To.

Shri. Lalit Gupta,

Deputy Director General,
Office of the Director General of Civil Aviation,
Opp. Safdarjung Airport,
Aurobindo Marg, New Delhi 110 003
31st July, 2013
Subject: Comments and Feedback on the Draft CAR on Carriage by Air Persons with
Disability and/or Persons with Reduced Mobility
Sir,
We, the undersigned representatives of Disabled Peoples Organizations and Organizations
working for Persons with Disabilities working across the Country, have gone through the
Draft CAR which you have placed for public comment. Many of the DPOs and Organizations
working for Persons with Disabilities supporting this memorandum have in fact contributed
to the Asok Kumar Committee Report. As you are aware, the DGCA constituted the Asok
Kumar Committee in response to a vociferous communication on behalf of several groups
demanding that the Civil Aviation Policy cater to persons with disabilities in an improved
manner over that which is permitted under the present regulations. The Committee, under the
Chairmanship of Shri Asok Kumar, Joint Secretary, Ministry of Civil Aviation, also
empanelled several representatives of Disabled Peoples Organizations and Organizations
working for Persons with Disabilities working across the Country. The resultant report was in
consonance with the various stakeholders who were part of the Committee, which included
representatives of the DGCA, the Ministry of Civil Aviation, the Bureau of Civil Aviation
Security, Air India, two Private Airline Operators, the Airports Authority of India, and a
Private Airport Operator.
Despite this, however, there are glaring omissions from the Draft CAR, which has been
notified by you, which were particularly stressed on in the Committee Report. We would like
to highlight the same, as well as point out a few other aspects, which have not found place in
either document and we strongly feel that the same should be included in the final CAR.

Section A: Recommendations of the Asok Kumar Committee that need to be

incorporated in the CAR.
1. Definition/Scope of the CAR: while the Asok Kumar Committee Reports proposed
definition was accepted, the Draft CAR also incorporates the category of
incapacitated persons which should be removed and substituted with persons with
additional /specific support requirements.
The term physical or mental impairment is defined to include such diseases and
conditions as orthopedic, visual, speech, and hearing impairments; cerebral palsy,
epilepsy, muscular dystrophy, multiple sclerosis, cancer, heart disease, diabetes,
mental retardation, emotional illness, drug addiction, and alcoholism and it is to be
noted that autism has been excluded from this. This must be rectified to include
autism, and in the alternative, the definition proposed by the Committee must be
accepted in its entirety.
2. Procurement of standardized assistive devices: The Committee recommended that all
airports should procure all assistive equipment based on a schedule of standardized
equipments. The Committee recommended that the standardization should be done in
consultation with the Department of Disability Affairs in a suitable time frame. This
is not reflected in the draft CAR, which poses a problem because then there will be no
obligation to standardize assistive devices and ensure a minimum quality for the
same. Therefore, the Committee recommendations with regard to procurement of
standardized assistive devices must be accepted.
3. Internal Audit Systems: The Committee recommended that Airlines and airport
operators must have an internal audit system in place to ensure that assistive devices
are available and are in good condition and assistance and training are provided in an
adequate and proper manner. The Committee recommended that the DGCA would
oversee as the regulator. The draft CAR mandates surveillance of the operators by the
DCGA as part of Annual Surveillance Programme. The audit system must be an
internal one, on the lines of the Asok Kumar Committee recommendations, which can
be more frequent and detailed.
4. Helpdesk: The Committee recommended a telephonic help desk, which would be
fully accessible, to be set up to receive assistance requests in advance from passengers
with disabilities. Any request for on board assistance would be communicated to the
airline by the helpdesk. This is a necessity as this would ensure a failsafe and fully

