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Designing and Operating Passenger Vessels and Passenger Shore Infrastructure:
Guidance on Meeting the Needs of Persons with Reduced Mobility

Chapter 1: General

1. Scope
   1.1. The purpose of the guidance
   1.2. Who is the guidance for
   1.3. What does the guidance cover?
   1.4. What this guidance applies to

2. Background
   2.1. People with disabilities
   2.2. Population trends in disability
   2.3. Transport and persons with reduced mobility
   2.4. Background documents
   2.5. The Disability Discrimination Act - creating inclusive and accessible services
   2.6. Corporate policies

3. Corporate responsibility
   3.1. Management
   3.2. Disability awareness training

1. Scope

1.1. The purpose of the guidance

1.1.1 This document is intended to be an easy to use guidance tool incorporating best practice which gives advice on inclusive design and accessibility in the operation of all services provided at ports and on board ships. Its aim is to help ensure that the design and operation of passenger ships, facilities at ports and ports infrastructure meets the needs of persons with reduced mobility as effectively as possible. The objective is the removal of barriers which create undue effort, separation or special treatments and to enable everyone to participate equally in mainstream activities independently with choice and dignity.

1.1.2 The term "persons with reduced mobility" is used in legislation and 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". This definition is also intended to include people with learning disabilities, people with mental health issues and people with cognitive impairments.

1.2. Who is the guidance for

1.1.3 Inclusive design creates inclusive environments, where everyone can access and benefit from the full range of opportunities available to members of society. This guide will be of interest to everyone involved in the process of providing inclusive and accessible services within the shipping industry and should be used by;

  1. Naval architects
  2. Ship designers
  3. Ship owners
  4. Ship operators
  5. Ship builders
  6. Marine surveyors
  7. Port operators
  8. Designers of port facilities
  9. Architects
  10. Port owners
  11. Port managers

"The Department (for Transport) aims to improve transport provision for disabled people - whether as pedestrians, public and special transport users, or motorists - while also improving accessibility in public places" (DfT, Access for disabled people).

"The Government is fully committed to an inclusive society in which nobody is disadvantaged. An important part of delivering this commitment is breaking down unnecessary physical barriers and exclusions imposed on disabled people by poor design of buildings or spaces." ODPM Planning and Access for Disabled People - A Good Practice Guide 2003. (The Office of the Deputy Prime Minister is now the Department for Communities and Local Government DCLG.)

1.3. What does the guidance cover?

1.1.4 The revised guidance is comprehensive guidance which brings together in to one document existing guidance on the design and operation of passenger ships and ports to respond to the needs of Persons with Reduced Mobility. Its contents updates and replaces the Disabled Persons Transport Advisory Committee guidance "The design of large passenger ships and passenger infrastructure: Guidance on meeting the needs of disabled people", Marine Guidance Note 31(M) "Recommendation of the design and operation of passenger ships to respond to elderly and disabled persons needs" and Marine Guidance Note 306(M) "Designing and operating smaller passenger vessels: Guidance on meeting the needs of persons with reduced mobility".

1.4. What this guidance applies to

1.1.5 This guidance applies to all passenger vessels operating in UK waters, regardless of registry and to all UK Passenger Shore infrastructures.

1.1.6 Passenger ship operators on international routes are recommended to follow these guidelines in order to improve the design and service provision of their vessels in respect of persons with reduced mobility. This document is intended to assist ship operators to comply with the content of the IMO Maritime Safety Committee Circular 735 "Recommendation on the Design and Operation of Passenger Ships to Respond to Elderly and Disabled Persons' Needs".

1.1.7 Sea going passenger ships engaged in domestic public transport routes are bound by Directive 2003/24/EC and these guidelines are intended to assist in meeting the safety requirements set out in Article 6b and Annex III (see Merchant Shipping Notice MSN 1789(M) Directive 2003/24/EC - Safety Requirements for Persons with Reduced Mobility on Domestic Passenger Ships) of this Directive.

1.1.8 Inland waterways vessels when carrying passengers are bound by chapter 15 of the 2006/87 Directive laying down technical requirements for inland waterways vessels and repealing Council Directive 82/714/EEC This document contains provisions for the safety of persons with reduced mobility, these guidelines complement them.

1.1.9 All other vessels carrying passengers are highly recommended tofollow this document as guidance to make their vessels ready for the use by persons with reduced mobility.

