Ten90 Solutions LLC

We are saved, all of us, from the prospects of human factor caused fatal train accidents.

"How's that?" you ask.  

Two US senators, Blumenthal and Schumer have convinced FRA to introduce a rule reguiring the application of outward-facing and inward-facing cameras.

Apparently, FRA which has long championed the RSAC process for development, discussion, and  validation of proposed regulations, has decided that in this case the RSAC model isn't adequate or appropriate or rapid or...dramatic enough, after the breathless, blood-stirring joint press release of the two senators.

I for one can't wait to read the NPRM, and get a chance to provide some comments.  But on the off chance that I might be somewhere else, engaged in something that has real significance for better railroading  I'll take this opportunity to comment on this proposed new rule for outward and inward facing cameras.

First thing we have to point out is that the press release states the cameras will be used to observe conductors.  Minor point, but conductors do not operate locomotives or control cars.  Conductors may or may not be present in the locomotive or control car, but they are prohibited by regulation from operating the controls.  The press offices of Richard and Charles probably meant "locomotive engineers" but the thing is with regulations and rules, you actually have to use the correct words, defining the correct parties with the correct duties. 

Mere technicality, I know.  I'm old fashioned that way.  I think people have to know what they are talking about when they are trying to inform the public.  (Word to the NTSB:  there is no "Riverton" on Metro-North's Hudson Line.  The location where the northbound passed 8808, whose engineer did not dim the headlights at 711 AM, is Irvington).

Next thing, we have to determine is:   if inward and outward cameras are going to be installed, will the video be streamed to a central location for real time review?  Or will it be archived, to be accessed in the event of an accident? 

If the video is to be streamed for real time observation and, if necessary, intervention,  who's going to be monitoring  the live video feeds? 

What qualifications will be required of these monitors? 

Will he or she be a certified supervisor of locomotive engineers?

Will that person be assigned to monitor more than one train at a time?  We assign only one train at a time for actual operation to a locomotive engineer, so it would seem logical to assign each train to a specific monitor.

If it is determined that more than one train at a time can be monitored by a single individual, how many trains can be assigned to an individual, operating at what speeds, within how much territory?

How will video feeds be transferred between control points, like divisions, of a railroad? 

How will they be transferred from one railroad to another?

What happens if a monitor misses something?

If the feed to the monitor is only the video feed, and does not include the data regarding train location, train speed, train schedule, signal indication, equipment restrictions, how will the monitor determine if the train is being operated safely?

Those are just some of the questions I have about the live, streaming feed.

If the live video stream is not made the mandatory mode of observation,  then what's the point of the inward-facing camera at all?  It will have no preventative function.  Data regarding safe or unsafe operation of the train can be assembled after an incident from the event recorders,  control centers' archives of train movements, etc.  So what additional information will the video archive provide that will prevent any accident?  None. Zero. Zip. Nada. 

The press release makes the claim that the video can be used to detect a broken rail, and presumably prevent a train from operating over a broken rail. 

Well, look, broken rail protection is provided by the signal system. It's not perfect.  It captures about half the broken rails, but the reason it works at all is that the signal system responds to the broken rail as if that section of track were occupied, so it transmits information to approaching trains to slow down, to decelerate, to be prepared to stop. 

If the signal system did not do that, there is no way on this earth, or in this universe, given the laws of physics, that a train operating 60 mph can stop within the range of vision for a broken rail.

Maybe Superman could see a broken rail 30-300  feet in front of him at 59 mph, but Superman doesn't take the train. 

Remember the primary reasons for establishing a signal system to begin with?  We operate trains at speeds that make it impossible for the train to be stopped within the distance of the locomotive engineer's line of sight.  So exactly what use is an outward facing camera in detecting broken rails?  None. Zero. Zip. Nada.

Outward facing cameras provide important information, after the fact, when the issues involve grade-crossings, trespassers, side swipes, and signal indications.  In prevention before the fact these incidents?  None. Zero. Zip. Nada

If we are going to require the installation of inward and outward facing cameras on the basis that these instruments are critical to the safe operation of trains, then how will cameras be tested for functionality before a train begins its first assignment of the calendar day?

What if the inward, or the outward operating camera is not functioning?  Will that locomotive with that camera be restricted from operating as the controlling end of a train?

How will a locomotive engineer test the functionality of the cameras when first taking charge of the train, when the equipment has been in service for a period of time?

We require a locomotive engineer to have knowledge of the initial terminal air test for a train, and then to participate in an intermediate, "road train," pre-departure brake test, that verifies the continuity of the brake system.

What happens if the cameras fail the equivalent of that intermediate pre-departure test?

We have, since December 1, been treated to a whole series of imprecise, vague, inapplicable and damaging suggestions, demands, mandatory directives, announcements, from those who know nothing about railroading, and those who do, or at least should. 

This stream has included the advocacy of the use of seat-belts in trains, which assumes that everyone has seats, an assumption totally at odds with how public transport is, and must be, organized to be effective. 

It has included  the letter from FRA directing MTA, which it does not regulate, to immediately implement a close-call confidential reporting system.  I can't wait to see if, after the derailment and explosion of a BNSF train outside  Casselton, North Dakota, FRA issues any directives to Warren Buffet and/or Berkshire Hathaway regarding the movement of hazardous materials over the BNSF.

In addition, FRA knows, or should know, such close-call confidential reporting systems cannot be implemented "directly" or "immediately" as they require negotiation and agreement with labor organizations; and that FRA's own initiating memorandum of understanding for the establishment of C3RSs is under revision.

We have reached a point where press conferences, what will generate a "buzz," is determining rule-making, and that undermines the integrity of the process itself, jeopardizing the development and implementation of practical, and vital, programs for improving safe train operations.

David Schanoes

January 12, 2014

Better railroading of, and by, better railroaders