accessible means of communication for persons with disabilities and also enable them
to communicate specific needs to airlines which may be unstated at the time of
booking. The Draft CAR removes this requirement completely, and the same must be
incorporated in the final CAR. The proviso to 4.1.1 leaves a loophole whereby if the
airline does not have a record of a request for assistance, on account of any internal
communication failure, the person with disability may be denied permission to board
the flight. This cannot be the case. Last minute accommodation of persons with
disabilities in 4.1.5 applies only to emergency travel. The bottom line is, airlines
must be always prepared to take a person with a disability on board, and so the 48
hour deadline for notification of requirements seems to indicate that airlines will not
be prepared otherwise if there is a time limit at all, it needs to be reduced.
Accordingly, amendments to the CAR must be made and the Helpdesk provision must
be incorporated.
5. Curbside Assistance Kiosks: The Committee mandates that curbside assistance kiosks
airport are to be set up by airport authority, providing live assistance and
intermediaries, including guides, readers and professional sign language interpreters
must be made at the curbside kiosks. These kiosks should be at the first point of
contact of the passenger and the airport premises. This may be at parking, in case the
passenger has his own transport, or at the drop-off points at the airport in case of hired
transportation. The airport must facilitate movement of persons with disabilities from
these areas to check-in counters by providing qualified/properly trained personnel and
necessary assistive aids/equipment. For this purpose the passenger will be required to
call the assistance kiosk in advance. This also provides for special provisions for
entering airports, for example, allowing auto rickshaws inside the airport where
barred, if plying a person with a disability. Similarly, for persons who are blind/are
visually impaired, getting from the drop off - point to the entry to the departure gate is
extremely difficult.
The draft CAR eliminates the curbside kiosk facility. The draft CAR states that Once
persons with disability or reduced mobility report at the airport with valid booking
and intention to travel, the airline shall provide assistance to meet their particular
needs and ensure their seamless travel from the departure terminal of the departing
airport upto the aircraft and at the end of the journey from the aircraft to the arrival
terminal exit, without any additional expenses. This seems to indicate that the CAR

does not cover entry into and exit from the larger airport premises, which is severely
problematic and must be amended to reflect the intention of the Committee.
6. Wheelchair usage: While the Committee Report retains the right of passengers with
disabilities to use their mode of assistance throughout their journey, the CAR places
several restrictions on the same. Passengers who intend to check-in with their own
wheelchair are to be given the option of using a station/airport wheelchair. If the
passengers prefer to use their own wheelchair, they shall be permitted to use it
provided the wheelchair conforms to specifications as laid down by Disabled Persons
Transport Advisory Committee (DPTAC), UK. The CAR also states that acceptance
of automated wheelchairs/assistive devices using batteries shall be subject to the
application of relevant regulations concerning dangerous goods, which will
inconvenience passengers. Instead, the CAR must lay down the protocol for traveling
with wheelchairs and storage of the same, with batteries being removed/kept safely
depending on whether they are dry or wet cell batteries. The BCAS website must
include the rules concerning carrying of battery-operated personal wheel-chairs or
other assistive devices/aids to avoid ambiguity.
In any event, if passengers are made/opt to use the airport provided wheelchair, they
should be allowed to keep wheelchairs till the point of boarding the aircraft and not be
forced to shift between the wheelchair and chairs to accommodate other passengers.
To that end, an adequate number of wheelchairs must be procured.
Also, it should not be the case that a person who is using a wheelchair, who is
accompanied by an escort, cannot use airport assistance to push his or her wheelchair.
It should not be obligatory on the part of the escort to take over the responsibility of
the airport assistance staff.
7. Checking in assistive aids: While airlines should never insist on assistive aids and
devices being checked in, in the event that assistive aids are to be checked in, the
Committee recommended that certain safeguards be in place e.g the use of Priority
tags, barring the transport of assistive aids/equipment by conveyor belt, prioritizing
the loading and unloading of assistive aids/equipment. These guidelines are
completely missing from the draft CAR.
8. Security Check - Responsibility of CISF: The Committee Report, in Annexure 4,
details the manner in which security checks should be handled by the CISF, from the
training of screeners to the protocols they should employ. The manner in which
passengers on wheelchairs, passengers who are blind/ have low vision, passengers