1.5 How to use this guide

1.5.1 This guide offers best practice advice to the shipping industry on how all participants in the provision of services at passenger shore facilities and services provided on board passenger ships can contribute to the delivery of high quality inclusive services that provide access to all members of society, including disabled people.

1.5.2 The document is separated into stand alone sections which can be read and referred to independently. Each chapter has been colour coded for ease of reference.

1.5.3 Chapters one and two contain general and background information stating the purpose of the guidance and setting out the legislation and regulation requirements for the provision of shipping services in meeting the needs of persons with reduced mobility.

1.5.4 Chapters three and four refer to the services provided at port side and the passenger interface between ship to shore transfer.

1.5.5 Chapter five relates to services provided by passenger vessels of all types engaged in international or domestic voyages of 500GT or more or certified to carry 250 passengers or more.

1.5.6 Chapter six relates to services provided by passenger vessels of all types engaged in international or domestic voyages of less than 500 GT or certified to carry less than 250 passengers. It is recognized that certain services and facilities are unusual on the board vessels of this size, however if these services or facilities (e.g. cabins) are provided and these are not referred to in this Chapter, the guidelines contained in Chapter 5 should be followed.

1.5.7 Chapter seven contains references and a glossary of the terms of reference used in the guidance.

1.5.8 The guide does not attempt to provide detailed and prescriptive lists of inclusive design requirements. That is the task of other reference material mentioned in the relevant sections of the guide. The document is intended to provide practical guidance in providing facilities and services for people with reduced mobility and draws mainly on the recommendations of British Standard BS8300:2001 'Design of buildings and their approaches tomeet the needs of disabled people - Code of Practice'. This British Standard takes the form of guidance and recommendations and should not be quoted as if it were a specification.

1.5.9 Where the BS8300 is silent on certain design issues the requirements in the Building Regulations 2000 'Approved Document M Access to and use of buildings' and 'Inclusive Mobility - A Guide to Best Practice on Access to Pedestrian and Transport Infrastructure' have been referred to.

1.5.10 Wherever possible, jargon and technical language have been avoided but where it is necessary to use certain terms, there is an explanation of these terms in the Glossary.

2. Background

2.1. People with disabilities

1.1.10 Disabled people and those with a long term illness account for some 10% of the population, including people with limiting longstanding illnesses; of which, 4.6 million are over state pension age and 700,000 are children[1]. While higher numbers of children are being born and living with impairments than ever before[2], levels of disability do increase with age.

1.1.11 Currently 985,000 people live with learning disabilities. 796,000 of these are adults aged 20 or over[3]. The adult figure will increase to855,000 (plus 7%) in 2011 and 891,000 (plus 11%) in 2021. It has been estimated that some 7 million adults have literacy problems.

1.1.12 Using a broad definition of disability, an Omnibus Survey by the Department of Social Services reported that the provisions of the Disability Discrimination Act 1995 covered approximately 11.7 million people, including 6.5 million people of working age. Multiple disabilities were common, as illustrated by prevalence figures indicating that a third reported sensory deficits, a third learning difficulties, half mobility problems and roughly as many impaired physical co-ordination. Long-term illnesses such as Alzheimer's disease and mental illness were included in the estimated total number of people affected by disability[4].

1.1.13 Disabled people are not an homogenous group with identical needs. The needs of people with mental health problems or learning disabilities are distinct from those of wheelchair users for example. Even among people with similar impairments needs vary, for example, profoundly deaf people will not benefit from induction loops.

1.1.14 Disabled people live throughout the community. One in four households has a disabled resident[5]. The need for access for disabled people is not limited to specific areas, but is present throughout the wider transport system.

2.2. Population trends in disability

1.1.15 The number of people over state pension age is projected to increase by 11.9% from 10.9 million in 2002 to12.2 million in 2011 and the population aged 80 and over is projected to grow from 2.5 million in 2002 tonearly 5 million by 2031[6]. The average age of the working population will increase as retirement ages advance. Over the same period that will bring about these changes in the population profile, the overall population will increase by about 9%.

1.1.16 The Department for Work and Pensions estimated in 2004 that disabled people have a spending power of around £80 billion each year[7]. Planning strategically to design transport facilities that meet the needs of disabled people is likely to further increase this amount, as more disabled people become creators of the national wealth, rather than consumers of its state benefits. Expectations to travel will be higher. There is a potential market of additional passengers for the shipping industry.

