To.

Shri. Lalit Gupta,

Deputy Director General,
Office of the Director General of Civil Aviation,
Opp. Safdarjung Airport,
Aurobindo Marg, New Delhi 110 003
27th June 2016
Subject: Comments and Feedback on the Draft CAR 2016 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 in consequence of the Supreme Court ruling in
Jeeja Ghoshs case. We are happy that there has been such swift compliance with the ruling, at
the same time, we would note that even the revised CAR, the draft of which we had responded
to in July 2013, is still highly lacking. 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, as well as in our
submission to you on the earlier draft. We, the individuals and organizations named at the end
of this submission, 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 remain to be
incorporated in the CAR.
1. Definition/Scope of the CAR:
2. Procurement of standardized assistive devices: While the recommendation of the
Committee that all airports should procure all assistive equipment based on a schedule
of standardized equipment, and that the standardization should be done in consultation
with the Department of Disability Affairs, has been partially incorporated. The draft
CAR says at 4.2.9: The airport operator shall ensure that the assistive devices used to
assist a disabled passenger are as per the standards prescribed by the Ministry of Social
Justice and Empowerment. A time frame must be specified for the procurement on line
with the Committee recommendation.
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. In 4.4.9, 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.
This is a necessity as this would ensure a failsafe fully accessible means of
communication for persons with disabilities and also communicate specific needs to

airlines which may be unstated at the time of booking. The Draft CAR suggests a
helpdesk in 4.2.5 A provision of helpdesk to be made which will provide all necessary
information to assist a disabled passenger. Even so, the proviso to 4.1.1 seems to keep
some leeway so that in the event that a travel agent or a representative or on account
of any communication failure, the airline does not have a record of such a request, the
person with disability may be denied permission to board the flight. This cannot be the
case. 4.1.5 Note 2 applies only to emergency travel. 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.
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 in 4.1.7 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. For 4.1.8 Note 3 states that the acceptance of
automated wheelchairs/assistive devices using batteries shall be subject to the
application

of

relevant

regulations

concerning

dangerous

goods,

which

will

inconvenience passengers. 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: The draft CAR provides that (4.1.23) For the purpose of this
paragraph, their checked-in baggage should be given Assistive Device tags with tag
number bearing sign of assistive device to ensure early identification and delivery of the
same at ladder point or at the convenient point after exit. However, in light of the
Committee recommendations it must also be stressed that airline officials should never
insist on the checking in of assistive aids.
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 still 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, particularly persons who use prosthetic devices.
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, 4.1.9 only applies to wide-bodied aircrafts having more
than one aisle. In other circumstances, passengers with disabilities may still be treated in
a manner that is against their dignity and self respect. This is especially relevant in the
north-eastern parts of the Country where small aircraft and helicopters, since there is a
prevalence of small aircraft (18/12 seater) and helicopters to access interior parts of
North East. 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. The draft CAR in 4.2.13 permits charges to be levied for the use of the
ambulift as long as the same are notified. 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. Safety measures in 4.1.19 and
4.1.20 are not comprehensive enough.
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 their dignity.
12. Ticketing Systems and Websites: The CAR must mandate in 4.4.1 that airline, airport
and ticketing websites have to adhere specifically to the latest 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 and may require update from time
to time.
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 and not merely as has been done
in 4.5.5 to the Chief Commissioner for Persons with Disabilities/Commissioner for
Persons with Disabilities in concerned state.
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 behaviour and language of the officials is often very derogatory and
insulting. At no point these persons should use rough behaviour and discourteous
language when checking in or dealing with persons with disabilities. 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: With regard to the requirement of medical papers in 4.1.26,
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. This includes conditions mentioned in the para for instance, reliance on
oxygen or bipap machine. The recent experience of Faisal Nawaz is an example of how
the requirement of certification continues to cause inconvenience. The Government
Issued Disability Card is sufficient documentation for all purposes. In 4.1.18 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. Further, the abhorrent practice of airline companies insisting
on undertakings from passengers with disabilities forfeiting the right to demand any
damages from the airline in case of any accident etc., must be deemed illegal and even
the insistence on such an undertaking should be considered a breach in service.
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, and failure to provide
adjacent seating should be actionable. There should also be a mandate of reserving front
seats for persons with disabilities. Often persons with disabilities are forced to walk or
maneuver the length of the aircraft to be seated near the back toilets. Since there is
always a toilet in the front of the plane this is unnecessary. 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, the mandate for this replacement to be
free of cost is missing from 4.1.8.
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 caps
this at 15kg.
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 recall the suggestions made in the previous representation to make these additional
inclusions in the CAR.
1. Special Provisions in relation to frisking of passengers with disabilities including those
using various assisitve devices: 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 particularly those using prosthetics and
other devices, which is at Annexure A. A power point presentation to accompany this
is also available at Annexure B.
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 latest 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 C 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 D.
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
Equals Centre for Promotion of Social Justice
amba@equalscpsj.org
With inputs from:
1. Suranjana Ghosh, Mumbai
[ghosh.suranjana@gmail.com]
2. Rajesh Bhatia, Gurgaon
[bhatia.rajesh19@gmail.com]
3. Smiti Bhatia
[smiti_bhatia@hotmail.com]
4. Shivani Gupta,
Co-Founder, AccessAbility, New Delhi
[shewany@gmail.com]
5. Smitha S.S.
Disability Law Unit South, Vidya Sagar, Chennai
[dlu.south@gmail.com]
6. Prof. V.S. Sunder
The Institute of Mathematical Sciences, Chennai
[sunder@imsc.res.in]
7. Dipendra Manocha
Saksham Trust, New Delhi
[dipendra.manocha@gmail.com]
8. Anjlee Agarwal
Executive Director & Access Consultant, Samarthyam, Delhi
[samarthyaindia@yahoo.com]
9. Merry Barua
Founder Director, Action For Autism, New Delhi
[actionforautism@gmail.com]
10. Mohd. Faisal Nawaz
Activist, New Delhi

