Captain W Cursiter, BC Coastal Transportation Society

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Sent: Mon 2014-01-20 12:10 PM

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Captain W Cursiter, BC Coastal Transportation Society

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Transportation Safety issues related to passengers with disabilities.

B C Coastal Transportation Society has presented the following concerns at the Canadian Marine Advisory Council in Ottawa on November 6th 2013 and the Regional CMAC meeting September 11th 2013 in North Vancouver. This presentation is regarding what the BCCTS considers to be deficiencies in the manner special needs passengers are dealt with on domestic passenger vessels in Canada.

We have concerns about vessels that may not have proper equipment to evacuate special needs passengers off a ship in an emergency, crew not having the proper training in all cases to assist these passengers, the requirement to self declare, the need for assistance by the passengers and the minimal level of care and understanding on the part of the Shipping Companies involved.

With the accidents involving Ferries and Cruise ships that have occurred in the last 20 years internationally more is being discussed on this topic, for example cruise ships visiting Vancouver are required to demonstrate to Transport Canada Inspectors that they meet the requirements to properly evacuate disabled persons from the vessel. This resulted from the investigations done after the Costa Concordia incident.

In the Marine Industry "Special Needs Passengers" include all persons with disabilities, infants, children too small to use evacuation equipment on their own, persons too large to safely use evacuation equipment, elderly persons who require assistance or could get fatal injuries using evacuation equipment and passengers returning from hospital after having surgery which affects their ability to be evacuated safely from the vessel.

Evacuation Equipment

Examples of evacuation equipment that may not be suitable for special needs passengers include evacuation chutes the company won't allow ships crew to use during training drills due to the likelihood of injury and then expecting all passengers to use this equipment in an emergency. Other vessels evacuation equipment requiring all passengers to evacuate using steel ladders or scramble nets.

Elevators

On all ships in an emergency it is normal to turn off the power to elevators as there is the possibility of it becoming stuck between floors if the vessel develops a list or loses power to operate it. Our concern then is a large number of people not being able to use stairs without assistance being in their cars and having to go up 2, 3 or 4 decks to get to the evacuation stations.

Crew Training

We feel that crew training should include disability awareness training of appropriate responses to different disabilities, being able to communicate appropriately, boarding and de-boarding, assistance that safeguards their safety and dignity, escorting techniques of visually and hearing impaired persons, being able to transfer a person in and out of a wheelchair and awareness of feelings of vulnerability because of dependence for assistance.

Self-identification

We are concerned that the current regulations for carriage of special needs passengers rely solely upon self-identification. Many ship owners may over-rely on their websites for self-identification, a concept that relies on all passengers being aware of the policy and having access to the internet.

The British Columbia Coastal Transportation Society is a non-profit organization and we are a group of volunteers who want to see safe and affordable transportation for all passengers and employees.

SSB # 06/2007 (Information on Persons on Board, Counting, Recording and Special Needs)

Capt. Willie Cursiter, BC Coastal Transportation Society

We appreciate the spirit and intent of Ships' Safety Bulletin 06/2007 and the subsequent regulations that have been drafted in response to TSB recommendations regarding adequate accounting of passengers on Canadian vessels. However we are concerned they may not have gone far enough in providing guidance for ship owners and operators, given the complexity of the issue. We raise the following concerns for discussion, with the understanding that we believe this is not a local or isolated issue regarding one specific ship-owner but rather a national issue speaking to a significant number of special needs passengers. This demographic is increasing as the population ages and an important group travelling on passenger ferries in Canada.

SSB #06/2007 and the subsequent regulations contained in Fire and Boat Drill Regulations do not specify requirements for implementation of systems that would ensure that all passengers who may need assistance are identified, nor are there means specified for notifying the Master or crew of the presence of all passengers requiring assistance that are on-board any given sailing. The regulations rely solely upon self-identification. Is the method of self-identification an adequate system given the broad spectrum of physical and mental challenges some passengers live with?

Furthermore operators may over-rely on websites for self-identification, a concept that relies on all passengers being aware of the policy and having access to the internet. We suggest identification of passengers who may need assistance be included in a more substantial way in the Passenger Safety Management training certification, as well as through recognized systems for passenger accounting that may be available to ship owners.

We are also asking how this important regulation is enforced and audited, including the means to communicate the policy to Masters and crew responsible for these passengers once they are aboard the vessel.

We support the recommendation put forward by the International Transport Workers' Federation that a certificate be issued to a vessel stating the number of special needs passengers that can be carried as well as the number of seafarers specially trained to deal with these passengers.

2010 EU regulations suggest training of ships' crew should include disability awareness training of appropriate responses to different disabilities, being able to communicate appropriately, boarding and de-boarding assistance that safeguards their safety and dignity, escorting techniques of visually and hearing impaired persons, being able to transfer a person in and out of a wheelchair and awareness of feelings of vulnerability because of dependence for assistance. We understand that at least one ship owner on the east coast has taken this more extensive approach; however they are still reliant upon the self-identification process.

We would also suggest that a national policy be developed making the Canadian Transportation Act applicable to all domestic passenger vessels in Canada in order to have all passenger vessels on par and create consistent standards for all special needs passengers regardless of what part of the country they live in or whether the ferries they ride on are vessels regulated federally or provincially.

We are also concerned the regulations do not specifically address what the evacuation equipment and arrangements for this group of passengers and the Domestic Fleet should be and we request a comment on when or whether they will.

We believe the design of new vessels should include not only accessible areas in accommodations but should address improved access to evacuation equipment for passengers requiring special care or assistance. Vessels in the domestic fleet have used a wide variety of systems, including slides, chutes and scramble nets for the evacuation of passengers and we suggest that a standardized system be explored for these passengers to assist ships' crews to evacuate them.

Finally at least one large passenger ferry operator permits free access to vehicle decks during the voyage on most of its routes which may complicate the crews' ability to respond effectively to an emergency and, more specifically, to assist special needs passengers.

This also makes assessing the numbers of special needs passengers who have not self-identified problematic and may hamper what could already be a difficult emergency scenario. The practice of using a 2% buffer for counting passengers could also skew the data regarding accounting for all passengers including special needs.

We are also concerned about the policy of enlisting the assistance of untrained and unqualified albeit able bodied or 'responsible'

passengers to supplement the crew during emergencies on some vessels in the domestic fleet, something that is reflected in some evacuation plans.

Captain Cursiter and the BCCTS respectfully request copies of risk assessments that may have been undertaken with regards to these issues, in particular the practice of permitting passengers on car decks during voyages and the ongoing use of a self-identification process for special needs passengers.

We also ask for verification of how the inspection and enforcement regimes work for these particular areas of concern.

As there is quite a lot of information on our website. We have included links to our Authority to Enforce series that relates to this subject.

Additional reference material;

Regulation (EU) No 1177/2010 of the European Parliament and of the Council of 24 November 2010 concerning the rights of passengers when travelling by sea and inland waterway and amending Regulation (EC) No

2006/2004 Text with EEA relevance

UN Article 9 - Accessibility

Regards

Captain William Cursiter

President BCCTS