2.3. Transport and persons with reduced mobility

1.1.17 From beginning to end the public transport journey must be accessible. This means that transport vehicles and buildings need to be accessible at all stages of a journey. This includes passenger vessels and the facilities provided at the ports that serve them. Persons with Reduced Mobility need toknow 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 port terminal can prevent a person with reduced mobility using the services.

1.1.18 The current level of awareness of the needs of disabled people post dates the time that many current vessels came into service, and therefore often not 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.

1.1.19 There remains much that can be achieved now at relatively low cost or disruption. Many of these changes relate tosimple and inexpensive equipment that would aid, for example, people with sensory impairments. Operators should be aware that even if it is judged to be toodifficult to make every possible improvement for wheelchair users, access needs for other passengers with reduced mobility can often still be met.

1.1.20 It is not the intention of this Guidance to either fundamentally change the exterior designs of vessels, or to put any operator out of business. 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.

1.1.21 These accessibility guidelines are intended to allow reasonable access to all public and service areas of both the shore infrastructure and 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.

2.4. Background documents

1.1.22 In June 1996 the International Maritime Organization (IMO) issued the Maritime Safety Committee Circular 735 "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. Member states were asked 'to bring the approved Recommendation to the attention of those concerned for action as appropriate'.

1.1.23 In September 1997, the Maritime and Coastguard Agency (MCA) issued the Marine Guidance Note 31 "Recommendation on the design and operation of passenger ships to respond to elderly and disabled persons' needs" in response to the IMO which contained recommendations on the design and operation of a new passenger ship. The integration of elderly and disabled persons with the other passengers, requires special consideration when designing a new passenger ship, with emphasis on passenger ferries which are part of the public transport system.

1.1.24 The Disabled Persons Transport Advisory Committee (DPTAC), through its Ferries Working Group, contributed tothe preparation of the IMO guidelines and fully supported them, but considered that they provide only basic advice. In 2000 DPTAC published guidance to support and assist all concerned in the interpretation and implementation of the guidelines to address the needs of the wide range of elderly and disabled people using large passenger vessels, particularly ferries. The advice was published as "The design of large passenger ships and passenger infrastructure: Guidance on meeting the needs of disabled people".

1.1.25 The Maritime and Coastguard Agency, in December 2005, issued the Marine Guidance Note 306 "Designing and Operating Smaller Passenger Vessels: Guidance on Meeting the Needs of Persons with Reduced Mobility" the aim of this document was to ensure that the design and operation of smaller passenger ships met the needs of people with reduced mobility as effectively as possible. It applied to smaller sea going passenger vessels of less than 500 GT operating on public transport domestic voyages in UK waters, regardless of registry, when certified to carry fewer than 250 passengers. Other passenger vessels (for example those not engaged on public transport services or those on inland waterways operations) within the same size range were recommended to follow this document as guidance to make their vessels ready for the use of passengers with reduced mobility.

1.1.26 The Disability Rights Task force recommended that Government should review the effectiveness of the IMoand DPTAC guidance and consider the need for legislative provision, if it was reported that the voluntary approach to improving access toshipping industry for disabled people was considered to be not working.

1.1.27 In 2005 DPTAC commissioned the Transport Research Laboratory Ltd (TRL) tocarry out research intothe usefulness and effectiveness of guidance and assess how the shipping and port industry were meeting the needs of disabled people in the design of large passenger ships and passenger infrastructure at ports.

1.1.28 This revised guidance document has been designed following recommendations from the research project[8] that the DPTAC guidance should be updated and revised to take account of changes to planning policy, new regulations and design specifications.

2.5. The Disability Discrimination Act - creating inclusive and accessible services

1.1.29 Ports and their infrastructure are already covered under part 3 of the Disability Discrimination Act (DDA). The DDA was passed in 1995 to end the discrimination that many disabled people face. It protects disabled people in;

  1. Employment
  2. Access togoods, facilities and services
  3. The management, buying or renting of land or property
  4. Education
1.1.30 Passengers may not be aware that their first point of contact for a ferry service may be with that service operator. It may be that the operator is also the port operator but, more often than not, the port operator will be someone else. It must be for the ferry operator toliaise with the port operator to use its best endeavour to ensure that disabled access recommended in this guidance is provided.

