The British Columbia Coastal Transportation Society is a non-profit organization and we are a group of volunteers who want to see safe and affordable transportation for all passengers and employees.
SSB # 06/2007 (Information on Persons on Board, Counting, Recording and Special Needs)
BC Coastal Transportation Society
We appreciate the spirit and intent of Ships' Safety Bulletin 06/2007 and the subsequent regulations that have been drafted in response to TSB recommendations regarding adequate accounting of passengers on Canadian vessels. However we are concerned they may not have gone far enough in providing guidance for ship owners and operators, given the complexity of the issue. We raise the following concerns for discussion, with the understanding that we believe this is not a local or isolated issue regarding one specific ship-owner but rather a national issue speaking to a significant number of special needs passengers. This demographic is increasing as the population ages and an important group travelling on passenger ferries in Canada.
SSB #06/2007 and the subsequent regulations contained in Fire and Boat Drill Regulations do not specify requirements for implementation of systems that would ensure that all passengers who may need assistance are identified, nor are there means specified for notifying the Master or crew of the presence of all passengers requiring assistance that are on-board any given sailing. The regulations rely solely upon self-identification. Is the method of self-identification an adequate system given the broad spectrum of physical and mental challenges some passengers live with?
Furthermore operators may over-rely on websites for self-identification, a concept that relies on all passengers being aware of the policy and having access to the internet. We suggest identification of passengers who may need assistance be included in a more substantial way in the Passenger Safety Management training certification, as well as through recognized systems for passenger accounting that may be available to ship owners.
We are also asking how this important regulation is enforced and audited, including the means to communicate the policy to Masters and crew responsible for these passengers once they are aboard the vessel.
We support the recommendation put forward by the International Transport Workers' Federation that a certificate be issued to a vessel stating the number of special needs passengers that can be carried as well as the number of seafarers specially trained to deal with these passengers.
2010 EU regulations suggest training of ships' crew should include disability awareness training of appropriate responses to different disabilities, being able to communicate appropriately, boarding and de-boarding assistance that safeguards their safety and dignity, escorting techniques of visually and hearing impaired persons, being able to transfer a person in and out of a wheelchair and awareness of feelings of vulnerability because of dependence for assistance. We understand that at least one ship owner on the east coast has taken this more extensive approach; however they are still reliant upon the self-identification process.
We would also suggest that a national policy be developed making the Canadian Transportation Act applicable to all domestic passenger vessels in Canada in order to have all passenger vessels on par and create consistent standards for all special needs passengers regardless of what part of the country they live in or whether the ferries they ride on are vessels regulated federally or provincially.
We are also concerned the regulations do not specifically address what the evacuation equipment and arrangements for this group of passengers and the Domestic Fleet should be and we request a comment on when or whether they will.
We believe the design of new vessels should include not only accessible areas in accommodations but should address improved access to evacuation equipment for passengers requiring special care or assistance. Vessels in the domestic fleet have used a wide variety of systems, including slides, chutes and scramble nets for the evacuation of passengers and we suggest that a standardized system be explored for these passengers to assist ships' crews to evacuate them.
Finally at least one large passenger ferry operator permits free access to vehicle decks during the voyage on most of its routes which may complicate the crews' ability to respond effectively to an emergency and, more specifically, to assist special needs passengers. This also makes assessing the numbers of special needs passengers who have not self-identified problematic and may hamper what could already be a difficult emergency scenario. The practice of using a 2% buffer for counting passengers could also skew the data regarding accounting for all passengers including special needs.
We are also concerned about the policy of enlisting the assistance of untrained and unqualified albeit able bodied or 'responsible' passengers to supplement the crew during emergencies on some vessels in the domestic fleet, something that is reflected in some evacuation plans.
and the BCCTS respectfully request copies of risk assessments that may have been undertaken with regards to these issues, in particular the practice of permitting passengers on car decks during voyages and the ongoing use of a self-identification process for special needs passengers.
We also ask for verification of how the inspection and enforcement regimes work for these particular areas of concern.
As there is quite a lot of information on our website. We have included links to our Authority to Enforce series that relates to this subject.
