Consultation outcome

Draft MGN 306 (M) Amendment 1 Designing and operating smaller passenger vessels

Updated 3 March 2022

Designing and Operating Smaller Passenger Vessels: Guidance on Meeting the Needs of Persons with Reduced Mobility - Amendment 1

Notice to all naval architects and ship designers, owners, operators, builders and marine surveyors

This notice should be read in conjunction with MSN 1789(M) Directive 2003/24/EC – Safety Requirements for Persons with Reduced Mobility on Domestic Passenger Ships This Notice supersedes and replaces the original version of MGN 306(M)

Summary

The purpose of this document is to help ensure that the design and operation of smaller passenger ships meet the needs of people with reduced mobility as effectively as possible.

The words “…Needs of Persons with Reduced Mobility”, in the title of this MGN are interpreted broadly and are intended to include any limitations, physical or mental, which persons may have on their ability to navigate their way around the ship or interact with safety guidance.

This Amendment to MGN 306(M) includes changes in legislation and general updating, including contact details for useful organisations.

1. Introduction/Background

1.1 Disabled people account for 20% to 25% of the population. Whilst greater numbers of children are being born and living with disabilities than ever before, levels of disability also increase with age. Some examples of disabilities are:

• difficulty walking and/or climbing steps;
• hearing loss;
• vision loss;
• learning disabilities;
• other mental health-related issues.

1.2 Disabled people are not a homogenous group with identical needs. For example the needs of people with mental health problems or learning disabilities are distinct from those of wheelchair users. Even within disabilities needs vary; for example a profoundly deaf person will not benefit from an induction loop.

1.3 From beginning to end, the public transport journey on board these passenger vessels should be accessible. Disabled passengers need to know that this will be the case before they set out. The lack of an accessible taxi or the absence of assistance on arrival at a terminal can prevent a disabled person using the services.

1.4 Levels of awareness of the needs of disabled people have developed after many existing vessels came into service, and was therefore not often fully reflected in their design. There may also be resource and operational constraints on the extent and speed with which vessel owners and operators can improve accessibility. However, there remains much that can be achieved with relatively low cost or disruption. Many of these changes relate to simple and inexpensive equipment that would aid, for example, people with sensory impairments. Operators should be aware that even where it is considered too difficult to make every possible improvement to accommodate wheelchair users, access needs for other passengers with reduced mobility can often be improved.

1.5 It is not the intent of UK Regulation to fundamentally change the exterior designs of vessels, or to put any operator out of business. Regulation (EU) 1177/2010 on passenger rights – which applies to vessels in some circumstances, but is good advice generally - was incorporated into UK retained law by section 3 of the European Union (Withdrawal) Act 2018. However, the full range of factors listed under “terminology” should be considered in deciding what is reasonable and practicable in making arrangements for on board access to all passengers on passenger ships.

1.6 The accessibility guidelines in the Annex are intended to allow reasonable access to all public and service areas of the vessel. They should allow a proportionate amount of access to representative facilities. This would include access to all services, but not necessarily to all the locations where that service is offered.

NB: For further information on non-MCA documents mentioned in this MGN, see Section 8, Useful documents”.

2. Terminology

2.1 “Persons with reduced mobility” is defined as “anyone who has a particular difficulty when using public transport, including elderly persons, disabled persons, persons with sensory impairments and wheelchair users, pregnant women and persons accompanying small children”. Although this expression is used in legislation, its use with passengers is discouraged. People with hearing impairments and those with small children, for example are unlikely to consider themselves to be “persons with reduced mobility”.

2.2 “Public transport” is a conveyance, either publicly or privately owned, provided to the general public or special service (but not including charter or sightseeing service) on a scheduled route between at least two different locations on a regular basis over a sustained period of time.

2.3 As far as defining what steps are reasonable and practicable, this will depend on all the circumstances of the case. It will vary according to:

• the type of services being provided;
• the nature of the service provider and its size and resources;
• the effect of the disability on the individual disabled person.

2.4 However, without intending to be exhaustive, the following are some of the factors that might be taken into account when considering what is reasonable:

• whether taking any particular steps would be effective in overcoming the difficulty that disabled people face in accessing the services in question;
• the extent to which it is practicable for the service provider to take the steps;
• the financial and other costs of making the adjustment;
• the extent of any disruption which taking the steps would cause;
• the extent of the service provider’s financial and other resources;
• the amount of any resources already spent on making adjustments;
• the availability of financial or other assistance.

2.5 It is important that service providers do not assume that the only way to make services accessible to disabled people is to make a physical alteration to their premises (such as installing a ramp or widening a doorway). Often, minor measures such as allowing more time to serve a disabled customer or serving at their location, will help disabled people to use a service. Disability awareness training for staff is also likely to be appropriate. However, physical alterations may be the only answer if other measures are not sufficient to overcome barriers to access.

3. Related Guidance

3.1 This guidance should be read in conjunction with any mandatory requirements for particular passenger vessel types, e.g, those which fall under the Merchant Shipping (Passenger Ships on Domestic Voyages) Regulations 2000 (SI 2000/2687).

3.2 In June 1996 the International Maritime Organisation (IMO) issued MSC/Circ.735, guidelines entitled “Recommendation on the Design and Operation of Passenger Ships to Respond to Elderly and Disabled Persons’ Needs”. The IMO guidelines covered the design and operation of new passenger ships, with the emphasis on ro-ro passenger ferries.

More Information

UK Maritime Services, Ship Standards
Maritime and Coastguard Agency,
Bay 2/23
Spring Place,
105 Commercial Road,
Southampton,
SO15 1EG.

Tel: +44 (0) 203 8172000 Email: dpv@mcga.gov.uk

Annex 1: Pre-journey information

Passengers information

1.1 Before they consider any journey, passengers with disabilities have to be certain that they will be able to complete the trip - passing successfully along the whole of the transport chain, including the part that covers the embarkation and disembarkation terminals and the vessel.

1.2 The GOV.UK website provides useful information on its “Transport support services for disabled people” page:https://www.gov.uk/transport-disabled.

