Scared Silly
Contributor
Requiring compliance with §§ 116.500 and 177.500 will ensure that all existing vessels with overnight accommodations for passengers will maintain at least two independent means of escape that allow for free and unobstructed egress from any point in a vessel to an embarkation station
I will be sending a comment regarding the proposed rules. Bluntly having two independent means of escape does not do a damn bit of good if there are 30 plus people in the bunk area. The number of exits needs to be tied to the number of passengers:
For instance, here are the FAA rules for small commercial aircraft. For 20-40 seats there are four exits.
(3) For a passenger seating configuration of 10 to 19 seats, there must be at least one Type III or larger exit in each side of the fuselage. (4) For a passenger seating configuration of 20 to 40 seats, there must be at least two exits, one of which must be a Type II or larger exit, in each side of the fuselage.
Further FAA rule requires that a plane can be fully evaluated in 90 seconds. If the primary exit is blocked from the sleeping berths there is little chance that 30 people will be able to exit up a ladder exit as I have seen as recently installed.
Point being the Coast Guard needs to take a page out of the FAA rules.