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C3RS Inside The Rail – Issue 18

ISSUE 18 – OCTOBER 2022

Playing a Game of Chance…  

When playing your favorite board game, there are always strict rules on how to play; however, we have all been tempted from time to time to bend the rules or even play with “house rules”. No matter which way you look at it, this defeats the purpose of the game. The same can be said for following rules and regulations of required daily tests for the operation of trains and equipment. Like having to pay rent to the owner of the valued Park Place in Monopoly™, railroad employees should always follow official rules and instructions when completing the necessary tests and inspections required daily.

Monopoly game

On a daily basis, railroad employees can come across many tests and inspections to complete. This includes: Positive Train Control related tests like Departure tests; Class I/IA/II Inspection tests, Running Air Brake tests, On Track Equipment inspections, Signal, Road Crossing Warning inspections, and many others!

Unlike Monopoly™, there are no “Chance” cards laying around. Failure to properly inspect cars or complete tests can lead to serious consequences. 

In this issue of Inside the Rail, C3RS provides close-call events from different crafts revealing instances that occurred in which tests and inspections were not completed as stated in the rules. The collection of narratives and callbacks gives insight to what led up to the mistake, and how the outcome affected the reporter. 

Do not Pass Go!

With a different crew and a change of routine, this Engineer explains how a crew missed a Class II Brake Test.

Typically, I get into the locomotive cab, cut the control stand in, set up Positive Train Control (PTC) and wait for the Carman to give me a Class II Brake Test. The Carman usually rides in the cab of the previous train, so I know if he is at work today or not. He started work, but usually comes out early to give me my Class II Brake Test. If he is not there that day, I make sure to get the test from the Conductor or Assistant Conductor. Then, the Conductor closes the doors and we leave. 

My normal crew was off and I had a different crew, but today the normal Assistant Conductor slid up to the Conductor position and I got an Assistant Conductor off the extra board. The Conductor closed the doors and we left before the Carman could come out and give us a Class II Brake Test. After about a mile, I thought to myself that we did not get a Class II. Upon returning, I asked the Carman if he gave us a test, he said that we were leaving when he walked up. So, it was a bit of departing when the Conductor closed the door, the extra crew, and the Carman being a bit later than normal.

C3RS Expert Analyst’s Callback Summary:

The reporter, an Engineer, attributed the missed Class II Brake Test to deviating from the normal routine prior to departure. The normal crew meshes well together and the reporter stated the expectation was the Conductor knew the Carman would perform the brake test. The Engineer said a written checklist for pre-departure activities could have prevented missing the test.

Pick a Car(d)!

When distracted by a complicated pick up en route, a Conductor realizes they forgot to complete an important task.

There was a late bad order on the outbound Train. We dropped off the bad order on the Track and then went to pick up the replacement. We grabbed the replacement, but had trouble getting the knuckles to separate. I went over to the other side to separate the cars. We finally got the car separated and did a Class II Brake Test. After thinking about it, we probably should have done a Class I Brake Test because we didn’t have an air slip for the car we were picking up.

Read the Instructions?

An Engineer relives the outcome of what happens when you mix an uncommon task with complicated instructions.

Our Crew took over the train from a previous Crew at the Station. I was told everything was good with the equipment; however, once I cleared west of the Control Point, I checked the paperwork and noticed the paperwork was expired. I never ran a pre-departure Positive Train Control (PTC) test before, so I followed the instructions in the General Notice and I believe I did everything correctly according to the provided instructions. 

I ran the tests and slipped the Cab Car with new paperwork. I notified the Dispatcher and proceeded with our run on the Train with that paperwork. For our next round trip, Mechanical reran the test and provided new paperwork. I may have done the pre-departure tests incorrectly. The instructions are not great in the General Notice and I feel like they should be a lot clearer. A lot of Engineers rarely have to run these tests and it’s unfortunate that when we do, we are provided with such bad instructions as to how to do it.

C3RS Expert Analyst’s Callback Summary:

The reporter, an Engineer, had not completed a PTC departure test since Engineer training. The Engineer further explained that Mechanical Department employees normally complete the test. The Engineer was unsure if the test was done properly. When the Engineer arrived at the station, the Mechanical Department came out to rerun the PTC test. The Engineer watched the procedure and the Mechanical Department seemed to do other tasks rather than what was stated in the General Notice. The Engineer believes there should be a pamphlet that Engineers could refer to if the test needs to be completed and possibly a PowerPoint during rules class or training to ensure knowledge of how to properly run the test.

Missing Pieces!

Not completing tests or inspections allows for the opportunity to miss something big, just ask this Signal Maintainer.