[faisalngo@gmail.com]
11. Dr. L. Govinda Rao,
Chairman & CEO,
Matrix Institute of Development Studies.
12. Lisa Beypi,
Disability Law Unit North East
Shishu Sarothi, Guwahati
[shishusarothi@gmail.com]

Annexure A

Nondiscrimination on the Basis of Disability in Air
Travel:
Screening Guidelines to be followed by
CISF Staff
for Passengers with Disabilities at Indian Airports

Total Pages: 34

Compiled by:
Rajesh Bhatia, Shivani Gupta, Smiti Bhatia and
Suranjana Ghosh Aikara
May 2014



70 million Indians have a disability.
On average, one out of every 10 travelers has some level of
disability. Not just major disabilities, but also the elderly and the
injured. This percentage is growing as the baby boomers are
aging.
India ratified CRPD, Convention on the Rights of Persons with
Disabilities, in 2007. By doing so, it recognized among other
things:
a) That discrimination against any person on the basis of disability is a
violation of the inherent dignity and worth of the human person;
b) The need to promote and protect the human rights of all persons
with disabilities, including those who require more intensive support;
c) The importance for persons with disabilities of their individual
autonomy and independence, including the freedom to make their own
choices,
d) Recognizing that children with disabilities should have full
enjoyment of all human rights and fundamental freedoms on an equal
basis.


An airport can be a stressful environment and poses
challenges for all travellers. Imagine encountering those
challenges with a disability --- now imagine how you can help
alleviate those challenges.
CISF personnel in charge of security screening at airports,
should ensure that passengers with disabilities have a positive
experience by being kind, courteous and knowledgeable.
The key to providing exemplary service is knowing how to
effectively interact with people with disabilities we will teach
you how.

Golden Rules for CISF Staff
Remember to pay emphasis and attention on the person, not
the disability.
People with disabilities are people first, people who happen
to have a disability.
Assist passengers with disabilities in a pleasant, helpful &
respectful manner.

Remember and Practice the following:

Everyone is a person first
Show respect for the individual
Be kind and courteous
Speak to the person, not their companion
Dont assume
Ask what you can do to help
Look for opportunities to assist
Listen and follow directions the best you can.
Be pleasant and helpful
Be Patient and Calm

Do not ask any personal questions

Go above and beyond to find solution to assist them
Bring them to the front of the line

In Section I, this manual covers Screening Techniques for

Travellers with the following Disabilities:

Use Wheelchair or Scooters
Cannot Remove Shoes
Have Metal Joint Implants
Have a Prosthetic device
Have a Cast, Brace, or Support Appliance
Have Autism or Intellectual Disabilities
Are Blind or Visually Impaired
Are Deaf or Hearing Impaired
Have Speech Impediments
Have Children with Disabilities
Need Dressings and bandages

In Section II, this manual covers Screening Techniques for

Travellers with the following Medical Conditions:
Have Internal Medical Devices
Need Medication
Have Medically Necessary Liquids
Have Medically Necessary Radioactive Substances
Use Portable Oxygen and have CPAPs, BiPAPs, and APAPs (Respiratory
Machines)
Use Nebulizers
Have Diabetes
Have Ostomies
Are Breast Cancer Survivors
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.


