Indian Railway making moving Lakshagrih – God forbid, a horrible fire incident should turn into reality

भारतीय रेल द्वारा पैसेंजर कोचों को चलता-फिरता लाक्षागृह बनाने की तैयारी हो रही है; अगर कोच में लगी सीटों/बर्थों में प्रयुक्त फोम की टॉक्सिसिटी इंडेक्स अधिकतम एक (1) हो, तो आग लगने की स्थिति में यात्री के जीवित बच निकलने की संभावना लगभग  30  मिनिट तक रहती है; और अगर टॉक्सिसिटी इंडेक्स आठ (8) हो तो यात्री को जीवित बाहर निकलने के लिए शायद 5 मिनट भी नहीं मिलेंगे! -विशेषज्ञ

“When Coaches are caught in fire, even steel gets melted, leave alone fire barrier cloth, then use of PU Foam with fire barrier cloth is nothing but a another camouflage to justify the introduction of such a toxic material!”

What is learnt from reliable sources is extremely shocking. The nexus of few greedy Railway officials and resourceful private vendors is so strong that they have killed their conscience and even ready to compromise with the life of travelling passengers for their personal gain. The kind of manipulation and treachery is unheard and unimaginable. Let all countrymen know the following-

Railway Board vide their letter no. 2017/M(c)/4 dated 16.09.2019 have mandated the use of Polyurethane Foam (PU Foam) to MCF specification MMDTS 19020. This decision jeopardizing the life of passengers as is brought out in the submission below:

The Indian Railway standard for toxicity is NCD 1409 with limiting toxicity value of 1.0. This is the ratio of the quantity of gas produced by burning 100g of material in air in a volume of one meter cube to the concentration of gas fatal to man in 30 minutes. A toxicity index 1.0 indicates that the person will remain alive for 30 minutes when exposed to such toxic fumes. This toxicity index as per NCD 1409 has been defined considering the evacuation time available to passengers, as per design of Indian Railway Coaches.

On the other hand, the toxicity standards for European trains like EN-45545 and French NFF-16-101 is much more lenient and has been defined considering the evacuation time available to passengers on European trains. Most of the trains on the European system are day trains and are not overcrowded. They do not have side berths which reduces evacuation times.

In addition, several additional safety features are also in place in the Europian trains. The EN-45545 Part 4 defines the fire safety requirements for rolling stock design to ensure proper evacuation for passengers in the event of fire.

Adopting of EN-45545-1 without conformance to EN-45545-4 (Fire requirements for Railway rolling stock design) and conformance to EN-45545-6 (Fire Control and Management System) is totally malicious.

Toxicity measured as per NCD-1409 with a limiting value of <1, to be tested as a  acceptance test during all inspection of materials is mandated for all materials used in coaches on Indian Railways including foams, curtains, PVC rexine, paneling, flooring etc.

Curiously for the use of Polyurethane Foam to MMDTS 19020 there is only one Fire Type Tests in lifetime for which equipment is not available in India hence sent abroad. There is no testing facility in India to conduct acceptance tests.  Relaxation in meeting toxicity requirements of <1 as per NCD 1409, and thereafter, not getting material tested during acceptance test is malicious and jeopardizes the life of passengers.

The NCD 1409 measures 14 gases whereas the European Standard measures only 8 gases. Polyurethane Foam tested to MMDTS 19020 when tested as per NCD 1409 gives toxicity index >7.

In the past Polyurethane suppliers promised conformance to RDSO Specification C-8914(Rev 1) and specification RDSO/2007/CG-04 with toxicity <1 as per NCD 1409. But after issue of this specification, no supplier could meet the standards. Hence, RDSO kept on granting relaxation on year to year basis for using the PU Foam with toxicity index upto 2.5.

Finally, in 2015, RDSO decided not to grant further relaxation and PU Foam was discontinued thereafter. However, subsequently in 2019, same material was introduced in the name of EN standard, which if measured on NCD standard gives Toxicity index of more than 7. Is it safe?? This needs to be answered.

Indian Railway in their submission to the Supreme Court in WP 178 of 2014 has emphatically stated that the toxicity standard of less than one as per NCD 1409 ensures safety of passengers. It was only after testing for toxicity as per NCD 1409 that the PIL of WP 178 of 2014 was closed. However, Polyurethane Foam tested to MMDTS 19020 when tested as per NCD 1409 gives toxicity index >7, which contradicts the submission made before Supreme Court in the past.

