Ten90 Solutions LLC

So, we've heard from our cousins across tha Atlantic, who, while having great experience and success with close-call confidential reporting, do not include employee operating rule violations under the C3RS protective umbrella.

But what about our railroads? FRA has been sponsoring pilot programs since 2007.   Four properties institued C3RS programs, using FRA's template for a Memorandum of Undestanding to fashion the terms of agreement with their labor  organizations.  Those four original pilot programs were conducted on Union Pacific North Platte Service Unit, Amtrak (confined to yard operations), New Jersey Transit Rail (systemwide), and Canadian Pacific Railroad. 

Canadian Pacific ended its participation in 2012, I think.  No information about that program is available on the closecalls website. 

Union Pacific ended its participation in 2013 (I think), with data now removed from the website, but material I archived in 2012 clearly identifies the North Platte Service Unit as the site of UP's program. . 

My criteria for evaluating and determining if the pilot programs had significant impact on operating rule violations and accidents might be different than the criteria others use. 

Some think that I  don't care for anecdotes, or about "feelings,"  "confidence,"  "trust," etc. etc. 

That's not true, I do care about them.  I just don't care about them as much as I care about real data and real evidence.  We would not develop or alter a business plan based on anecdotes or feelings.  I don't see why we would alter or modify a system safety plan based on those things.

I think those making claims for the improvements in safe train operations that will flow from C3RS have an obligation to provide detailed, extensive, analyses of data if they wish those claims to be taken seriously by those conversant with and responsible for the  safe train operations. 

FRA's Office of Railroad Policy and Development, in its newsletter, Research Results, published two  articles reporting significant declines in switching accidents and derailments due to movements over a "run-through" switches subsequent to the activation of C3RS pilot programs.  The reports conclude that the protection of employees from discipline made it easier for the employees to report running through a switch, thus leading to timely repair and a derailment of either the employees' train, or a subsequent move over the switch.  

I found the reports very interesting, for a couple of reasons.  The first reason is that I worked as a trainmaster in freight terminals for several years.  My territory included both flat-switching and gravity hump yards.  Except for the switches leading into the classification yard from the top of the hump, all the switches were manually operated. And never once, in those years in those yards did I  pursue formal discipline when a crew voluntarily reported running through a switch.  Not once.  Ever. 

Better than that, I don't know of any of my colleagues working those yards who pursued formal discipline when a crew voluntarily reported running through a swtich.

Why was that?  Was I less of  "disciplinarian" in my youth?  Not hardly. 

Why didn't I pursue discipline?  Because it wasn't worth the hassle? No, because on any given day, the most reliable and productive crew I had working, the crew I was absolutely grateful to have working the hump, or the pullout, might run through a switch. I would not pursue discipline against them.

And if I didn't pursue discipline against the  best crew when that crew ran through a switch, I couldn't pursue it against the "middling" crews, the "average" and the "below average" crews.

It was a simple matter of equitable treatment.  

Imagine that.  Trainmasters making decisions based on equitable treatment without ever having heard the words "just culture" uttererd by a Ph.D., or a member of a government organization?  Who would have thought?  Who would believe?

The second reason I found the reports interesting is that it gave me a reason to go search the safety data FRA provides on its website.  There are lots of statistical summaries on the website, but I focused my efforts on the ten year overview.

Reasonable person that I am, I thought it was reasonable to look at the trend for the railroads involved in the pilot programs where I had at least some information.  Reasonable person that I am, I thought it reasonable to compare the number of incidents occurring in 2014 versus 2005 in specific categories.  Reasonable person that I am, I thought it reasonable to use the following categories:

train accidents (thus eliminating incidents, grade-crossing events, etc)- abbreviated below as TrnAcc; 

human factor accidents because that's the target area for C3RS-- abbreviated below as HuFactor;

derailments since that was one of the concrete categories FRA had studied-- abbreviated below as DeRl; 

yard accidents as most of the C3RS reporting takes place in yard environments.

The subject railroads selected were:

Class 1s including Amtrak to represent the industry as a whole-- designated below as C1+Amtrak;

Amtrak;

NJT;

Union Pacific (UP); 

Union Pacific, North Platte Service Area--designated below as UP-NPlatte. North Platte is within FRA Region 6.  FRA statistics can be sorted by railroad and FRA region

Now ladies and gentlemen, the moment, and the numbers we've all been waiting for:

Ten Year Comparison 2014 v. 2005, Change in Number of Incidents Expressed as Percentage

RR          TrnAcc   HuFactor   DeRl     Yd Acc C1+Amtk    -61%      -62%        -61%   -59%  Amtrak       -52%      -16%        -34%    -31% NJT             -27%      +19%        +83%   +75% UP               -62%      -73%         -63%    -61% UP-NPlatte -53%      -71%         -51%    -59%

Let me say, I'm no statistician.  After that, let me say that US railroads made remarkable strides in safe train operations during the ten year peiod.  Let me also say that it appears those railroads, and portions of railroads where the pilot programs were operational, performed slightly less well than the overall industry. 

Let me repeat, I'm no statistician, and maybe I'm missing something or everything.  Or maybe I'm missing nothing.  Maybe there is no evidence for any significant improvement in safety performance under the umbrella of close-call confidential reporting.   

Maybe I'm wrong when I say that those advocating expansion of C3RS to  protect decertifiable violations have failed to make a case for improved system safety and reduced risk. 

Maybe I'm not wrong. Maybe those advocates need to stop and listen to the "military-like" "punishment prone" trainmasters, those who are conversant with and responsible for safe train operations, and who, despite all their limitations, know enough to act equitably. 

November 29, 2014

"The theory that all negligence which causes serious disaster will always be found to have been more or less habitual is still worthy of respect"--

Railway Gazette, Vol 21, 1889 (with thanks to PN)