FYI - today is last day for submission on RPwD Rules amendment.

---------- Forwarded message ---------
From: Vaishnavi Jayakumar
Date: Thu, 21 Jul 2022 at 20:57
Subject: Rights of Persons with Disabilities (Amendment) Rules, 2022
To: <panda...@nic.in>


Dear Mr. Panda,

DRAFT RULES' AMENDMENT
> <https://disabilityaffairs.gov.in/upload/uploadfiles/files/236720(1).pdf>
> 1. Short title and extent.-
>     (1) These rules may be called the Rights of Persons with Disabilities
> (Amendment) Rules, 2022.
>     (2) They shall come into force from the date of their publication in
> the Official Gazette.
> 2. In the Rights of Persons with Disabilities Rules, 2017, in rule (15),
> in sub-rule (1), for clause (a), the following clause shall be substituted,
> namely:-
>     “ (a) Standard for public buildings as specified in the Harmonised
> Guidelines and Standards for Universal Accessibility in India – 2021,
> issued by the Government of India, Ministry of Housing and Urban Affairs
> vide letter no. 28012/09/2019-W3, dated the 27th December, 2021
> <http://mowr.nic.in/core/Circulars/2022/Coord._27-12-2021.pdf>, as
> amended from time to time and made available on
> https://drive.google.com/file/d/1d4dedBt2cw-JEvy_qqSodQ9ENfOyNfef/view
> ”.
> [F. No. 38-05/2022-DD-III (Part -1)]
> RAJESH YADAV, Jt. Secy.


1) As the remit of the 2021 Harmonised Guidelines is of universal
accessibility and not restricted to buildings per se, I would suggest that
the above amendment clause (a) instead should echo the first line of
Section 15 (1) and read :

       (a) Standard for public buildings *and physical environment* as
specified in the Harmonised Guidelines and Standards for Universal
Accessibility in India as revised from time to time by the Ministry of
Housing and Urban Affairs, Government of  India and published on
accessibilitycode.gov.in .

*Explanation for changes : * Providing the contents of the Harmonised
Guidelines currently in force, as well-structured, hyperlinked html on a
standalone official website with '.gov.in' extension will make these
statutory requirements more discoverable, easier to look up the verified up
to date accessibility code and cross reference the same instead of the
current confusion of many documents with the same cover. (The gazette
version referenced for example is 360 pages
<https://drive.google.com/file/d/1d4dedBt2cw-JEvy_qqSodQ9ENfOyNfef/view>
and published December 2021, whereas the more recent version on the CPWD
website published in March 2022 is 474 pages
<https://cpwd.gov.in/Publication/HG2021_MOHUAN.pdf>.) The online resource
could also provide the soft copy of the print version as ePub and PDF, high
resolution images of the drawings, scope for Indian language versions of
the code, and the interface for suggesting further changes and
improvements. Removing the date from the Standard's name in the RPwD Rules
will make further minor amendments of this sort redundant.

2) There are already changes that need to be made in the Harmonised
Guidelines - bus shelter design lacks the boarding platform for low floor
buses, non-slip floor parameters are not defined clearly, emergency
provisions for crisis scenarios need to be expanded. Given that this should
ideally be a living standard, I would propose that a committee be formed
with suitable representation on the lines of BIS committees which will
receive and review suggestions in a transparent manner and make changes to
this evolving document on a 6 monthly basis to start off with.

3) A similar form of feedback is essential for the RPwD Act and Rules, many
other amendments and corrections are pending - see http://bit.ly/rpwd-annot
. Can this be addressed too, please?

Thanks,

Sincerely,

Vaishnavi Jayakumar

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