It's good to have friends. A friend of mine, having read my concerns with the remark of NTSB Chairman Sumwalt that "the Chester accident also illustrated the fact that drug use by rail workers has been on the rise in recent years" pointed me to this page from the December 28, 2017, Federal Register.
There FRA published its "Drug and Alcohol Testing: Determination of Minimum Random Testing Rates for 2018." Wrote FRA:
For the next calendar year, FRA determines the minimum annual random drug testing rate and the minimum alcohol testing rate for railroad employess covered by hours of service regulations...based on the railroad industry data available for the the two previous calendar years (for this document, calendar years 2015 and 2016.
And the results?
Railroad industry data submitted...shows that rail industry's random drug testing positive rate for covered service employees has continued to be below 1.0 percent for the applicable two calendar years....In addition...the industry-wide random alcohol testing violation rate for covered service employees has continued to be below 0.5 percent for the applicable two calendar years...
I wouldn't declare less than 1 percent, and less than 0.5 percent, to be the final victory, but I would declare that an ongoing and sustainable success, and not indications of "violation creep."
Now neither Chairman Sumwalt, nor NTSB in its investigation of the Chester, Pa. accident made any recommendaton for increased drug and alcohol testing, or for any other program generally recognized as effective in reducing drug and alcohol abuse in the workplace. That's good because there's little to be gained in dedicating a greater portion of resources to reversing a trend that doesn't exist, and there is a great deal that can be lost in terms of supervisory time, effort, and....money.
Not the case, unfortunately, with one of the other MWL items-- that of elminating sources of employee distraction. In its investigation Frankford Jct., Pa. accidents found:
3. The Amtrak engineer accelerated the train to 106 mph without slowing the train for the curve at Frankford Jct due to his loss of situational awareness, likely because his attention was diverted to the emergency situation with the SEPTA train.
4. Training, focusing on prospective memory strategies for prolonged, atypical situations that could divert crewmember attention may help operating crews become aware of, and take measures to avoid, errors due to memory failure.
NTSB follows-up those findings with the recommendation to AAR and APTA for communication to their member railroads:
Develop criteria for initial and recurrent training for operating crewmember that reinforces strategies for recognizing and effectively managing multiple concurrent tasks and prolonged atypical situations to sustain their attention on current and upcoming train operations, and distribute those criteria to your members.
It is at this point that I, if I were an official of the AAR or APTA, would reread the recommendation, maybe twice, and then a third time aloud, then a fourth time aloud with colleagues, and then after all that, look around the room and I might say "Does anyone here have the slightest clue what that means?" I might say that, but I'd probably just use the short version and say, "WTF?"
Why WTF, you ask? First and foremost, all of operating crewmember training is about recognizing and effectively managing multiple concurrent tasks without ever losing focus on the primary task of operating the train safely. For a locomotive engineer, that training means multiple tasks are managed to the goal of properly controlling the speed of the train
Secondly, that training is designed to integrate those multiple concurrent tasks with the primary task so that crewmember create a safe operating environment for all trains. For a locomotive engineer, that means that successful discharge of multiple tasks is part of controlling the speed of the train in order to create a safe operating environment for all trains.
Thirdly "atypical situations" are not that atypical in the railroad environment. Trains being hit by stones is hardly an unusual occurrence. Back in the day, and on occasion, objects such as concrete blocks, bowling balls, sofas, and even the odd refrigerator would be hurled against or onto a moving train. I know of no instance, and I include Amtrak 188, where such an event caused the struck train, or any following train to overspeed, or violate a signal rule.
For a locomotive engineer, every task means, no matter what, properly control the speed of the train.
Now locomotive engineers uses lots of "tricks" to help them recognize where they are and what that speed should be, and what the speed will have to be in the very near future. Those "tricks" are actually the physical characteristics of the railroad-- recognizing that station A is 3000 feet from a 50 mph rated curve; that the interlocking one mile ahead permits a maximum speed of 30 mph on crossover moves.
All of this, and more, are part of the training, testing, qualification certification, and retraining, retesting, requalification, recertification of locomotive engineers. We do not, we must not, we cannot, separate any task from the integrated whole, which is always controlling the train's speed. Location, location, location means speed, speed, speed.
Finally, those who have worked in this business know that the unusual occurrences, and/or the necessity to handle multiple inputs of information and take appropriate actions are not, and I would say never, the greater risk to safe train operations. The greater, even fundamental, risk is in the routine, the ordinary, the habitual. I know of no incidence of a train overspeeding because the locomotive engineer was "too busy" with "other duties"-- i.e. inspecting a passing train for defects, repeating a mandatory directive, acknowledging a radio transmission, reporting an obstruction to the safe movement of trains on another track. On the other hand, I have investigated any number of stop signal violations by train and engine crews operating the same train over the same route at the same time as they operated that train over that route at that time everyday for last 30, 60, or 90 days.
The problem here is that NTSB has introduced speculation into the determination of cause in a human factor accident, and then recommended programs designed around that speculation as functional necessities to safe train operations.
The answer, the remedy, is not in speculation, and not in programs that rely on the human factor to remedy the human factor. The solution is to be found in enforcing compliance indepently of the will, or the memory, of the crew.
David Schanoes
March 28, 2018
To strangers! K., Blade Runner 2049
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