A world for all

In 2013, when Parul Kumtha, principal architect at Nature Nurture Architects and Planners, was roped in by Arvind Prabhoo, founder of Access 4 All Foundation, to make Nasik more accessible, it came as a dream project for the Mumbai professional. The objective of the N.A.S.I.K. Project (Negotiating Accessible Spaces for Inclusion in a Keystone Project) was to provide universally designed, barrier-free and accessible spaces to everyone, regardless of age, ability and circumstance. "The question was, where do we begin?" says Kumtha. They decided to first target locations that saw heavy footfall, with the hope that this would have an osmotic effect, and spread little by little to the rest of the city. Inclusive design is based on the principle that designing for the widest range of people creates better designs and benefits everyone. Like most citizen-centric projects, this one too hit roadblocks. "As far as implementation goes, while some places like the Government Girls School could carry them out, many of the suggested interventions were possibly shelved due to various reasons," remembers Kumtha.

Nine years later, the discussion around universal design and equitable-use is back in the public domain.

Accessible toilet designed by Parul Kumtha's Nature Nurture Architects and Planners at Prabodhankar Thackeray Krida Sankul, Vile Parle

In December 2021, the Central Public Works Department (CPWD) released the Harmonised Guidelines and Standards for Universal Accessibility in India 2021 through its website. The guidelines are a revision of the Harmonised Guidelines (HG) and Space Standards for Barrier-Free Built Environment for Persons with Disabilities and Elderly Persons released by the CPWD, under the Ministry of Housing and Urban Affairs (MoHUA) in February 2016. Drafted by a team of the Indian Institute of Technology-Roorkee and the National Institute of Urban Affairs of the MoHUA, the revised guidelines aim to take a holistic approach. Disability rights activists, however, aren't impressed.

Several among them have raised concerns, and sought clarity from the government on which version will be applicable for auditing public buildings.

Parul Kumtha, Anjlee Agarwal and Gaurav Raheja

Anjlee Agarwal, executive director of Samarthyam, which has worked with NITI Aayog, government departments and state governments on accessibility, has written to the Social Justice and Empowerment Ministry highlighting the "flaws, non-conformity and discrepancies related to dimensions, tactile pavers, figures and illustrations" in the new guidelines. "There is a lack of connect between the standards mentioned in the 2016 document and the new one," observes Agarwal, whose company is accessibility auditor for the Prime Minister's office, ASI monuments and heritage sites. "Let's take handrail height on ramps, for example. It has been changed from 760 mm for short statured people and 900 mm for adults to 600-750mm and 900-1,000 mm. On what basis was this call taken? The 2016 guidelines were based on Indian anthropometrics and ergonomics. The upper level handrail on ramp is at 900-1,000 mm, while on steps, it is 900-1,100 mm. Is everyone six-feet tall?"

She argues that the average Indian man is 5.8 feet (177 cm), and woman is 5.3 feet (162 cm). "You must take an average or a median of these ergonomic proportions to create a solution according to universal design standards." Agarwal says her firm spent three years on research when they were roped in to co-author the Harmonised Guidelines 2016 and National Building Code 2016 to ensure accessibility standards in built environment. "Most government and private buildings follow the 2016 guidelines. Which means that what they have built in accordance with those measurements, is now obsolete. So the marginalised will be pushed further down the fringes," she says.

A field study being done by Samarthyam, which has worked with NITI Aayog, rates government departments and state governments on accessibility

While the earlier guidelines were drafted to create a barrier-free environment, the revised one makes universal accessibility its cornerstone, says professor Dr Gaurav Raheja of IIT-Roorkee, who was the principal investigator and consultant for the project. "We were roped in by the National Institute of Urban Affairs, so we had to submit a detailed proposal. Unfortunately, it happened during the pandemic, so a lot of the surveys and research had to be done online. Those were the limitations, but the intent was not to compromise on the outcome," says Dr Raheja. While making public buildings and transport fully accessible for wheelchair users is covered in the guidelines, Raheja says they have now taken into consideration other users who may experience temporary problems. "The guidelines are human-centric. The focus is on people. Segregated provisions serve to reinforce feelings of difference and deviance. We are saying, let's make the main entrance to a site or building accessible to all visitors, rather than having a separate entrance on the side for wheelchair users and pushchairs. In fact, a couple of months ago, when I was infected with the Coronavirus, I had no idea about its debilitating effect. It was a struggle for me to walk from one room to the next. What I mean is, it concerns all of us."

Dr Raheja adds that they have also tried to highlight not just what needs to be done, but also what should not be done. "You may have built a very nice building, but if it's flanked by flowerpots around the ramp, people will find it difficult to hold the hand rail. The shift is that we have authored the guidelines in a way that multiple audiences can read it while keeping it crisp. Hence, it's colourful and visual peppered with original drawings made by us."

For Dr Raheja, one big shift has been to make establishments accountable. It states the uncompromising minimal level that sectors will have to abide by. "In chapter six, there's a line that says: ‘It is reiterated that no new built forms shall be sanctioned for approval or occupancy without prior incorporation of accessibility standards and compliance with them.' It is a very strong statement. Tomorrow, if a person with a form of dependency finds that a built environment is discriminatory, s/he can produce this line in the court of law." But he is also aware of the criticism that the guidelines have generated. That they are not comprehensive enough and bus, railway coach, airplane, are barely covered is a common grouse, he adds. To which, he says: "Any building typology comes under a specific ministry. While an airport comes under the purview of the Civil Aviation Ministry, an AIMMS building will come under the Ministry of Health and Family Welfare. While I can provide suggestions [for accessibility], the implementation can happen only if those specific ministries take the initiative. It [guidelines] has to be tweaked to make it sector-specific."

Another evolution from the HG 2016 is a section titled Building Operation and Maintenance. "The buck shouldn't stop at designing alone. If those facilities aren't maintained, any good that you have done will become futile. Let's say, you make an accessible washroom, but if it's unclean, or kept locked after a certain hour, who will it benefit?" says Dr Raheja.

Kumtha believes any guidelines need to be reviewed as it's an evolving process. "Having applied the 2016 guidelines to architectural practice, it is amply evident that certain aspects should be added by way of review and revision. These include looking at universality in design for invisible disabilities like dyslexia, autism, gender identities and cultural practices like the use of tricycles by locomotor disabilities." Having worked closely with the MCGM on four major roads in K/East and K/West wards of Mumbai to create accessible pavements, she says such initiatives are dependent on the efforts of individuals and NGOs that work with affected stakeholders. "For change to be substantial, universal design needs to be mandated into the building and urban design bylaws. I hope the revised guidelines make that possible."