At approximately XA:00 hours, there was a bridge opening on the Bridge and, after the bridge was re-seated, one of the Detectors for Track X failed. Signal Maintainer X and Signal Maintainer Y responded to investigate the failure, performed a Test and the Detector worked as intended. Onsite at the bridge opening was Signal Supervisor X, along with the Buildings/Bridges Department, the Structure Department, Track Department and Electrified Rail Department. Later that day, at approximately XJ:30 hours, a Track Foreman noticed the miter rail for Track X was not seated properly, and there was a sheared bolt head that was wedged under the miter rail. The Track Department requested an emergency opening of the bridge, removed the obstruction, and [the] Signal Department retested the Detectors.

Apparently, the miter rail on Track X that was not seated properly, was the same Detector that failed during the bridge opening. 

A contributing factor to the problem was that the Signal Maintainers did not perform a full inspection of the miter rail and should be re-instructed. Also, there was very poor lighting on the bridge. More important, the departments that are responsible for the miter rail and saddle system did not perform a thorough inspection of their equipment after the bridge opening and this should be a requirement.

C3RS Expert Analyst’s Callback Summary:

The reporter, a Signal Maintainer, added that there needs to be someone specific who is responsible for the final inspection of the tracks or bridges, anytime repairs are made. The reporter suggested that since the Track Inspector is the one who found the issue after multiple trains had already traversed the area, maybe the carrier should have the track inspected prior to the track segment being released for operation. 

Did You Know?

If you submit a C3RS report, a NASA C3RS Expert Analyst may call you if you do not include enough information or to better understand the safety issues you are sharing. It is very important that you return our call within three days so that your identification (ID) strip (sent by the U.S. Mail) can be returned to you quickly.

The more information you include in your report, the faster the ID strip can be returned to you!

Report Intake By Craft

January through September 2022

Transportation – 2,127

Engineering – 61

Mechanical – 56

Monthly Report Intake

Previous 3 Months

July – 262

August – 281

September – 258

Inside The Rail – Issue 18

Online Resources

  • Visit c3rs.arc.nasa.gov for a detailed overview of C3RS, instructions on how to submit C3RS reports, report forms and a list of Frequently Asked Questions. 
  • See the FRA C3RS web page for more information and access to the IMOU agreements of the participating railroad carriers and unions.
Report to C3RS
Contact the Editor

NP-2022-10-01-ARC

NASA Confidential Close Call Reporting System  |  c3rs.arc.nasa.gov

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Preventing Discrimination & Harassment Training

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2023 RAIL T&E Holiday Schedule

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The Time Is NOW to Stand for the Rule of Two

The Time Is NOW to Stand for the Rule of Two – SMART Union (smart-union.org)

The rule of two will affect Passenger RR operations, we are encouraging all members and their family’s to comment a on the FRA proposed rule requiring.

Please click and share the above link!

On July 28, 2022, the Federal Railroad Administration (FRA) published a Notice of Proposed Rulemaking (NPRM) to announce its intent to make a formal federal regulation mandating the minimum crew size on most trains in America to be no less than a crew of two in the cab of a locomotive.

As part of the rulemaking process, FRA must open a comment period to ensure that its actions are in-line with public preference, concern, and safety. The comment period has been extended for 60 days and will expire on Dec. 2, 2022. Click here to watch a brief how-to video for submitting comments.

It is vital to the safety of our industry that your stories be told, and your fears be aired. Therefore, we are asking all of you to please take the time to comment, and to share this action with your friends, family and loved ones – encouraging them to do the same.

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Each letter needs to be somewhat different.

Our members should take their thoughts on the subject and put them into a few sentences and submit them. 
Keep it simple. Friends, family and others are also welcomed to show support. 
We are in favor but need to strengthen the waiver process especially in passenger service. 

Sample Comment 1:

My name is xxxxxxx, and I’m writing to comment on FRA’s Proposed Rule on Train Crew Size Safety Requirements. This issue is important to me because of my concern about the community where I live.

Trains that run through the country carry everything from mineral freight to spent nuclear rods. While working safely, these everyday commodities are transported with relative ease and no issues. However, with a strained workforce on call 24/7, it has made a complex job that usually could be done safely into a nearly impossible ticking time bomb absent the current two-person crew standard.

The conductor has a second set of eyes and in multiple areas takes a burden off the engineer, who is in charge of operating the locomotive. Usually, the conductor is the immediate responder who resolves the situation when the train experiences an emergency. A simple accident may become a fatality if the person on the ground has no one to call and cannot get through to the dispatcher.

Keeping the team of an engineer and a conductor aboard trains provides safety reinforcement, rapid response and will keep our trains running safely.