1.3 Passengers need to be provided with sufficient reliable information that they can use to check the facilities available, and ensure that they are aware of any practical difficulties and/or physical obstructions that will have to be coped with on the journey.

1.4 Passengers should be advised to notify the vessel operators involved at least 48 hours in advance of the needs of any persons with reduced mobility in their party (unless a shorter period is agreed between the passenger and the carrier or terminal operator), so that the vessel operators can make appropriate arrangements and warn passengers in advance of any difficulties or obstructions.

1.5 When the same itinerary is served by different vessels providing an equivalent level of service, then, provided their schedules are published in a range of accessible formats, different vessels can accommodate people with different disabilities.

1.6 All personnel dealing with enquiries or bookings, whether by telephone or in writing, should be knowledgeable about the facilities and services available for people with reduced mobility - including elderly persons, disabled persons, persons with sensory impairments and wheelchair users, pregnant women and persons accompanying small children.

1.7 In addition, a single identified post should be identified to deal with written requests, bookings and the provision of written information. Section 7 gives further details of the need to train such staff effectively.

a. Operators must^{[footnote 1]} provide, on demand, documents in a range of formats. These could include good-quality standard print and large print, Braille and audio versions. Requests for Braille versions will probably be infrequent.

b. Where brochures, leaflets, factsheets, plans of terminals and travellers guides are provided they must1 also be made available in large, clear print, in audible format, and, where appropriate, in Braille, giving details of any services and facilities designed to assist disabled passengers. Documents in Braille should not refer to diagrams unless they have been clearly explained in the Braille text.

c. Where timetables are provided, they must1 also be made available in large, clear print and in audible format, giving details of all sailings for each ship, departure terminal and destination. Where a telephone enquiry line is available then textphone capabilities should be provided

d. Information about services and facilities should include the following where relevant:

Terminal

• Layout;
• parking, including parking for blue badge holders;
• information systems, including an induction loop system;
• availability of telephones and textphones; at least one phone should be accessible by wheelchair users;
• illuminated and variable message displays;
• reception arrangements for users;
• location / availability of unisex wheelchair-accessible toilets;
• wheelchair availability;
• reporting/checking-in system;
• marshalling of cars for disabled motorists;
• information on any practical difficulties with the journey, such as long walking distances;
• facilities for assistance dogs, including relief areas.

Shore to ship

• details of any ramps, lifts, escalators, gradients and distances;
• availability of wheelchair-accessible vehicles for transfer of passengers;
• availability of staff assistance including information on any limitations to the services for disabled people^{[footnote 2]}.

On board

• contact points / officers on journey and whereabouts of available information;
• unisex wheelchair-accessible toilets;
• baby changing facilities;
• safe play areas;
• wheelchair-accessible cabins;
• information systems and notices, including illuminated and variable message displays;
• restaurant facilities and services lifts and escalators to vehicle and passenger decks;
• parking availability near lifts and escalators
• wheelchair availability;
• facilities for assistance dogs, including any relief areas.

Disembarkation

• advance notice required;^{[footnote 3]}
• arrangements at terminal of disembarkation, including options for onward travel;
• details of any known practical difficulties or physical obstacles at the terminal of disembarkation.

Ship and shore emergency procedures

1.8 Where relevant, booking arrangements must^{[footnote 4]} be established, including details of advance notice required, and the provision of a reservation notice for registering requirements and giving information in advance to operators and crew. This must^{[footnote 5]} include a system enabling operators to identify individuals on arrival at the terminal.

Annex 2: On-board accommodation

New and existing vessels

2.1 Ship owners and operators are encouraged to achieve as many of these provisions to provide the safest environment possible for all passengers. New and refurbished ships and port terminals must be accessible.^{[footnote 6]}

Access by Passenger Gangway

2.2 The interface between the gangway and where the gangway end comes into the ship should be near to level as possible, free of trip hazards and covered with a non-slip surface. The crew member stationed at the entrance, for security and passenger counting procedures, should assist disabled passengers if required. The crew member should be able to request back up and consideration should be given to how this will be applied to single person operated passenger vessels.

2.3 Vessel and gangway engineering limitations frequently require a maximum slope of 1 in 8. As a result, in tidal waters it may only be reasonable and practicable to assist disabled people on and off gangways [with steep gradients] at certain times. Reasonableness of safe access will depend on a risk assessment that pays due regard to sea state, currents and tidal ranges. Any restrictions to the hours at which assistance is available should be widely notified to known and intending passengers at the earliest opportunity, and no later than when they book.

2.4 Vessel operators are not required to do anything which would endanger the health or safety of any person, including a member of the crew or person with reduced mobility, in order to meet accessibility goals. However they should ensure that any action taken, or not taken, in relation to health or safety is proportionate to the risk. There must be a balance between protecting against the risk and restricting persons with reduced mobility from using the service. It should also be noted that persons of reduced mobility are entitled to make the same choices and to take the same risks within the same limits as other people.

Access by Car Deck

2.5 If possible operators should avoid the need for disabled passengers to have to leave their vehicle to check in.

2.6 Where there is a check-in within the terminal the disabled person, once identified, should be asked to switch on their vehicle’s hazard warning lights before accessing the ship. This practice is generally used in all UK terminals to indicate a vehicle requiring priority loading. Once identified as a ‘reduced mobility person’s’ vehicle, the crew should endeavour to load it such that it is parked on board as near as possible to any available lift.

2.7 Attachment points for storm chains should, as far as practicable, be avoided on the routes from the parking spaces reserved for people with reduced mobility to the accommodation facilities, these routes should be marked and have a non-slip surface in all weathers. Attachment points for storm chains, when in those routes, should be painted in contrasting colours.

2.8 Operators should note that on Ro-Ro journeys passengers (including disabled passengers and their guidance dogs) should not be permitted to remain on the car deck except in exceptional circumstances.

