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120 Pax Small Cruise Ship Case Study (Private Entity)

June 25, 2013

Introduction

The small cruise ship was built in the late 1980s and carries about 120 passengers in 60

passenger guest rooms. The vessel has an overall length of about 302 feet and breadth of 

about 50 feet, and has six decks. Decks two through six are passenger decks. With a draft of 

about 14 feet, the vessel travels to ports and areas of the world not navigable to larger 

vessels. Decks two through six are entry decks.

Figure 1. Outboard Profile - Original Design

 Deck 1 – The first deck is open only to crew members.

 Deck 2 – The second deck (main deck) is approximately 302 feet long and 50 feet wide.

Eleven staterooms are provided in the forward half of the deck, and a galley and 

restaurant is provided in the after half. Near the middle of the stateroom area, a stair 

tower connects decks one through six. Adjacent to the stair tower is the vessel’s hospital. 

Near the bow, an enclosed stair connects an open bow area on the third deck. Between 

the galley and stateroom area, an elevator lobby contains two multi-user toilet rooms (one 

male and one female), and a stair connects deck two through six. The one elevator also 

connects decks two through six. From the restaurant, two aft exterior exit doors with 24 

inch high coamings lead to an exterior stair which connects the third deck, and the doors 

also lead to the tender loading platform. The tender loading platform is about 24 to 30 

inches below the level of second deck and is connected by a short stair to the main level 

of the deck. As the exit doors are for emergency use, the stair to the third deck is used by

passengers when tenders are being loaded and unloaded.

Figure 2. Second Deck – Original Design
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 Deck 3 – The third deck is approximately 302 feet long and 50 feet wide. In the forward 

half of the deck, 19 state rooms are provided. Toward the bow, an enclosed stair 

connects the second deck and an open stair connects the fourth deck. These stairs are 

only used by passengers in emergencies. A third stair connects the enclosed crew area on 

the second deck at the bow. Near the middle of the stateroom area, a stair tower connects 

decks one through six. Aft of the stateroom area, an elevator lobby with two multi-user 

toilet rooms (one male and one female) and stair separate the staterooms from the lecture 

lounge near the stern. From the elevator lobby, through two exterior doors with 11 inch 

high coamings, two open walkways (one of each outboard side of the lounge) connect the 

lobby with the stern area which contains storage space for five inflatable 10-passenger 

tenders. Also, from each walkway, an adjustable stair/gangway can deploy to connect a 

portable tender boarding platform located at the level of the second deck. At the after 

end of the lounge, two emergency doors (one on each side of the lounge) connect the 

open walkways. At the forward end of the lounge, a curving stair connects the club/bar

on the fourth deck. Near the stern area of the third deck, two open stairs (one on each 

side of the deck) connect the fourth deck, and a third open stair connects the second deck.

Figure 3. Third Deck – Original Design

 Deck 4 – The fourth deck is approximately 234 feet long and 50 feet wide. In the 

forward half of the deck, 15 state rooms are provided. An exterior walkway (jogging 

track) encircles the deck. At the bow, an open stair (used by passengers in emergencies) 

connects the third deck and near the middle of the stateroom area a stair tower connects 

decks one through six. An exterior door connects the stair tower to the exterior walkway. 

Aft of the stateroom area, an elevator lobby contains a stair that connects decks two 

through six, two single leaf doors (one on each side of the vessel) connect the open 

walkway and two double leaf doors in series connect the club area located toward the 

stern. In the aft area of the club, a library is provided, and two doors (one on each side) 

connect the open walkway. A bar is provided in the club and a curving stair connects the 

lecture lounge on the third deck. At the stern, two open stairs (one on each side) connect 

the third deck and another open stair connects the Jacuzzi at the stern area of the fifth 

deck.
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Figure 4. Fourth Deck – Original Design

 Deck 5 – The fifth deck is approximately 218 feet long and 46 feet wide. At the bow, the 

pilot house is located, followed by officer cabins. Near the middle of the deck, eight 

staterooms with balconies are provided. Between the officer cabins and staterooms, a 

stair tower connects decks one through six. Aft of the stateroom area, a small elevator 

lobby contains two multi-user toilet rooms (one male and one female), a stair which 

connects decks two through six, and one door connects a short exterior walkway on the 

starboard side of the vessel. From the lobby, an aft door accesses a passageway running 

past a small gym (on the port side) to the stern area. The stern area contains a buffet and 

an open deck area, about half covered by an awning. At the aft end of this area, a Jacuzzi 

and open stair to the fourth deck is provided.

Figure 5. Fifth Deck – Original Design

 Deck 6 – The sixth deck is approximately 165 feet long and 45 feet wide. At the bow 

end, a large stateroom “owner’s suite” with a forward facing balcony is provided. After 

entering the owner’s suite, two steps connect the level of the suite. Aft of this stateroom, 

on the port side, a (narrow) stair tower connects decks one through six. Aft of this stair, 

six staterooms with balconies are provided. Aft of this stateroom area, a small elevator 

lobby is provided which contains a stair that connects decks two through six. Adjacent to 
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the elevator lobby, the hair dresser’s space is located. All other spaces on this deck are 

not open to passengers and principally contain air conditioning equipment.