Additional reference material;
Regulation (EU) No 1177/2010 of the European Parliament and of the Council of 24 November 2010 concerning the rights of passengers when travelling by sea and inland waterway and amending Regulation (EC) No 2006/2004 Text with EEA relevance
UN Article 9 - Accessibility
Regards
President BCCTS
2014-01-20
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My comments throughout are going to be the same. "Begin with increased funding" is the answer to almost every question they have posed.
The clients I support via Community Living are limited in their access to the community and services not only because of physical barriers but because we lack the funding to maintain appropriate staffing levels to ensure that clients are able to get out into their community on a regular basis. We cannot attract nor retain qualified staff to work in community living. They will be paid better by working in complex care or as an EA. This leaves us in a constant struggle for staff and leaves clients lacking continuity of care and long term staff who know them.
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2014-01-21
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I agree!!! As a health care worker I witness time and time again huge holes opening up in our so-called 'world-class' health care system. It is disgusting and i am embarassed to mention I work for the health authority i do. I see more and more health managers (on a pay scale I could only imagine) questioning the validity of pro-active programs (run on a shoe-string) and staff they do not understand while ignoring descent research supporting these community programs. 'Do more with less' is the name of the game-this is not sustainable and is becoming harmfull. Clark and her government are directly to blame-their treatment of health care workers and teaching professionals is disgusting. I fear for the state of this country they will leave my kids. I think venues like this are useful but am dubious as to if comments here will create any serious consideration...I doubt it.....
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2014-01-21
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Through my own research I have found that needing an increase in PWD payments is not exactly new to this Government.
What has been needed for a decade is to increase rates for basic income assistance and Persons with Disability (PWD), but it seems as though people can talk until they're blue in the face and this government doesn't get it, or care, that its most vulnerable citizens and their children are living in deep, dark poverty.
In 2011 the BC office of the Canadian Centre for Policy Alternatives calculated that poverty costs British Columbia $8.1 billion to $9.2 billion every year. The estimated cost of a poverty reduction plan would be $3 billion to $4 billion a year – or less than half of what we lose to poverty (Campaign 2000).
Advocacy B.C.
Obviously it's cheaper to eliminate poverty than it is to keep things as they are now.
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2014-01-22
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I have recently learned that my son has to choose whether he is a manual chair user or a power chair user when he goes into adult services. I think this could be compared to asking a person without a disability to choose if they would like to drive a car to get around or ride a bike, (you can only choose one)!! Why is this? My son needs both equally. A manual chair works much better for him indoors and a power chair is essential for getting places safe and in a timely manner outdoors. My son did not choose to be a person with a disability, he was born this way. He has grown up in a system where there are lots of options for children with disabilities to access extra funding through charities. Now as an adult it seems so depressing. I listen to the news and our government is sending millions of dollars to aide other countries. My son is living right here in BC in need of aide!!!!
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2014-01-22
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I am both a person with a disability and an advocate and service provider to persons with disabilities. While I will certainly be posting other comments and solutions on all the categories, there is one point that I forgot to bring up at today's in person consultation session. The BC Bus Pass Program is great, but now with Translink moving to their Compass Card system, those of us on the BC Transit system have to pay for transit down there, even with our BC Bus Pass, as the kind the Ministry issues outside of the GVRD will not be recognized by Translink's new technology. The problem is for people like myself and many others, who regularly travel to Vancouver for medical services now have to come up with money for transit down there. I was down there in November to see both a cornea specialist and a cataract surgeon. One specialist was in Vancouver and the other in North Vancouver. This is two different fare zones. If I had to pay cash, it would be a $4.00 fare each time, good for only 90 minutes (albeit in both directions, which is better than on BC Transit). I can buy a day pass for $9.75, but if you're down there for a few days, that gets expensive. Since I have PWD, I imagine the Ministry will give me extra money for transit, if they're also paying for the trip. How about people with disabilities who don't receive assistance from PWD, including seniors with disabilities. I would encourage the Ministry of Social Development and Innovation to work together with the Ministry of Transportation, Translink and BC Transit to come up with a solution that works for everyone. I should also mention that this works both ways: now people in the Lower Mainland travelling outside of the Lower Mainland will also have to pay for transit when riding a BC Transit bus. Either way, it's a major concern of mine.
