Railway accessibility guidelines - objections and suggestions

[Vaishnavi Jayakumar]

28 January 2024

Shri. Ram Charan Meena, 

Under Secretary to the Government of India,
Department of Empowerment of Persons with Disabilities, 

Room no 11A, 5th floor, 

Pandit Deendayal Antyodaya Bhavan, CGO Complex, 

Lodhi Road, New Delhi 110003

Dear Mr. Meena,

 

With reference to the Railway Board OM No.2019/Stn.Dev.-l/03/06/Policy(PwDs) dated 28-11-2023 claim "that no media report or representation has been received/came to the notice of this ministry while notifying these accessibility standards" I would like to clarify that the Freedom of Movement Coalition has been in communication with the Railway Board from mid-2023 and a detailed representation submitted. Please find attached documents including media coverage detailing the same emphasizing Indian Railways statutory responsibilities to provide accessible  facilities and services (as per sections 44-46 of the Rights of Persons with Disabilities Act 2016 read with  section 15 of the Rights of Persons with Disabilities Rules 2017) especially given the rollout of the Amrit Bharat Station Scheme and Vande Bharat trains.

As the 2023 representation has already outlined comprehensively, the 2022 Guidelines on Accessibility of Indian Railway Stations and Facilities at Stations for Differently Abled Persons (Divyangjan) and Passengers with Reduced Mobility need to be extensively reworked to be on par with or better than the Harmonised Guidelines 2021. It may be a good idea henceforth to vet the sectoral guidelines with an empanelled access auditor before releasing anachronistic or plain dangerous guidelines (as has been recommended shockingly with tactile guidance for the blind.) Additionally the railways seems to be belabouring under the misconception that selective and leisurely accessibility compliance is the way forward. Has the DEPWD not informed ministries that the Accessible India Campaign is now history and that all deadlines for accessibility compliance required under disability law lapsed on 15 June 2022? 

Members of the Railway Board have been cc'ed here, as have disability groups so that we can all be on the same page in rejecting this unsuitable document and moving on a war footing to ensure that the massive spending currently flowing out via Gati Shakti is not wasted in developing disability-hostile infrastructure. 

At the very least,  the following non-negotiable features must be assured in modern India  : 

• No polished granite flooring
• 920 mm HIGH PLATFORMS.
• Standard tactile platform edge warning.
• Level Boarding.
• Ramped Foot Over Bridge (FOB) access to all platforms.
• Toilet with bi-lateral wheelchair transfer.
• Multimodal communication

While public comments on a granular level have been collated and crowdsourced in a public document, broadly the concerns include

• Faulty Foot Over Bridge logic
• Ramped access to every platform
• MEA for PwD = imperative not optional
• Incorrect platform edge warning for blind
• 920 mm high platform
• Boarding solutions not specified
• Conflicting flooring standards
• Changing Places NBC Type A bilateral transfer toilet required
• Communication to be made multimodal with simple UI
• Escalator safety for people with low vision, elderly, children etc
• Door widths & Interior accessibility of rolling stock
• Absence of WTORS
• Fixtures at usable heights with standardised placement
• Non Emergency Oxygen Concentrator Power Supply
• Dedicated end row for ambulant PRM
• UDID-enabled disabled passenger ticketing solutions
• Empanelled Access Auditor reports as integral part of project

In the absence of any changes in the 2022 Railway Accessibility Guidelines, the prior representation still holds good. 

While available online as a live document, it is also attached.

Do reply if any further clarifications are required.

Sincerely,

Vaishnavi  Jayakumar

Member, Freedom of Movement Coalition

&  Disability Rights Alliance (India)

http://about.me/vjayakumar