Ten90 Solutions LLC

Speaking frankly, which I am so hesitant to do, much disservice has been done to our industry by those who want to help.  Really.  I'm sure that they, those who want to help, have the best of intentions, but we all know where intentions get us--probably on a "no-fly" list.

First we need to ask how is it that  the well-intentioned, the concerned, the responsible, produce this disservice?  What is the root cause?

The answer is, as most things on the railroad are, simple in its identification, difficult in its application. 

Usually, the source of the disservice is an attempt to mitigate a problem, or prevent a reoccurrence without first grasping the root cause of the problem.  No root cause of the problem, no root cause in the solution, and that's the root cause of the disservice.  The problem, the practice, the behavior is not explored at its source-- remedies are proposed that the well-intentioned are convinced will eliminate the manifestations of the problem rather than the problem itself.   

The specific principles of safe train operation are not apprehended, understood, or utilized in these attempted solutions, and that absence is more than omission, it is an act of comission against the principles of safe train operations presented, or excused, as an enhancement to safety.  Odd, isn't it? Truth is stranger than fiction.  For example...

For example after the December 1 2013 derailment on Metro-North the issue of seat belts for passengers was raised, and by more than one person.  "Airlines do it," those of us in this business were told, "railroads should do it." 

No, not exactly.  Airlines do it because everybody on a plane gets a seat and must have a seat.  That is one of the principles of safe plane operation.  That is not a principle of safe train operation.  It cannot be because a) unlike planes, not everybody on a train gets on at a single location b) unlike a plane, not everybody who gets on at any location gets off at the same station as anybody else on the train and c) no railroad can meet its obligation to deliver a scheduled service if train movements are limited to passengers with seats and only when all such passengers are seated and seat-belted.

Safe train operations have been, currently are, and will continue to be achievable, to the highest degree and to the lowest risk,  when passengers stand, when they walk around, when they can't find seats,  because the risk of injury during train movement is mitigated by the principles of safe train operations-- which are 1) the knowledge of and compliance with operating rules and procedures by the train and engine crews, and the supervision of the crews; 2)the testing and maintenance of the rolling stock and it's ability to satisfy the signal design distance to zero velocity from any speed; 3) the proper maintenance of track to prevent sudden lateral or vertical accelerations that might produce injury;4) the design, maintenance, and functioning of the signal control system such that safe separation of trains is maintained even when the signal control system fails. 

The nonsense about seat belts is one example of a disservice, minor and easily dismissed.

Not so minor or easily dismissed is the push from FRA to all railroads, and the directive from FRA to Metro-North to install close-call confidential reporting systems that would protect not only employees who report safety violations, but also protect employees who commit safety violations.

The explanation for this directive is derived from the notion that employees on railroads are prevented from truthfully reporting operating rule violations, unsafe conditions, and unsafe behaviors by the disciplinary systems railroads have developed, (with the participation and agreement by the way of labor organizations and the Railway Labor Board), to investigate, determine responsibility, and enforce sanctions when such violations occur. 

There's a lot of anecdote and very little evidence to support the notion that train and engine service and other transportation employees are indeed intimidated and hindered from reporting unsafe conditions by the disciplinary process, or that employees will take such actions when shielded from the investigation/enforcement/discipline process.

Data from the three railroads where C3RS is in limited use is pretty hard to come by.  I know of only two releases of information, both, I think concerning the North Platte service division of the Union Pacific where a substantial drop in run-through switches (presumably in yards) correlates with the introduction of C3RS. 

There may be other evidence of effectiveness on the UP, New Jersey Transit, or Amtrak railroads,  but I haven't seen it released by FRA, DOT, Volpe, or the railroads themselves. That might be my personal shortcoming, though.

But since anecdote is so important to C3RS,  I will tell you this anecdote based on my experience with a form of C3RS-- "Operation Red Block"-- by which an employee could confidentially report himself, or another employee as a violator of the railroad's substance abuse policy, and receive help, counseling, treatment at the railroad's expense, without the threat of discipline as long as the employee agreed to follow up random drug and alcohol testing.  

Again, this is anecdote, not analysis of evidence of frequency of use or effectiveness.  One night at about 7:30PM, I was working in my office, catching up on paperwork that I had neglected for.... for as long as I could.  I had the railroad radio on in my office, as I always did, and I heard one of the district train dispatchers talking to the locomotive  engineer of a New Canaan bound rush hour train as to the reason for his delayed departure from Grand Central Terminal. 