The box below sets out the stages at which the provisions within the Disability Discrimination Act have been introduced.

The Disability Discrimination Act (DDA) 1995 and DDA 2005

For service providers (e.g. businesses and organisations):

Since December 1996 it has been unlawful to treat disabled people less favourably than other people for a reason related to their disability.

It is unlawful to discriminate against disabled people by:

  • Refusing to provide a service without justification;
  • Providing a service to a lesser standard without justification;
  • Providing a service on worse terms without justification;
  • Failing to make reasonable adjustments to the way services are provided for disabled people;
  • Failing to make reasonable adjustments to the physical features of service premises, to overcome physical barriers to access.

Since October 1999 service providers have been required to make reasonable adjustments for disabled people, such as providing extra help or making changes to the way they provide their services.

1.1.31 Passenger vessels are not at the time of publication of this document included under Part 3 of the Disability Discrimination Act 1995 (DDA) which gives disabled people a 'right of access' to goods, facilities, services and premises. However, ports and ports infrastructure are covered by Part 3 of the Act.

1.1.32 The Disability Discrimination Act 2005 included powers for the Government tolift the transport exemption in respect of any form of transport service including shipping. The Government has stated that it will consider the need to lift the current exemption if research shows that the industry has not taken sufficient account of the voluntary code and guidance to improve the accessibility of its transport services.

1.1.33 In the meantime, it is recommended that shipping operators take account of the duties that the Disability Rights Commission have outlined for the provision and use of vehicles in their statutory Code of Practice and the Part 3 Code of good practice as a matter of good practice in all their operations. There are also separate nonstatutory codes available for reference on many aspects of good practice (see www.equalityhumanrights.com).

1.1.34 It should be noted that providers of shipping services are not wholly exempt from DDA Part 3. They still have a duty to avoid discrimination against disabled people and to make reasonable adjustments for them in respect of matters such as information in accessible formats such as timetables, booking facilities and waiting rooms at ferry terminals.

A wheelchair user has no protection under Part 3 of the Act if a ferry on which he wishes to travel is not accessible.
However, if he is refused service in the buffet bar of the ferry terminal because of his disability, this is likely to be unlawful.

(DRC Code of practice for transport vehicles 2006)

2.6. Corporate policies

1.1.35 Corporate policy should be that the vessel owner/operator ensures 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 tothe design and operation of the passenger ship or terminal.

1.1.36 In providing a transport service, vessel operators should review their practices, policies, 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.

1.1.37 Any restrictions in the hours at which assistance is available should be widely notified to known and potential passengers at the earliest opportunity, and at the latest when they book.

1.1.38 It will be more cost-effective if access for persons with reduced mobility is included from the initial design or operation of a ship rather than as an afterthought. Meeting the needs of passengers with reduced mobility is both a personal and a corporate responsibility. It can be very valuable to consult the local disability groups, which operate in the area of the terminal(s), used.

1.1.39 At the personal level, it is not only important to be able to identify people with reduced mobility including people with invisible impairments with 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 roles affects elderly and disabled people.

1.1.40 DPTAC have developed a commitment to an inclusive design statement in the form of a 'Practice Statement' that can be used by architects and other professions. It sets out a company or organisation's commitment to incorporating the principles of inclusive design into all its projects and practices. It is recommended that this is used by those associated with the shipping industry and adapted accordingly. The full document can be viewed at: www.dptac.gov.uk/inclusive/commitment/index.htm. The practice statement is outlined below.

Practice Statement

Internal Actions - We shall:

1. Establish and implement an internal quality assurance system to ensure compliance with the principles of inclusive design.

2. Designate a practice member with responsibility for the practices commitment to inclusive design.

3. Ensure that all relevant staff undertake appropriate training and personal and professional development including regular Continued Professional Development so that they have a thorough understanding of the processes needed to implement the principles of inclusive design and that they keep their knowledge and skills up to date.

4. Be proactive in involving disabled people as employees, as professional access consultants and as building users.

5. Regularly review our policies, practices and procedures to ensure that the principles of inclusive design continue to inform all our work.

6. Maintain an up to date library of legislation, regulations, standards, codes of practice and good practice guidance on all aspects of inclusive design.