Section I: Travellers with Disabilities:
1. Screening of Passengers with Mobility Impairment
Use Wheelchair or Scooters
Use Mobility Devices like canes, crutches or braces
Have Metal Joint Implants like artificial knees or hips
Have a Cast, Brace, or Support Appliance
Have difficulty walking or standing
Cannot remove shoes
Passenger with any of the mobility impairment listed above should
inform the CISF officer before screening begins if he or she has:
Difficulty Walking or Standing including difficulty standing from the
wheelchair
Uses Mobility Devices like canes, crutches, braces or calipers
Has a Cast, Brace, or Support Appliance
Cannot Remove Shoes
Have Metal Joint Implants

Do's of Screening of Passengers with Mobility Impairment:

 Screen all such passengers with a thorough pat down process.

Screening be conducted in a private area with the CISF officer of the
same gender as that of the passenger.
Use ETD, Explosive Trace Detection to screen the passenger's wheelchair, scooter including the seat cushions and any non-removable
pouches or fanny packs. Any removable items be required to undergo
X-ray screening.
Passengers who intend to check-in with their own wheelchair 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.
If wheel-chair passenger is made/opts to use the airport provided
wheelchair, he/she should be allowed to keep wheelchair till the point
of boarding the aircraft and not be forced to shift between the
wheelchair and chairs to accommodate other passengers.
The passengers walker, crutch, cane, or other device must undergo
X-ray screening, unless it cannot fit through the X-ray. If an item
cannot fit through the X-ray, or the passenger cannot be separated
from the item, it must be inspected by an officer. The passenger should
tell the officer if he/she needs to be immediately reunited with the
device after it is screened by X-ray.



Passengers who cannot remove shoes be screened with a thorough
pat down process. Screening to be conducted with the CISF staff of the
same gender as that of the passenger. Use ETD to screen shoes.

Passengers who have metal implants such as artificial knees or hips,

should inform a CISF officer before screening begins. If a passenger
cannot or chooses not be screening by imaging technology/ETD or the
passenger alarms a walk-through metal detector, the passenger be
screened using a thorough pat-down procedure.
Passengers with cast, brace or calipers or supportive appliances
should be screened without removing them with a thorough pat down
process. Screening be conducted with the CISF staff of the same
gender as that of the passenger. Use ETD to screen cast, brace or
calipers.

Don'ts of Screening Passengers with Mobility Impairment

Do not force wheel chair users to stand from their wheel chairs
Do not attempt to manually lift the wheel chair user as this is against
his/her dignity and most of all it jeopardizes his/her safety
Under no circumstances should the passenger be asked to remove
cast, brace, calipers, metal implants or supportive alliances and even
shoes if the passenger cannot remove shoes.

Etiquette for Screening of Individuals with Mobility Devices

The CISF staff should be respectful of and courteous towards such
passengers
Speak directly to the person, not to a travel companion or assistant.

Should not ask any personal questions from them.

Should not make any disgraceful or humiliating comments to them.
Respect the passengers mobility equipment and handle with care.
Request permission before assisting.
Move around obstructions to create direct eye contact.
Try to be on same eye level, if possible.
When giving directions, consider weather conditions, time constraints,
distance and building level changes (ramps, stairs, etc.).
Persons that are newly or temporarily disabled may be more inclined
to accept assistance.

2. Screening of Passengers with Prosthetics
Passengers with prostheses (usually worn by patients with mobility
impairment) should be screened without removing them.
The passenger should inform the CISF Officer of the existence of a
prosthetic device or caliper, his or her ability, and of any need for
assistance before screening begins.
Passengers with prostheses should be screened using advanced
technological mechanisms such as Explosive Trace Detectors (ETD).
Airport Operators should be mandated to procure Explosive Trace

Detectors and other necessary equipment according to international

standards.
Upon production of the Government Disability ID Card (if available),
the security official should begin the specified screening process
ensuring discretion and privacy for the passenger.

Do's of Screening of Passengers with Prosthetics

If additional screening aside from ETD is required, 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 ETD.
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.

Don'ts of Screening of Passengers with Prosthetics
Under no circumstances should the passenger be asked to remove
his/her prosthesis.
Under no circumstances should the passenger be asked to strip to
remove prosthesis.
Under no circumstances should the passenger's prosthesis be put
through X-Ray machine.

