Appendix 2 - Of Concerns and Commitments Not Kept_Dra to Cmrl_20150715.PDF

8/20/2019 Appendix 2 - Of Concerns and Commitments Not Kept_Dra to Cmrl_20150715.PDF

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APPENDIX 2

KEY CONCERNS & COMMITMENTS NOT KEPT

Contents

KEY CONCERNS: ................................................................................................................................................................................ 2 A. INDEPENDENT TRAVEL RENDERED IMPOSSIBLE BY NON-COMPLIANT DESIGN: ............................................... ...................... 2

B. SAFETY FROM HAZARDS AND POTENTIAL INJURY: ............................ ............................... ................................ .......................... 2

C. INEFFICIENT, INCOMPLETE INFORMATION CHANNELS ..................................................... ............................... ........................... 2

D. RAIL COACH ERGONOMIC FLAWS: ............................. ............................... ................................ .............................. ...................... 2

COMMITMENTS NOT KEPT ...................................................................................................................................................... 3

Guidelines and space standards for barrier free built environment for disabled and elderly persons ....................... 3

[A] IN METRO STATIONS: ............................................................................................................................................................... 3

DRA OBSERVATION .................................................................................................................................................................... 3

1. Signages within and outside the Station ............................ ............................... .............................. ................................ ........... 3

3. Non slippery floors and well lit passages. ......................................................... .............................. ................................ ........... 4

4. Convenient design of station structure for free movement. ................................ ................................ .............................. ........... 4

5. Dedicated tactile tiles to access for the functional areas and platforms. ............................ ................................ .......................... 5

6. Bumpy tiles to alert customers who are blind or have low vision that they are nearing the edge of the platform. .......................... 5

7. Accessible toilets. ....... ..... ...... ..... ..... ..... ..... ...... ..... ..... ...... ..... ..... ..... ..... ...... ..... ..... ..... ..... ..... ..... ..... ...... ..... ..... ..... ...... ..... ..... ..... . 6

8. Ticket issuing window and Ticket Vending Machine counters with accessible heights. ..... ...... ..... ..... ...... ..... ..... ..... ...... ..... ..... ...... 7

9. Dedicated Automatic Fare Collection (AFC) gates. ................................ ................................ ............................... ..................... 8

10. Induction loops at ticket counters for hearing impaired passengers. ................................ ................................ ........................... 8

11. Simple and Uniform Terminal Design avoiding glossy surfaces/glasses. .......................... ................................ .......................... 8

12. Ramp as per standards and with handrail. ...................................... ............................... ................................ ........................... 8

13. Adequate landing space at the start and end of every ramp. ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ...... ..... ..... ..... . 8

14. Stair cases as per standards with handrails..................................... ............................... ................................ ........................... 9

15. Steps with contrasting coloured nosing or anti skidding tiles at the edge of the steps will be provided for easy access. ..... ..... .... 9

[B] IN LIFTS: ......................................................................................................................................................................................... 9

Lift in street level at convenient location and lift facility within the station. ..................................................... ................................ ........... 9

Lift cars with required space and wide doors. ................................ ................................ ................................ .............................. ........... 9 Audio announcement and Braille facilities within lift. Signs printed in Braille in the lifts to indicate floors as well as visual/ audibleannouncements. ................................................................................................................................................................................... 9

Grip rails on 3 walls inside the elevator car. ............................................. ............................... ............................... ............................... . 9

Elevator control buttons positioned at convenient heights. ............................. ............................... ................................ .......................... 9

[C] COACHES: .....................................................................................................................................................................................10

General ...............................................................................................................................................................................................10

Wheelchair Egress Request .......................................... ............................... .............................. ................................ ..........................12

CAUTION : VISUAL DESIGN ..................................................................................................................................................13

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KEY CONCERNS

These are the key concerns that need immediate or timebound redressal:

A. INDEPENDENT TRAVEL RENDERED IMPOSSIBLE BY NON-

COMPLIANT DESIGN:

As things stand today, visiting a Chennai Metro station with its significant barriers outlined in

Appendix 2 is impossible for a visually impaired cane user or a wheelchair user unless they are

escorted. This redundancy needs to be reduced so that travellers are as independent as possible

and so that avoidable cost. Crucial problems include: structural design errors in toilets, gap

between train and platform, incorrect height of equipment service buttons and patchy tactile

pathways.

