This letter was send to the European Commission last
year about sitting disability:
European Commission
Directorate-General for energy and transport
Comments from The Back Pain Association of Norway regarding the questionnaire on the protection of passengers' rights on board ships
The European Commission has described the legislation to cover the following categories of disabled passengers:
"A person with reduced mobility (PRM) is a person who has a particular difficulty when using public transport, including elderly persons, disabled persons, persons with sensory impairments and wheel chair users, pregnant women and persons accompanying small children (Directive 2003/24/EC of 14 April 2003)."
The Back Pain Association of Norway would like to bring to the Commision's attention that one of the most notable disabilities for people with back problems is a reduced ability to sit. A person with a sitting disability caused by excessive pain will be unable to sit or stand for long periods of time, and will thus have a need to lie down. The availability of benches or other devices where to lie down may be a critical factor that determines whether a means of transportation is usable or not for many pesons with these back problems. The Directive's description of disabled people does not seem to include passengers having sitting problems. At least this is a reasonable interpretation since the specific problems for persons with back problems are not addressed anywhere in the questionnaire for the analysis of protection of passenger rights in maritime transport.
To make sure that people with back problems are not discriminated against, the wording of the general definition of disability or its specification needs to include passengers with reduced sitting ability.
Today, people with sitting disability are often confronted with barriers in maritime transport. They do not necessarily have limited mobility, but may nevertheless encounter difficulties when travelling by ship. Usually, neither the terminals or the ships have benches where to lie down. Also, some persons with severe back problems, need a wheel bench to enter and to move around the ship. A wheel bench needs more space than a wheel chair. Some terminals and many ships don't have large enough elevators for a wheel bench, which makes it impossible for these people with severe back problems to access the ship.
The objective of the legislation needs to establish rules to protect all categories of disabled persons travelling by ship, to protect them against discrimination. To ensure this, sitting disability needs to be addressed in the documents from the European commission. People with reduced sitting ability also need to be included in the regulation's definition of disabled people.