with hearing impairments and those with hidden disabilities are to be managed is
detailed. This detail is lacking in the draft CAR, and it is quite surprising because it is
at the stage of security checks that most trouble is caused to persons with disabilities
and there are violations of their dignity.
9. Transfer to aircraft: The Committee clearly demarcates the separation of
responsibilities between the Airport and the Airlines, and that the Airport is
responsible for placing the passenger in the aircraft and disembarking the passenger
as well. On board, the responsibility is solely with the Airline. With regard to
boarding and disembarking, the Committee Report mandates that Airports have
appropriate boarding ramps, ambulifts, aerobridge, boarding-aisle chair, wheelchairs
or other assistance needed, as appropriate. The Committee Report stresses that no
passenger shall be manually lifted. In the draft CAR, the onus is on airlines and they
are only required to have provision of onboard aisle wheelchairs for persons with
disability or reduced mobility not carried on stretchers, wherever possible subject to
limitations of aircraft. This leaves scope for passengers with disabilities being treated
in a manner that is against their dignity and self respect. This must be removed.
Airports must be responsible for procuring assistive aids and devices to ensure hassle
free boarding and disembarking from the aircraft.
10. Ambulift: Presently, ambulifts are procured by airports and airlines are asked to pay
ambulift charges every time they use it, and so it is advisable that they be charged a
sum amount for a month whether they use it or not. By this every airline will be made
to use the service for its disabled passengers rather than not use it for want of extra
payment for each use. Also the ambulift and other equipment shall be maintained in
good condition with periodic monitoring and it should be registered in record about
maintenance details, repair details, duration under maintenance / repair, dates,
duration and number of times for which service was unavailable to passenger. The
Complaints Resolution Officer should also monitor the register.
11. On Board the Aircraft: The Committee Report mandates that for the benefit of
passengers with disabilities, Communication of essential information concerning a
flight should be in accessible formats. Safety videos should be available in sign
language and with subtitles. In flight entertainment must be in accessible formats, and
cabin crew should assist passenger to access toilet if requested using onboard aisle
chair. Further, Aisle chairs should be mandated to be carried on board for flights

longer than 3 hours. These provisions do not find mention in the CAR, and they are
most essential to ensure the safety and comfort of passengers with disabilities.
On board airlines which serve meals, or where paid meals have been requested for in
advance by a passenger with a disability, the same will be served with cutlery which
is universally designed so as to allow for the passenger to eat unassisted as far as
possible. In cases where the passenger is unable to eat on his own, the crew will assist
in feeding the passenger in a manner which does not impinge upon his dignity.
12. Ticketing Systems and Websites: The draft CAR does not, unlike the Committee
Report, mandate that airline, airport and ticketing websites have to adhere specifically
to

W3C

web

accessibility

standards

(available

at

http://www.w3.org/WAI/intro/wcag.php). The same must be mandated as it is the

global standard in accessibility.
13. Complaint Mechanism: In case of deficiency of service relating to persons with
disabilities, the Committee Report details a procedure which begins from the
Complaints Resolution Officer (CRO), who is placed at the Airport itself, who will
make attempts to resolve the grievance, and if the same fails, he is mandated to assist
the passenger in making a complaint to the Ombudsman appointed under the DGCA.
In the draft CAR, the complaint mechanisms places the sole burden on the passenger
to file the Complaint before the Nodal Officer, and there is no accessible means of
complaint mechanisms and neither is there any obligation on any authority to try and
resolve the matter at the first stage. The draft CAR must incorporate the Complaint
redressal mechanism as suggested under the Committee Report.
14. Accessibility, wayfinding and signage: The Committee Report has detailed the
manner and extent to which Universal Design must be adopted by Airports in their
infrastructure. It is important that the same be designed in accordance with the
principles of Universal Design which have been detailed in Annexure 3 of the
Committee Report. While the same has been mentioned in the draft CAR, the
provisions are not as comprehensive as that of the Committee Report. The draft CAR
must expand the same.
15. Seating Areas: The Committee Report deals with the importance of designated
seating areas and their positioning and signage for the benefit of passengers with
disabilities. Aircraft and airport staff should be able to identify these areas and
provide regular updates to persons with disabilities seated in these areas on the status
of their flights and enquire about their needs. Further, seating areas should allow for