Even the dated CPWD guidelines have been serially violated.

Similarly, crutch users, the Deaf, people with low vision, short people, etc could also be forced into

dependence on support - the reasons being slippery flooring, lack of sign language assistance,

height of buttons/switches/counters, inadequate colour contrast and font size of displayed writteninformation, etc.

B. SAFETY FROM HAZARDS AND POTENTIAL INJURY: Complaints

have been received from senior citizens and public at large about near-falls on the glossy, reflective

highly slippery floor surfaces in the stations. Crutch users are exhausted with the effort involved in

ensuring their crutch and legs don’t slip. The lack of uniform diffused lighting adds to the overall

glare as does the lack of attention to sufficient colour contrast. Why has polished granite with its

high cost and poor slip resistance under even the best conditions been used? Emergency refuge

points have not been planned for situations when lifts cannot be used. With current placement ofplatform edge warning tiles chances of a visually impaired person falling on the tracks is extremely

high.

C. INEFFICIENT, INCOMPLETE INFORMATION CHANNELS: The

signage design lacks adequate colour contrast even without taking into consideration the

interaction of material type, reflectance, illumination, viewing angle and distance. Tactile signage

when it is rarely present has not taken into account localisation usability tweaks needed in India.

Inadequate / lack of sign language assistance for the Deaf, absence of audio induction loop for

hearing aid users and inadequate colour contrast and font size on display information pose barriers.

Audio and tactile feedback has not been consistently applied to the detriment of the blind and

deaf-blind. The customer care is not aware of details of services that will be offered ex: availability

of wheelchairs, boarding assistance, mobile ramp to get into the train, communication on

assistance required to the destination station etc,

D. RAIL COACH ERGONOMIC FLAWS: The grab pole situated at wheelchair

entrance is a barrier to wheelchair manoeuvring as well as a hazard for visually impaired travellers

who risk banging into the same when boarding in a hurry. Fixes to the accessibility errors pointed

out already by DRA in the past have not been implemented for eg. folding seat impracticality.

Additionally the (currently non-functioning) emergency intercom and long stop button are

confusing in user interface.


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DRA OBSERVATION: While DRA has urged from 2011, the need to follow principles of

Universal Design, CMRL’s commitment reassured that at least infrastructural

components of the service would be of a particular quality standard.

(One must point out here that India’s 1998 guidelines are outdated and myopic in their

focus on the built environment alone instead of the entire service continuum)

As DRA’s preliminary access walkthrough indicates, these basic standards themselves

have been flouted.

Pictogram contrast insufficient,

made worse by excessive

reflectance / uneven lighting glare

COMMITMENTS NOT KEPT

CMRL MEDIA RELEASE OF 2012 ANNOTATED WITH POST INAUGURATION OBSERVATIONS BY DRA 3-7-15

CMRL PRESS RELEASE 2012:”Facilities Planned for Physically

Challenged Persons in Chennai Metro Stations and Coaches”

GUIDELINES AND SPACE STANDARDS FOR BARRIER FREE BUILT ENVIRONMENT FOR DISABLED AND ELDERLY PERSONS

The facilities for Physically Challenged persons within the station will generally beprovided based on Guidelines and space standards for Barrier Free Built Environment

for Disabled and Elderly Persons". Also, the design in general will be in accordance

with "Guidelines and Space Standards for Barrier Free Built Environment for Disabled

and Elderly Persons", Central Public Works Department, Ministry of Urban Affairs &

Employment, 1998. The following facilities are planned to be provided within the

station for Physically Challenged Persons:

[A] IN METRO STATIONS:

1. SIGNAGES WITHIN AND OUTSIDE THE STATION

2. Dedicated parking space subject to space availability.

- NIL –

Signs lit patchily, pictograms

are incompletely displayed


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3. NON SLIPPERY FLOORS AND WELL LIT PASSAGES.