The engineer on the train was not the regular engineer.  His voice was unfamiliar to me. And the responses he gave were garbled at best. The more I listened, the more I was convinced that this engineer was drunk. Not just mildly intoxicated, but slobberingly drunk.  I called the chief train dispatcher and told him what I thought was going on and we agreed that the train should be stopped at the first practical place and held until I arrived with a relief engineer.  

That we did.  We delayed the train at least an hour until I could get there with the relief engineer.  When I opened the cab door, the engineer almost fell out of the seat onto the floor.  I removed him from service, put the relief engineer in the seat, and walked to the platform, holding up the original engineer, awaiting the trainmaster for that section to meet me and follow through with the testing and the paperwork. 

By the time I got back to my office, it was almost 10 PM.  The voicemail box on my telephone contained messages from five different rank and file employees who worked with this individual in the location and on the trains he usually worked (which was not the mainline, and did not involve trips to GCT).  This was his day off and he had taken this job for the 6th start overtime pay. 

All five thanked me for removing this individual from service as all five knew he had a long-standing problem,"for years,"  as in showing up to work intoxicated everyday; as in drinking while working.

 All five asked if I might try and arrange for the "Red Block" bypass of discipline to be made available, despite the fact that this individual was not entitled to utilize the program having performed service thus risking the safety of employees and passengers, while in violation of Rule G. 

None of the five had bothered to use the confidential "Red Block" reporting system to report this individual and obtain help for him.  None.   That means not one. Zero.  O-zer.  Nada.

But you know what? We can live with that, with the employees thinking they are "protecting" one of their own and not reporting the problem, because our principles for safe train operations are not determined by such employee confidential reporting. 

Our principles for safe train operation require that the supervisor where ever and whenever the employee might be unfit to perform service immediately intervene to prevent that employee from performing that service.  What the railroad cannot live with is supervisors knowing exactly what the co-workers know (and we do, believe me) and failing to act.    

Which gets me to this.  The greatest well-intentioned disservice is the one that proclaims  that Metro-North emphasized on-time performance at the expense of safety. This assertion has actually been repeated by, and has become the basis for a plan of action by the management of the railroad itself.   The new president of the railroad has been quoted as saying:  "I needed to take the focus off increasing on time-performance to make sure everyone knew our first priority is safety."  Those might sound like words to live by, but the sound isn't quite right to my non-tin ear.

Now is there any evidence that reducing the performance goals of a railroad, reducing the desired level of OTP to 93% from 98% improves safety on a railroad?  If reducing OTP goals from 98% to 93% improves the focus, and the achievement of safe-train operations, why is 93% OTP as opposed to 85% or 75% OTP preferable?  Wouldn't 85% be more safe?

The answers are, in a nutshell, no and no.  There is no evidence.  It would not be safer.  There is evidence to the contrary and right on Metro-North itself for the decline in on-time performance correlates (not exaclty of course, there's always a lag) with the increasing number of incidents.  You can look it up.  

Why is that? It's that because the principles for safe train operations are designed to operate, to govern, to be in effect, 100% of the time.  For the railroad to be safe at 93% OTP, it has to be safe at 100% OTP.  The principles for safe railroading are absolute.   

Delays are by definition exceptions; if your signal control system is designed to maintain safe train separation at speeds up to 80 or 90 mph, then reducing the speed to 60 mph does not improve the safety of the signal control system. 

If your vehicles are designed to achieve rates of deceleration and acceleration, supporting your schedule, the vehicles are then designed to support that schedule 100% of the time not 93% and the standards for maintaining the vehicles is for 100% performance, not 93%; if the track has to be maintained to a certain standard to support your operating program, your service delivery, not maintaining the track to that standard degrades performance and safety.  Most importantly, if we train, test, qualify, supervise our crews for safe train operations, we train them to operate safely 100% of the time; we train them to operate on-time and safely 100% of the time.  We cannot "gear down" a railroad for less than optimal performance, optimal efficiency and  think we are enhancing safety; we cannot evade the absolutes of safe train operations; we can only meet them when the railroad runs  at 100% of plan.  

March 26, 2014

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