resting accommodation, where persons with severe dysfunction / disabling medical

conditions could lie down and rest/stretch/straighten themselves. There is no such
emphasis in the Draft CAR, which is silent on the specific issue of seating.
16. Service Animals: While the general concerns relating to service animals and their
ability to travel with the person they are assisting have been addressed in the
document, the question of relieving areas for the Service Animals, which has been
detailed in the Committee Report, has not been dealt with in the Draft CAR.
17. Training and Sensitization: Annexure 2 of the Committee Report has detailed
provisions relating to training and sensitization of all personnel working dealing with
the traveling public at various levels in the airports and airlines. The disability
sensitivity extended to needs of all types of disabilities, especially those which are not
given much importance in the mainstream, like psychosocial disabilities and autism.
However, the Draft CAR restricts this extensive training programme to staff of
Airlines and Airport Operating Staff only, and not to Governmental Agencies who
come into contacts with passengers like Security Personnel, Immigration Officers,
and Customs Officers, to name a few. Best practices shall also include training of all
officials at airport and airlines functioning within the airport to undergo periodical
orientation on perspective to disability rights and dignified ways of handling persons
with disabilities and not just the security personnel alone. The orientation can be part
of their periodic internal review meetings.
18. Accessible Airport Infrastructure: It is essential that the needs for accessible and
universally designed Airport Infrastructure are met by Airport Operators. To this end,
the Committee Report detailed an extensive Annexure viz. Annexure 3 with each and
every requirement. Not only is this not reflected in the Draft CAR, but no standards of
any sort are mentioned. Nor is there any requirement specified that persons with
disabilities or universal design experts would be consulted in the design aspects of
Airports. This is a major shortcoming of the Draft CAR.
19. Offloading of Passengers: While the Draft CAR seems to be clear on the question of
medical papers, the exact grounds on which medical clearance is required by
passengers and the medical grounds on which a passenger can be refused travel or
offloaded is not clarified. Under no circumstances can persons with disabilities be
asked to provide medical clearance papers if they have no other ailment or medical
condition which would hinder their ability to fly. The Government Issued Disability
Card is sufficient documentation for all purposes. There is some ambiguity with

regard to a pilots discretion in offloading passengers which requires to be clarified as

well and this discretion cannot extend to evicting persons with disabilities off a flight.
20. Seating versus Safety: The Committee Report has dealt with this issue in detail, and
laid down the important guidelines in seating of persons with disabilities to ensure the
greatest emphasis on safety of the person with disability as also the fellow passengers.
The Draft CAR does not reflect the importance of this issue. The placing of the
escort/companion of the person with disability and the person with disability should
be mandated and not give the loophole of all reasonable efforts. There should also
be a mandate of reserving front seats for persons with disabilities. The additional
priority to not discomforting persons with disability or reduced mobility while
considering decisions relating to offloading passengers is appreciated.
21. Temporary replace of damaged wheelchairs:

While the Committee Report

categorically states that temporary replacement wheelchairs must be provided to

passengers on a like-for-like basis as far as possible, free of cost, in the Draft CAR the
provision is modified to state that in the event a passengers wheelchair is damaged,
temporary substitute shall be provided on request. The term on request needs to be
removed. Also, the mandate for this replacement to be free of cost is missing.
22. Guidelines relating to the maximum permissible weight and dimensions of assistive
aids/equipment to carried: The Committee Report specifically deals with this issue
and prescribes that irrespective of the weight and dimensions of assistive
aids/equipment they should be allowed to be checked in free of cost. It is important
that the permissible weight is high enough such that motorized wheel chairs and
mobility scooters can be checked-in free of cost. All assistive aids/equipment that can
fit in the internal storage space shall be allowed to be taken on board. Other than for
takeoff and landing, the assistive aids shall be made available for the passenger on
request. The Draft CAR does not deal with this issue at all.
23. Priority in using toilet facilities in aircraft: The Committee Report specifies that
persons with disabilities must be given priority to access toilets on the aircraft. The
Draft CAR is silent on this.
24. Priority check-in counters: The Committee Report specifies that airlines shall operate
priority check-in counters for those persons with disabilities who require quick checkin. The Draft CAR is silent on this.
Section B: New recommendations to be incorporated.

In light of several concerns raised by persons with prosthetic limbs, who have been subjected
to undignified and unnecessary methods while passing through security checks, we feel
necessary to prevail upon the Ministry to make these additional inclusions in the CAR.
1. Special Provisions in relation to passengers with prosthetics: Several persons using
prosthetics have shared instances of degrading treatment being meted out to them on
account of a lack of training, technology and sensitivity on the part of security staff.
Three members of this community viz. Suranjana Ghosh, Rajesh Bhatia, and Smiti
Bhatia, have suggested a detailed protocol for persons with disabilities using
prosthetic devices, which is at Annexure A.
2. Special provisions in relation to parking facilities: The reserved parking facility shall
provide access to any kind of vehicle that a person with disability travels by and not
just cars. Eg: vans, motor cycles with extra wheels, auto rickshaws, etc, and a
curbside assistance kiosk must be available at these parking areas.
3. Passenger awareness about security protocol: Along with information on assistance
provided by airport operators and airlines to persons with disabilities, on their
respective websites, the Bureau of Civil Aviation Security must also be made fully
accessible, in line with the W3C Web accessibility guidelines. The BCAS website
must have a page, which is easily locatable, to enumerate the safety procedures for
persons with various disabilities, and what to expect. The categories of persons whose
needs should be covered are at Annexure B this is by no means an exhaustive list.
The rights of travellers with disabilities and medical conditions on the BCAS web site
must be underlined, and all efforts must be made towards a zero tolerance policy for
any form of their harassment, discrimination and infringement of their privacy,
dignity, respect and human rights.
4. Addition to Annexure 4 of the Committee Report on Security Procedures:
In addition to the suggestions made in Annexure 4 of the Committee Report in
relation to Security Procedures, there are other suggested best practices which can be
incorporated which have been included in Annexure C.
We sincerely hope that you will take cognizance of our requests and recognize the
importance and the suitability of the extensive work put into the Asok Kumar Committee
Report. We eagerly await your response on this issue.
Thanking you,

Prepared by:
Amba Salelkar
Inclusive Planet Centre for Disability Law and Policy
With inputs from:
1. Anjlee Agarwal
Executive Director & Access Consultant, Samarthyam, Delhi
[samarthyaindia@yahoo.com]
2. Dipendra Manocha
Saksham Trust, New Delhi
[dipendra.manocha@gmail.com]
3. Merry Barua
Founder Director, Action For Autism, New Delhi
[actionforautism@gmail.com]
4. Rajesh Bhatia, Gurgaon
[bhatia.rajesh19@gmail.com]
5. Shivani Gupta,
Co-Founder, AccessAbility, New Delhi
[shewany@gmail.com]
6. Smiti Bhatia
[smiti_bhatia@hotmail.com]
7. Smitha S.S.
Disability Law Unit South, Vidya Sagar, Chennai
[dlu.south@gmail.com]
8. Suranjana Ghosh, Mumbai
[ghosh.suranjana@gmail.com]
9. Prof. V.S. Sunder
The Institute of Mathematical Sciences, Chennai
[sunder@imsc.res.in]
Supported by:
1. AccessAbility, New Delhi
[www.accessability.co.in]