CQM/MCF got tested a sample of PU Foam in a reputed laboratory. Report revealed that Toxicity index was 7.25, which means highly toxic. Use of PU Foam with fire barrier cloth is another camouflage to justify the introduction of such a toxic material. When Coaches are caught in fire, even steel gets melted, leave alone fire barrier cloth.

Interestingly, the decision to proliferate PU Foam to EN-45545 was taken without conducting trial even on single coach. Not only that, in order to introduce it, MCF even went on to tell lies that it is cheaper than other alternate cushioning materials. Based on his version, RDSO in turn, advised the Board that it is economical.

However, on factual matrix, such a statement was lie, pure lie, and nothing but the lie which is proved from a simple fact that subsequently, MCF himself advised the Railway Board that cost is actually Rs 5 Lakhs per coach higher and Railway Board didn’t denied it till date

Further, normally, such policy decision having huge financial implication does require approval of Finance Department. However, for the reason mentioned above, their concurrence was not taken. Infact, the entire issue was processed with malafide intention with a undue haste in a manner, which was most arbitrary and worse, discriminatory.

@RailMinIndia सुप्रीम कोर्ट में दिए शपथपत्र को संज्ञान में ले#PUFoam की सप्लाई के लिए किया गया ₹100 करोड़ का टेंडर रद्द हो@KapurthalaRcf द्वारा फाइनल किया जा रहा लगभग ₹225 करोड़ का टेंडर स्थगित हो
पूरे मामले की जांच होकि 2019 में इस हजारों करोड़ के घोटाले की शुरुआत कैसे हुई? pic.twitter.com/f5pRANxKWS

— RAILWHISPERS (@Railwhispers) January 11, 2022

In view of the above, following QUESTIONS need answer from the policy makers of the Railway Board-

1. Is it not true that when PU Foam was introduced in the past conforming to specification RDSO/2007/CG-04 with toxicity <1, no supplier could meet the standards?

2. Is it not true that when Toxicity index < 1 couldn’t be achieved, RDSO kept on granting relaxation on year to year basis for using the PU Foam with toxicity index upto 2.5?

3. Is it not true that Indian Railway in their submission to the Supreme Court in WP 178 of 2014 (Abhay Singh Vs UOI) had emphatically stated that the toxicity standard of less than one as per NCD 1409 ensures safety of passengers and it was only after testing for toxicity as per NCD 1409 that the PIL of WP 178 of 2014 was closed? And, if so, does it not mean that PU Foam prescribed in 2019 having toxicity index > 7 completely contradicts affidavit filed under oath before Supreme Court?

4. Is it not true that in 2015, RDSO decided not to grant further relaxation and stick to toxicity index <1 and thus discontinuing the use of PU Foam as cushioning material?

5. Is it not true that when PU Foam was re-introduced in 2019 for 70% coaches, No trial was conducted whereas alternate cushioning material for 30% quantity was introduced only after conducting trial for 2 years period on 25 coaches only? If so, is it not a case of hostile discrimination?

6. Is it not true that while introducing PU Foam for 70% quantity, no finance concurrence was taken whereas alternate cushioning material for 30% quantity was introduced only after taking finance concurrence of Railway Board Finance? If so, is it not a case of hostile discrimination?

7. Is it not true that when PU Foam was adopted, only 2 sources were approved, out of which only one source was indigenous and thus practically, it was only single source item?

8. Is it not true that all three production units wrote back to Railway Board that being a single source item, it would not be advisable to adopt the PU Foam on such a large scale?

9. Is it not true that all such requests/advices were completely ignored by the Railway Board and they were directed to fall in line else face the consequences?

10. Is it not true that Finance Department of all three Production Units (PUs) – RCF, ICF & MCF – refused to concur the purchase proposal of PU Foam on the ground that policy letter to this effect has been issued without obtaining the concurrence of Railway Board’s Finance Department?

11. Is it not true that since 2020, all three PUs kept on repeatedly writing to Railway Board that finance concurrence should be obtained and advised but concerned officers in Board never sent the case file to Finance Department of Railway Board? If so, is it not a matter of investigation to find out the reasons for short circuiting and avoiding the finance concurrence?

12. Is it not true that Executive Director/ Carriage/RDSO in one of his letter to Railway Board had advised that PU Foam is cheaper than Silicon Foam and thus he justified the introduction of PU Foam on economical grounds also?