2.9 Operators should note that extra space on the driver’s side or passenger’s side (depending on whether the disabled person is the driver or passenger) may be needed to allow a wheelchair user to transfer to and from their car and wheelchair where they need to leave the car. Extra space may also be needed by people who use walking aids or who have stiff and painful legs e.g. arthritis. Similarly, where cars are parked one behind another additional space may be needed to allow wheelchair users to get around the rear of the vehicle. The car deck itself in the vicinity of any lift or staircase should be clearly marked for disabled access. Standard lift requirements apply unless they conflict with current Passenger Ship Construction Regulations.

2.10 Where passenger facilities are not on the same level as the car deck, passengers with walking impairments will generally need to use any lifts, but the stairs should also be designed to appropriate standards with regard to colours and stair nosings (see Section 3.20). For widths and angles of stairways refer to the construction standards for the type of vessel being built. If building to MSN 1823(M) or the Small Seagoing Passenger Ships Code, see requirements in 5.6 of MSN1823 and 6.5 of the SSPS Code. When constructing to meet other standards, it is recommended that these standards are used unless alternatives are specified in that other standard. The steps themselves should be of uniform dimensions with closed risers. Alleyways and doorways to which passengers have access should have a minimum width of 850 mm.

Toilets

2.11 Where provided toilets should be adequately signed and fitted out internally using non-reflective surfaces, colour and tone contrast, and good lighting. Seating intended for passengers with reduced mobility should have easy access to toilets.

2.12 When only a single toilet is provided, it should be wheelchair-accessible. This may not be practicable to achieve on existing vessels. Consideration clearly needs to be given to the length of the journey and the facilities at either end of the journey.

2.13 Any accessible toilets should be designed in accordance with Building Regulations Part M. (Attention should be paid to a suitable height of wash basins, light switches, exposure to hot water pipes, etc. to aid the users of the disabled toilet.) Access to any toilets should be available during all operational times. If multiple toilets are provided directions to the disabled toilets, in appropriate formats, should be posted at the entrances to other toilets not suitable for wheelchair users.

2.14 All toilet doors should have a clear minimum opening width of 925 mm and be fitted with ‘L’- or ‘D’- shaped handles on the inside of the door. It should be possible to open the doors by using a force not more than 15 newtons, unless the doors are required to be fitted with self closers, in accordance with marine legislation.

2.15 Doors should swing outwards or slide sideways and it should be possible to unlock them from outside in an emergency by means of a key, even when the door signals “occupied”. Means to call assistance should be available in each toilet.

Baby-care Facilities

2.16 Where provided, baby-care facilities, for feeding and nappy changing need to be accessible. Wherever possible baby-care facilities should be separate from any wheelchair accessible toilet. Where this is not practicable, a nappy-changing shelf could be provided in accessible toilets, but this should not impinge on access to the toilet facilities for disabled users.

Restaurants, Cafeterias and other Service Areas.

2.17 Assistance dogs must be permitted in restaurants and other catering and service areas.

2.18 In self-service facilities the design should reflect the mobility and information needs of people with reduced mobility - for example, clear pricing displays will benefit deaf, hard-of-hearing and visually impaired passengers so that they will not have to enquire. Displays also should be at an appropriate height for a passenger in a wheelchair. A continuous system should be used, terminating at the cash register and cutlery rack. Cash registers should provide information in visual formats.

2.19 Service areas and counters should be accessible to people with reduced mobility, including wheelchair users. For service counters, there should be at least one section set at a height suitable for wheelchair users. In existing vessels, passengers of reduced mobility could be identified and assisted if required as a solution to this rather than refitting the area.

2.20 The height of drinking water fountains, where provided, should also accommodate the needs of passengers in wheelchairs.

2.21 Where there are dedicated seated areas for eating, there should be a designated seated area that is wheelchair accessible with adequate space for manoeuvring. Tables, if rectangular, should have rounded corners. A proportion of chairs should not be fitted with armrests. To assist partially sighted people the furniture should contrast in colour and tone with surrounding surface materials, e.g. carpets and walls.

2.22 When existing vessels under go refurbishment (e.g. of soft furnishing) they are expected to follow the standard laid down herein.

General Lighting

2.23 Care should be taken to assure that the position and intensity of lighting will not adversely affect the bridge visibility and navigation of the vessel at night.

2.24 Lighting should be uniformly distributed so that pools of light and dark are avoided. Different lighting levels can be used to differentiate one area from another. For example, brighter lights can be used over circulating areas and pedestrian routes, and a lower lighting level over waiting areas.

2.25 Light fittings and luminaires should be chosen so as to avoid glare and dazzle.

2.26 Where crew need to communicate with passengers, there should be sufficient light to enable those passengers who lip read to do so.

2.27 In some areas adjustable levels of lighting could be helpful - for example any transition zone at the entrance to the vessel.

2.28 In any alleyways and corridors, light fittings should be positioned well above head level.

2.29 Floor level and low level lighting should not be used except where required by Passenger Ship Construction Regulations to indicate escape routes, stairways and exits. Such lighting used in other circumstances can be disorientating and confusing to visually impaired people. Discotheques are an exception to this.

Ship Plans

2.30 Operators could consider making available tactile plans of the vessel where considered appropriate. Safety plans, when displayed, should be at a height suitable for all passengers.

First Aid

2.31 Operators should decide their first-aid policy and make appropriate arrangements to ensure that in the event of a disabled passenger becoming ill they can be given the same attention, including access to any first-aid rooms, as any other passenger.

Seating

2.32 When designing furniture layout within public spaces, operators should, in addition to complying with statutory regulations, provide facilities for people with reduced mobility, such as a combination of fixed or moveable seats (within the Regulations), armrests, suitable heights, etc.

2.33 Any permanent wheelchair spaces should be designed in the ratio of at least one per hundred passengers so that the wheelchair user may travel sitting in the wheelchair together with other passengers. It should be possible to place the wheelchair safely in position.

2.34 As a guide 4% of the ship’s passenger seats should be suitable for disabled persons. These seats should have sufficient space and be provided with suitable handholds so that disabled persons may support themselves when sitting down or getting up from the seat.