Figure 6. Sixth Deck – Original Design

Methodology

In providing estimates on the costs of implementing (in new construction situations) the 

provisions of the passenger vessel accessibility guidelines, vessels selected for case studies 

needed to be of recent construction. Since newer vessels incorporate more access features as 

part of industry practices, such vessels provide a clearer picture of the impacts the guidelines 

would have on current new construction practices. Because the number of existing newer 

small cruise ships is low and the willingness of vessel ownership to participate in this study is 

even lower, it was found necessary to use a small cruise ship built in the late 1980s. 

Although the vessel is a foreign flagged vessel, the case study evaluated the impacts also 

based on the vessel being a US flagged vessel subject to international requirements.

This study was first made available on the Board’s website in 2008 and was originally based 

on the requirements in the 2008 draft guidelines. The Access Board has updated the study to 

represent the requirements in the proposed passenger vessel accessibility guidelines. The 

costs recorded in the 2008 draft of the study (that applied to provisions in the proposed 

guidelines) were multiplied by 1.08591to produce 2011 values. In some places, cost ranges 

provided in the 2008 study are now based on average costs and have been rounded. The 

updates have not been reviewed by the vessel representative.

Since the vessel was designed and constructed before the Americans with Disabilities Act 

(ADA) went into effect, there was concern that if the original designs of this vessel were 

used in the case study, the guidelines would produce greater impact than if the cruise ship 

had been constructed in the 2000s. However, maybe because the vessel was constructed for 

a clientele which expected more luxury and space, many of the provided features are at least 

consistent with current practices. Nevertheless, in three places (number of mobility guest 

 

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1.085857424 and results have been rounded.
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rooms, number with balconies, and public toilet rooms), the cruise representative believes the 

features did not represent current practices and the applicable impacts were adjusted to 

reflect outcomes modified by current practices.

To determine the impact, the analysis went through three steps: 

Step 1 - A representative of the Access Board reviewed the original general arrangement 

drawings of the vessel with a representative2of the cruise company to identify passenger 

features that would not meet the draft passenger vessel accessibility guidelines3. 

Step 2 - The cruise representative proposed new designs complying with the guidelines. 

However, the designs only showed how the impacted features were changed and the effect on 

surrounding spaces, but the surrounding spaces themselves were not in most cases further 

adjusted (for example, the enlarged elevator overlaps the adjacent stair, but the stair was not 

repositioned). In most situations, the adjustment of bulkheads (walls) to provide necessary

clearances for access were determined to not increase the cost of a new vessel, but did create 

noteworthy space (and operational) impacts summarized below and resolved in Step 3. The 

issue numbers below correspond to the issues (and actions) discussed in more detail in the 

section titled “Impacts and Other Outcomes”. The Board has provided update notes to reflect 

changes based on the proposed guidelines.

Space/Operational Impacts Summary

 1. Guest Rooms - Provided three guest rooms equipped with mobility features, and 

provided balconies at 11 more guest rooms on the fourth deck.

o Outcome: Reduced the interior size by about 25 square feet (SQFT) (about 10 

percent reduction) for each of the three adjacent non-accessible guest rooms, 

and removed a portion of external walkway (jogging track) which encircles the 

fourth deck to provide the 11 balconies.

o Update Note: The proposed guidelines would only require three guest rooms to 

be equipped with mobility features. V224.2 Exception. A reduction in impacts 

on the new designs could not be determined due to this change. However, it is 

assumed for the updated study that the space savings regarding the number of 

mobility accessible guest rooms balances off the increased space needs required 

in the ship’s hospital (see issue 2 below). Therefore, no modification was made 

to the updated cost estimates. 

 2. Hospital - Increased the footprint due to larger bath room and clearances at a bed.

 

2 Although the report notes decisions made by the cruise representative, it should be noted that the Access 

Board hired a consultant (acceptable to the cruise representative) to provide most impact information (including 

cost estimates) which was used by the cruise representative in the case study decision making process. 

3 The draft guidelines, as amended by Board action at the 2007 and April 2008 meetings. The first public 

version was based on the requirements in the 2008 draft passenger vessel accessibility guidelines (dated June 

26, 2008), and reflected 2008 costs. The Access Board has updated this study to reflect the proposed guidelines 

and 2011 costs.
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o Outcome: Occupied about 110 SQFT of two adjacent officer cabins which have a 

total area of about 270 SQFT.

o Update Correction: The proposed guidelines (and 2008 draft guidelines) have no 

specific scoping for beds in medical care facilities, so the “general access” 

requirement applies which means all bed in accessible spaces of medical care 

facilities must be accessible. V201.1. As only one patient room is provided, it 

therefore must be accessible in the new designs, and all beds in it must also be 

accessible. It is not known how much additional space would be needed for the 

hospital to provide more clear deck spaces at a second bed on both sides, but it is 

assume in the updated case study that any increase in space needs would balance 

off the space savings mentioned above (issue #1) due to the reduction in the 

number of mobility accessible guest rooms. 

 3. Accessible means of escape (AMOE) - Space impacts occurred generally in 

providing a second AMOE from spaces required to be accessible.

o Outcome: Discussed in issues #4 and #5 below.

