Fwd: Comments on Suggestions received from DRA & FMC.

[Vaishnavi Jayakumar (Inclusive India)]

FYI

---------- Forwarded message ---------
From: Vaishnavi Jayakumar (Inclusive India) <vaishnavi...@inclusiveindia.info>
Date: Wed, 24 May 2023 at 17:25
Subject: Re: Comments on Suggestions received from DRA & FMC.
To: Nilesh Raosahab <nilesh....@gov.in>, Ketna Mehta <ninafou...@gmail.com>, Komal Kamra <Ko...@thespinalfoundation.org>
Cc: Sushil Kumar Geeva <geev...@nic.in>, K C SHARMA <kcshar...@gov.in>, Piyush Jain <directo...@gov.in>

Dear Mr Nilesh,

I) While the Ambulance Code AIS 125 has seemingly appropriate requirement for pick up / scoop stretcher for Type C and Type D road ambulances, it needs to be reiterated that spinal cord injuries may not present as a life-saving emergency with the result that Type B road ambulances are deployed. 

3.3.1 Type A Road Ambulance / Medical First Responder

Road Ambulance designed to provide emergent out of hospital medical care to patients when stationary. This vehicle may be any CMVR approved Category M or L vehicle suitable for the terrain to be used in but will not have the capability to transport patients in supine state or provide them medical care inside the vehicle. 

3.3.2 Type B Road Ambulance / Patient Transport Vehicle

Road ambulance designed and equipped for the transport of patients who are not expected to become emergency patients. 

3.3.3 Type C Road Ambulance: Basic Life Support Ambulance 

A vehicle ergonomically designed, suitably equipped and appropriately staffed for the transport and treatment of patients requiring non-invasive airway management / basic monitoring. 

3.3.4 Type D Road Ambulance: Advanced Life Support Ambulance 

A vehicle ergonomically designed, suitably equipped and appropriately staffed for the transport and treatment of emergency patients requiring invasive airway management / intensive monitoring.   

II) Additionally AIS 125 Part 2 specifies the table of requirements as recommendatory in nature,  For highway accidents the specified requirements need to be prescribed as mandatory with fitness certificate and surprise checks.  Similarly the lack of clarity in the standard regarding the usage of X can be nitpicked by reluctant ambulance providers as varying quantity could include none / 0. The usage of the  x mark 'X' commonly understood as 'No' or indicating negation  can be avoided with usage of a plus mark '+' instead which communicates the intent better. While the AIS makes reference to the age range of patients it does not include the diversity of body type and range of possible impairments. A pregnant person for example, could well be a person with spinal cord injury.

5.0 LIST OF EQUIPMENT The Tables 1 to 11 designate the recommendatory equipment carried by the road ambulances according to their type A, B, C and D. Supplementary devices may be introduced depending on local requirements. For most items a specific quantity is given. "X" in the column indicates that quantity may be varied in accordance with the local needs of the state / district. Where applicable the equipment should be available across the full age range of patients. 

Table 1  : Type of Patient Handling Equipment  as per Road Ambulance type

Sr. No.	Device	Standard	Ambulance Type B	Ambulance Type C	Ambulance Type D
1	Main Stretcher / Undercarriage	AIS- 125 (Part 1	1	1	1
2	Pick up stretcher	EN 1865	-	1	1
3	Vacuum Mattress	EN 1865	-	X	X
4	Transfer mattress/ Carrying Sheet	EN 1865	X	X	X
5	Long spinal board complete with head immobilizer and securing straps	EN 1865	-	X	X

III) Requiring a pick up / scoop stretcher as the default stretcher in even Type B patient transport ambulances (which may be deployed in situations perceived as not life saving emergencies) would be prudent where poor first responder handling worsens outcomes for those with spinal cord injury. If only one stretcher is being carried, why not by default, a scoop / pick up stretcher with an optional C collar to additionally immobilise the neck? The extending of scoop stretchers as necessary equipment to other types of ambulances is already part of NHM's most recent Specifications of medical equipments for ERS Ambulances under National Health MissionAnd type of ambulances ( S. No 12 & 18).

For National Highway Accident Relief Service Scheme (NHARSS) ambulances similarly, the absence of blood or surface injury for people who may need to be extricated from their vehicle should nevertheless necessitate a mandatory Extended Upper Spinal Immobilization Extrication Devices or Short Spinal Board additionally for Type B ambulances deployed at highways.

IV) Even recent procurement tenders for Government ambulances are not specifically including the scoop stretcher - as in the 2022 West Bengal RFP where Schedule 2: List of Medical Equipment along with Technical Specifications to be available in Ambulances does not specify a pick up stretcher in the minimum list of medical equipment to be available in the ambulances under the NHM 108 ambulance project. A 2022 dipstick survey conducted by Nina Foundation  revealed only a single ambulance in Mumbai equipped with a scoop stretcher. This is abysmal given the National Ambulance Code compliance date of 2018.

V)  Improper pre-hospital patient handling and transport is reported by several survivors living with paraplegia and quadriplegia in India as the reason for the severity of the disability.

