Assistance for Locating Passenger Seats and Tactile Row Markers: A Guide

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1. Purpose

This guide explains the requirements in the Accessible Transportation for Persons with Disabilities Regulations (ATPDR) regarding assistance locating passenger seats and tactile row markers. In particular, this guide describes:

  • What are tactile row markers;
  • Obligations of air, rail, marine (ferry) and bus carriers concerning:
    • Services for persons with disabilities who need assistance locating their seat; and
    • Technical requirements for tactile row markers on aircraft, trains, ferries and buses; and
    • Responsibilities of persons with disabilities who need assistance locating their seat.

Transportation service providers not covered by the ATPDR may still have obligations regarding assistance locating passenger seats and tactile row markers on transportation equipment.

This is not a legal document. The explanations and definitions it provides are for general guidance purposes only. Curbside assistance obligations can be found in the ATPDR, Part 1 and in Annex A of this guide. In case of differences between this guide and legislation or regulations, the legislation and regulations prevail.

2. What are tactile row markers

A tactile row marker is a wayfinding measure for persons who are blind or who have a visual impairment. It is used to identify the row for a bank of seats and is located either on the passenger seat closest to the aisle or on the overhead storage bin.

Through touch, a tactile row marker permits a person who is blind or who has a visual impairment to independently locate the row for their passenger seat.

3. Obligations for carriers

Services for persons with disabilities who need assistance locating their seat

The ATPDR require air, rail, marine (ferry) and bus carriers to assist a person with a disability with locating their passenger seat. Carriers must also permit the person, on request, to board in advance of other passengers to receive the assistance.

Recommendations:

Carriers should not make assumptions about whether a person who is blind or who has a visual impairment wants assistance with locating their seat or the type of assistance they might want. Instead, carrier personnel should have a dialogue with the person at the time of boarding and, whenever possible, this dialogue should occur before boarding by other passengers.

If the person prefers to use tactile row markers instead of relying on carrier personnel to guide them to their seat, the person should be briefed by carrier personnel on:

  • the characteristics of the tactile row markers (raised characters and Braille) and their location (on the sides of seats and above the armrests or adjacent to the mechanisms for opening the overhead bins); and,
  • the row number; location of the bank of seats containing the person's seat (which side of the aisle or, where there is more than 1 aisle, whether it is in the middle of the row); and location of the person's seat within the bank of seats (for example, aisle, middle or window seat).

Technical requirements for tactile row markers

All Canadian carriers are required to meet the technical requirements in the ATPDR found in Part 3. Information on the applicability of these requirements for all modes can be found in the Transportation service providers covered by the Accessible Transportation for Persons with Disabilities Regulations: A guide.

Aircraft, Trains and Buses

Aircraft, trains and buses must be equipped with tactile row markers, in raised characters and Braille, that are installed, either permanently or temporarily, on the sides of passenger seats and above the armrests or adjacent to the mechanisms for opening overhead bins.

Ferries

If a marine carrier (ferry operator) offers assigned seats to passengers, those seats must have tactile row markers, in raised characters and Braille, that are installed, either permanently or temporarily, on the sides of passenger seats and above the armrests.

Recommendations:

Carriers are to be consistent in the type of tactile row markers (permanent or temporary) and where they are located (on seats or overhead bins) within their fleet.

4. Responsibilities of persons with disabilities who need assistance locating their passenger seat

The ATPDR recognize that carriers may need to establish conditions that persons with disabilities have to meet to ensure that they can respond to requests for services in an effective and timely manner.

Advance notice

A carrier may require a person with a disability to provide it with advance notice if the person makes a request pertaining to seating, including a request to board before other passengers because they need assistance locating their passenger seat.

Note : If you wish to reserve specific seating, you should make your request with your carrier well in advance of travel. Advance notice improves the likelihood that the seat required to meet your disability-related needs will be available. In addition, if the seat that you wish to reserve is in an emergency exit row, there are regulatory requirements related to safety that must be met and the carrier may have to assess your capacity and capabilities to meet those requirements before permitting you to sit in such a seat.

A carrier is required to make a reasonable effort to provide a disability-related service even if the person does not provide advance notice. More information about advance notice can be found in the CTA's Advance Notice When Requesting Services for Persons with Disabilities: A Guide.

Boarding requirements

    A carrier may dictate the time of boarding if it is necessary in order for its personnel to provide assistance locating a person with a disability's passenger seat. A carrier may require a person with a disability to:

    • board before the other passengers; or
    • board after the other passengers if the person arrives at the boarding area after the end of priority boarding.

    Tips for persons with disabilities:

    • Ask the carrier whether a person with a disability who needs assistance locating their passenger seat needs to pre-board (board before the other passengers);
    • If the carrier requires pre-boarding, arrive at the boarding area earlier than the usual time and identify yourself to the carrier.
    • Ask the carrier whether you can pre-board if you would prefer to have more time to board or more privacy when receiving assistance getting settled in your seat. (Note: a carrier is not obligated by the ATPDR to permit pre-boarding under these circumstances but may choose to do so).

    5. We're here to help

    For more information and guidance about accessible travel and the CTA’s dispute resolution services, please contact us at info@otc-cta.gc.ca.

    Annex A:

    Obligations in the Accessible Transportation for Persons with Disabilities Regulations regarding assistance locating a passenger seat and tactile row markers

    Assistance

    Provisions in the Accessible Transportation for Persons with Disabilities Regulations concerning assistance locating passenger seats are set out in Part 2 (Service Requirements Applicable to Carriers).

    Conditions for priority boarding

    34 (1)A carrier must permit a person with a disability, on request, to board in advance of other passengers if

    (a) the person has requested assistance with boarding, locating their passenger seat or cabin, transferring between a mobility aid and their passenger seat or storing carry-on baggage

    Requirement to board

    (2)If a person with a disability requests the assistance referred to in paragraph (1)(a) or

    (b) a carrier may require the person, in order for members of personnel to provide that assistance, to board before the other passengers or, if the person arrives at the boarding area after the end of priority boarding, to board after the other passengers.

    Tactile row markers

    Provisions in the Accessible Transportation for Persons with Disabilities Regulations concerning technical requirements for tactile row markers are set out in Part 3 as follows: Division 1 (Technical requirements applicable to Air Carriers); Division 2 (Technical requirements applicable to Rail Carriers); Division 3 (Technical requirements applicable to Marine Carriers); and Division 4 (Technical requirements applicable to Bus Carriers).

    Air Carriers

    75 Aircraft must be equipped with tactile row markers, in raised characters and Braille, that are installed, either permanently or temporarily, on the sides of passenger seats and above the armrests or adjacent to the mechanisms for opening overhead bins.

    Rail Carriers

    103 Trains must be equipped with tactile row markers, in raised characters and Braille, that are installed, either permanently or temporarily, on the sides of passenger seats and above the armrests or adjacent to the mechanisms for opening overhead bins.

    Marine Carriers

    148 If a marine carrier offers assigned passenger seats to passengers, the assigned passenger seats must be equipped with tactile row markers, in raised characters and Braille, that are installed, either permanently or temporarily, on the sides of the seats and above the armrests.

    Bus Carriers

    194 A bus must be equipped with tactile row markers, in raised characters and Braille, that are installed, either permanently or temporarily, on the sides of passenger seats and above the armrests or adjacent to the mechanisms for opening overhead bins.

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