 4. Doors (High Thresholds) - Ramped 24 inch high threshold (coaming) at 

restaurant rear exit door to provide second AMOE out of the restaurant. Also ramped 

11 inch high threshold at lecture lounge rear/side exit door to provide an onboard 

accessible route to the exterior areas of the third deck and a second AMOE.

o Outcome: In the 1700 SQFT restaurant, a switchback ramp structure reduced 

the space by about 160 SQFT (9.4 percent reduction) and caused the loss of 

three tables with a total of 12 seats. In the 110 seat, 1800 SQFT, lecture lounge, 

a ramp structure reduced the lounge by about 90 SQFT (a 5 percent reduction) 

and caused the loss of eight seats, and created minor external appearance issues 

due to the raising of the exterior walkway and associated guardrails.

o Update Note: The proposed guidelines allow protected waiting areas to 

substitute for a ramping structure bridging a door coaming. Advisory V207.1. 

As the vessel owner could not be contacted to determine the feasibility of using 

the alternative to the ramping structure, no changes have been made regarding 

impacts identified at this door in the new designs.

 5. Doors (Maneuvering Clearances) - Provided maneuvering clearances at public 

doors which were part of an onboard accessible route or (principally at stair tower 

doors) part of an AMOE. Three groups of doors in series were further separated.

o Outcome: In general, increased the size of the center stair tower which 

impacted the layout of the hospital and other adjacent spaces and the size of the 

second deck bow stair enclosure which impacted entries to adjacent officer 

cabins. The changes for doors in series impacted adjacent spaces and some 

entries to adjacent cabins/guest rooms.

 6. Elevator Enlargement - Increased the footprint of the elevator.

o Outcome: Reduced adjacent space, principally the adjacent stair and lobby area 

by about 10 SQFT on each passenger deck (50 SQFT total) to provide a larger 

elevator.

 7. Tender Boarding Platform Access – Providing a platform lift connection from 

the third deck.

o Outcome: The platform lift structure coming down from the third deck and the 

platform lift occupying a portion of the tender boarding platform interferes with 
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mooring and tender operations. In addition, the lift location on the third deck 

occupied space used to store inflatable tenders. 

Step 3 - From a review of the space impacts, the cruise representative provided an estimate 

on how much the size of the original vessel must be increased to restore the space

characteristics to that of the original vessel. Also, the cruise representatives provided 

estimates on applicable cost increases and comments on other outcomes. 

Enlarged Vessel (Step 3 Results) - The cruise representative estimated that the 

original cruise ship would cost approximately $60 million to $70 million to construct 

in 2008, updated by the Access Board to $70.58 million in 2011. For a vessel 

enlarged to restore space characteristics, the cruise representative estimated that the 

new enlarged vessel would have to be 310 feet long, an eight foot increase. This 

increase in size would add $2,117,400 to the vessel’s (updated) construction cost. In

addition, the enlarged elevator ($2,700), assistive listening system ($4,400), two ramp 

structures ($41,200), visible alarms ($48,900), and platform lift from the third deck to 

the tender boarding platform ($27,100) increased costs. Therefore, the case study

estimated the cost of the vessel would increase by $2.4 million, or an increase of 

approximately 3.2 percent.

Below, the case study provides more details on the impacts and other outcomes. 
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Impacts and Other Outcomes

1. Guest Rooms (State Rooms/Cabins) 

The cruise ship has 60 passenger guest rooms. No rooms were designated as “ADA” guest 

rooms. The 2008 draft guidelines required that four passenger guest rooms be equipped with 

mobility features (mobility guest rooms) and at least one be equipped with a roll-in shower. 

V224.2. The guidelines require the mobility guest rooms4to be dispersed among the types 

(e.g., rooms with balconies) of guest rooms provided. V224.5. 

Update Note: The proposed guidelines would only require three guest rooms to be equipped 

with mobility features. V224.2 Exception. A reduction in impacts on the new designs could 

not be determined due to this change. However, it is assumed for the updated study that the 

space savings regarding the number of mobility accessible guest rooms balances off the 

increased space needs required in the ship’s hospital (see issue 2 below). Therefore, no 

modification was made to the updated cost estimates. The remainder of the issue write up 

reflects the outcomes from the 2008 draft study which are the same outcomes due to the 

proposed guidelines.

As the cruise representative believes that at least

one ADA mobility guest room would have been 

provided based on current industry practices (if 

the vessel was constructed in the early 2000s), the 

impact evaluation is based on the need to provide 

three additional ADA guest rooms, one with a 

roll-in shower. 

Another industry practice was raised concerning

the number of guest rooms with balconies. 

Currently 15 guest rooms (on the fifth and sixth 

decks) have balconies, but industry practice would 

have much more. The case study calculated its 

impacts assuming 11 of the 15 guest rooms on the 

fourth deck have balconies and the critical exterior 

jogging track which encircles the deck would be 

provided elsewhere in the enlarged version of the 

vessel (Step 3), probably on a seventh deck. This 

increased the number of balconies by 11 which 

 

4 The proposed guidelines V224.4 would also require cruise ships with 51 to 75 guest rooms to have seven guest 

rooms equipped with communications features (communications guest rooms). Per V224.5, one 

communications guest room is required to be located in one mobility guest room. The other six 

communications guest rooms are not permitted to be placed in the “required” mobility guest rooms. Although 

these six guest rooms are not required to be equipped with any mobility features, such as clearances at doors, 

water closets, lavatories and beds, the rooms would still have to meet the protruding object requirements in 

V204. The case study assumes that to provide seven communications guest rooms, the impact would have an 

insignificant increase on the cost of a new enlarged vessel (Step 3).
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provides a total of 26 guest rooms with balconies. Balconies were not provided on the port 

side aft of the center stair tower because this portion of the jogging track is part of a means of 

(emergency) escape to the stern of the vessel.

