Fwd: Comments on draft Road Safety SOP
Vaishnavi Jayakumar (Inclusive India)
Date: Wed, 10 Sept 2025 at 09:46
Subject: Comments on draft Road Safety SOP
To: <policy...@gmail.com>, <debala....@gov.in>
SUBMISSION ON DEPWD ROAD SAFETY DRAFT
Section 1. Introduction
Correct typo - temporary or permanent disability
Section 2 - Scope
The title and scope are narrow, limited to post accident measures rather than the Supreme Court order’s more expansive focus in S. Rajaseekaran on the right of pedestrians with disabilities (who are intersectionally vulnerable road users) to safely use encroachment-free, consistent footpaths and footways that are accessible and in good condition as guaranteed under Article 21 of the Constitution of India.
Car-centric transportation planning bias disproportionately distributes risk to those who often have the least ability to mitigate it (e.g., children, the elderly, those with disabilities, or low-income individuals reliant on walking/cycling). With 24 instead of 60 buses per lakh population, and State Transport Undertaking (STU) fleets further diminishing over the years instead of increasing, 2-wheeler usage has boomed, with private vehicles choking roads. Converting and incentivising private vehicle owners to use a range of consistent, comfortable and convenient public transport services will potentially do far more for road safety than the measures outlined in the document.
Mandating laning for buses and cycles and rolling out transformer level anti- electrocution safety systems could similarly make a huge positive impact on pedestrian road safety.
Section 3 - Definitions :
The following additions need to be made :
‘vulnerable road users’ (VRU) means non-motorised road users, such as pedestrians and cyclists as well as motor-cyclists and persons with disabilities or reduced mobility and orientation; with an increased risk of being injured or killed in traffic because he is not surrounded by a protective cover which would significantly reduce the severity of an accident.
‘Scoop stretcher’ also known as a clamshell stretcher, is a specialized medical device used to transfer patients with suspected spinal, pelvic, or limb injuries with minimal movement. It consists of two longitudinal halves that separate and reassemble around the patient, allowing them to be "scooped" from the ground without rolling the patient over, which reduces the risk of further injury, especially to the spine.
‘Accessible Pedestrian Signal’ is a device that communicates information about pedestrian signal status, timing and in multiple formats - visual, audible tones, speech messages, and vibrotactile surfaces. It could also permit on demand crossing with additional time for pedestrians with reduced mobility to safely cross.
‘Mobile accessible pedestrian signal’ system is a V2P (vehicle-to-pedestrian) application that enables an automated call from a visually impaired pedestrian’s smart phone to the traffic signal.
‘Accessible Emergency Communication Service’ is a multimodal helpline platform available online, as an app with IP calls, text, sign language video relay options in addition to the voice and SMS based cellular network with Advanced Mobile Location.
4. Accessibility Standards for Roads and Transport
Compliance with standards
All references to IRC SP-137 and IRC-37 to be removed as they pertain to bridges and flexible pavements respectively, with no reference to accessibility. IRC:117-2018 (Universal Accessibility for urban roads) needs to be inserted along with IRC:67-2012 (Road Signs), IRC:SP:56-2011 (Pedestrian Bridges), and IRC:99-2018 (Traffic calming) instead as does AIS:052 & AIS-153 - the Bus Body Code.
Pedestrian Facilities:
Substitute Tactile Ground Surface Indicator (TGSI) for ‘tactile paving’, and kerb for ‘curb’
With insertions, this para should read :
‘Install Tactile Ground Surface Indicator (TGSI) for blind pedestrians’ guidance and warning, accessible pedestrian signals at zebra crossings, traffic lights with audible signals , signage with symbols accompanying text (tactile when within reach), kerb ramps for footpaths, bollards with minimum 1m spacing, accessible wayside amenities for and ramped grade-separated crossings like foot over bridges / underpass / subway (with lift provisions and seating) for barrier-free and safe movement.;
Add
Pavement bollards parallel to the carriageway should be crash-rated to potentially save pedestrians’ lives in case of collision with an out of control vehicle.
To avoid time-consuming repositioning of utilities and natural barriers like trees, 2 metres minimum walking pedestrian zone (as specified in IRC-103-2022 Table 2) can be reclaimed from the carriageway for the footpath with markings for a 3 feet wide wheelchair ’lane’ and 1 foot wide tactile guiding path. Tactile warning strip at kerb ramps and vehicular crossovers (in case of continuous footpath) shall be mandatory. The pavement surface shall be smooth but non-slip, and pattern-free with adequate contrast to differentiate it from the road.
Monitoring:
Substitute ‘regular walkability audits’ for’ regular audits’
Vehicle Adaptation
Add :The current electric vehicle registration plate design white / yellow on green fails contrast tests - a more readable design - perhaps a green border / line as in UK. Acoustic Vehicle Alerting System (AVAS) for electric / Quiet Road Transport Vehicles must be mandated for safety of blind pedestrians as per AIS:173.
Enforcement:
Fines to be incorporated for pavement encroachment by way of parking, driving or a building entryway’s ramp or outward opening gates or dumped building construction debris. This could be automatically challaned via CCTVs with automatic name plate recognition. Additional penalties to be introduced for blocking kerb ramps or bollards, forcing wheelchair users into dangerous traffic and removing manhole covers during flooding. Penalties to be levied on road surfacing contractors who reduce the 150 mm pavement height above the carriageway by not milling or coring the road before relaying, thus necessitating pavement raising. Similar penalties are required for low hung cable TV wires and insufficiently pruned tree branches which can be very dangerous for blind pedestrians.