2.35 Any handholds should be marked in a contrasting colour.

2.36 If the leg space available in the seats available for persons with reduced mobility does not have enough room for persons with stiff legs, the seat in front of the designated seat should be a removable one. If seats are arranged in rows, any armrests which may constitute an obstruction to a disabled person, should be of a type that can fold away.

2.37 Any seats for passenger with reduced mobility should be situated near evacuation routes, assembly areas and suitable toilets.

Wheelchair spaces on board High Speed Craft.

2.38 A wheelchair space should be sufficient to enable any passenger in a wheelchair to travel facing the bow of the vessel;

2.39 A wheelchair space should be fitted with a wheelchair user restraint system which should comprise the option of a full harness (both shoulders and a lap belt) and should be suitable for general wheelchair application;

2.40 Any wheelchair restraint system should comply with the requirements of Annex 9 of the International Code of Safety for High-Speed Craft (HSC) Code, 1994 or Annex 10 of the International Code of Safety for High-Speed Craft (HSC) Code, 2000 as applicable;

2.41 Any wheelchair user restraint or wheelchair restraint system fitted to a wheelchair space should be capable of being easily released in the case of an emergency.

Cabins

2.42 Wherever possible, a proportion of any passenger cabins provided should be accessible to disabled people, including wheelchair users who cannot walk at all.

2.43 A list of cabins occupied by passengers who may need assistance from the crew should be available and arranged as part of the vessels emergency procedures.

2.44 In ships with cabins, persons with reduced mobility who may need assistance in an emergency should be assigned cabins, where practicable, situated in the proximity of the embarkation deck, so that they may be assisted to the survival craft quickly and easily. It is important that these cabins are equipped with facilities to enable disabled passengers to summon assistance in the event of illness or other emergencies.

2.45 In these cabins any free space in front of the bed or resting place should be at least 1400mm wide. Beds (secured to the deck) should be used instead of bunks (low front edge), so as to allow a disabled person to be able to sit on the bed when changing.

2.46 Where bunks are used, the lower bunk should have a free height above it of at least 1100 mm to permit a person to sit.

2.47 The bed should be between 550 mm and 650 mm above the floor.

2.48 The switch for any reading light over the bed should be placed so that it can be reached from a wheel chair and from the bed. Electrical switches should be within easy reach and placed 900 mm above the floor.

2.49 Handholds should be positioned at the bed.

2.50 The cabin door should be of the side sliding type or swing outwards, unless enough space is available within the cabin to permit the door to swing inwards leaving sufficient space for a wheelchair. The free door opening width should be at least 900 mm.

2.51 If a hand basin is placed in the cabin it should be arranged in accordance with the guidance contained in the paragraph 2.13.

2.52 All furnishings and bedding shall as far as possible be made from non-allergenic materials. Where practicable the use of some cabins and areas of the vessel should be prohibited from use by passengers who are accompanied by animals likely to cause an allergic reaction.

Assistance Dogs

2.53 Where appropriate, vessel operators should provide assistance dog owners with a designated area where the dog could be offered the opportunity to relieve itself during an extended trip.

2.54 The area should be free of rubbish and any other hazards and preferably away from crowded areas. If possible, it could be helpful for the area to be enclosed, thus allowing the dog to spend time off lead/harness, but where this is not practicable, a suitably trained person could be made available to assist the assistance dog owner in this matter, if required.

2.55 Access to the area should be free of steps and other hazards to allow the disabled person to access the area independently, a health and safety risk assessment should be carried out to ascertain that this area is hazard free and suitable for the purpose.

2.56 A record of this risk assessment should be retained by the operator who should subject the area to regular checks to ensure that this standard is maintained.

Annex 3: Lifts, steps, stairs and ramps on vessels

3.1 These guidelines cover all aspects of design for lifts, steps, stairs and ramps, where they are provided. The “Part M Approved Document” (ODPM 2004) contains additional guidance covering dimensions which should be followed wherever possible, except where physical or design constraints (such as a ship’s hull or bulkheads) prevent the use of these dimensions.

3.2 Existing vessels should attempt to meet these standards when undertaking any major conversion.

Lifts

3.3 Lifts should not be required if access to comparable services, other than sightseeing, are provided on the embarkation deck.

3.4 Alleyways and corners on the approaches to and exits from customer lifts should be wide enough for all lift users, with an unobstructed space for manoeuvring of at least 1500 mm on bends and corners for wheelchair users.

3.5 Seating should be provided close to lift entrances for waiting passengers who cannot stand for long periods. Care should be taken to ensure that such seating does not obstruct access to the lift or evacuation routes and a clear space of 1500 mm by 1500 mm is required in front of the lift doors.

3.6 Lift doors should be clearly indicated in a colour/tonal contrast with the surrounding wall.

3.7 A handrail should be provided on at least one wall of the lift at a height of 900 mm from the floor, and the back wall should include a mirror to enable a wheelchair user to see the floor indicator. Apart from the mirror, which should finish no lower than 300 mm from the floor, the lift cabin walls should not be reflective. If walls are of a metal finish they should provide adequate contrast to indicate the position of the controls and handrails.

3.8 Plain glass should be avoided because it can cause confusion to visually impaired people, but lift doors (except for those which are fire doors) should have sufficient glazing to enable lift users to be seen clearly from outside and vice versa. Lift floors should be covered with non-slip material.

3.9 The lift interior should be lit to similar levels as those floors at which it calls.

3.10 Controls both inside and outside the lift should be centred at 1100 mm above floor level, with buttons at a minimum height of 900 mm and a maximum of 1200 mm. There should be nothing protruding more than 100 mm from the wall below the buttons. The buttons themselves should be at least 20 mm in width/height, slightly raised from their surroundings, and capable of being operated by using the palm of the hand as well as the fingers, and internally illuminated.

3.11 Floor numbers and other control information should be clearly visible in contrasting colours/tones with raised characters/numerals, in both text and Braille. There should be a visual and audible acknowledgement that a call has been registered, when the lift arrives and which lift it is, if there are more than one.