Sample Comment 2:

My name is xxxxxxx, and I’m writing to comment on FRA’s Proposed Rule on Train Crew Size Safety Requirements. This issue is important to me because it affects the health and safety of my family, my community and people all over our country.

Freight trains are crucial to our country’s supply chain, which means they transport everything from coal and grain to chemicals, hazardous or flammable materials and spent nuclear rods. These trains carry the goods that keep our country running. They also carry materials that, if not transported safely, have the potential to put our communities in danger.

Given the importance of the freight that trains carry and the potential danger for cities and towns these trains travel through when an accident occurs, two-person crews just make sense. Two pairs of eyes are better than one, in the cab of a freight train as much as in an airplane and having a conductor on-board can be a life-saver in case of fatigue, injury or accident. Keeping the team of an engineer and a conductor aboard trains provides rapid response and will keep our trains running safely. I strongly support this proposed regulation.

 

 

F. Current Operations
Since FRA already has regulations
requiring certain minimum standards
for locomotive engineers and
conductors,147 FRA has chosen not to
define the duties of the two required
crewmembers in this proposed rule.
Nearly every movement of a locomotive,
whether the locomotive is coupled to
other rolling equipment or not, requires
that the operation be performed by a
certified locomotive engineer.148 For
most current railroad operations, this is
accomplished with a two-person train
crew consisting of a locomotive
engineer and a conductor. Train crews
consisting of two people, one a
locomotive engineer and the other a
conductor, are universally the norm
because that crewmember configuration
provides the railroad with the necessary
flexibility to assign the crew where
operations have more complexity than a
one-person crew can be expected to
perform alone. That is, a train crew with
both a locomotive engineer and
conductor can be expected to work
independently, without the need for the
railroad to have separate plans regarding
how the train will accomplish switching
cars, protecting highway-rail grade
crossings, and other safety-related tasks

typically requiring more than just one-
person. It is also more efficient with a

conductor who can fill out any required
paperwork and receive mandatory
directives transmitted by radio while
the locomotive engineer keeps the train
moving.
Each current operation of a
locomotive or train that requires a
locomotive engineer is also required to
have a conductor, but FRA recognizes
that there are circumstances where a
person is ‘‘serving as both the conductor
and the engineer.’’ 149 With a one-person
train crew, the single crewmember must
be dual-certified as a locomotive
engineer and a conductor.150 In this
way, FRA currently requires that each
locomotive or train must have a crew
that can perform all the duties described
by the qualifications requirements in
FRA’s locomotive engineer and
conductor certification regulations.
FRA currently permits a train crew
consisting of a certified locomotive
engineer, who is not dual-certified as a
conductor, and a second person who is
a certified conductor attached to the
train crew, but not traveling on the
train.151 As proposed, this rule would
limit this practice to the excepted small
railroad operations under proposed
§ 218.129(c)(1), as the NPRM would
generally require crewmembers to be on
their moving train and only would
allow disembarking temporarily from
the train to perform duties assigned.152
Thus, a second person, even if that
person is a certified conductor, would
not be a train crewmember under this
proposed rule if the person is
intermittently assisting the train’s
movements and traveling in a motor
vehicle along a highway near the train.
If this proposed rule is finalized, FRA is
considering whether to amend the
references in the locomotive engineer
and conductor certification rules that
permit the current operation to explain
how these provisions are limited. FRA
would appreciate comments on this
issue.
Additionally, a railroad operation
with a train crew that consists of either:
(1) a locomotive engineer and
conductor; or (2) one crewmember that
is dual-certified may have other
operating employees identified as train
crewmembers. FRA currently defines

‘‘train crew’’ in § 218.5 as one or more
railroad employees who are: assigned to
a controlling locomotive; called to
perform service subject to the Federal
hours of service requirements; involved
with the movement of the equipment
they are called to operate; reporting and
working together as a unit that remains
in close contact, if more than one
employee; and subject to the railroad
operating rules and program of
operational tests and inspections
required in 49 CFR 217.9 and 217.11.
Thus, as FRA has an existing definition
of the requirements for a train crew,
FRA did not propose any new or
additional requirements for the train
crew in this proposed rule. FRA would
appreciate comments on this issue. An
alternative option is that FRA require a
second crewmember be a conductor,

even if the other crewmember is dual-
certified, in an effort to ensure a level

of teamwork that may not be attainable
with any other crewmember. This issue
is further explained below for freight
and passenger train operations.

Secure Your Future — 3 Ways to Vote in 2022

 

General Chairman’s Report October 2022

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2022 Fall Optional Displacement

Attention All Members,

The 2022 Fall Optional Displacement will be effective November 13, 2022. This will correspond with the Fall Timetables.