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Feedback on Revision of Manual on Policies and Procedures for Purchase of Goods (30th September 2016)

India is home to over 70- 100 million persons with disabilities. The United Nations Convention for Persons with Disabilities (UNCRPD) to which India is a signatory mandates:

  1. Respect for inherent dignity, individual autonomy including the freedom to make one’s own choices, and independence of persons;
  2. Non-discrimination;
  3. Full and effective participation and inclusion in society;
  4. Respect for difference and acceptance of persons with disabilities as part of human diversity and humanity;
  5. Equality of opportunity;
  6. Accessibility;
  7. Equality between men and women;
  8. Respect for the evolving capacities of children with disabilities and respect for the right of children with disabilities to preserve their identities.

The same is mandated across all sections of the Disability Act, 1995. Yet, education, employment, equality and nondiscrimination cannot achievedunless products and services are made accessible for this group. Accessibility here extends beyond the built environment, ICT to also other products, services that are used by persons with disabilities and also procured by the Government.

Disabled people and the elderly form a formidable end user group too and ensuring accessibility now makes for business and ethical sense.

Accessibility standards hence need to be incorporated in our Procurement Policy to ensure inclusion of accessibility as a rule and not exception to the rule. Global accessibility standards adopted by other countries and Governments are easily available and can be used as a reference to ensure inclusion of accessibility across all provisions of the Manual on Policies and Procedures for Purchase of Goods. It is important to remember that people with disabilities form an equal part of the ‘vulnerable sections’ of society often cutting across gender, caste etc. hence their representation needs to be ensured whether granting purchase preferences to representation in the procurement committees. All products and services must necessarily incorporate the principle of Universal Design and all information related to purchase procedures and the portals and websites announcing the same be in accessible formats, adhering to the provisions of the WCAG 2.0, Web Access Guidelines.