The cruise representative proposed in Step 2 to provide one mobility guest room with a 

balcony on decks four through six (for a total of three guest rooms). The fourth mobility

guest room required by the proposed guidelines is assumed in this case study to already exist 

on deck two or three. 

Deck four is proposed to have the guest room with a roll-in shower, and decks five and six

will have transfer showers (36 inches by 36 inches). In making the three bath rooms comply

with the proposed guidelines, the size of the bath rooms increased from around 32 square feet 

to around 52 square feet for the transfer shower bath rooms (62 percent increase) and around 

57 square feet for the roll-in shower bath room (78 percent increase). 

Combined with needs for maneuvering clearances at the mobility guest room entry doors 

(which moved the room closet forward) and keeping the amenities and space needs the same 

as other similar guest rooms, the increase in bath room size necessitated over a 10 percent 

increase in the interior area of the guest rooms. 

Figure 8. New Bath Room Layouts – Transfer Shower and Roll-in Shower5

These actions are estimated in Step 2, for each of the three mobility guest rooms, to reduce 

the size of one adjacent guest room by an average of about 25 square feet6. The use of 

drainage systems at the three balcony doors is discussed below, in the door threshold section

(issue #4 below).

 

5 The plumbing chase was widened to support the shorter grab bar (see V608.3.2 Exception).

6 The case study did not evaluate if furniture layouts were impacted in the mobility guest rooms and corrections 

may require additional square footage from adjacent guest rooms and are assumed resolved in Step 3.
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2. Hospital

The cruise ship has a small hospital with one patient sleeping room containing one bunk bed 

and one single bed. A bath room with a tub serves the patient sleeping room. The hospital 

also has an examination room with a portable examination table and a small waiting room. 

The hospital area wraps around a stair tower which connects decks one through six. Officer

cabins are located forward of the hospital and passenger state rooms are located aft and on 

the starboard side. The vessel is required to have three beds should passengers need isolation 

due to infectious diseases. The proposed guidelines require that one bed have a clear deck 

space on both sides (36 inches wide) and a turning space be provided in the room. V223, 

V805.2, and V805.3. In addition, the bath room (and tub) must be accessible. V805.4. 

Update Correction: The proposed guidelines (and 2008 draft guidelines) have no specific 

scoping for beds in medical care facilities, so the “general access” requirement applies which 

means all beds in accessible spaces of medical care facilities must be accessible. V201.1. As 

only one patient room is provided, it therefore must be accessible in the new designs, and all 

beds in it must also be accessible. It is not known how much additional space would be 

needed for the hospital to provide more clear deck spaces at a second bed on both sides, but it 

is assume in the updated case study that any increase in space needs would balance off the 

space savings mentioned above (issue #1) due to the reduction in the number of mobility

accessible guest rooms. Except for the bed discussion, the remainder of the issue write up 

reflects the outcomes from the 2008 draft study which are the same outcomes due to the 

proposed guidelines.

The double-leaf doors which connect the outside passageway to the waiting room, to the 

exam room, to the sleeping room, have a clear opening of about 48 inches wide. The active 

leaf of each door has a clear opening of about 30 inches and the inactive leaf a clear opening 

of about 18 inches. The door to the bath room has a clear opening of about 27 inches. The 

proposed guidelines require all four doors to be accessible and have a clear opening of at 

least 32 inches at the active leafs (plus have maneuvering clearances on both sides). V206.5, 

V404.2.2, V404.2.3, and V404.2.4.

The cruise representative proposed in the new designs to have the hospital comply with the 

guidelines. This action is estimated in Step 2 to cause the loss of about 40 square feet from 

one officer cabin (26 percent reduction) as shown below in the figure. The majority of the 

increase in the size of the hospital was due to the sleeping room needing clear deck spaces

(36 inches by 48 inches) on both sides of the beds and the enlargement of the bath room. 
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Figure 9. Hospital Impact – Original Designs and New Designs (stair unchanged)

However, because the adjacent stair 

needed to be adjusted to provide a 

maneuvering clearance on the pull side of 

the entry door, the stair tower had to be 

lengthened by about 20 inches. This 

action no longer allowed the bath room to 

be placed on the port side of the stair (as 

shown above) which required the cruise 

representative to propose a new hospital 

layout (see figure 10). This new layout, in 

Step 2, caused the loss of about 110 square 

feet from two adjacent office cabins which 

have a total area of about 270 square feet Figure 10. Hospital Impact

(40 percent reduction). As the side of the New Design and New Stair Layout

vessel curves, the bath room could not be (bed impact incorrect7)

positioned adjacent to the port side bulkhead 

(wall).