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2014-01-22
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These bus passes should work all over bc, as they did before
The government needs to changes this RIGHT AWAY as this is simply administrative red tape, if you live in bc and are disabled legally this should be challenged on the bus, and drivers should yield and understand their circumstances, The COMPASS Program shouldn't limit the disabled choice for public tavel
WHY CHANGE THIS NOW? WHEN THIS HAS BEEN IN PLACE FOREVER
COMPLETELY STUPID
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2014-01-22
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LISTEN UP EVERYONE
THE GOVERNMENT WILL NOT RAISE THE RATES
THEY COULD, HOWEVER, AT LEAST INDEX THEM FOR INFLATION UNTIL THE ECONOMY IMPROVES
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2014-01-22
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ONCE THE ECONOMY IMPROVES, THEY SHOULD GO TO 1200 and up
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2014-01-22
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STOP SPENDING ON CAPITAL PROJECTS, SPEND ON INVESTING IN PEOPLE
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2014-01-22
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I THINK THE DISABLED SHOULD DRAFT THEIR OWN CONSTITUTION, AND COUNTRY FOR THAT MATTER
THEIR SHOULD BE NO CONSULTATION UNTIL RATES ARE RAISED
PERIOD.....
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2014-01-22
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LETS ALL GO TO VICTORIA FOR A PROTEST
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2014-01-22
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Seriously, People I am scared of the government
When they hold your purse strings it is frightening
Too Bad a non-profit organization couldn't administer the PWD Program
The whole system needs to be revised
We need to be looked at as HUMANS not a financial burden
Disability and Poverty should not go hand in hand
We have too many struggles to be lumped together with welfare
WE DON'T NEED EXTRA STRESS
ELIMINATE US FROM WELFARE, PUT US IN TOUCH WITH CARING PEOPLE
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2014-01-22
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I suffer from mental illness, and do not have hope that I will find a job now that y contractor does not serve me.
Jobs are hard to come by for the non disabled
The government wants you to work your way out of poverty
good luck to you all
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2014-01-22
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I have no more rants
So Sorry for the comments
I am frusturated
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2014-01-22
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Canada is a country that has strong social support programs
That takes care of people
I would like to see a federal disabilty program that combines federal and provincial monies and is determined by cost of living by city etc
People are also free to move their assistance to other provinces
I think the government can make great progress and makes things more efficient for all disabled by having a federal non cpp program
It can administered better by the federal govt with more money and resources
and less discrepancy
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2014-01-22
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I am an individual who is deaf and use a cochlear implant. I use my CI on a daily basis for work and communication. It is suggested that the users of the Cochlear implant are to upgrade their speech processors every 6 to 7 years as technology is always evolving and of course, the speech processers get worn out by daily use just like hearing aids. The first processor that I received over 8 years ago was provided along with my surgery at no cost and covered by health insurance. However, when I decided to upgrade almost 2 years ago, I was told that I had to pay the upgrade out of my pocket at the tune of $5,000 ! I was like NO way so contacted Pacific Blue Cross, they only were willing to cover it up to $700 ( it took them over 3 months for a response because they only would cover hearing aids not a cochlear implant speech processor. ) and then the tax write-off was an another $700.
The upgrade of the speech processor will be an on-going issue for all users of cochlear implants and costly. I consider this as a necessity as same as people with disabilities having to upgrade their wheelchairs and other aids. Yet their wheelchairs are replaced at no cost to them and costs way more than just a speech processor. Whats wrong with the picture here ?
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2014-01-23
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Having worked in employment programs for people with disabilities for approximately 7 years, I have had the opportunity to work with clients on a variety of issues and have experienced both successes and challenges.
With regards to financial supports, while I do wish the monthly amount was higher, I have witnessed how the PWD support can be of assistance to help clients become a bit more stable compared to when they were only receiving regular income assistance benefits. Whenever appropriate, I have encouraged clients to apply for PWD and the results have been mixed. At times, clients are provided useful help from income assistance workers and are guided through the application process, while other experiences are a lot more negative.
