Ground Reality - Centre vs State on bus safety regulation

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Vaishnavi Jayakumar (Inclusive India)

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Jan 1, 2025, 11:53:30 PM1/1/25
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it's good that the fitness certificate angle has been brought up. That is one route towards pressuring without litigating tenders.

The prescriptive specifications for varied end  has also been highlighted by questioning suitability for hilly areas.

They should even have standards for tourist / sightseeing buses, the way they have for school buses.

This bus has steps btw. Inside to upper deck is unavoidable, but if no safety issue with centre of gravity, no reason why these can't be low floor.


January 1, 2025

The newly inaugurated KSRTC Royal View double-decker bus, aimed at boosting tourism in Munnar, faces criticism over its lack of fitness certification and insurance coverage.

ksrtc royal view busThiruvananthapuram: mParivahan of Motor Vehicle Department has raised concerns regarding the fitness and insurance of the newly refurbished Royal View Double Decker bus of KSRTC in Munnar, which was flagged off by Transport Minister KB Ganesh Kumar on Tuesday.

The bus, which has been in operation for 13 years, has undergone renovations but is reportedly lacking proper fitness certification and insurance coverage. There are also worries about its suitability for hilly routes, particularly in Munnar.

Opposition members have criticised the bus service, pointing out that the bus had been out of service for seven months for repairs and renovations. They also claim that the design of the double-decker bus is not ideal for the winding, uphill roads of Munnar. Additionally, there were no consultations with labor unions regarding the renovation and use of the bus.


Arushi Singh

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Jan 3, 2025, 8:10:50 AM1/3/25
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Hi All,

Vaishnavi, this sounds interesting. I am not sure if accessibility features in commercial vehicles are evaluated while granting a fitness certificate. It would also be good to check if any subsidies are given by the government to incorporate accessibility in such vehicles. I will read up on this and get back.

Some inputs on the Road Transportation:

  • Uninterrupted footpath and tactile pathways with curbs and point to point connectivity of such pathways. 
  • Accessible and shaded bus stops with proper tactile ground surface indicators (TGSI)
  • Route and schedule information in braille at accessible locations and digital screens or LED boards to show real-time bus schedules, route numbers, and service announcements.
  • Availability of low floor buses.
  • Raised platforms to ensure level boarding with buses.
  • Apps for the timing of buses/arrivals and departures/booking of tickets.
  • Priority seating inside the buses with buttons to indicate the point of disembark.
  • Accessible Restrooms and stops for refreshments at regular intervals on highways.
  • Designated accessible parking spots with extra room for wheelchairs at public spaces and bus stands.
  • Availability of wheelchairs at bus stands.
  • Indication of accessible bus stops in the app/bus stops/bus stands.

Thanks,

Arushi

Arushi Singh

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Jan 9, 2025, 1:34:59 PM1/9/25
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Hi All, 


I did some preliminary research on the parameters required for the grant of fitness certificates. I found this link - https://www.godigit.com/traffic-rules/vehicle-fitness-certificate. 


The forms talked about on this link are below. None of these forms though list anything about accessibility.


Form 20 - https://parivahan.gov.in/parivahan/sites/default/files/DownloadForm/form%2020.pdf


Form 21 - https://parivahan.gov.in/parivahan/sites/default/files/DownloadForm/form21.pdf


Form 22 - https://parivahan.gov.in/parivahan/sites/default/files/DownloadForm/cmvr/FORM-22.pdf


Not sure if we can include accessibility as a compulsory feature at the stage of either registration or grant of fitness certificate.


I also wanted to share some mandatory guidelines in terms of accessibility of airports and airplanes. Part of it also emanates from the judgment dated 12 Nov, 2024. I have enclosed the same along with this mail. 