3. Accessible Means of Escape 

The cruise ship is subject to means of escape requirements from the International Convention 

of Safety of Life at Sea (SOLAS) and, for purposes of this case study, US Coast Guard 

(USCG) regulations. In general, these requirements mandate at least two means of escape 

(MOE) paths from each passenger deck to the primary area of refuge (mustering station) in 

the third deck lecture lounge and to the secondary area of refuge at the open stern area on the 

fourth deck. From these two locations, two MOE paths are required to the primary life boat 

embarkation area at the side exterior walkways located near the stern of the fourth deck and 

 

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Figure 10 is from the 2008 draft study and does not correctly show the clear deck space requirement for both 

beds. It only shows it for the non-bunk bed.
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to the secondary embarkation area at the side exterior walkways near the stern of the fifth

deck. Stairs are the components in the MOE paths which connect the decks.

The proposed guidelines require that two accessible means of escape (AMOE) also connect 

the areas of refuge and life boat embarkation areas. V207.1. The proposed guidelines allow 

stairs to be components in an AMOE path. Advisory V207.1. This means the two MOE stair

towers are part of the AMOE from each passenger deck, since the vessel representative did 

not want to use the one elevator in place of one stair tower. Because this vessel is protected 

by an automatic sprinkler system complying with SOLAS, protected waiting areas are not 

expected at the stairs. Advisory V207.1. Although the proposed guidelines do not require 

changes to be made to the stairs, the doorways to the exit stair towers that are part of an 

AMOE are expected to be accessible. Advisory V207.1. The AMOE impacts principally

relate to door thresholds and maneuvering clearance issues and are discussed below in more 

detail.

4. Doors - High Thresholds 

The cruise ship operates in international waters and, for purposes of this case study, is also 

subject to USCG requirements. Therefore under the International Convention of Load Lines 

and USCG requirements, certain exterior doors must have coamings (e.g., high thresholds). 

The proposed guidelines require doors which are part of an onboard accessible route or part 

of an AMOE to have conforming (beveled) thresholds 1⁄2 inch high maximum. V206.5 and 

V404.2.5. However, where doors are required to have coamings, the guidelines allows 

higher thresholds for the coamings if ramps are provided. V404.2.5 Exception and 

V404.2.5.2

Door Coamings - Coamings are only required on decks two and three. To meet the 

requirements of the proposed guidelines, the cruise representative proposed the following 

actions. 
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 Deck 2 - Two aft emergency exit doors from the restaurant to the stern area have 24 

inch high coamings (thresholds). The cruise representative proposed to add a 41 foot 

long (including three landings) switchback ramp to the starboard side exit door to 

provide a second AMOE from the restaurant to the base of the exterior stair 

connecting the third deck8, the path of the AMOE. A 24 inch high platform which is 

at the height of the coaming would also be included at the base of the stair. In Step 2, 

this action is estimated to require the removal of three tables and a total of 12 seats in 

the restaurant. The ramp structure occupies about 160 square feet of the 1700 square 

foot restaurant (a 9.4 percent reduction). Access to the tender boarding platform is 

discussed below (issue #7). The ramp structure to the exit door is estimated to 

increase the cost to construct the enlarged new vessel to the new designs (Step 3) by 

$14,100.

Figure 11. 2nd Deck - Restaurant Ramp to External Stair

Update Note: The proposed guidelines allow a protected waiting area to be substituted for 

the ramping structure bridging a door coaming. Advisory V207.1. As the vessel owner 

could not be contacted to determine the feasibility of using the alternative to the ramping 

structure, no changes have been made regarding impacts identified at this door in the new 

designs.

 

8 A platform lift could not be used as part of an AMOE from the rear of the restaurant because the AMOE runs 

first up to the third deck and does not run directly to the tender boarding platform. Therefore, V206.7.6 cannot 

be used.
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 Deck 3 - On each side, toward the after end of the lounge, an emergency exit door 

connects the side walkways which lead to two exterior stairs (one on each side of the 

vessel) connecting the fourth deck. The cruise representative proposes to add an 11 

foot long ramp and two five foot long landings to the port side exit door for the 

required second AMOE out of the lounge. In Step 2, this action would reduce the 

size of the 110 seat (1800 square foot) lounge by 90 square feet (a 5 percent 

reduction) and reduce seating by eight seats to a total of 102 seats. Also, this action 

would require the port side external walkway to be raised by about 11 inches to 

provide a platform (with a grating) outside the door with ramps at each end. The 

guardrail would also be raised along this part of the walkway and would create a 

minor appearance issue. Forward of the lounge, the elevator lobby has two exterior 

doors with 11 inch coamings. These doors are not required to be ramped, since the 

ramped lounge exit door provides access to the external areas on that deck9. This 

action is estimated to increase the cost of the enlarged new vessel by $27,100. A 

majority of this cost increase was due to work on the external walkway.

Figure 12. 3rd Deck - Lecture Lounge

 Vertical Clearance On Ramps - As the distance between the surface of the second 

deck and third deck, and the surface of the third deck and fourth deck, is over 105 

inches, both decks have sufficient vertical clearance available to ensure the ramp 

surfaces have at least 80 inches of head clearance. In providing this head clearance, 

Step 2 would require some overhead space removed to provide the necessary head 

clearance at the top of the ramps. Step 3 results do factor in the rerouting of ducting 

or other features in the overhead to other locations. 

 

9 The cruise representative proposed to not limit the ramped exit door to only emergency use but would use it as 

part of the onboard accessible route connecting the interior areas of the third deck to the exterior areas. 