I don't believe the process of applying for PWD is particularly difficult and understand that applicants need to properly qualify for the benefit, but given the severity of some disabilities as well as the lack of having a regular doctor to confirm it, the process of applying for PWD can require more abilities than some clients have. In short, I wish that the application process could be more easily facilitated so that the clients who need it have an easier time accessing it.
My second comment pertains to regular income assistance benefits, particularly related to clients who are on the support, but are making efforts to become gainfully employed. One challenge I continue to experience with clients in this category is the concern they have that if they lose their new employment (e.g., fired, quit, laid off, etc) before they earn enough to go on EI, they will have had their income assistance cut off and will face severe consequences (e.g., not being able to pay their housing, food, child care needs, etc). This policy continues to impede some clients from making progress with employment as they fear that getting a job can have dire consequences if they are not able to maintain it. Considering that many clients who are on regular income assistance have had difficulty with employment in the past, it is realistic to say that this is a legitimate concern.
The advantage of PWD is there is a 'safety cushion' which allows recipients to start receiving their income supports rather quickly if for some reason they lose their employment. I would suggest that a similar type of safety net be established for clients with disabilities who are not eligible for PWD and who are trying to gain employment. When I have worked in certain ministry sponsored employment programs, I have often called income assistance offices on behalf of my clients to confirm to the worker their efforts in attempting to gain employment. Often, once the worker understands the client is connected to an employment program and is aware of the efforts the client is making, there seems to be some wiggle room with regards to the supports that can be delegated.
If possible, I would see the value of changing the policy regarding the termination of income assistance benefits for clients who have a disability. If benefits are to be terminated once a client becomes employed, it would be useful to have their file remain open for 3 - 6 months so that should they lose their employment, they can more easily reactivate their income assistance benefits to more rapidly receive their funds. While not a radical change, I believe this shift will reduce some anxiety with clients about starting a new job as they will feel a bit more secure if things go wrong with their employment.
My last comment is that not all Income Assistance Workers are created equal. I have no doubt that the job is incredibly challenging and have respect for the work they do. However, I have had clients who face significant barriers to employment (and life) due to their disability or multiple disabilities. While I wish there was more funding, I do appreciate the types of supports our province has for income assistance, housing, and employment. However, trying to navigate through the system, connect with the proper departments, associations, registries, etc., can be a difficult and confusing process. Clients with disabilities and no family or friends to help guide them through the system can be particularly challenged to access supports. While it is my experience that some IA workers have been helpful and respectful when assisting some of my clients with some of the processes, I have also experienced other workers who are rude, disconnected, and apathetic to the needs of some clients. While it may be unrealistic, I would like to see the customer service aspect of workers improve so that all clients, but particularly the ones with disabilities, do not feel intimidated to get information or assistance and are treated with more dignity and respect.
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2014-01-23
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I agree
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2014-01-23
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I live in a rural area without transit or handy-dart. I receive no assistance for travel. I live 45 minutes from town one way. Its deplorable how people on a disability are treated.
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2014-01-24
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My comment is about accessability to the community. Where I live and support people who use a wheelchair van it seems that the shopping centres have decided that "handicapped" parking is not necessary. Two new shopping centres have cut back on their parking for permitted vehicles, and we can't shop at Walmart anymore unless we want to unload and walk in the rain and wind to a very slow and over used elevator, then do the same on our return. It takes more than 5 minutes to unload a wheelchair van, and the first one out sits out in the rain until everyone is out. No thanks! We are in Victoria where the "handicapped" parking is almost always taken by older people driving cars. We need spots that are only for the use of wheelchair vehicles, since we can't park in a regular spot. People who access their community in wheelchairs do need special consideration and it should be offered without prejudice - their money spends just like everyone elses.
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2014-01-24
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Fact is 80% of the disabled will never enter the workforce full time.
Yet we are forced into total poverty, yesterday I had to spend $145. on rapid insulin that is only 50% covered, now I can not afford healthy food, yet without insulin I will die! |