Etiquette for Screening of Passengers with Prosthetics

The CISF staff should be respectful of and courteous towards such
passengers.
Request permission before assisting.
Speak directly to the person, not to a travel companion or assistant.
Should not ask any personal questions from them.
Should not make any disgraceful or humiliating comments to them.

3. Autism or Intellectual Disabilities
Passengers with intellectual disabilities or developmental disabilities,
such as Down Syndrome or autism, be screened without being
separated from their traveling companions.
The passenger or his or her traveling companions be allowed to offer
suggestions on the best way to approach and screen the passenger,
especially if it is necessary to touch him or her during screening.
The passenger be given the option of being screened using walkthrough metal detectors.
If the passenger declined this option, then he/she be screened using a
thorough pat down process instead.

Etiquette for Screening of Individuals with Developmental

Disabilities
Display a calm, patient attitude.
Act naturally and maintain eye contact.
Be considerate. Maintain or enhance self-esteem.
Focus on the person not the disability.
Avoid taking confrontational action or frightening the individual.

4. Are Blind or Visually Impaired

Passengers who are blind or visually impaired should notify a CISF
officer and inform him or her of the kind of assistance needed to
complete the screening process.
Passenger to be screened using ETD and a thorough pat down
procedure.
In addition to screening the passenger, canes and other devices like
Braille note takers must undergo X-ray screening, unless they cannot fit
through the X-ray. If an item cannot fit through the X-ray, or the
passenger cannot be separated from the item, it should be inspected by
an officer. Passengers should tell the officer if they need to be
immediately reunited with the device after it is screened by X-ray.

Etiquette for Screening of Blind or Visually Impaired
Introduce yourself as an Airport employee and give your name.
Address the person directly when starting a conversation.
Ask the person how you can best assist.
Be aware that a noisy environment might be a distraction.
Dont touch the person without asking permission.
Dont engage with a guide dog without permission. Remember, they
are working!
Be specific when giving directions, but do not point!
To assist with seating, you should ask permission to place his or her
hand on the back or arm of the chair.

To act as a Human Guide, offer your elbow for the person to take.
When faced with an obstruction, straighten your arm behind you so
the person knows to move in behind you.
When approaching steps or a slope, pause and explain whats ahead.
Ask if they would like to hold on to the handrail.
Keep in mind the importance and dignity of a cane.

5. Deaf or Hearing Impaired/Hard of Hearing Passengers
Passengers who are deaf or hard of hearing should notify a security
officer of any assistance needed or technology used, such as hearing
aids or cochlear implants, before screening begins.
Passengers be screened using walk-through metal detectors. If a
passenger cannot or chooses not to be screened by a walk-through
metal detector, the passenger be screened using a thorough pat down
procedure instead.
If a passenger who is deaf or hard of hearing uses hearing aids or a
cochlear implant, he or she be screened without removing the device.
Additional screening, including a patdown or inspection of a device,
may be required if it alarms a walk-through metal detector or appears
as an anomaly when screened by imaging technology. Devices may also
be subject to additional screening if they are X-rayed as part of the
passengers carry-on bags.

Etiquette for screening of Deaf or Hearing Impaired/Hard of
Hearing Passengers
Get the persons attention. The best method is to wave, but its also
okay to touch the person on the shoulder or back of the arm.
Determine the best method of communication.
Have a pen and paper handy.
Speak directly to the person.
Speak clearly and at a normal speed. Be patient.
If you need to speak loudly, do so for the entire conversation. Avoid
sounding harsh.
Provide a clear view of your face.

Body language and facial expression should match the message.

6. Have Speech Impediments/Cannot Speak Clearly
Passengers be screened by a walk-through metal detector and ETD.

If the passenger chooses not to be screened by a walk-through metal
detector, the passenger be screened using a thorough pat down
procedure instead.

Etiquette for screening of Individuals with Speech Difficulties

Listen, but if you have difficulty understanding, dont pretend you
understand. Be patient.
Repeat what you do understand for confirmation.

Ask person to spell, rephrase or write down the information. Have pen
and paper handy.
If possible, ask questions that require short answers or a nod or shake
of the head.
Maintain eye contact.
Move to a quieter location if necessary or possible.

7. Children With Medical Conditions, Mobility Aids Or
Disabilities
Parent/Guardian should inform the CISF Officer if the child has a
disability, medical condition or medical devices, and if they think the
child may become upset during the screening process. Welcome
suggestions from parent/guardian on how to best accomplish the
screening process to minimize any confusion for the child.