Therefore, an onboard accessible route complying with V206.3 connects the lobby to the exterior areas of the 

deck and the lobby exterior doors are not required to be accessible. 
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Drainage - Coamings are not required on decks four through six, but the cruise representative 

was concerned about water from rain, sea spray and storm waves entering the exterior doors 

(including balcony doors) with low thresholds due to ship movements and creating 

maintenance and safety problems inside the vessel. To address this concern, the cruise 

representative proposed in the new designs to add drainage systems to the outside of the 

exterior doors which are required to be accessible on these decks and also to have thresholds 

which do not exceed a height of 1⁄2 inch beveled. These actions are estimated to have an 

insignificant impact on the cost of an enlarged new vessel (Step 3) and do not create head 

clearance issues on the decks below the drainage systems.

5. Doors – Clear Widths and Maneuvering Clearances 

The passageways are at least 36 inches wide and have overheads which are 82 inches high

with doors having 78.5 inch vertical clearances. Public doors along the passageways have at 

least 32 inch clear openings. However, many doors which would be part of an accessible 

route to public spaces or are part of an AMOE do not have sufficient maneuvering 

clearances, and some passageway doors are in series with other doors (which may only be 

fire doors held open by magnets) and may

not have sufficient space between the inseries doors. 

The proposed guidelines require that each 

door used as part of a required onboard 

accessible route or an AMOE be 

conforming. V206.5, Advisory V207.1, and 

V402.1(b). Complying manual doors must 

have maneuvering clearances and comply 

with the doors in series provision. V404.2.4 

and V404.2.6. 

The cruise representative proposed in the 

new designs to provide the necessary

maneuvering clearances at the public doors

which created minor space impacts on 

adjacent spaces in Step 2. However, the 

doors in the center stair tower (see Figure 

10) created the greatest difficulty as 

maneuvering clearances were not provided 

on the side of the doors inside the tower. To 

provide these clearances, the tower needed 

to be widened by a few inches on the fourth, 

fifth and sixth decks, and increased in depth 

by about 20 inches on the second and third 

decks. In Step 2, the case study recognizes 

that additional refinement in the stair tower 

layout may be necessary to ensure 
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clearances are provided and are factored into the Step 3 results. Providing maneuvering 

clearances at the stair enclosure at the forward end of the second deck also significantly 

impacted surrounding spaces in Step 2, as the stair enclosure had to be enlarged which 

blocked entry to adjacent crew cabins.

At the forward end of the elevator lobby, on the second through fourth decks and sixth deck, 

doors in series were proposed to be further separated in Step 2. At these locations, light 

weight lobby doors (with no latches which swing in both directions) separate the lobbies

from the forward passageways. Pass these doors, toward the bow, magnetically held open 

fire doors (more than 36 inches wide) are provided. Separating the doors to provide 48 

inches between the lobby doors and the swing of the fire doors had significant impacts on the 

adjacent spaces in Step 2, as the new location of the fire doors blocked the entry to spaces on 

one side of the passageways. Maneuvering clearances however, created minor space impacts 

in adjacent guest rooms and crew cabins. On the sixth deck, also, the series doors to the hair 

dressers room were replaced with one door.

6. Elevator 

A small elevator is provided which serves all five passenger decks (decks two through six)

with a travel distance of about 36 feet. The elevator car size is estimated to be 53 inches in 

depth and 45 inches wide. 

In this new construction situation, two options were evaluated. Either use two limiteduse/limited-application elevators (LULA10) or one standard elevator to connect decks two 

through six. Although the guidelines recommend that elevators comply with ASME A17.1, 

the case study assumes the US Coast Guard would require ASME use in US Flag vessels. 

Therefore, a LULA is restricted by ASME to a vertical travel distance of 25 feet, thereby

requiring that two LULAs be provided to connect the 36 feet travel distance between the five 

decks. ASME does not restrict a standard elevator to a 25 feet maximum travel distance. 

The guidelines allow standard elevators to use a number of different dimensional sizes that 

include a minimum size of 60 inches by 60 inches, and 80 inch depth by 54 inch width. 

V206.6 and V407.4.1. The LULA is allowed to be smaller (e.g., 54 inches by 42 inches). 

V206.6 Exception 2 and V408.4.1. 

The cruise representative proposed in the new designs to use a standard elevator which is 60 

inches by 60 inches to connect decks two through six. This action in Step 2 would cause the 

footprint of the elevator to increase by 10 square feet and overlap the adjacent stair and lobby

area by less than a foot. In Step 3, the stair would have to be moved outside the footprint of 

the new elevator. The larger elevator is estimated to increase the cost of the enlarged new 

vessel by $2,700.

7. Tender Boarding Platform

 

10 As the vessel is assumed to be less than 10,000 ITC gross tons, use of a limited-use/limited-application 

elevator (LULA) is allowed. V206.6 Exception 2. The The US Coast Guard informally communicated to the 

Board that they would interpret ASME A17.1 as not prohibiting shipboard elevators from being LULAs.
17

At the stern of the second deck a tender boarding platform is provided. The platform is about 

24 to 30 inches below the main level of the second deck. A small stair of five or more steps 

connects these two levels. As discussed above, on the second deck level, two exterior doors

with 24 inch high required coamings connect the stern area with the restaurant. As the doors 

are for emergency use, passengers embarking or disembarking the tenders use the exterior 

stair which connects the second deck stern area with the third deck. 