4. CONVENIENT DESIGN OF STATION STRUCTURE FOR FREE MOVEMENT.

Worst possible floor surface material has been used. And then polished to a high gloss. Non-diffused

illuminance and resultant glare and retro-reflectance further confuses. This is a travesty!

When selecting colours, designers and managers of buildings can have a major impact on the ability of

visually impaired people to use buildings. Two colours that contrast sharply to someone with normal

vision may be far less distinguishable to someone with a visual impairment. Therefore the contrast

between, for example door surrounds and walls must achieve a certain level - measured by its light

reflectance value (LRV).

The minimum requirements for colour contrast are as follows: LRV of wall should be 30 points

different from that of the floor and the ceiling. Skirting should have same LRV as wall. LRV of door

surround (architrave and frame) should be 30 points different from that of the wall. Door surround

and door can be the same or different colours. It is the surround that should contrast with the wall. .

The purpose of this is that if the door is open and the wall in the background and foreground are the

same colour the door opening can still be identified. LRV of the door furniture should be 15 points

different from that of the door.

No colour or luminance contrast between walls

and floors, and between walls and ceilings. Mirrorreflections and glare further confuse.


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5. DEDICATED TACTILE TILES TO ACCESS FOR THE FUNCTIONAL AREAS AND PLATFORMS .

6. BUMPY TILES TO ALERT CUSTOMERS WHO ARE BLIND OR HAVE LOW VISION THAT THEY ARE NEARING THE EDGE OF

THE PLATFORM.

The platform should

have one row ofdotted uidin blocks for ersons with im aired vision, 800 mm. or more from the ed e.

Not only are TWSI warning blocks required for the length of the platform, with a 30 cm width row there

are cases in which a blind person falls from the platform as he or she steps over a TGSI installed near the

platform edge without recognizing it. The width of the platform edge warning should be a row of 60 cm

dotted tactile blocks.

Also there must be a distance of 80 to 100 cm from the front end of the TGSI to the platform edge for a

blind person to be able to stop after recognizing the TGSI.

Tactile walking surface indicators are available in fits and starts and are not available to guide people to

the toilets for example.


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7. ACCESSIBLE TOILETS.

TOILETS Page 43 http://bit.ly/CpwdGuidelines

Light-weight PVC door shutter should be provided as a sliding door

Guidelines and Space Standards for Barrier Free Built Environment for Disabled and Elderly Persons

Central Public Works Department, Ministry of Urban Affairs & Employment 1998

• The main toilet door is too heavy to push / pull for a person with Cerebral Palsy or for a calliper / crutch

user.

• Once inside the toilet of Alandur station, the toilet door entrance is too narrow. Where ideallydimensions could cater to power wheelchairs, - not even a medium adult wheel chair could enter.

• The latch to close door is on top not reachable for wheel chair / crutch / calliper or somebody with a

height of or below 4 ft.

• Grip rail availability was random. One toilet, not in the picture had no grab rails making access to even

the sink impossible. Where available, the sharp edges rendered them unsafe.

• The hygiene faucet and flush button are not easily accessible.

Reaching hygiene faucet

requires contortions !

Shoes removed as wet flooroffered no slip resistance

Very sharp edges on

grab rails are unsafe


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8. TICKET ISSUING WINDOW AND TICKET VENDING MACHINE COUNTERS WITH ACCESSIBLE HEIGHTS.

COUNTERS, VENDING MACHINES Page 49 http://bit.ly/CpwdGuidelinesA minimum of 1 lowered service counter and 1 lowered vending machine on the premises.

Counter height not > 850 mm with space 350 mm deep and 700 mm high underneath

Coin slots of vending machines etc. to be located no higher than 1200 mm.