13. Is it not true that later, it was found that cost of Coach with PU Foam is about Rs 10 Lakhs higher than the Cost of coach with alternate cushioning materials i.e. Silicon foam? If so, does it not mean that ED/Carriage/RDSO misled everyone? And, as a linkage to that, is it not necessary to obtain finance concurrence for adoption of PU Foam when cost per coach is getting increased by such a huge margin?

14. Is it not true that in contrast to Indian Railway, most of the trains on the European system are day trains and are not overcrowded and do not have side berths which reduces evacuation times? If so, is it prudent to adopt their standard, which is much lenient and has been framed as per their prevailing conditions, which are far different than ours.

15. Is it not true that while framing specification of PU Foam as per EN-45545 (MCF specification MMDTS 19020), Part 4 of the EN specification which defines the fire safety requirements for rolling stock design to ensure proper evacuation for passengers in the event of fire and part 6 which defines the Fire Control & Management System has been completely left out and deleted from the specification? If so, why?

16. Is it not true that while framing the specification of so called EN compliant, toxicity test has been deleted from acceptance test? If so, why?

17. Is it not true that EN-45545 basically defines the specification of entire coach as a whole, which includes coach design & collective and collateral effects of all components used in the coach put all together? If that be so, is it not a matter of investigation as to why only one component is brought on that specification without studying the coach design/lay out and effects of all other components? Can Railway Board certify that merely by using PU Foam as per EN-45545, coach will be EN compliant?

18. Is it not true that as of now, there is no testing facility in the entire country for testing the PU Foam as per EN- 455545? If so, how Indian Railway shall ensure the quality?

19. Is it not true that specification so framed prescribes only type tests to be conducted after every 500 coaches, and even for that samples are to be sent abroad as no testing facility is available in the country? If that be so, how type test done once shall guarantee of the quality of supply of each lot without conducting any acceptance test as no facility is available in the country to do so? And as regards ceiling of 500 coaches for conducting even the type tests, does it not mean that it is 500 coaches for each approved vendor, meaning thereby, that say, if there are 5 approved vendors of PU Foam, it implies 2500 coaches?

20. Is it not true that ED/Carriage/RDSO in his letter No. MC/CB/Cushion/PU Foam dated 16.08.2019 had recommended the use of PU Foam? 

21. Is it not true that based on ED/Carriage/RDSO recommendation, Railway Board vide their letter no. 2017/M(c)/4 dated 16.09.2019 had directed to adopt Polyurethane Foam? If so, does it not mean that he is becoming judge in his own case when he is assigned to carry out the investigation into a complaint challenging his own recommendation of adoption of PU Foam? Under such a situation, can anyone expect impartial and fair investigation?

These questions need answers. We have all relevant documents in our possession to prove our reasoning. As a foot soldier of truth and justice, we are ordained to carry on our crusade to establish the truth till each such wall of lies and deceit are dismantled, brick by brick and inch by inch.

When ED/Carriage/RDSO Mr Sameer Lohani was contacted on phone, he was quite evasive in his replies. On being told that MCF had sent the sample of PU Foam to Shri Ram laboratory who in their test report has indicated that toxicity index is > 7.25, he even demanded a copy of the test report as if he is completely unaware about it and pretended his ignorance. On being replied that it is officially available with him, he maintained complete silence.

However, it gave some solace to note that when it was brought to the notice of Chairman, Railway Board, he assured that matter is being investigated and he has directed the concerned officials to look into it.

Since most of the deaths in a fire accidents take place on inhalation of toxic fumes, instructions mandating use of Polyurethane Foam to benefit a few suppliers at the cost of safety of common public must be kept in abeyance till completion of the investigation by an independent expert committee preferably by experts of IIT Kanpur who have the distinction of a having a fire lab and for that purpose, samples of PU Foam drawn from the recently turned out Garib Rath coaches can be sent to CIPET Hyderabad or CPRI Bangalore for testing the toxicity index.
To be continue…

Represented – Surresh Tripathi

#Fire Breaks out in Train between Muraina-Dhaulpur, Train was Coming from Katra. pic.twitter.com/b9PbB0d3Fl

— Kamlesh Kumar Ojha🇮🇳 (@Kamlesh_ojha1) November 26, 2021

#BurningTrain #PUFoam #FireInTheTrain