3.12 Within the lift audible and visual information should indicate the direction the lift will travel in, and the floor reached. To assist visually impaired users and mobility impaired people, audible announcements complemented by visual indication should be given both inside and outside the lift when the doors are opening and closing and when the floor has been reached.

3.13 Controls inside the lift, while complying with the above recommendations, should be fitted on a side wall at least 400 mm from the front and back wall. The emergency controls should be positioned at the bottom of the panel; the centre line of these controls should be no lower than 900 mm from the lift floor.

3.14 A visual and audible two-way emergency communication system should be provided between the lift and a point outside, with the highest part of the system no more than 1200 mm from the lift floor.

3.15 A foldable seat should be available in a position from which the controls can be reached.

3.16 Lifts should be fully automatic, and should also be fitted with automatic floor-levelling devices. Lift doors should remain open for at least 20 seconds unless overridden by the door closing button.

Lift Dimensions

3.17 Lift door(s) should open to a clear width of at least 900 mm, except where building constraints or physical design prevent it. 3.18 Larger lift cars may require the fitting of control panels on either side of the doors designed to the specifications given in the above section.

Steps and Stairs

3.19 The steps should be of uniform dimensions. Fewer than 3 or more than 12 risers should be avoided.

3.20 A contrasting stair nosing should be provided on every step. The nosing should extend the full width of the step, approximately 50 mm to 60 mm depth on the tread and the riser. The nosing should contrast in tone and colour with the step finishing materials.

3.21 A handrail should be provided on each side of the steps. A central double handrail is desirable on wide staircases (over 2000 mm). The handrails should be of a rounded cross-section, diameter between 45 mm to 50 mm and at a height of 1000 mm above the nose of the steps or 900 mm above the pitch line. The handrails should be extended horizontally 300 mm beyond the top and bottom steps.

3.22 Corduroy-profile hazard warning tactile paving should be used at the top and bottom of the steps in accordance with the Department for Transport guidelines “Guidance on the Use of Tactile Paving Surfaces”. The profile of the corduroy surface comprises rounded bars running transversely across the direction of pedestrian travel.

3.23 The underside of the staircase should be enclosed or protected to prevent people walking underneath the staircase and sustaining head injuries. Open sides should be avoided; if used, balustrades, cross-rails or similar should be installed. The bars are 6mm (± 0.5mm) high, 20mm wide and spaced 50mm from the centre of one bar to the centre of the next.

3.24 Stairs should have closed risers. Open risers can become trip hazards and disorientate people.

3.25 Lighting should be provided specifically to illuminate the staircase. It is not acceptable to assume that adequate lighting will spill over from other areas.

3.26 At half landings, where the direction of travel changes, a 90-degree or 180-degree turn should be provided. Handrails should always be continuous across or around half landings. Corduroy surfacing is not required on half landings.

3.27 Wherever possible, curved or spiral staircases should be avoided.

3.28 Except where physical constraints prevent it, the maximum rise of a flight of steps between landings should be half that of the height between decks. Resting areas should be a minimum size of 1200 mm by 1200 mm, although 1800 mm by 1800 mm is preferred. The minimum width of stairs between handrails should be 1200 mm.

3.29 To assist visually impaired people, a colour or tonal change to the surface at the top and bottom of each flight of stairs is useful to complement the corduroy paving.

Stair lifts

3.30 Platform should be rated for a minimum load of 225 kg.

3.31 Deck and ramps should be on non-slip surfaces.

3.32 Lift should be equipped with a platform grab rail.

3.33 Proper procedures should be in place for the operation of the stair lift and the assistance to the passenger.

3.34 The store location of the platform should not obstruct or reduce evacuation routes.

Ramps

3.35 Longitudinal slopes and ramps should be kept as shallow as possible, and of consistent gradient. As many people cannot negotiate ramps without assistance - particularly when descending - the provision of a separate flight of steps, where possible, can be beneficial. Stepped ramps (ramps incorporating one or more steps) should not be used.

3.36 Where ramps are required to give access over a door sill (e.g. Loadline Requirement) then care must be taken not to allow this to become a tripping hazard to other passengers.

3.37 Staff assistance should also be available.

3.38 It is helpful to paint or ‘hatch’ a ramp so that it is easily recognizable as a change in floor level height.

Handrails

3.39 Handrails should be rounded off, with a diameter of 45 mm to 50 mm and no sharp bends. There should be a minimum clearance of 45 mm (preferably 50 mm) between handrails and any adjacent surface. Handrails should be easy to grip, in a bright colour which provides a clearly visible contrast (in both colour and tone) with the background against which it is seen.

Doors on vessels

3.40 Door openings to public spaces should 800 mm. Ramps and coamings should be marked in contrasting colours.

Annex 4: Information and announcements

Written information

4.1 Vessel operators could make leaflets available to disabled people covering the facilities on request. If unsure, discuss with the Royal National Institute of Blind People (RNIB), details at the end of this MGN..

4.2 Many people with poor eyesight will be able to read large print. Large print is easy and simple to produce on most standard word processors and printers. Legibility is enhanced by using black type on off white or pale yellow paper. If coloured text is to be used, it should be in a dark tone. Many organisations around the country have good quality recording and production equipment, such organisations include the RNIB and many local associations for blind and partially sighted people.

4.3 Information is required to be made available in accessible formats to passengers on request.^{[footnote 7]} Article 9(4) of Regulation (EU) 1177/2010 states that: “Carriers, travel agents and tour operators shall ensure that all relevant information, including online reservation and information, concerning the conditions of carriage, journey information and access conditions is available in appropriate and accessible formats for disabled persons and persons with reduced mobility. Persons needing assistance shall receive confirmation of such assistance by any means available, including electronic means or Short Message Service (SMS).

Signage

4.4 Any signs used on board should not conflict with the requirements of IMO Resolution A.760(18), which concerns signage symbols relating to life saving appliances and of A.654(16) which concerns graphical symbols for fire control plans.

