unable to access the tender lift on this ship. After much discussion and trial, it was decided to lift the tender (which is also a life boat) up on the davots to the Promenade deck (which is a life boat station) to take my mother off in her wheelchair. Once the tender had been raised to this level, it was discovered that the wheelchair accessible doorway on the tender did not line up with the access gate in the deck railing. This required the crew to pick my mother up in her wheelchair, tilt the wheelchair 45 degrees, and lift her over their heads to get her over the rail onto the ship's deck. They clearly had never drilled this, nor anticipated the need to move someone on or off a lifeboat in a wheelchair before. In an emergency, this delay could be fatal, not only to the wheelchair user, but to other passengers and crew as well. There should be the ability to accomodate wheelchairs on all lifeboats, not just selected boats. The latter risks these boats being damaged in an accident or collision and not being available for equal access to evacuation. Chapter 5 Toilet and Bathing Shower units should require that the controls be reachable and easily usable from any installed permenantly mounted seat. Often they cannot be reached from this position, requiring someone else to operate the shower or risk a fall.
There is often a non-beveled lip which is higher than 1/2" around the roll-in shower which can make the use of a rolling shower/commode chair or even a wheelchair difficult or unsafe. This is found on all Crystal Cruise line ships, and also creates a trip-hazard as it is only 4" in front of the toilet.
Even a 1/2" threshold on a roll-in shower can be a problem unless it is beveled. Please consider adding this to the standards. At least half of the public restrooms should have wheelchair accessible toilet facilities, and these should be marked on both ship maps as well as the door. Although not technically bathing, since this is not addressed elsewhere, at least one pool and hot tub on a ship with swimming pools or hot tubs should be equipped with a lift to allow equal access to passengers with mobility disabilities. Chapter 7 Lodging Doorways for accessible cabins, both entrance, bathroom and balcony doors, should be at least 34" wide, and have an accessible turn space to allow access from the hallway or area of the room. Balconies should have a safe method for wheelchair access. Often ramps to cabin balconies are non-existant, or jerry-rigged, too steep, too narrow, and generally unsafe.
The required minimum number of accessible cabins is insufficient. People with mobility impairments who cruise will tell you that these cabins sell out months or even years before the non-accessible cabins. The nature of cruising is that many elderly and disabled people choose to travel this way. There should be more required cabins. These cabins can be sold to those without disabilities, so this does not cause the cruise line to loose money. There should also be accessible cabins in all cabin categories, not just in the more expensive categories as frequently is the case currently. In addition, it is extremely rare to have wheelchair accessible cabins that are interconnecting with non-accessible cabins, or which will accomodate more than 2 passengers. People with mobility disabilities often need to travel with a personal care assistant in addition to their spouse, or may have children just as people without disabilities. There should be an equal proportion of family rooms that are accessible as exist in the non-accessible rooms on a ship. Beds should be required to be non-platform beds to accomodate mobile lifting devices, with at least 4-5" of clearance under the frame to allow this. There should also be a minimum height of the mattress that is at 19-22 inches. Often we have had beds so low that transfers (either manual or with a lift) were very difficult. I understand others have encountered beds that are too high as well.
There should be accessible room and reading light controls within reach of a person in bed in at least one of the beds in the accessible staterooms. Other comments While we recognize that the cruise lines do not technically provide the shore excursions available to cruise passengers, they do serve as the booking agent, and do provide the only information passengers have about these excursions. Often the cruise ships have arranged exclusive contracts with tour providers which result in no tours being available for hire unless arranged through the cruise line. Of course in US ports the tour operators are required to follow ADA standards (although there is exceedingly poor compliance), and this does not apply to foreign ports, as the booking agent the cruise line should at a minimum be required to indicate 1) which of their tours can provide (or not provide) wheelchair accessible transportation and facilities, and 2) alternative resources for tours in ports which do provide accessiblity transportation, when available. Currently cruise lines will sometimes advertise their tours as "accessible" but when inquiring about the details, it is discovered that these are NOT accessible, but only require minimal walking. They often sell "accessible" tours with no lift equipped transportation, and expect that everyone can get up or down "just a couple of steps" into a regular van or bus.
Cruise ships also often provide shuttle services from airports to their ships (sometimes free, sometimes for a charge) but often do not provide equivilant accessible transportation for wheelchair users, requiring them to find their own transportation at their own expense. This is not equal access. I hope these comments will be included in consideration of the development of the final cruise ship ADA standards.
Kathleen L. Dunn, MS, RN, CRRN-A
Clinical Nurse Specialist & Rehab Case Manager
Spinal Cord Injury Center (128)
VA San Diego Healthcare System
3350 La Jolla Village Dr.
San Diego, CA 92116
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