M reports about her accident in 2017 : 

Mine was a RTA, I was taken to hospital via ambulance , but to my memory, they didn't use any board to transfer to the ambulance. I think they lifted me , because there were no symptoms  like scratch / blood and external mark of accident. In the hospital they used the spinal board. Later during the check up  visit after 2 months, they used the trolley stretcher. 

S reports :

While I was shifted from Kullu to gurgaon, it was the main stretcher where I was lifted and placed. The moment I reached Fortis, Gurgaon, they used a scoop stretcher and since then we knew something like this does exist.

VI) In conclusion, given paucity of trained personnel, it is best that even the log roll manoeuver required for spinal board usage be conducted in a hospital setting. Currently for avoiding further disability while being mindful of the golden hour and minimally trained first responders, the usage of scoop stretchers as default (with padding of gaps and C collar if indicated) is recommended as a mandatory ambulance equipment as it is scientifically proven to be safest. 

I have cc'ed Ketna Mehta from Nina Foundation and Komal Kamra of The Spinal Foundation who have been advocating for this issue for years now so we could all benefit from their expertise and networks. 

Thanks for your prompt email. We look forward to making the pre-hospital handling of road accident survivors a less traumatic experience.

Regards,

Vaishnavi Jayakumar

Member, Disability Rights Alliance 

          & The Freedom of Movement Coalition

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VAISHNAVI JAYAKUMAR

http://about.me/vjayakumar

On Tue, 23 May 2023 at 17:17, Nilesh Raosahab <nilesh....@gov.in> wrote:

Dear Madam,

With reference to your meeting on 19th May 2023 in the Ministry of Road Transport and Highways regarding the issue of scoop stretchers in the ambulance. It is submitted as per below,

1. With reference to AIS 125 (PART 2): Medical Equipment for Road Ambulances, the following type of patient-handling equipment can be installed in the ambulance as per their type.

 

Sr.No	Device	Standard	Type of road Ambulance
			B	C	D
1	Main Stretcher/ Undercarriage	AIS 125 (Part 1)	1	1	1
2	Pick up Stretchers	EN 1865	--	1	1

2. Pick-up stretchers shall meet the minimum requirements set in EN 1865 for the design and performance of stretchers.

 

3. Requesting you to refer to the AIS 125 (Part -1) and AIS 125 (Part-2).

Thanks and Regards,

Nilesh.T

Scientist 'B'

Ministry of Road Transport and Highways

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From: "Sushil Kumar Geeva" <geev...@nic.in>
To: "Nilesh Raosahab" <nilesh....@gov.in>
Sent: Monday, May 22, 2023 4:08:33 PM
Subject: Fwd: Suggestions received from DRA & FMC.

Dear Nilesh,

Please see the trailing mail and do the needful. 

Regards

(S.K. Geeva)
US(MVL)
Ministry of Road Transport & Highways

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From: "GH Gupta" <gaurav...@gov.in>
To: "Sushil Kumar Geeva" <geev...@nic.in>
Cc: "Piyush Jain" <directo...@gov.in>
Sent: Friday, May 19, 2023 6:27:45 PM
Subject: Re: Suggestions received from DRA & FMC.

Comments may be taken from SE( Highway operations) MoRTH.

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From: "Sushil Kumar Geeva" <geev...@nic.in>
To: "GH Gupta" <ghgupta...@gov.in>
Cc: "Piyush Jain" <directo...@gov.in>
Sent: Friday, May 19, 2023 4:40:16 PM
Subject: Suggestions received from DRA & FMC.

Sir, 

I am to say that a meeting was held today in the Chairmanship of AS(MVL) with Ms. Vaishnavi Jayakumar,  Member, DRA & FMC. In the meeting she raised the issue of Scoop Stretchers for the victims of road accident while putting them in ambulance. She suggested that the ambulances available on the Highways or otherwise must be equipped with scoop stretchers. You are requested to provide the comments in this regard.

Regards

(S.K. Geeva)
US(MVL)
Ministry of Road Transport & Highways

[Vaishnavi Jayakumar (Inclusive India)]

---------- Forwarded message ---------

From: Vaishnavi Jayakumar (Inclusive India) <vaishnavi...@inclusiveindia.info>

Date: Tue, 21 Nov 2023 at 08:35
Subject: Scoop stretchers to prevent rescue-caused spinal cord injuries after road accidents Fwd: Comments on Suggestions received from DRA & FMC.
To: <mahmoo...@nic.in>

Dear Mr. Ahmed,

I had met you in May 2023 to discuss MORTH's role in ensuring road transport accessibility and compliance from the point of view of citizens with disabilities.

At that time, we had also discussed providing of scoop stretchers to prevent pre-hospital response-related injuries caused by improper equipment or handling at road accidents.. 

After prompt communication from your office which was responded from our end with corresponding alacrity, there has been no progress on this provision of MRI compatible, plastic scoop stretcher with head immobilisation in ambulance equipment protocols.

Looking forward to MORTH expediting this road-safety measure - email trail is below.

Thanking you,