4.5 Fixed signs should be designed in accordance with the advice in the Sign Design Guide (Published by the Sign Design Society and the Royal National Institute of Blind People (RNIB). See also MGN 556(M+F) which explains the requirements of the Merchant Shipping and Fishing Vessels (Safety Signs and Signals) Regulations 2001. Where new signage is provided it should be tactile as this is essential for people with no sight at all or with only sufficient vision to locate a sign but not distinguish individual characters.

4.6 Where overhead signs are used, care should be taken to position them so that they are not seen against a background of light fittings.

4.7 Signs should be positioned so that their faces are well illuminated, or alternatively back-illuminated signs may be used. Care is needed to avoid glare.

4.8 Portable signs should be mounted on a sturdy structure designed to assist those who are long-cane or assistance-dog users.

4.9 Audible signs could be considered, as they are of particular use to blind and partially sighted people.

General Information Signs

4.10 Any general information signs should be provided in accordance with the following design criteria:

a. Use clear fonts such as Helvetica medium san serif, Arial or Verdana.

b. Character size should be 100 mm high, at a viewing distance of 3 m or pro rata, with a minimum height of 25 mm.

c. Wherever practical, use pictograms rather than text signage. Pictograms should be in accordance with ISO standards or common practice where an appropriate standard does not exist.

d. The sign board should be in a colour which contrasts with the background against which it is seen, and the characters on the sign should contrast with the sign board.

e. Useful advice on the design of signs and signage systems can be obtained from publications of the RNIB.

Visual displays

4.11 Visual display units, when provided, should be positioned at a height which enables passengers to get close. The VDU or electronic display should have a non-reflective surface. Light coloured text against a dark background assists readability. The text should be bright and in a clear font. If it is necessary for the information to scroll, it should do so slowly with sufficient text displayed on the screen at any one time to make reasonable sense of the message. Safety Announcements

4.12 4.12 Safety announcements should be given over the public address system before leaving the berth, including details of emergency arrangements such as donning of lifejackets, and can be complemented by a simultaneous video or written notes, wherever practicable. The size of the vessel may preclude the usefulness of the public address system, in which case the crew will advise passengers directly. The announcement must identify the location of safety instruction information.

4.13 Evacuation arrangements vary considerably between ships, and crews should take part in regular exercises to train them in assisting disabled passengers.

4.14 On small passenger vessels, in the event of weather giving rise to danger for wheelchair users, the operator and the wheelchair users should ensure, where possible, transfer from their wheelchairs into secured seats and the securing of the wheelchair itself. Alternatively, appropriate wheelchair-restraining deck clamp systems should be available.

Information Systems

4.15 Information provided must also be provided in accessible formats. For example; text; Braille; audio; visual; electronic formats.^{[footnote 8]}

4.16 VDUs should be positioned at a height where a disabled passenger can get very close. Screens should be non-reflective. Character size should be at least 18 point. If the signs are dynamic, the message should change or scroll slowly. The screen covers should provide good contrast. In addition, travel emergency information and all essential information should be provided through clear audible announcements and clear visual displays.

4.17 Public areas fitted with broadcast public address systems should have Induction loops and textphone facilities. When provided these should be fitted and screened so as not to cause interference with the ship’s navigation systems.

4.18 Destination

4.19 The destination of the vessel should be clearly displayed at all points where passengers come aboard.

Websites

4.20 Websites, where used, can easily be designed so that they are accessible to those using text to speech computer systems. They also need to be adaptable to the needs of readers with visual impairments and with learning difficulties.

4.21 Advice on website design can be obtained from RNIB, the World Wide Web Consortium and the Disability Rights Commission.

Audible Information

4.22 Audible announcements to passengers, when used, should be made in a clear voice with good diction. Announcements should be well structured, with the key words at the beginning to attract attention. Use plain language and avoid jargon and technical terms. Spoken announcements should be preceded by a tone to attract attention.

4.23 There are some circumstances where specific announcements might need to be made for the benefit of disabled people. For example on some, particular smaller, vessels, disabled people may have to wait for a member of staff to operate a lift. In such cases a specific embarkation and disembarkation message for disabled people may be appropriate.

Information for people with learning disabilities

4.24 Information should be made available in forms that are easy to understand. This will be particularly helpful for people with learning disabilities, those whose first language is not English, and children. Signs and other material can be made easy for these groups to understand, or operators can produce alternative “easy read” versions.

Dual sensory loss

4.25 A small number of people have a hearing and visual impairment. They will not be able to access information by any of the means listed above other than possibly Braille. It is recommended that, where reasonable, a member of staff receive training in use of the deafblind alphabet. This is a simple system, which can be easily learned. As a member of staff is unlikely to use a deaf blind alphabet regularly, they could carry an instruction card to assist them. Further advice is given in RNIB’s “See It Right”.

Annex 5: Safety announcements and signage

5.1 Safety announcements, required to satisfy marine legislation, should also meet the needs of hearing impaired people if they are complemented by signage, video, or staff demonstrations.

5.2 The design of safety signage used throughout the vessel should consider the requirements of disabled people, particularly in respect of lettering, size and positioning including height as outlined above. The content will need to cover the needs of other persons with reduced mobility, where the arrangements may be different from those that would apply to other passengers.

Annex 6: Emergency egress from the vessel

6.1 The safety management system of the company must^{[footnote 9]} directly address the safety of any passengers with reduced mobility with regard to the usual operation of the vessels and in case of an emergency.

6.2 The operator should consider what number of passengers with reduced mobility, or the number as a proportion of the total passengers carried, that can be safely carried on board, under normal operating conditions, given consideration for emergency situations. Regard should be paid to the number of crew members required by the Maritime and Coastguard Agency safe manning, and the severity of the disability. The operator should then cap the number of passenger with reduced mobility on this basis for a given sailing. This can be addressed within the safety management system.

6.3 In an emergency on board a passenger ship most passengers are expected to be able to evacuate themselves from any passenger accommodation to the assembly and embarkation deck. The integration of persons with restricted mobility - including infirm, very young, elderly and disabled persons - with the other passengers should be achieved wherever possible, and given special consideration when designing a passenger ship and preparing contingency plans for such a ship.