The proposed guidelines require that an onboard accessible route connect the boarding

platform (which functions as an entry point). V206.4. The guidelines allow a platform lift to 

be used to connect the boarding platform. V206.7.6. As a platform lift would be exposed to 

waves, the guidelines also allows use of a manually powered boarding lift to connect the 

boarding platform. V206.7.6 Exception. The cruise representative evaluated three options in 

providing access to the tender boarding platform. All options will experience maintenance 

difficulties due to potential storm wave actions in following seas at the exposed stern location

and create complications and obstructions for crew in operating the tender boarding platform 

and operating mooring equipment and running mooring lines.

Option 1 (54 Inch High Platform Lift) – A 

hydraulically operated platform lift (36 

inches by 60 inches), approached from the 

side, would connect an onboard accessible 

route by an elevated walkway to the 

restaurant’s 24 inch high coaming door at 

the base of the stair to the third deck. This 

option is estimated to increase the cost of the 

enlarged new vessel (Step 3) by $13,000 to 

$23,90011. As the 24 inch high raised 

walkway cuts across the mooring equipment 

area and needs guardrails, it creates an 

obstruction to crew member use of the 

mooring equipment and some operations 

related to the tender boarding platform. 

Also, a second small stair would be needed 

for passengers (who would not be using the 

platform lift) to provide a path from the 

raised walkway down to Figure 14. Tender Boarding Platform

the other small stair. Onboard Accessible Route

In an enlarged vessel design (Step 3), a grated deck surface at the height of the 24 inch 

coamings could be provided with raised mooring equipment. This would remove the need 

for the raised walkway and the 24 inch coamings would still protect the doors to the 

restaurant, but the drop-off to the tender platform would increase and therefore increase the 

size of the small stair.

 

11 The platform lift uses the hydraulic power unit used by the mooring equipment which reduces the potential 

cost of the platform lift which is estimated to be $5,000 to $15,000, and the elevated walk from the restaurant 

exit door is estimated to be around $7,000.
18

Option 2 (144 Inch High Platform Lift) – A hydraulically operated platform lift would be 

provided running from the third deck down to the tender boarding platform. As the lift 

platform and most of the operating mechanisms can be stored on the third deck, the platform 

lift has less exposure to waves, but the lift and the onboard accessible route occupies spaces 

on the third deck used for inflatable tender storage. However, the raised walkway (elevated 

accessible route) from the restaurant’s 24 inch high coaming door to the platform lift is not 

required and the elevated maneuvering clearance on the outside of the coaming door is less 

of an obstruction for crew members working in the stern area of the second deck. In this 

option, although there is no platform lift shaft, the structure to support the lift’s decent from 

the third deck could interfere with mooring operations and some tender operations. This 

option is estimated to increase the cost of the enlarged new vessel (Step 3) by $27,100 with 

hydraulic power coming from the mooring equipment hydraulic power source.

Option 3 (54 Inch High Manually Powered Boarding Lift) – A manually powered boarding 

lift would be used instead of the hydraulically operated platform lift used in option 1. This 

option is estimated to increase the cost of the enlarged new vessel (Step 3) by $10,900 to 

$16,300 but (due to the raised walkway) create the same crew problems as noted in option 1. 

Added to this expense is the cost of the raised walkway which is estimated to be $7,600, for a 

total increase of $23,900 for this option.

In evaluating the options, the cruise representative selected option 2, as the raised walkway

created a greater obstruction to crew members.

8. Public Toilet Rooms 

The second, third and fifth decks each have two multi-user toilet rooms (one male and one 

female) in the elevator lobby. The cruise representative believes that current industry

practices would have produced clusters of two single-user (uni-sex) toilet rooms on these 

three decks with at least one on each deck being accessible. The proposed guidelines only 

require one toilet room in a cluster of two single user (uni-sex) public toilet rooms to be 

conforming. V213.2 Exception 4. Therefore, as sufficient space is available to convert the 

multi-user toilet rooms into two single-user (uni-sex) toilet rooms (with space to spare), one 

of which complies with the guidelines, this outcome is determined to have no impact on the 

enlarged vessel designs (Step 3).

9. Assistive Listening System 

The cruise ship has a lounge in which amplified lectures are held. The lounge has a seating 

capacity of 110 seats. Because the lecture lounge is an assembly area where amplified 

communication is provided that is integral to the use of the space, the proposed guidelines 

require the lounge to be served by a permanently installed assistive listening system (ALS). 

V219.2.1. For a seating capacity of 110 seats, the guidelines require five receivers, two of 

which must be hearing aid compatible. V219.3. It is estimated a permanently installed ALS 
19

and the necessary number of receivers would increase the cost12 of the enlarged new vessel 

by $4,400 (Step 3). Since passengers are assigned designed muster stations to go to in an 

emergency, a ship-wide ALS is not required. V219.2.2 Exception.

10. General Alarm

When getting underway, the crew instructs the passengers on what actions to automatically

take when the general (audible) alarm sounds and passengers are given a practice alarm drill. 