Guidelines and Space Standards for Barrier Free Built Environment for Disabled and Elderly Persons

Central Public Works Department, Ministry of Urban Affairs & Employment 1998

A minimum of 1 lowered service counter and 1 disbursing machine on the premises.

Counter heights should not be in excess of 850 mm.

Allow a space at least 350 mm deep and 700 mm high under a counter, stand, etc.

Make sure that the coin slots of vending machines etc. are no higher than 1200 mm.

A knee recess beneath the ticket vending machines should be provided.

Install guiding blocks 300 mm. away from the vending machine for visually impaired.

The fare buttons, cancel buttons and other information buttons should be written in Braille or in

a distinct relief pattern.www.bit.ly/CpwdGuidelines


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9. DEDICATED AUTOMATIC FARE COLLECTION (AFC) GATES.

10. INDUCTION LOOPS AT TICKET COUNTERS FOR HEARING IMPAIRED PASSENGERS.

11. SIMPLE AND UNIFORM TERMINAL DESIGN AVOIDING GLOSSY SURFACES/GLASSES.

Refer No 3: NON SLIPPERY FLOORS AND WELL LIT PASSAGES.

No 4: CONVENIENT DESIGN OF STATION STRUCTURE FOR FREE MOVEMENT

12. RAMP AS PER STANDARDS AND WITH HANDRAIL.

13. ADEQUATE LANDING SPACE AT THE START AND END OF EVERY RAMP.

AFCs are much too high for people on wheelchairs – Ummul on the left is shorter than Smitha who is

5’5” – both are unable to see location to tap token. This could have been easily avoided by having

the validation area on front on the machine instead of the top.

At Alandur, the ramp on the front side starts on the pavement which is not accessible. People directed us

to take the side entrance in the parking area.

The only induction loop spotted…high away where none can see it 8 feet high! Where are the

induction loops at ticket counters? The real-world functioning of this is to be tested.


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Maximum number of risers on a flight shall be limited to 12.

www.bit.ly/CpwdGuidelines

14. STAIR CASES AS PER STANDARDS WITH HANDRAILS.

15. STEPS WITH CONTRASTING COLOURED NOSING OR ANTI SKIDDING TILES AT THE EDGE OF THE STEPS WILL BE

PROVIDED FOR EASY ACCESS.

16. Adequate seating arrangement in platform

- To be checked

[B] IN LIFTS:

15 risers instead of 12

No colour contrast

on anti-skid nosing

LIFT IN STREET LEVEL AT CONVENIENT

LOCATION AND LIFT FACILITY WITHIN THE

STATION.

LIFT CARS WITH REQUIRED SPACE AND WIDE

DOORS.

AUDIO ANNOUNCEMENT AND BRAILLE

FACILITIES WITHIN LIFT. SIGNS PRINTED IN

BRAILLE IN THE LIFTS TO INDICATE FLOORS AS

WELL AS VISUAL/ AUDIBLE ANNOUNCEMENTS.

GRIP RAILS ON 3 WALLS INSIDE THE ELEVATOR

CAR.

ELEVATOR CONTROL BUTTONS POSITIONED AT

CONVENIENT HEIGHTS.


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[C] COACHES:

GENERAL

1. DEDICATED SEATING FACILITIES IN THE TRAIN .

Braille unevenly embossed

Unreachable from

wheelchair

Yellow flashing 'BUSY' light

w/o audio or tactile

equivalent

No pictogram for non-

English / cognitivelydisabled

Braille is English contracted

which is unknown by

majority.

Also Braille available only

for button, not label

While button is raised, the

letters in relief aren't

outlined hence poorly

contrasted

No tactile / audio equivalent of button-pressed illumination.

Emergency intercom w/o video excludes deaf /deaf-blind etc

Music playing. ambient noise makes announcement inaudible

No clarity on usage of alarm vs emergency intercom

Vertical panel installed instead of horizontal –range not to > 900-1100 mm from floor

Note the strange location of the International accessibility sign tucked away near the ceiling likesomething to be ashamed about!