6.4 In an emergency situation, reduced mobility passengers may be physically assisted into live saving appliances, having due regard to the safety of all on board.

6.5 For the purpose of safety, new passenger ships should be designed, as far as practicable, in such a way that there is barrier free passage for passengers with reduced mobility both in public spaces and along escape routes to assembly stations.

Annex 7: Management and training

7.1 It would not be considered reasonable or practicable to employ additional crew, above those required for the safe manning by The Merchant Shipping (Safe Manning, Hours of Work and Watchkeeping) Regulations 1997 as amended, on vessels which are small operations (either due to size of the vessel or the operating company, or when the number of crew is not greater than two) to satisfy the requirements of passengers with reduced mobility. Any restrictions that this leads to in the times at which assistance is available should be widely notified to known and intending passengers at the earliest opportunity, and no later than when they book.

7.2 Where providing a transport service, vessel operators are required to review their policies,^{[footnote 10]} procedures, services and facilities provided for non-disabled passengers to ensure that they are accessible to persons with reduced mobility. All passengers are likely to benefit from a more accessible ship, although disabled people are likely to benefit particularly.

7.3 Vessel operators are required to design-in^{[footnote 11]} access for persons with reduced mobility from the initial design of a ship rather than as an afterthought. Meeting the needs of passengers of reduced mobility is both a personal and a corporate responsibility. It is a requirement that local disability groups, which operate in the area of the terminal(s), are consulted on proposed designs.

7.4 At the personal level, it is not only important to be able to recognise disabled passengers and to develop the skill and confidence to assist or communicate with them, but it is also of benefit for the ship designer and master of the vessel to have an understanding of how their role affects elderly and disabled people.

7.5 At the corporate level, the vessel operator must ensure that responsibility for meeting the needs of elderly and disabled passengers is accepted at the highest level, and delegated to people with the skills and authority to make changes to the design and operation of the passenger ship or terminal.

7.6 Four key principles which should underpin a business’s approach to accessibility are:

• On an existing vessel accessibility for persons with reduced mobility must^{[footnote 12]} be considered when an operator is to undertake any alterations, refurbishment or modifications to public spaces;
• Providing accessibility for persons with reduced mobility should be a mainstream goal of the company;
• Users requirements must^{[footnote 13]} be considered when determining accessibility;
• Achieving accessibility for passengers with reduced mobility is the responsibility of the provider.

7.7 It is a corporate responsibility to ensure that training in disability issues consistent with professional responsibilities is given to all the relevant staff and that it is properly evaluated. Training is available on a wide range of disability issues, as written guidance alone is unlikely to prepare staff to cover every eventuality or the needs of every disabled person. Guidance on training for staff assisting disabled people, developed for transport operators in Scotland but of equal relevance to the rest of the UK, was published by the Mobility and Access Committee for Scotland. It is entitled “Staff Training and Awareness”: https://www.transport.gov.scot/our-approach/accessible-transport/vision-and-priorities-for-2021-2022/staff-training-and-awareness/

7.8 Training in disability issues should be an integral part of the induction and familiarisation process, in both direct service training and professional training courses if appropriate.

7.9 Disability awareness training should include:

• information on all disabilities, including hidden disabilities
• barriers faced by disabled people, covering attitude, environment and organisation
• suggestions for removing barriers faced by disabled people
• principles of access audits
• enabling staff to deal with unexpected occurrences - to ‘think on their feet’ when a problem arises
• communication and interpersonal skills for communicating with disabled persons, particularly those with a hearing impairment or with learning disabilities, and listening to needs expressed by the disabled persons
• providing physical assistance
• handling mobility aids
• assisting with special equipment or aids.

7.10 Vessel operators could commission specific disability awareness training to meet their needs, and should monitor that any training is suitable for their operation. The training should involve disabled people who understand the needs and problems of other disabled people. This has the further advantage of giving staff contact with disabled people.

7.11 Disability awareness training and disability equality training can be obtained from the following organisations: Royal National Institute for the Blind, Royal National Institute for Deaf People, RADAR, SCOPE, which offer pan-disability training. Other voluntary or commercial training organisations also offer training.

7.12 The Department for Transport have produced training material for maritime transport operators. This is entitled REAL training: introduction and all transport modes modules and is available at: https://www.gov.uk/government/publications/real-training-introduction-and-all-transport-modes-modules

Annex 8: Useful publications/addresses

8.1 Ministry for Housing, Communities and Local Government

Approved document on Part M of the Building Regulations 2003:https://www.gov.uk/government/publications/access-to-and-use-of-buildings-approved-document-m

Equality Act 2010: https://www.gov.uk/guidance/equality-act-2010-guidance

The Merchant Ship Construction: Ships of Classes III to VI (A) Regulations 1998 (SI 1998 No. 2515): https://www.legislation.gov.uk/uksi/1998/2515/contents/made

The Merchant Shipping (Passenger Ship Construction: Ships of Classes I II II(a)) Regulations 1998 (SI 1998 No.2514) https://www.legislation.gov.uk/uksi/1998/2514/contents/made

www.legislation.gov.uk

The Public Service Vehicles Accessibility Regulations 2000 http://www.legislation.hmso.gov.uk/si/si2000/20001970.htm

8.2 Department for Transport

Guidance on the Use of Tactile Paving Surfaces
https://www.gov.uk/government/publications/guidance-on-the-use-of-tactile-paving-surfaces

Inclusive Mobility 2002: https://www.gov.uk/government/publications/inclusive-mobility/inclusive-mobility

8.3 Royal National Institute of the Blind

Building Sight https://www.thenbs.com/PublicationIndex/documents/details?Pub=RNIB&DocID=201935

8.4 University of Reading

Bright, K.T., Cook, G.K., Harris, J., 1997, Colour, Contrast and Perception - Design Guidance for Internal Built Environments, Brooker Publications, ISBN 0 70491 202 3. Available from Tracey Wigmore The Research Group of Inclusive Environments School of Construction Management Whiteknights Reading Berks RG6 6AW

8.5 Society of Light and Lighting

Code for Lighting https://www.cibse.org/knowledge/knowledge-items/detail?id=a0q20000008I6xiAAC