  • Having a real time app showing the availability of wheelchairs, ambulift, towable ramps and all assistive devices, as well as the amenities and transportation of the wheelchairs, mobility devices and all assistive devices on the airport. This should be developed pan - India and should be provided free of cost.
  • Having mechanised wheelchairs at wheelchair collection points for the benefit of solo travellers.
  • Coding of the boarding passes, both alphabetically to denote the disability and by color to denote the severity of the disability.
  • The integration of disability certificates on the booking websites for the receipt of the boarding pass.
  • Separate kiosks for dispensing of the boarding pass.
  • Ambulifts/ towable ramps to be provided at airports where aerobridges are not available. 
  • International symbol of Disability to be displayed within the visible proximity of the main entrance of the arrival/ departure terminal, informing that they may contact the concerned airline operator for special assistance. 
  • Special assistance to be provided by Airport operator/ security agencies to the visually impaired in locating concerned airline operator counter/ office. 
  • Airport operator shall provide dedicated reserved parking space, toilets with independent entrance with proper signage and barrier free access to all areas in the terminal.
  • The passenger must be onboarded and off-boarded on priority, before the rest of the passengers, to avoid any delays. 


We should also urge for continuous and updated disability literacy encompassing all forms of transportation. 


Thanks,

Arushi


Order-7337_2024-12-11-2024.pdf

Vaishnavi Jayakumar (Inclusive India)

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Jan 9, 2025, 1:57:47 PM1/9/25
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The fitness certificate for buses tackles accessibility through a recent CMVR amendment on automated testing stations that are integral to fitness certificate process in near future. The deadline keeps shifting as the states don't have ATS ready, but the provisions for  wheelchair access are in any case manually verified, so technically most of the Type 1 city buses in India should technically not be running!



As the city bus accessibility explainer linked above states :

As per MoRTH G.S.R. 959(E)  dated 27 Dec 2019 no bus would be given a fitness certificate unless the requirements of sub-rules (1) and (7) of rule 125C, AIS-052 (Rev. 1) and AIS-153 are complied with by latest  1 October 2020. Elements covered under the fitness certificate include : 

  • Priority Seats, 

  • Signs, 

  • securing of crutches/canes/walker, 

  • hand rail/stanchions, 

  • controls at priority seats for differently abled passengers and passengers with reduced mobility

  • Wheel chair entry/housing/ locking arrangement for wheel chair for differently abled passengers and passengers with reduced mobility



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Vaishnavi Jayakumar (Inclusive India)

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Feb 17, 2025, 10:41:52 AM2/17/25
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Hey Arushi,

So the fitness certificate accessibility angle is this : as per MoRTH G.S.R. 959(E)  dated 27 Dec 2019 no bus would be given a fitness certificate unless the requirements of sub-rules (1) and (7) of rule 125C, AIS-052 (Rev. 1) and AIS-153 are complied with by latest  1 October 2020. Elements covered under the fitness certificate include : 

  • Priority Seats, 

  • Signs, 

  • securing of crutches/canes/walker, 

  • hand rail/stanchions, 

  • controls at priority seats for differently abled passengers and passengers with reduced mobility

  • Wheel chair entry/housing/ locking arrangement for wheel chair for differently abled passengers and passengers with reduced mobility



Form 22B has the GFH (Ground to Floor Height) 


On Fri, 10 Jan, 2025, 00:04 Arushi Singh, <arushi...@gmail.com> wrote:
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On 2 Jan 2025, at 10:23 AM, Vaishnavi Jayakumar (Inclusive India) <vaishnavi...@inclusiveindia.info> wrote:

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Vaishnavi Jayakumar (Inclusive India)

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Feb 17, 2025, 10:47:15 AM2/17/25
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Extracting earlier Jan 10th message from Arushi - wanted clarity on boarding / deboarding priority of passengers on wheelchairs.

Boarding first is understood, but deboarding last is there any logic? Is this the practice elsewhere in the world?

What are the practical issues here? 🔻
Order-7337_2024-12-11-2024.pdf

Arushi Singh

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Feb 18, 2025, 2:19:33 AM2/18/25
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Hi Vaishnavi,

I stand corrected. While deboarding on priority is not really a practice anywhere in the world, more often than not, passengers incur delays on account of wheelchairs not being made available on time. 

Perhaps, we can address the gaps in communication, especially in cases of passengers having connecting flights so that no delay or inconvenience is caused.

Hope this helps.

Thanks,
Arushi

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