Suggested feedback on draft Manual on Policies and Procedures for Purchase of Goods
Para No and Page Number Provision in Manual on Policies and Provisions of Goods Proposed Changes Justifications and Reasons for
Suggestions/ Comments
Point 7 Para 1.10.4 Page 12 Within this 20% quantity, a purchase preference of 4 per cent (that is, 20 per cent out of 20 per cent) is reserved for MSEs owned by Scheduled Caste (SC)/ Scheduled Tribe (ST) entrepreneurs Owned by SC/ST entrepreneurs and entrepreneurs with disability and /or from suppliers/ MSMEs where a minimum of 5% of the total workforce constitutes persons with disabilities People with disability occupy the same space among vulnerable groups and the same benefits should be extended to them too
Point 8 Para 1.10.4 Page 14 For enhancing participation of MSEs owned by SCs /STs in Government procurement, Central Government Ministries /Departments /PSUs may conduct Special Vendor Development
Programmes /Buyer-Seller Meets.
SCs/STs/ People with disabilities as above
Para 1.10.5 Page 15 Additionally, such products shall meet the criterion of specified domestic value addition (on a self -certification basis) as laid down in the policies, issued vide various notifications, for being classified as DMEP. Additionally, such products shall meet the criterion of specified domestic value addition (on a self -certification basis) as laid down in the policies, and also adhere to principles of Universal design and accessibility issued vide various notifications, for being classified as DMEP. Universal Design needs to be incorporated as a mandatory stipulation across all Domestically Manufactured Electronics Products (DMEP)
Para 2.1.1 Page 18 The expression/description of the needkeeping in view the Value for Money and to ensure wide competition. Therefore to the extent practicable it should be:
  1. Unambiguous, complete, using common terminology prevalent in relevant trade;
  2. In accordance with the guidelines prescribed if any in this regard;
Value for Money, Universal Accessibility and Usability and to ensure wide competition Accessibility features are used by groups beyond those with disability. Hence Accessibility needs to be mandated in all needs assessments across products and services
Point j Para 2.2.1 page 22 Should have emphasis on factors such as efficiency, optimum fuel/power consumption, use of environmental-friendly materials, reduced noise and emission levels, low maintenance cost, and so on. Should have emphasis on factors such as efficiency, universal accessibility optimum fuel/power consumption, use of environmental-friendly materials, reduced noise and emission levels, low maintenance cost, and so on. As above
Point 2 Para 2.2.2 Page 24 All essential technical, qualitative, functional and performance characteristics and requirements (such as material composition, physical, dimensions and tolerances,
workmanship and manufacturing process wherever applicable; test schedule; if any),
All essential technical, qualitative, functional and performance characteristics and requirements (such as accessibility and usability, material composition, physical, dimensions and tolerances, workmanship and manufacturing process wherever applicable; test schedule; if any), As above
Para 2.4.2 Page 27 The procuring entity may publish information regarding the planned procurement activities for the forthcoming year or years on the central public procurement portal and website/
eProcurement portal used by the procuring entity
The procuring entity may publish information regarding the planned procurement activities for the forthcoming year or years on the central public procurement portal and website/
eProcurement portal, compliant with Web Access Guidelines (WCAG 2.0). used by the procuring entity
For information accessibility
Point f (a) Para 3.3.8 Page 36 Any firm, situated in India or abroad, which is in the business of providing
goods/works/services, of specified categories of interest, shall be eligible for
registration;
Any firm, situated in India or abroad, which is in the business of providing
goods/works/services, in keeping with principles of Universal Design of specified categories of interest, shall be eligible for
registration;
For increased usage esp for people with disabilities and the elderly
Para 4.1 Page 46 The various modes of procurement that can be used in public procurement are: The various modes of procurement, necessarily to be in accessible formats, that can be used in public procurement are: Information accessibility
Para 4.11.2 Page 60 The composition of SPC (usually three members) would be decided by HOD or as indicated in SoPP; The composition of SPC (usually three members, with at least one person with disability) would be decided by HOD or as indicated in SoPP; Ensure representation and expertise
Para 4.15.3 page 67 Invitation of EoI Tenders Tenders, advertisements and submission formats all to be in accessible formats. Guidelines to be developed to explain the same. Information accessibility
Para 4.16 Page 69 National Informatics Centre (NIC) has an e-Procurement portal called Government eProcurement of NIC (GePNIC). There are other service providers in Public
Sector (e.g. MSTC) and Private sector which can be utilized for e-Procurement
National Informatics Centre (NIC) has an e-Procurement portal called Government eProcurement of NIC (GePNIC). There are other service providers in Public
Sector (e.g. MSTC) and Private sector which can be utilized for e-Procurement and all of these should accessible for people with disabilities
Information accessibility
Para 4.18.2 Page 71 DGS&D has developed an online Government e-Market Place for common use goods and services. DGS&D has developed an online Government e-Market Place for common use goods and services and the same should accessible for people with disabilities Information accessibility
Para 4.18.7 Page 72 Full Fledge Version of GeM:DGS&D will float an RFP for selection of the Managed Service Provider (MSP). The MSP will develop the full-fledged GeM which will be launched by DGS&D in
2017-18.
Full Fledge Version of GeM:DGS&D will float an RFP for selection of the Managed Service Provider (MSP). The MSP will develop the full-fledged GeM, accessible for people with disabilities, which will be launched by DGS&D in
2017-18.
Information accessibility
Para 8.2 Page 137 Use of following modes of procurements may be utilised in order of speed (under Disaster Management situations, threshold limits of modes of procurement may be increased for higher level of officers, with the sanction of Secretary of the Department): Use of following modes of procurements may be utilised in order of speed (under Disaster Management situations, threshold limits of modes of procurement may be increased for higher level of officers, with the sanction of Secretary of the Department): A committee must be constituted to assess and address needs of people with disabilities in emergency situations and procurement for them to be approved by this Committee

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