Parent/Guardian to tell Security Officer what the child's abilities are.
For example: whether the child can walk through the metal detector or
can be carried through the metal detector by the parent/guardian.

At no time should the Security Officer remove your child from

his/her mobility aid (wheelchair or scooter). The parent/guardian
should be responsible for removing his/her child from his/her
equipment, at parent's/guardian's discretion, to accomplish screening.

If the child is unable to walk or stand, the Security Officer should
conduct a pat-down search of your child while he/she remains in their
mobility aid, as well as a visual and physical inspection of their
equipment. Parent/guardian to remain with his/her child at all times,
and to can ask the child screened in private.

8. Passengers with Bandages and Dressings
If a passenger has dressings or bandages used to cover wounds from
an injury or surgical procedure, he or she should inform the CISF officer
of the location of the dressings and/or bandages and of any need for
assistance before screening begins.

Passengers with dressings or bandages can be screened using walk
through metal detector, ETD or a thorough pat down.

Section II: Travellers with Medical Conditions:

1. Travelers with Internal Medical Devices
If a passenger has an internal medical device, such as a pacemaker or
a defibrillator, it is important for him or her to inform the officer
conducting his or her screening before the screening process begins.

Do's of screening passengers who have internal medical

devices
They should be screened by a pat down process.

Don'ts of screening passengers who have internal medical

devices
They should not be screened by a metal detector as that could have a
harmful affect on their medical devices.

2. Passengers Needing Medication

Passengers should be allowed to bring medications in pill or other
solid form through security screening checkpoints in unlimited
amounts, as long as they are screened.
Passengers should inform officers of medications and separate them
from other belongings before screening begins.
Medication should be screened by X-ray; however, if a passenger does
not want a medication X-rayed, he or she may ask for an inspection
instead. This request must be made before screening begins.
The medication may be screened through ETD.

3. Medically Necessary Liquids

Medically required liquids, such as baby formula and food, breast milk
and medications be allowed in excess of 3.4 ounces in reasonable
quantities for the flight.
Liquids, gels, and aerosols be screened by X-ray and, medically
necessary items in excess of 3.4 ounces should receive additional
screening.
Accessories required to keep medically necessary liquids, gels, and
aerosols cool such as freezer packs or frozen gel packs be permitted

through the screening checkpoint and may be subject to additional

screening.
Supplies that are associated with medically necessary liquids and gels
such as IV bags, pumps and syringes be allowed through a
checkpoint once they have been screened by X-ray or inspection.

4. Passengers Who Have Undergone a Medical Treatment with

Radioactive Materials and Those with Radioactive
Medication
Such passengers be screened with a thorough pat down process or a walkthrough metal detector.
If a passenger has radioactive medication, it should be permitted
through a screening checkpoint once screened.

5. Portable Oxygen & Passengers with CPAPs, BiPAPs, and

APAPs (Respiratory Equipment)

If a passenger uses a portable oxygen concentrator, the manner in
which the passenger is screened should depend on whether he or she
can disconnect from the oxygen concentrator. Passengers should check
with their doctors to determine whether they can safely disconnect
during screening. It is important for a passenger to inform the officer
conducting the screening whether he or she can disconnect before the
screening process begins.
Passengers who can disconnect be screened with ETD or with a pat
down process.
If the passengers respiratory equipment cannot be disconnected, it
should be tested for traces of explosives. If explosive material is
detected, the passenger should be asked to undergo additional
screening.
All CPAPs, BiPAPs, and APAPs must be screened by X-ray. If the X-ray
cannot see through all parts of the CPAP, BiPAP, or APAP, additional
screening by X-ray or other methods may be required.
Passengers should be required to remove CPAPs, BiPAPs, and APAPs
from its carrying case, though facemasks and tubing can remain in the
case.

6. Passengers Using Nebulizers (Drug delivery devices used to
administer medication in the form of a mist inhaled into the
lungs).

Nebulizers should be allowed through CISF security checkpoints once
they have been screened.

A Nebulizer should be screened by x-ray, and passengers should be
required to remove their Nebulizer from its carrying case; facemasks
and tubing may remain in the case.

A passenger may provide a clear plastic bag in which to place the
Nebulizer during x-ray screening; however, a CISF officer may need to
remove it from the bag to test it for traces of explosives.

7. Passengers with Diabetes

Diabetes-related supplies, equipment, and medication, including
liquids, be allowed through the checkpoint once they have been
properly screened by X-ray or hand inspection.