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2. EASY ACCESS TO THE CARS FOR PERSONS WITH DISABILITIES, INCLUDING WHEELCHAIR USERS, SHALL BE PROVIDED

THROUGH THE SIDE DOORS.

3. The rake shall be a high-floor design, with level boarding from platforms.

While this standing pole is useful for people entering

and exiting to grab for safety / stability, its position

could perhaps be relocated in coaches which have

wheelchair spaces.

Apart from it being a barrier to manoeuvring forwheelchair users, it is a hazard for visually impaired

passengers who may walk straight into it while

boarding.


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(CAPTIONS - CLOCKWISE FROM TOP LEFT)

a) The gap is enough to impede independent travel for a wheelchair user

b) …Unless they use a power wheelchair (Sunder faced no issue apart from dodging the pole, but his

wheelchair ran out of battery by end evening and India is yet to see wheelchair recharging

stations)

c) Meenakshi got stuck going in and required help to get back on platform. Even when attempting

backwards entry she was unable to board independently despite attempts at leverage and

considerable effort.

d) Smitha required assistance to board within the specified time, even then her assistant had to exert

significant effort at negotiating the gap.

WHEELCHAIR EGRESS REQUEST

i. A wheelchair egress request signal shall be provided which shall permit apassenger in any car of a train to alert the operator to stop the car for

a prolonged time to enable wheelchair passengers to exit the train. This

system shall be ADA compliant and accessible to wheelchair-seated

passengers.

ii. The stop request shall consist of the following and shall be inhibitedwhen doors are open.

iii. Stop-request strips shall be located at wheelchair accommodations.

iv. An audible-non-repeating chime and alarm light shall be installed in each

operator’s cab area.

4. Wheelchair and mobility-impaired boarding shall not require the use ofbridging or lifting devices.

5. The horizontal gap between the passenger door thresholds and platformedge at rest shall not exceed 50 mm in nominal operating conditions, and

75 mm maximum.

6. The maximum vertical gap between the passenger door thresholds andplatform edge shall not exceed 31 mm in nominal operating conditions. In

no cases (including the worst operating conditions) shall the top

surface of the horizontal threshold of the car be lower than the top

edge of the platform. The gap between platform and the rail car enables

wheelchair users to enter and exit the train safely.

7. At least two wheelchair parking areas shall be available in each drivercar of the 4-car rakes. Four seats shall be available for the elderly

and handicapped passengers in all driver car ends.

8. Seats shall be provided for handicapped persons.

9. The designated areas for wheelchair parking shall be located adjacent to

an accessible entrance and shall be compliant with all ADA requirements.

10. Wheelchair users must be able to exit the car from any wheelchairparking position through either of at least two accessible doors (on the

same side of the train).

A twin provision to be made for passengers with reduced mobility on the platform to enable to the

maximum extent possible, independence in boarding and deboarding.


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SIGNAGES, Page 44 http://www.bit.ly/CpwdGuidelines

Signs should be in contrasting colours and preferably be embossed in distinct relief to allow visually impaired persons to

obtain the information they contain by touching them. The size, type and layout of lettering on signs shall be clear and

legible.

Guidelines and Space Standards for Barrier Free Built Environment for Disabled and Elderly Persons Central Public Works Department, Ministry of Urban Affairs & Employment, 1998.

Poor interface, confusing UX,

not yet functional, cramped

lettering, no relief / Braille

embossing, not high contrast,

no tactile / audio feedback,

deaf-blind needs ignored

VERDICT : FAIL

DRA expresses grave concern over

the signage colour palette as usability has been

compromised. Contrast tests of recommended

combinations have mostly failed in compliance.

Size norms have been ignored too with grossly

limiting consequences.

CAUTION VISUAL DESIGN

Documents

Appendix 2 - Of Concerns and Commitments Not Kept_Dra to Cmrl_20150715.PDF