APPENDIX 2

KEY CONCERNS & COMMITMENTS NOT KEPT

Contents
KEY CONCERNS: ................................................................................................................................................................................ 2
A.
B.
C.
D.

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

SAFETY FROM HAZARDS AND POTENTIAL INJURY: ..................................................................................................................... 2
INEFFICIENT, INCOMPLETE INFORMATION CHANNELS ............................................................................................................... 2
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.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.

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

Non slippery floors and well lit passages. .................................................................................................................................. 4
Convenient design of station structure for free movement. ......................................................................................................... 4
Dedicated tactile tiles to access for the functional areas and platforms. ...................................................................................... 5
Bumpy tiles to alert customers who are blind or have low vision that they are nearing the edge of the platform. .......................... 5
Accessible toilets. .................................................................................................................................................................... 6
Ticket issuing window and Ticket Vending Machine counters with accessible heights................................................................. 7
Dedicated Automatic Fare Collection (AFC) gates. .................................................................................................................... 8
Induction loops at ticket counters for hearing impaired passengers. ........................................................................................... 8
Simple and Uniform Terminal Design avoiding glossy surfaces/glasses. .................................................................................... 8
Ramp as per standards and with handrail. ................................................................................................................................ 8
Adequate landing space at the start and end of every ramp. ...................................................................................................... 8
Stair cases as per standards with handrails............................................................................................................................... 9
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/ audible
announcements. ................................................................................................................................................................................... 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

Page 1 of 13

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 written
information, 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 dont 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 of
platform 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.
Page 2 of 13

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 be
provided 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:

DRA OBSERVATION: While DRA has urged from 2011, the need to follow principles of
Universal Design, CMRLs commitment reassured that at least infrastructural
components of the service would be of a particular quality standard.
(One must point out here that Indias 1998 guidelines are outdated and myopic in their
focus on the built environment alone instead of the entire service continuum)
As DRAs preliminary access walkthrough indicates, these basic standards themselves
have been flouted.

[A] IN METRO STATIONS:

1. SIGNAGES WITHIN AND OUTSIDE THE STATION

Pictogram contrast insufficient,

made worse by excessive
reflectance / uneven lighting glare

Signs lit patchily, pictograms

are incompletely displayed

2. Dedicated parking space subject to space availability.

-

NIL
Page 3 of 13

3. NON SLIPPERY FLOORS AND WELL LIT PASSAGES .

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!

4. CONVENIENT DESIGN OF STATION STRUCTURE FOR FREE MOVEMENT .

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. Mirror
reflections and glare further confuse.
Page 4 of 13

5. D EDICATED TACTILE TILES TO ACCESS FOR THE FUNCTIONAL AREAS AND PLATFORMS.
Tactile walking surface indicators are available in fits and starts and are not available to guide people to
the toilets for example.
6. BUMPY TILES TO ALERT CUSTOMERS WHO ARE BLIND OR HAVE LOW VISION THAT THEY ARE NEARING THE EDGE OF
THE PLATFORM .
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.

The platform should

have one row of
dotted guiding blocks for persons with impaired vision, 800 mm. or more from the edge.
Page 5 of 13

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 ideally
dimensions 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 !

Very sharp edges on

grab rails are unsafe

Shoes removed as wet floor

offered no slip resistance
Page 6 of 13

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

COUNTERS, VENDING MACHINES Page 49

http://bit.ly/CpwdGuidelines

A 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
Page 7 of 13

9. D EDICATED AUTOMATIC FARE COLLECTION (AFC) GATES.

AFCs are much too high for people on wheelchairs Ummul on the left is shorter than Smitha who is
55 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.
10. INDUCTION LOOPS AT TICKET COUNTERS FOR HEARING IMPAIRED PASSENGERS.
The only induction loop spottedhigh 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.

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.
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.

Page 8 of 13

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 .

No colour contrast
on anti-skid nosing

15 risers instead of 12

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

www.bit.ly/CpwdGuidelines
16. Adequate seating arrangement in platform
- To be checked

[B] IN LIFTS:
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 .

Page 9 of 13

 Braille unevenly embossed

Unreachable from
wheelchair
Yellow flashing 'BUSY' light
w/o audio or tactile
equivalent
No pictogram for nonEnglish / cognitively
disabled
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

[C] COACHES:
GENERAL
1. D EDICATED SEATING FACILITIES IN THE TRAIN .

Note the strange location of the International accessibility sign tucked away near the ceiling like
something to be ashamed about!
Page 10 of 13

2. E ASY ACCESS TO THE CARS FOR PERSONS WITH DISABILITIES , INCLUDING WHEELCHAIR USERS , SHALL BE PROVIDED
THROUGH THE SIDE DOORS .

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 for
wheelchair users, it is a hazard for visually impaired
passengers who may walk straight into it while
boarding.
3. The rake shall be a high-floor design, with level boarding from platforms.

Page 11 of 13

(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.
4. Wheelchair and mobility-impaired boarding shall not require the use of
bridging or lifting devices.
5. The horizontal gap between the passenger door thresholds and platform
edge 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 and
platform 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 driver
car 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 wheelchair
parking position through either of at least two accessible doors (on the
same side of the train).

WHEELCHAIR EGRESS REQUEST

i. A wheelchair egress request signal shall be provided which shall permit a
passenger 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 inhibited
when 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

operators cab area.

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.

Page 12 of 13

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
CAUTION : VISUAL DESIGN
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.

Page 13 of 13