28 March 2019
The World Blind Union is encouraging national members to urgently intensify advocacy efforts towards delegates of International Civil Aviation Organization (ICAO) to address pressing issues affecting blind and partially sighted Air travellers. ICAO will be holding their 40th session in Montreal, Canada from 24 September to 4 October, 2019. WBU is therefore mobilizing its members to sensitize relevant state authorities in their respective countries to ensure that delegates present and approve a resolution to establish international regulations which address the following key issues:
(The member states and their associated ministries/delegate representatives can be found by following this URL: https://www.icao.int/Pages/Links.aspx?#Government)
Identified advocacy issues
- Accessibility of self-serve travel kiosks;
- Universal policies surrounding guide dogs and air travel;
- Accessible/usable websites and inflight entertainment systems.
Accessibility in UNCRPD
Article 9 of the UN Convention on the Rights of Persons with disabilities (UNCRPD) urges States Parties to take appropriate measures to ensure persons with disabilities access, on an equal basis with others, to the physical environment, to transportation, to information and communications, including information and communications technologies and systems, and to other facilities and services open or provided to the public, both in urban and in rural areas. State Parties are obliged to identify and eliminate obstacles and barriers.
In addition, the General Comment 2014 no. 2 of the UNCRPD reiterates that “as long as goods, products and services are open or provided to the public, they must be accessible to all, regardless of whether they are owned and/or provided by a public authority or a private enterprise” (para. 13).
The World Blind Union recognizes and emphasizes that these core principles are applicable in the area of tourism and air travel.
Advocacy issue 1. Self-serve kiosks at airports
International air travel has seen a rapid increase in digitalization and automation of customer services in the spirit of improved efficiency. Check-in counters are being replaced by self-serve kiosks where passengers enter booking details, check-in, select their seat, print boarding passes and luggage tags. Accessible self-serve kiosks have been introduced, but the interface is difficult to navigate as it requires excessive keystrokes, using a menu-based navigation protocol instead of the multi-tap interface adopted internationally for automated teller banking machines (ATMs).
WBU notes that many blind and partially sighted travelers are confident in independently navigating airport terminals. However, others prefer being assisted by visual guides. In line with the UNCRPD, the choice of the level of support must remain with the traveler.
In the absence of internationally acknowledged accessibility standards, the International Air Transport Association (IATA), has presented technical specification requirements for the accessibility of Self-serve kiosks. This initiative was done in their ambition to establish uniformity and common use of self-services. However, these are guidelines, not standards. They are neither legally binding nor have they undergone the rigorous process typically undertaken when standards are established. Furthermore, their implementation is voluntary with only a few exceptions; primarily, Canada, the United States and the European Union. Their additional weakness is that they were established without consultation with the disability community.
The World Blind Union is concerned that travel experiences of blind and partially sighted persons or any other disability may deteriorate if compliance with accessibility standards is not enforced. As reiterated in the CRPD General Comment 2014 no. 2 (para. 15) the strict application of universal design to all new goods, products, facilities, technologies and services should apply. Such application shall enable unrestricted chain of movement between spaces included inside particular spaces with no barriers. Universally designed self-serve kiosks accessible to blind and partially sighted persons should, in view of WBU, incorporate the following:
- Consistent interface design
- The ability to magnify text
- The ability to adjust contrast based on ambient lighting or a person’s sight capacity
- The ability to obtain audio feedback
- The ability to verify details
- The ability to navigate on-screen menus using screen magnification, audio or haptic feedback.
What should WBU member countries ask of their State authorities?
- To raise the issues of inaccessibility of self-serve kiosks today and the vitality of universal design for equitable access to products and services provided and open to the public.
- To advocate for ICAO to adopt Standards of accessibility of self-serve kiosks which reflect best practices on accessibility.
- To advocate that such standards incorporate and build onto the IATA Technical Specifications in consultation with blind and partially sighted persons’ organizations.
Advocacy issue 2: Guide dog policies
Airlines have recently begun to advance their policies on permitting service animals onto their aircrafts. The result is that travellers with guide dogs will face increased administrative hurdles when attempting to travel with their trained, certified guide dogs.
This has been done without consulting Guide dog handlers or organizations of blind and partially sighted persons resulting in confusion and stress among airline staff and guide dog handlers.
The World Blind Union is concerned that these policies, stringent restrictions and bureaucratic procedures imposed are disproportionately affecting the freedom of mobility and access to air travel for blind and partially sighted persons. Beyond mainstreaming accessibility for all, State Parties and private actors need to recognise that some persons with disabilities need human or animal assistance in order to enjoy full accessibility, and that banning trained guide dogs from entering public spaces constitutes to disability-based discrimination (CRPD General Comment no. 2, para 29).
WBU recognises that some of the major airlines operating out of countries where the anti-discrimination legislation is weak are still not allowing guide dogs to enter their carriers providing limited possibilities to seek legal redress.
What should WBU member countries ask of their State authorities?
- To encourage ICAO to publicly recognise guide dogs trained by organizations certified by the International Guide Dog Federation (IGDF) without additional requirements.
- To propose ICAO to encourage Member States to enforce requirements of acceptance onto national airlines currently prohibiting guide dog teams onto their carriers.
- That ICAO adopt a regulatory regime that will require international carriers to provide adequate space for a guide dog and their handler by providing an extra seat at no extra charge.
- To propose ICAO to issue a statement to its Member States recommending that any changes in definitions of and distinctions between guide dogs, service animals and emotional support animals affecting their rights to travel are done in consultation with guide dog handlers and organizations representing blind and partially sighted persons in the respective member state.
- That ICAO member states require that airport terminal buildings provide suitable relieving areas post security.
Advocacy issue 3: Accessible websites and inflight entertainment systems
Regarding accessibility and usability of booking and airline websites, the WBU notes that a growing number of airlines are adopting web technologies which fail to meet usability guidelines. Even though many of these websites may comply with international standards such as those set out by the World Wide Web Consortium, if not properly user tested with assistive technology, shopping for and completing online reservations, managing travel plans and reviewing associated documents can prove unnecessarily difficult.
The guidelines and standards as well as best practices on ensuring that websites are usable by visitors with sight loss are well established. Thus, evidence demonstrates that the usability of many international airline websites remains difficult if not impossible to operate using a screen reader or screen magnification software.
Regarding entertainment systems, the WBU is concerned about the increasing use of more technologically advanced inflight entertainment systems within aircrafts. These systems are mostly in the form of individual touch screen displays where the passenger can not only access movies, television programs, and radio, but also safety information, flight details and the Call button. These systems are creating barriers for our community who are unable to use touch screens to access significant information. Consistent with the UNCRPD accessibility principles, it is the standpoint of WBU that such systems must be accessible to all incorporating magnification and text-to-speech technologies.
What should WBU member countries ask of their State authorities?
- To advocate to ICAO to recognize and endorse the existing international standards for website and web content accessibility.
- To stress the importance of usability testing, where users relying on assistive devices to navigate websites are consulted.
- To demand accessible inflight entertainment systems for all passengers.
For further information, please contact:
Hannes Juhlin Lagrelius
Program officer, Accessibility in Smart Cities initiative
Hannes.lagrelius@wbu.ngo
+254 757 075 704