External Actions - We shall:

1. For all projects recommend that the developer or client has an access consultant or access champion.

2. Ensure that the project team works closely with the access consultant and/or inclusive design/access champion at all stages of the project.

3. Ensure inclusive design principles are incorporated at every stage of a project, from initial concept to development brief or master plan through to detailed design, construction, completion and on handover.

4. Encourage disabled people to be involved at every stage of the project by working with organisations of disabled people, local access groups and/or forums of disabled people set up to engage on a particular project.

5. Specify inclusive products that are useable by everyone.

6. Architects must provide sufficient information through the specification process for the handover book which, in turn, will inform the facilities manager regarding the maintenance manual and any necessary training.

3. Corporate responsibility

3.1. Management

3.1.41 Four key principles which should underpin an organisation's approach to accessibility are:

  1. On an existing vessel accessibility for persons with reduced mobility should be considered when an operator is to undertake any alterations, refurbishment or modifications to public spaces;
  2. Providing accessibility for persons with reduced mobility should be a mainstream goal of the organisation;
  3. User requirements should be considered when determining Accessibility; and
  4. Achieving accessibility for passengers with reduced mobility is the responsibility of the provider.
1.1.42 It is a corporate responsibility to ensure that training in disability issues consistent with professional responsibilities, is given to all the relevant staff and is properly evaluated.

1.1.43 The Disability Discrimination Act 1995 has been amended by the Disability Discrimination Act 2005 to place a duty (the Disability Equality Duty) on all public sector authorities to promote disability equality. In providing a transport service, public port operators will therefore need to review their policies, procedures, services and facilities provided to ensure that they are accessible to persons with reduced mobility. All passengers are likely to benefit from a more accessible service, although disabled people are likely to benefit particularly.

1.1.44 The Disability Equality Duty came intoforce on the 4th of December 2006. This new legal duty means that any public body will need to proactively look at ways of ensuring that disabled people are treated equally.

1.1.45 The basic requirement for public authorities when carrying out its functions is to have due regard to do the following:

  1. promote equality of opportunity between disabled people and other people;
  2. eliminate discrimination that is unlawful under the Disability Discrimination Act;
  3. eliminate harassment of disabled people that is related to their disability;
  4. promote positive attitudes towards disabled people;
  5. encourage participation by disabled people in public life; and
  6. take steps to meet disabled people's needs, even if this requires more favourable treatment.
1.1.46 Information about the public sector duties is in "The Duty to Promote Disability, Equality, Statutory Code of Practice" which can be downloaded from the Disability Rights Commission website[9].

3.2. Disability awareness training

1.1.47 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.

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

1.1.49 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 people, particularly people with a hearing impairment or people with learning disabilities; providing physical assistance; handling mobility aids; and assisting with special equipment or aids.
1.1.50 Vessel and shore infrastructure operators should commission specific disability awareness training to meet their needs, and monitor that any training provided 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.

1.1.51 Comprehensive 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 "recommended minimum training standard for staff assisting disabled people". Details of this guidance can be found in Chapter 7.

1.1.52 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, Royal Association for Disability And Rehabilitation and SCOPE, which offer pandisability training. Other voluntary or commercial training organisations also offer training.

1: Department for Work and Pensions press notice 9 February 2006 - "Updated estimate of the numbers of disabled people including people with limiting longstanding illnesses, and their associated spending power".
2: Improving the Life Chances of Disabled People 2005 at www.cabinetoffice.gov.uk/strategy/.
3: Foundation for People with Learning Disabilities 2006, www.learningdisabilities.org.uk.
4: K Williams, T Savill and A Wheeler "Review of the road safety of disabled children and adults" 2002, available at www.trl.co.uk.
5: James Ruppert, Independent June 15, 2004.
6: (DRC Report for Party Conferences 2004).
7: www.dwp.gov.uk/mediacentre/pressreleases/2004/dec/spending.asp.
8: "Review of DPTAC guidance on the design of large passenger ships and passenger infrastructure tomeet the needs of disabled people", (TRL, Middlesex University, JMU Access Partnership 2005).
9: www.equalityhumanrights.com/en/forbusinessesandorganisation/publicauthorities/disabilityequalityd/Pages/Disabilitye.aspx.

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Published: 11 September 2007 | Copyright disclaimer | Content disclaimer | © Crown copyright 2008