Therefore, an audible emergency alarm is provided for passenger use and passengers know 

the meaning of the alarm and take immediate actions without crew direction. The proposed

guidelines require in US flagged passenger vessels (which is applied to this ship) that visible 

notification appliances must be provided in public areas and guest rooms equipped with 

communication devices . V215.1 and V224.4 . The cruise representative proposed to 

provide in the new enlarged designs (Step 3), visible alarms (strobes) complying with NFPA 

72 (2007) in the public passenger spaces and in the seven guest rooms required to be 

equipped with communications features. The vessel will take approximately 110 alarm 

points to cover the applicable spaces. The total cost of the visible alarm system will be 

approximately $43,400 to 54,300 (average of $48,900). There might be some cost savings if 

the visible alarms were integrated into the SOLAS audible general alarm system13, but that 

would be hard to quantify. The visible alarm strobes themselves draw about 250 watts. 

Adding in the alarm control system and monitoring, the total will be on the order of 500 to 

1,000 watts. This power need is not estimated to impact the size of the emergency generator. 

Providing visible alarms is estimated to be not significantly more expensive than just the 

audible alarms, nor is the power requirement significantly larger.

11. Storage Facilities 

No storage facilities are provided for passengers outside their guest rooms. Life jacket 

storage lockers are intended to be used only by crew members, in handing out life jackets to 

passengers, and are therefore not subject to the guidelines. V203.2.

 

12 The assistive listening system (ALS) cost has been updated from the 2008 draft study. The ALS’s new 

estimated cost is $4,400; it requires 5 quality receivers with headsets/neckloops ($1,400), one FM transmitter 

with related support material ($1,400), and engineering, installation, and other expenses ($1,600). 

13 US Coast Guard has indicated informally that in their reading of SOLAS, SOLAS would not prohibit a 

visible alarm system from being attached to the SOLAS required general alarm. In addition, the consultant 

hired to provide impact costs contacted the American Bureau of Shipping and they confirmed that in their 

opinion SOLAS would not prohibit a visible alarm system from being attached to the SOLAS required general 

alarm.
20

12. Spa (Jacuzzi) 

The stern area of the fifth deck contains one 

raised spa (Jacuzzi). The proposed guidelines 

require either a means of entry which is a 

swimming pool lift, transfer walls, or transfer 

system. V234.4. The cruise representative

proposed in the new designs to provide a transfer Figure 15. Transfer Wall

wall (see figure 15) which is connected to an 

onboard accessible route. This action is estimated to 

have an insignificant impact on the enlarged new vessel costs (Step 3).

13. Electrical Power, Fuel Consumption, and Vessel Stability Impacts

The vessel has four 1,000 KW generators. Two run off the vessel’s propeller shaft and two 

run off motors. One 240 KW emergency generator is provided. The larger elevator14, 

platform lift, and assistive listening system have an insignificant impact on the normal power 

supply of the vessel.

For emergency power, the larger elevator has a very similar power draw to the original 

elevator, within a few horsepower, and is estimated to have an insignificant impact on the 

emergency power supply. If the platform lift to the tender boarding platform was required to 

be part of an accessible means of escape, it would be expected to have emergency power. 

Advisory V207.1. Therefore, a separate hydraulic power unit (HPU) on emergency power 

would be needed (instead of using the larger mooring equipment HPU). This smaller HPU 

would likely not drive the emergency power over its current limit. In addition, the 500 to 

1,000 watts needed for the visible alarm system (issue #10) is estimated to not have a 

significant impact on the capacity of the emergency generator.

14. Passenger Boarding System

Passenger boarding systems were not addressed in the case study.

 

14

 The consultant noted that the elevator is required to have emergency power for half an hour to bring 

passengers to a deck. In practice, the elevator will be on emergency power.
21

Summary

The cruise representative estimated that the original cruise ship would cost approximately

$60 million to $70 million to construct in 2008, updated by the Access Board to $70.58 

million in 2011. For a vessel enlarged to restore space characteristics (Step 3), the cruise 

representative estimated that the new enlarged vessel would have to be 310 feet long, an 

eight foot increase. This increase in size would add $2,117,400 to the vessel’s (updated) 

construction cost. Plus, the following table summarizes other costs which would add 

$124,300 to the above amount. Therefore, the case study estimated the cost of the vessel 

would increase by $2.2 million, or an increase of approximately 3.2 percent.

120 Passenger Small Cruise Ship 2008 Estimates 2011 Estimates 

(rounded/average)

Construction Cost (original vessel) $60M - $70M $70.58M

8 Foot Lengthening (due to space impacts) 1.8M - 2.1M 2,117,400

Elevator Enlargement 2,500 2,700

(revised) Assistive Listening System revised 4,400

Restaurant Ramp Structure 13,000 14,100

Lecture Lounge Ramp and Raised Exterior 

Walkway

25,000 27,100

Platform Lift From Third Deck to Tender 

Boarding Platform

25,000 27,100

Visible Alarms 40,000 - 50,000 48,900

Total (% increase) $1.91M - $2.23M

(2.7% - 3.7%)

$2,241,700 

(3.2%)
22

Attachment – Other Case Study Notes

(from the 2008 draft which were retained)

1) The cruise representative believed that the cost increases due to the 2008 draft guidelines to 

provide a 310 foot vessel (Step 3) are not unreasonable.

2) The cruise representative does not see as unreasonable that four mobility guest rooms are 

required for a 60 guest room cruise ship (as required in the 2008 draft guidelines). With the 

aging of the US population, market forces are creating a greater demand for mobility guest 

rooms.

3) The cruise representative sees no problem in selling the four mobility guest rooms as many

passengers seek larger accommodations even if they are not disabled.