10

2. Action for Autism, New Delhi

[www.autism-india.org]
3. Andhjan Kalyan Trust, Rajkot
[http://www.aktrust.org]
4. Prof. Anita Ghai, Associate Professor, Jesus and Mary College, New Delhi
[anita.satyapal@gmail.com]
5. Disability Law Unit South, Vidya Sagar, Chennai
[www.vidyasagar.co.in]
6. Human Rights Law Network, New Delhi
[www.hrln.org]
7. Inclusive Planet Centre for Disability Law and Policy, Chennai
[www.inclusiveplanet.org.in]
8. National Platform for the Rights of the Disabled, New Delhi
[nprd.in@gmail.com]
9. Saksham Trust, New Delhi
[www.saksham.org]
10. Samarthyam, New Delhi
[www.samarthyam.org]
11. Trinayani, Mumbai
[trinayani.org]
12. Xaviers Resource Centre for the Visually Challenged, Mumbai
[www.xrcvc.org]

11

Annexure A: Security Guidelines in relation to persons with prosthetic limbs

1. Passengers with prostheses or caliper (usually worn by patients with mobility
impairment) can be screened without removing them.
2. Under no circumstances should travellers wearing prostheses be asked to remove it &
made to put the prosthetic device into the x-ray scanner that is used to scan hand
baggage.
3. Passengers

with

prostheses

should

be

screened

using

advanced

technological mechanisms such as Explosive Trace Detectors (ETD), metal detector,

imaging technology and/or a thorough pat down, based upon their abilities. Airport
Operators will be mandated to procure Explosive Trace Detectors and other necessary
equipment according to international standards.
4. The passenger should inform the Security Officer of the existence of a prosthetic
device or caliper, his or her ability, and of any need for assistance before screening
begins.
5. Upon production of the Government Disability ID Card, the security official will
begin the specified screening process ensuring discretion and privacy for the
passenger.
6. Regardless of whether a passenger is screened by a metal detector, imaging
technology, Explosive Trace Detectors (ETD), or a thorough pat down, a prosthetic
can be subject to additional screening if deemed necessary by the Security Official,
provided that an officer of the same gender as the passenger will need to see the
prosthetic, which may require the lifting of clothing without exposing any sensitive
areas or indecent exposure or removing a belt that secures the prosthetic device to the
passengers body. This prociedure will always take place in a closed private room or
setting. In cases where the person with disability is accompanied by an escort, under
no circumstances, shall the escort be asked / demanded to move away from the person
except when the concerned person with disability wants so.
7. If any trace of explosive material is detected, the passenger will have to undergo
additional screening.
8. If a passenger cannot or chooses not to be screened by imaging technology or a walkthrough metal detector, the passenger should be screened using a thorough physical
pat-down procedure instead. A physical pat-down procedure should be used to resolve
any alarms of a metal detector or anomalies identified by imaging technology.