8.6 Disability Rights UK

The Web address https://www.gov.uk/rights-disabled-person

8.7 World Wide Web Consortium (W3C)

Website accessibility guidelines http://www.w3.org/TR/WCAG10

8.8 Useful addresses

Versus Arthritis
Copeman House, St Mary’s Court
St Mary’s Gate
Chesterfield
S41 7TD

Telephone 0300 790 0400

Email: enquiries@versusarthritis.org

British Standards Institute
389 Chiswick High Road
London
W4 4AL

Telephone +44 345 086 9001

Contact form click here

Centre for Accessible Environments
Nutmeg House
60 Gainsford Street
London
SE1 2NY

Telephone 020 7822 8232

E-mail info@cae.org.uk

Chartered Institution of Highways and Transportation
119 Britannia Walk
London
N1 7JE

Telephone +44 (0)20 7336 1555

info@theNBS.com

E-mail info@ciht.org.uk

Deafblind UK
19 Rainbow Court
Paston Ridings
Peterborough
Cambridgeshire
PE4 7UP

Telephone 0800 132320

Text 07903572885

Text relay 18001 then 0800 132320

E-mail info@deafblind.org.uk

Disability Action (NI)
Portside Business Park
189 Airport Road West
Belfast
BT3 9ED

Telephone 028 9029 7880

E-mail hq@disabilityaction.org

Disability Rights Commission
DRC Helpline
FREEPOST MID02164
Stratford upon Avon
CV37 9BR

Telephone 08457 622 633

Textphone 08457 622 644

Disability Wales/Anabledd Cymru
Bryden House, Block B
Caerphilly Business Park
Van Road
Caerphilly
CF83 3ED

Telephone 029 2088 7325

E-mail info@disabilitywales.org

Disabled Drivers Association
National HQ
Ashwellthorpe
Norwich
NR16 1EX

Telephone 01508 489449

E-mail info@disabledmotoring.org

Disabled Motoring UK
Rowan House
28 Queens Road
Hethersett
Norfolk
NR9 3DB

Telephone 01508 489449

E-mail info@disabledmotoring.org

Foundation for People with Learning Disabilities
7th Floor
83 Victoria Street
London
SW1H 0HW

Telephone 020 7802 0300

E-mail fpld@fpld.org.uk

5th Floor, Merchants House
30 George Square
Glasgow
G2 1EG

Telephone 0141 572 0125

E-mail fpld@fpld.org.uk

Maritime Passenger Rights
Department for Transport
4th Floor
Great Minister House
76 Marsham Street
London
SW1P 4DR

Telephone: 0300 330 3000

Mobility and Access Committee for Scotland
Transport Scotland
Area 2D Dockside
Victoria Quay
Edinburgh
EH6 6QQ

Tel: 0131 244 0848

E-mail macs@gov.scot

Website: http://www.macs-mobility.org

Multiple Sclerosis Society
MS National Centre
372 Edgware Road
London NW2 6ND

Telephone 0808 800 8000

E-mail info@mssociety.org.uk helpline@mssociety.org.uk

ShopMobility UK
c/o Driving Mobility
2 Princes Street
Truro TR1 2ES

Telephone 07984 740271

E-mail shopmobility@drivingmobility.org.uk

Royal National Institute for the Blind (RNIB)
105 Judd Street
London WC1H 9NE

Telephone 0303 123 9999

E-mail helpline@rnib.org.uk

The Royal National Institute for Deaf People (RNID)
19-23 Featherstone Street
London EC1Y 8SL

Telephone 020 7296 8000/8001

Text message 0780 000 0360

Relay UK 18001 then 0808 808 0123

Textphone 0808 808 9000

E-mail information@rnid.org.uk

Royal Society for Mentally Handicapped Children and Adults (MENCAP)
123 Golden Lane
London EC1Y ORT

Telephone 020 7454 0454

Learning Disability Helpline 0808 808 1111

SCOPE
Here East Press Centre
14 East Bay Lane
London, E15 2GW

Telephone 0808 800 3333

E-mail help@scope.org.uk

Scottish Accessible Transport Alliance

Telephone 0141 370 0968

E-mail admin@disabilityequality.scot

Spinal Injuries Association
SIA House
2 Trueman Place
Oldbrook
Milton Keynes
MK6 2HH

Telephone 01908 604191

E-mail sia@spinal.co.uk

The Stationery Office / TSO
Publication Centre
PO Box 276
London SW8 5DT

Telephone 0333 202 5070

E-mail customer.services@tso.co.uk

UK Council on Deafness

Telephone 07903 560037

Email info@deafcouncil.org.uk

1. If vessel is subject to Article 9(4) of Regulation (EU) 1177/2010 Passenger Rights Regulation. If not, this is still strongly recommended. ↩

2. See Article 10 of Regulation (EU) 1177/2010 ↩

3. See Article 11(a) of Regulation (EU) 1177/2010 ↩

4. If Article 9(4) of Regulation (EU) 1177/2010 applies, otherwise strongly recommended. ↩

5. If Article 12(3) of Regulation (EU) 1177/2010 applies, otherwise strongly recommended. ↩

6. If Article 13(2) of Regulation (EU) 1177/2010 applies, otherwise strongly recommended. ↩

7. If Article 9(4) of Regulation (EU) 1177/2010 applies, otherwise strongly recommended. ↩

8. If Article 9(4) of Regulation (EU) 1177/2010 applies, otherwise strongly recommended. ↩

9. If Annex 3 of Regulation (EU) 1177/2010 applies, otherwise strongly recommended. ↩

10. If Article 13(2) of Regulation (EU) 1177/2010 applies, otherwise strongly recommended. ↩

11. If Article 13(2) of Regulation (EU) 1177/2010 applies, otherwise strongly recommended. ↩

12. If Article 13(2) of Regulation (EU) 1177/2010 applies, otherwise strongly recommended. ↩

13. If Article 13(2) of Regulation (EU) 1177/2010 applies, otherwise strongly recommended. ↩