Mobility and Access Committee for Scotland (MACS) - response to questionnaire on the subject matter of the marine guidance note (MGN)on the small seagoing passenger ship (SSPS) code - 2021

Read the consultation letter MGN 535M

Inaccuracies

1. Do you believe that the MGN is accurate?

­­­­­­­­­­­­­­­­­­­No. The title of the MGN should be changed to reflect all disabled passengers.. Many disabilities are hidden but have a profound impact on a person’s ability to travel and the barriers they face on that journey. These barriers often require individuals to need support and assistance to undertake and complete their journeys.

This would then comply with the Equalities Act 2010 and the Equality and Human Rights Commission where disability is a protected characteristic.

2. Para 1.3. Reference could be made to the guidance on Accessibility at ferry terminals as it is vital that the transition for a disabled person is compatible. 

3. Para 1.6. We would suggest that some of the recommendations in this document are necessary for the safety of passengers, and would therefore suggest the wording includes safety, or health and safety.

4. Para 2.5 This statement should be replaced by a stronger worded statement, emphasising that ‘Disability awareness training for staff must be provided’. This can be undertaken effectively and economically using on-line or video material or by involving Disabled People Organisation or Disabled People (see NorthLink example with Disability Awareness Training, training co-delivered by NorthLink and Access Panel Orkney).

Annex document.

5. Para 1.3. Add alternative formats of information and means of contacting the service provider should be available.

6. Para 1.7d. Terminal and On Board-Please add audio and visual announcements.

On Board

Please add ‘Location of quiet areas (for people with autism and dementia)

Many vessels are lifeline services so passengers returning from medical treatments need to make the journey. Some vessels provide a first aid room or dedicated seating for these passengers.

There is a need to inform passengers where they can ‘park’ a mobility scooter, and where they can charge either a scooter or electric wheel chair.

Access by Passenger gangway

7. Para 2.2.Please add ‘a hand rail should be provided.

Also the gangway needs to have markings and tactile surface to indicate where it starts and finishes so that a blind or partially sighted person can find these points.

8. Para 2.3. If it is not possible to use the gangway, passengers may be escorted on via the car deck, but this must be done in a dignified way with full accompaniment to the passenger areas of the vessel.

Toilets

9. Consideration should be given to including a Changing Place at some point on the journey. https://pamis.org.uk/news/category/changing-places-toilets/

Depending on the length of the journey it may be sufficient for the facility to be at the terminal, but on longer journeys this facility should be designed into the ferry. For example: Northlink Ferries have retrofitted Changing Places, which have been partly funded by Transport Scotland Ferry Accessibility Fund.

Seating

10. Please add: there should be sufficient space for both a wheelchair user and an assistance dog to sit together, likewise suitable seating for an ambient person with an assistance dog should be available. There should also be space for a wheelchair user and carer/companion to sit together. These should be signposted and marked appropriately.

Cabins

11. Para 2.52. The exception to this is a cabin used by a person with an assistance dog.

Assistance dogs

12. Water and water bowls should be provided for the dogs. In the relief area poo bags and a bin to place them in should be provided as well as hand sanitiser.

Lifts

13. Where possible the lift should be large enough for a wheelchair user and their carer to travel at the same time. Lifts should be large enough to accommodate mobility scooters. Roll in, roll out lifts work particularly well for disabled people using mobility equipment.

Doors on vessels

14. Para 3.40 Doors should be easily opened, with little force needed to open them.

Information and announcements

15. Consideration should be given to having an Easy Read version of information. 

16. Para 4.9. Add, however, an area where no audible announcements are made or music is played should be available so that people with autism and dementia can sit in a quiet area.

Emergency egress from the ship

17.  Add an evacuation chair should be available if egress is via stairs.

Management and Training

18. Para 7.6 Please consider adding; Consultation with Disabled People’s Organisations (DPO), Access Panels and people with lived experience will be beneficial and a critical success factor to inform the design of a vessel, the management and training.

Typographical errors

2. Do you believe the MGN is free of typographical errors?

Yes

Non-statutory advice

3. Do you agree with any non-statutory advice or statements given in the MGN?

Yes