The Hearing Access Program commends The Access Board for developing these Guidelines. They do not, however, go far enough for people with hearing loss.

My testimony is based on my work with over 70 organizations including the National Park Service and our family’s personal disastrous experiences on Cunard’s QE2 and QM2, Holland America and Royal Caribbean cruises. In addition, I was a member on the PVAG committee and the only member on the committee who represented people with hearing loss who had actually taken a cruise.

My daughter who is hard of hearing is now 19 years old. Our experiences on cruises have sadly, not improved over the years despite my sitting on the PVAG committee and having access to the Access Coordinators for all the ships. I have come to the conclusion, that without clear black and white regulations for people with hearing loss similar to those for people with mobility issues, the access for people with hearing loss will not change. Access Coordinators for the ships do not fully understand or choose not to understand what effective access is. The coordinators rely on what is cheapest and/or easiest to install. Other issues are just ignored. What people with hearing loss want or if the access is used appears to be irrelevant. The ships just want to be in compliance and will do the barest minimum to accomplish that goal. I have yet to sail on a ship that went even slightly beyond the barest minimum and most of the time they do not even meet the barest minimum. I am tired of being the ADA cruise police.

There were numerous instances where during the PVAG meetings, I discussed our daughter’s needs for an upcoming cruise only to arrive at the ship and find the assistive listening system broken, the access not available and no one knowing how to resolve the issue. One cruise, I worked my entire cruise and someone had to be flown in because the system in the main auditorium was broken. Imagine if I was not on the PVAG and did not have access to the people in charge? The entire situation would be unmanageable. People with hearing loss should not need a deep Rolodex or a mother who is fearless to receive the access they are legally entitled to under the ADA.

Hearing access is a civil and human right.

The following are some of the issues but I will be filing more detailed comments:

The “Exception” in section V219.2 needs to be removed. There are many instances where amplification is not used but an ALS is still needed for those with a hearing loss. In fact, it is probably needed more so since there is no amplification. The children’s camp typically does not use amplification because the assumption is that the children are young and don’t need the additional amplification. This Exception would prevent a child with hearing loss from having the benefit of an ALS.

V703.7.2.1 International Symbol of Accessibility

The use of Figure V703.7.2.1 as the International Symbol of Accessibility is inappropriate, antiquated and needs to be updated. This symbol does not represent people who are deaf, hard of hearing, visually impaired or those who have mental disabilities. It does represent people who use wheelchairs. The “International Symbol of Accessibility” is thus attitudinally discriminatory and frankly flies in the face of common sense.

V703.7.2.2 Assistive Listening Systems

The ear symbol with the slash through it is also inappropriate. While an “umbrella symbol” might work for people who use wheelchairs, it does not work for people who are hard of hearing or deaf because it doesn’t delineate the type of access available. The proposed Guidelines are intended to reflect a wide range of access available that is inconsistent with a one size fits all symbol.

For example, a person with no residual hearing who cannot use an Assisitive listening Device “ALD” will think there is appropriate access for them on the ship when they see the ear with a slash. That person will be frustrated when they discover that the movies on board only offer ALDs and not captioning. There is no ability to anticipate the access available since the umbrella symbol does not provide the clarity the passenger needs.

A universal symbol forces consumers to rely on employees to learn what is available. This is imperfect since it is impossible to ensure that the entire staff is informed and has the appropriate knowledge of what is actually available. Also, it assumes the passenger is informed of all the various types of access so that the passenger can even ask the appropriate question. We have yet to sail on a ship where the staff was fully informed on the access available.

5- V706 Assistive Listening Systems

The benefits of the induction loop are not fully highlighted including the most critical part which is the elimination of stigma and that there is less breakage or issues of battery charging. Passengers who have tele-coils prefer an induction loop since it is invisible and discreet. No one is aware that they are using an ALS. The Passenger Vessel also doesn’t need to buy, distribute or replace as many pieces of equipment.

V904 Sales and Service Counters

An induction loop needs to be required. This is standard protocol in the United Kingdom A person will not ask a question if they cannot hear the answer.

8- Chapter 11: Tenders

An ALS needs to be mandated for all tenders. In an emergency situation, audible communication is paramount. In addition, on cruise ships, tenders are utilized to transport passengers to docks when large ship access is not possible. Instructions on departure/embarkation and general information are routinely provided during this transition. This information needs to be conveyed in an audible manner via an ALS such as an induction loop.

9- Additional Areas that Need Addressing

The Guidelines have failed to provide information on the following subject areas. It is not clear that the Guidelines do not apply to these areas and that the “Effective Communication” standard still applies since some of the areas are not built-in:

Tours
Movies
Audioguides
Back-up Portable ALS
Websites, Advertisements, Daily Program and Brochures
In-Room Televisions
Shipboard Announcements

SUMMARY

While we commend the US Access Board for incorporating many of the suggestions, we feel that the new Guidelines need improvement for people with hearing loss. The current Guidelines do not achieve appropriate access for people who are hard of hearing or deaf. We respectfully request that the above recommendations and my formal submitted comments are incorporated in the proposed Passenger Vessel Access Guidelines. Being aboard a ship can be a terrific experience but it can also be extremely frustrating when there is inappropriate access. Unlike other situations e.g. a hotel, a passenger can be trapped on a vessel for an extended period of time. In addition, safety is paramount. The current proposed Guidelines do not afford passengers with hearing loss the same appropriate access as passengers with other disabilities. We assume that this was an oversight but this oversight must be corrected.

Thank you.

Janice L. Schacter
Chair, Hearing Access Program