Buses, trucks and trailers shall not be granted fitness certificates if not equipped with Rear Underrun Protective Devices (RUPD). Front Underrun Protective Devices (FUPD) and Side Underrun Protective Devices (SUPD) as required by AIS and mandated by MORTH.
+Add the following subheadings
Traffic Communication :
IS:7537-14 to be amended to ensure that colour is not the only visual means of conveying information, indicating an action, prompting a response, or distinguishing a visual element. A secondary cue in addition to colour (such as shape or text), is essential to distinguish information and convey meaning.
Traffic lights can be redesigned for those with colour blindness to incorporate shape in addition to colour differentiation. Using the current road sign logic where triangles warn, rectangles inform and circles give orders, the red light can be a triangle, the yellow a square and the green light a circle.
During the process of developing BIS standards for Accessible Pedestrian Signals, and Mobile Accessible Pedestrian Signals, retrofitting of existing traffic signals can undertaken as per the Manual on Uniform Traffic Control Devices (MUTCD) specifications. Signals, zebra crossings, legal speedbreakers, grade-separated pedestrian crossings, auto / taxi stands, public transport stops, metro station gates, accessible parking slots and drop off zones, dog pack zones shall be mapped with accessibility status and published as open data for ease of wayfinding. A system of real-time service alerts based on lifts not working, traffic diversions, waterlogging etc can supplement QR coded street names and geographic database of street ids for safety.
IRC:676-2012 (road signs) to be amended to change warning signs for zones with concentration of deaf / blind pedestrians into a more intuitive international symbol of deafness and blindness respectively within the red warning triangle. A similarly intuitive sign for pedestrians with restricted mobility has to be developed for the standard as do signs for 2 wheeler parking, 4 wheeler parking and drop off zones. A behaviour change communication campaign of disability-specific road signs and what they mean should be undertaken with rollout of ‘wheelchair lane markings’ at bollards.
Accessible Parking, Drop-off Zones, Level Boarding Bus stops:
Standardised dimensions and drawings for both stage carriage and contract carriage public transport terminals with near-level boarding as well as accessible adapted 2 wheeler parking, and drop off zone are required to be formulated by MoRTH and implemented without deviation nationwide without further delay.
Intelligent Transportation Systems (ITS) shall include user-triggered bus identification and homing system for blind passengers to board a particular bus when multiple buses arrive simultaneously at a bus stop.
Stage Carriage buses with hydraulic wheelchair lifts shall be removed from circulation due to safety concerns in urban Indian traffic. Safety standards and tests for wheelchair lifts in long distance bus travel need to be developed and conducted.
6. Sensitization/Training:
Substitute with following text
First responders (police/ paramedics / road safety professionals / helpline counsellors etc) shall be sensitized/trained to recognize signs of disabilities, including physical impairments, sensory loss, neurological or mental health issues, with training facilitated by DEPwD’s NI/CRC network.
DRSC shall arrange training on safe commute, transfer, support and handling of PwDs to the staff of establishments with high footfall of persons with disabilities and hospitals.
First responders and medical personnel shall undergo mandatory training on disability identification, safe handling, and initial care to minimize future disabilities, conducted by AIIMS or state health departments in collaboration with NI/CRCs and State Disability Welfare Departments. The training to be held annually to update skills and incorporate new disability care protocols.
Physiotherapists, occupational therapists, speech-language pathologists and clinical psychologists shall be trained in advanced rehabilitation techniques, including mental health support, tailored for road accident victims and newly disabled, at NI/CRCs in collaboration with State Health and State Disability Welfare Departments.
7. Mandatory facilities:
Safe Handling:
Substitute with following text :
MRI compatible, plastic scoop stretcher (with optional cervical collar) to be carried by default across all ambulance categories so as to prevent rescue-caused spinal cord injuries after road accidents. From level V trauma centres upwards, Victims with suspected spinal or limb injuries shall be handled using immobilization techniques (e.g., cervical collars, spine boards) to prevent further damage and minimize future disabilities. Medical boards assessing and certifying disability shall be equipped with a height adjustable examination table and trauma centres with a height adjustable transfer chair.
Ambulance Deployment:
Add text at end
The Union Government shall set up and fund a pan-Indian multilingual ‘accessible emergency communication service’ to extend capabilities of 108 / 112 / 14416 / 1070 and other crisis helplines.
Rehab Services
Add text at end :
Deployment of Non-Emergency Patient Transport Services (102):
States/UTs shall ensure non-emergency patient transport services with trained assistants and passenger service vehicle with hydraulic wheelchair lift equipped with Evacuation Chair, foldable wheelchair, Wheelchair Tiedown and Occupant Restraint System (WTORS), portable ramp, transfer board, Augmentative and Alternative Communication (AAC) picture chart etc).
Step down hospital wards, rehabilitation centres, long stay residential choultries / dharmashalas shall be barrier-free as per relevant provisions of the National Building Code with centre oriented (Type A) wheelchair accessible toilet with swivel grab bars and space for assisted bilateral transfer.
References
Delete :
Irrelevant IRC codes :
IRC-SP-37: Guidelines for Evaluation of Load Carrying Capacity of Bridges" and relates to bridge assessment, not pedestrian facilities or tactile paving
IRC-37: standards for the design of flexible pavements (road layers/structural pavement design)
Add :