difficulty of traveling to learning centers along narrow, steep, uneven, often slippery paths in the crowded camps is a barrier to education for children with physical disabilities. Restrictions on International NGOs that Provide Education Some international humanitarian NGOs described what they believed to be arbitrary difficulties obtaining government permission to carry out education projects for Rohingya refugee children. According to local and international NGO staff, before being eligible to apply for permission to carry out projects, NGOs must be registered, a process that entails an “FD 1” application to a specialized body, which is then transferred to the Ministry of Home Affairs, which then requests investigations by security agencies.248 Three international NGOs described opacity and delays in the registration process, and as a result, difficulty in planning and carrying out projects and obtaining work permits for foreign staff.249 One education specialist who worked in Cox’s Bazar in 2018 said that it had been especially difficult for INGOs to obtain government approval for education projects: First you need an FD 1. These are undera big rock for international NGOs. They don’t want to register new NGOs. Then you should get an FD 6, a permit to operate for development projects. The normal procedure is that permit for the project would include staff work permits, valid for one year. But the government doesn’t want to sign off for any NGO to deliver education. So you have to get an FD 7 permit. It’s valid for three months, meant for short emergency response projects, and you can’t hang a work permit off of it. You have to get a new FD 7 every three months — and if you write ‘education’ they won’t sign it for you - some NGOs write in ‘play areas’ or whatever instead of ‘education’ for their project descriptions.25° Child Labor 248 Human Rights Watch interviews with INGO staff, Cox’s Bazar, February 15 and 16, 2019. See also Shafquat Alamgir, “Registration of INGOs in Bangladesh,” Daily Observer, April 13, 2019, https://www.observerbd.com/details.php?id=193122 (accessed July 23, 2019). 249 Human Rights Watch interviews with international NGO staff, Cox’s Bazar, February 16-20, 2019. 259 Ibid. “ARE WE HUMAN?” 64