12

9. If a physical pat-down is required in order to complete screening, the following points

should be considered:
a. The pat-down should be conducted by an officer of the same gender. The
passenger can request a private screening at any time and a private screening
should be offered when the officer must pat-down sensitive areas. During a
private screening, another CISF employee of the same gender as the passenger
should also be present and the passenger may be accompanied by a companion
of his or her choosing.
b. A passenger may ask for a chair if he or she needs to sit down.
c. A passenger should be given the right to inform an officer before the pat-down
begins, of any difficulty in raising his or her arms, remaining in the position
required for a pat-down, or any areas of the body that are painful when
touched.
d. A passenger should not be asked to remove or lift any article of clothing to
reveal a sensitive body area.
10. Bureau of Civil Aviation Security shall document a Standard Operating Procedure to
be followed by the security staff deployed at all Airports in India, on screening of
people who are amputees and wear prostheses. The document should, inter-alia,
specify the following:
a. A document listing the steps to be followed for screening passengers using
prostheses should be readily available with security personnel deputed at all
airports.
b. All security personnel, irrespective of rank, should undergo periodic trainings
(at least once in every quarter) on the security procedures that need be
followed for screening passengers wearing prostheses. An annual training
calendar should be available for imparting first time/re-enforcement training to
these personnel.
c. Manufacturers of prostheses like Ottobock, Endolite etc, who have a pan India
presence should be engaged by Bureau of Civil Aviation to give a firsthand
feel of different types of prosthesis and the parts used in them. The frequency
of the training should be at least once in every quarter.

13

Annexure B: Groups for which special instructions must be specified on the BCAS
website (reference can be made to http://www.tsa.gov/traveler-information/travelersdisabilities-and-medical-conditions)

Have Difficulty Walking or Standing

Uses Wheelchair or Scooters

Cannot Remove Shoes

Have Metal Joint Implants

Have Internal Medical Devices

Needs Medication

Have Medically Necessary Liquids

Have Medically Necessary Radioactive Substances

Use Portable Oxygen

Have CPAPs, BiPAPs, and APAPs

Use Nebulizers

Have Diabetes

Have Ostomies

Have an External Medical Device

Are Breast Cancer Survivors

Have Children with Disabilities

Have Autism or Intellectual Disabilities

Are Blind or Visually Impaired

Use Service Dogs

Have a Prosthetic device

Have a Cast, Brace, or Support Appliance

Have Difficulty Being Touched

Need Dressings and bandages

Are Deaf or Hearing Impaired

Have Difficulty Waiting in Line

Those who want to wear gloves, socks, scarf or facial / nasal mask and cannot remove
due to their sensitivity to external temperature like cold, air condition, smoke, etc

14

Annexure C: Additions to Annexure 4 of the Committee Report

a) The Security Officials should be trained in the identification of various
notification cards for persons with disabilities and medical conditions and how
to ascertain the genuineness of the same. They should be trained to accept
these cards and proceed with the security protocol accordingly.
b) The Security screening process drawn up by the Board of Civil Aviation
Security must be vetted by the DCGA and ensure that it complies with all
applicable civil liberties and civil rights laws, regulations and policies and do
not discriminate against travellers on the basis of disability. The protocol must
be drawn up in consonance with persons with disabilities through a dialogue
wherein the concerns of both parties are addressed.
c) The BCAS must create an internal disciplinary mechanism whereby its
officials can be held accountable for any violation of the civil rights of
travelers with disabilities and medical conditions. The Complaints Resolution
Officer, under the Committee recommendations, should assist the aggrieved
passenger in clarifying the protocol with the Security Officers, as well as
helping the aggrieved passenger file a Complaint in the BCAS internal
disciplinary mechanism.
d) Internal audit reports should be made public and hosted on the website of
BCAS. As a follow up, the BCAS should also host a Corrective & Preventive
Action Report (CAPA) on the deficiencies noted during the internal audit
review on their website along with timelines.
e) Along with the website, the BCAS must also maintain a separate helpline
pertaining to information on security checks. The helpline should be available
365 days from at least 9:00 am until 9:00 pm IST, every single day of the
week to answer any questions of travellers with disabilities and medical
conditions and their loved ones who want to prepare for screening process
before flying.
f) Passengers with orthotic aids shall not be instructed to remove their aids or
outfit under any circumstances unless preliminary testing shows the presence
of explosive materials.

15

g) As and when a deaf/hearing-impaired person is to be searched, the Security

Officer will call for a sign language interpreter facility.
h) Best practices should ensure there is a private screened area in close proximity
to main security screening area to make private screening convenient for the
persons with disabilities, without any open sections like roofs or doors for a
close scrutiny check.

16