Ten90 Solutions LLC

So, maybe you noticed.  I've been quiet for awhile, hoping to burnish my reputation as a serious, thoughtful, experienced professional in this business...

Well, enough of that.  I don't think it's worked, and it certainly hasn't been much fun, and if it's not much fun, it's not worth it.  

I've been quiet for months waiting for the NTSB to release its final report on the highway/rail collision at the Commerce St. crossing in New York that took place back in.......2015.  

So where's the report?  What takes two years to determine what happened and why at a grade crossing?  

My report?  

Ban the use of cellphones by drivers.  Enforce ban.

Place cameras at all grade crossings (why not? We're putting them in locomotive cabs). Impose fines on all vehicles photographed violating the crossing protection warnings. 

I've been quietly waiting for the NTSB to issue reports on the fatal injuries to Amtrak MOW employees about a year ago.  

Here's my report:  Employees given absolute authority to occupy a section of track should not be allowed to keep or transfer that authority when they leave the property, but must return authority to the train dispatcher.  Leaving the property nullifies the authority as it nullifies the ability of the employee-in-charge to actually function as the employee-in-charge.  Employee goes home. Employee is no longer in charge.

Work needs to continue?  A new authority must be issued.  How do we do that?  How do we do anything? We schedule. 

I've been quietly awaiting for anyone, anyone at all to explain the collision between MOW equipment and a passenger train operating at maximum authorized speed, in an interlocking, on the Long Island Rail Road.  

So here's my report.  The accident was caused by the application of jumpers in the interlocking to bypass the occupancy indications when one end of the crossover was reversed for maintenance.

Use of jumpers in an interlockings to bypass occupancy indications should be eliminated. If jumpers are used, the most favorable signal indication for any route on any track in the interlocking should be proceed at restricted speed.   

I've been quiet while a derailment at Penn Station disrupted a week's worth of service... because I'm pretty much speechless that a low-speed derailment was allowed to disrupt a week's worth of service-- and please don't tell me about ladders, and double slip switches, and track circuits, and  blah,blah,blah.  Our job is to find a way to restore service no matter what.  

I've refrained from commenting on FRA's update on progress made, or not, with the installation of PTC. 

FRA reports that Amtrak has submitted its PTC Safety Plan and has PTC in operation on 67 percent of its track.

FRA reports that BNSF has received conditional certification for its PTCSP and has 56% of its track so equipped.  

CSX has received conditional certification and 28% of its track equipped.  

SEPTA has received conditional certification with 99% of its track equipped.  

SCAX (Metrolink) has 99% of its track equipped.  

Now that's not a lot, only 10,102 miles given the track that must be equipped, 62,149 miles, but it is significant, and there are now a significant number of daily train movements where PTC enforcement is operational.  

So.....so I'm waiting for the performance report. Aren't you?  

According to 49 CFR 236.1023

(c) a railroad shall: (1) specify the railroad's process and procedures in its PTCSP for action upon their receipt of notification of safety-critical failure as was as receipt of a safety-critical upgrade, patch, revision, repair, replacement, or modification.

and

(e) (1) Notify the applicable vendor or supplier or vendor and FRA of the failure, malfunction, or defective condition that decreased or elminates the safety functionality.

We're not talking technology here, we're talking about operating safety, and as such,incidents where PTC improperly functions, not just those where PTC fails to enforce a braking requirement, or a speed requirement, or an authority restriction, but also those in which PTC initiates an unwarranted action, require investigation and analysis.

Is FRA collecting, requiring, submission of data from railroads regarding a)number of PTC initiated brake applications b)number of  PTC failures to initiate brake applications c) number of improper or unwarranted PTC initiated brake applications d)number of PTC initiated brake application for trains when required to stop  e) number of PTC initiated applications when trains exceed temporary, or permanent speed restrictions? 

Anecdotal reports from some railroads, and the early statistical reports from PTC operation on Metrolink indicate a significant number of failures of the PTC system to properly function and/or operating crew failure to comply with PTC required actions. Anecdotes don't cut it.

But there is good news...... Take a look at the ten year operating trends in the FRA's safety database.  

The trend is your friend, and the trend is good.

Between 2007 and 2016, total train accidents declined 21%, total fatalities declined 6%, employee on duty deaths down 17%, non-fatal employee on duty accidents down 27%, derailments down 41%, hazmat releases down 78% (twice as great as the decline in hazmat cars handled), and a 79% decline in mainline collisons.  

The good numbers are still really good after adjusting for the decline in employee hours worked, down 9.5%, and the 13% decline in total train miles over the 2007-2016  period.  

So even if NTSB can't answer certain fundamental questions; even if PTC is delayed, and its performance has not been analyzed, railroads and railroading are safer.  And that's because, the vital processes of the railroad, the rules, regulations, systems, and supervision, for designing, installing, maintaining, measuring, testing, organizing, enforcing, and disciplining safe train operations are so deeply embedded in every detail of railroad operations.  Part of that, I like to think is the product of railroad professionals who recognize the importance of not being quiet.

David Schanoes

May 9, 2017

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