Accessories required to keep medically necessary liquids, gels, and
aerosols cool such as freezer packs or frozen gel packs be subject to
additional screening.

Liquids, gels, and aerosols be screened by X-ray and medically
necessary items in excess of 3.4 ounces receive additional screening.

If a passenger uses an insulin pump, he or she must be screened
without disconnecting from the pump.

The passenger using the insulin pump to be screened by a thorough
pat down followed by an explosive trace detection sampling of the
hands.

The passengers insulin pump to be subject to additional screening.

8. Ostomies (Ostomy is a Surgical procedure that creates an

artificial opening for the elimination of bodily wastes)
Ostomy images:

If a passenger uses an ostomy, he or she be screened without having
to empty or expose the ostomy. However, it is important for passengers
to inform the officer conducting the screening about the ostomy before
the screening process begins.
Passengers with ostomies be screened using metal detector, or a
thorough patdown.
Regardless of whether the passenger is screened with a a walkthrough metal detector, the passengers ostomy be subject to
additional screening. Under most circumstances, this should include the
passenger conducting a self patdown of the ostomy, followed by an
explosive trace detection sampling of the hands.

9. Breast Cancer Survivors

CISF officers should make every effort to accommodate a persons
needs and to treat all such passengers with respect and dignity.
All such travelers must undergo security screening including with walk
through metal detectors, ETD or a thorough pat down procedure.

10. Have Difficulty Waiting in Line

There should be separate lanes at screening check points specifically
for use by passengers with disabilities and medical conditions or those
traveling with young children.
The passenger should inform the personnel overseeing the line that
he or she may have difficulty standing or waiting in line due to a
disability or medical condition before entering the line.
The CISF staff should courteously screen such passengers first and
foremost before they screen the rest.

Take the following quiz. If you do not get all of the questions
correct, please review that section again.
1. If possible, one should sit down when speaking with a person who
uses a wheelchair.
True
False
2. When talking with a person who is deaf and is accompanied by a
sign language interpreter, speak directly to the interpreter.
True
False
3. The first thing to do when greeting a person who is using a guide
dog is to kneel and pet the dog.
True
False
4. You should always have a pen and pad of paper available.
True
False



5. Asking a person with speech impairment to repeat themselves will
only make matters worse.
True
False
6. Only people who are legally blind may bring service dogs into the
Airport terminals.
True
False
7. If you are not sure how to assist a person with a disability, asking
them for advice will embarrass them. Just use your best judgment.
True
False
8. It is okay to touch the arm of a person who is deaf in order to get
their attention before speaking to them.
True
False


9. When giving directions to a person who uses a wheelchair, telling
them about distance and ramps puts unnecessary emphasis on their
disability.
True
False
10. When guiding a person who is blind, let them take your arm.
True
False

Answers
1. For an extended conversation, pull up a chair if convenient. It is also
okay to kneel on one knee.
True
2. Always talk with the person directly, not to a travel companion or
assistant.
False
3. Never engage with a guide dog without first asking permission.
Remember, they are working!
False


4. Absolutely! They can come in handy in a variety of scenarios.
True
5. Dont assume you know what the person is trying to say. Ask for
clarification.
False
6. Anyone with any disability may utilize a service animal.
False
7. The person with the disability knows best the method and degree of
assistance needed. Ask, then follow their direction.
False
8. The best method of getting the attention of a person who is deaf or
hard of hearing is to wave, but is also okay to touch or tap the shoulder
or back of the arm.
True
9. It is very helpful to persons who use wheelchairs to know distances,
level changes, and ramp locations. You should also consider weather
conditions and time constraints.
False
10. You should let the person know that you are to their right or left,
and announce that your elbow is extended for them to take.
True

Disclaimer: In order to keep the recommended guidelines in synch

with internationally followed screening practices for People with
Disabilities, this document has been put together with references
from:

1) The Transport Security Guidelines of the United States of America

(http://www.tsa.gov/traveler-information/travelers-disabilities-andmedical-conditions); and
2) Recommendations from representatives of various constituencies
of disabilities in India.

Refer to Power Point Presentation to view images of:

1) Common Types of Wheelchairs (Slide 10)
2) Common Types of Braces, Calipers and Casts (Slide 11)
3) Common Types of Mobility Devices (Slide 12)
4) Different Types of Prosthetic Limbs (Slide 14)

****THANK YOU****

Annexure B: Power Point presentation on the security protocol training (see

separate attachment to email).

Annexure C: 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

Annexure D: 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.

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.