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Preservation, Safety, and Compliance
https://rypn.org/forums/viewtopic.php?f=1&t=40294		 Page 1 of 1
Author:  hotbox [ Fri Jan 27, 2017 1:49 pm ]
Post subject:  Preservation, Safety, and Compliance
Many times smaller heritage/ preservation operations don't get the same level of attention from the FRA as Class I, Regional, and Shortline Conglomerates do. This can be both good and bad. It might mean you can get away with more stuff for while but, it also means you don't have the same level of guidance available for things that do actually apply to your railroad.

There are operators that don't know where to find the information they need. Below is a link to the Online CFR title 49 parts 200 - 299. These are the most up-to-date version of federal regulations that effect railroads.

http://www.ecfr.gov/cgi-bin/text-idx?SID=77329a6410243a0cef4f8ff4525918f7&mc=true&tpl=/ecfrbrowse/Title49/49cfrv4_02.tpl#0

Disclaimer: Reading from the CFR doesn't make you the subject matter expert especially when you deal with the FRA. It is always best to reach out and talk to your LOCAL INSPECTOR and communicate with them regularly. There are different "disciplines" in the FRA just like the crafts on a railroad.

There are Track inspectors, in addition to looking at the track and bridges these inspectors also address issues involving maintenance of way workers (roadway workers.)

Signals & Train Control (ST&C) inspectors look at crossing signals, Power operated switches, wayside signals, portions of locomotives and railcars, and of course highway crossings.

Motive Power & Equipment (MP&E) inspectors look at cars and locomotives as well as employees working in the shop. They also inspect EOTs and observe brake tests and securement of equipment.

Hazmat inspectors shouldn't really effect most preservation operations, but their job is self explanatory.

Operating practices (OP) inspectors cover anything that a railroad employee does. They review records for hours of service, drug testing, accident/ incident reporting, engineer and conductor certifications, and employee testing programs.

Each inspector is different as far as enforcement tools that they use. They don't always stay in one place, so assuming that everything is fine since you haven't seen an inspector in years may be quite a folly. You may have a new inspector who has never heard of your operation. They often have plenty of work with class Is and busy shortlines so museums fall low on the priority list. If you ask for help, particularly if it is documented in an email, FRA / PUC inspectors will provide what they can.

There are lots of resources available through shortlines and class Is. Genessee and Wyoming, although not friendly to museum and shortline operations on their lines, has been happy to provide and share company-wide circulars related to industry events and even to offer seats in their own training classes for ANY railroad who wishes to send its employees (this includes tourist lines and museums.)

If anyone running through trackage rights or partnerships with larger railroads has access to the various "industry briefings" that frequently circulate through the railroads please share them as the become available.
Author:  Mike Tillger [ Fri Jan 27, 2017 11:12 pm ]
Post subject:  Re: Preservation, Safety, and Compliance
The FRA maintains an elibrary, it contains compliance manuals which can be helpful with some interpretation of the rules.https://www.fra.dot.gov/eLib/Find#p1_z5_gD_lCM

Mike Tillger
Author:  robertmacdowell [ Sat Jan 28, 2017 4:39 am ]
Post subject:  Re: Preservation, Safety, and Compliance
hotbox wrote:
Many times smaller heritage/ preservation operations don't get the same level of attention from the FRA as Class I, Regional, and Shortline Conglomerates do. This can be both good and bad.

And intended. Read 49 CFR 209 Appendix A.

Preservation suffers an endless parade of starry-eyed foamers who pleasure themselves reading the track alignment tables and other technical data, and ignore the deadly dull "formality stuff" which is actually about 2/3 of the regs. And about 7/8 of the work!

No. That stuff's important. You will find that some regs don't apply to you. If you don't haul revenue freight on your line for hire, you'll find that *most* of the regs don't apply to you. The slang for this category is "FRA-Lite".

The problem is, most of the industry is deeply blue-pilled in the general-system rules. Most of them haven't read the deadly-dull sections any more than you have. I have records of back-n-forths where the FRA man comes out, inspects, finds 34 defects, then later says "um, turns out you're exempt, nevermind" and is never seen again.

For a non-general-system tourist railway, talking to the local FRA men, or going to shortline railroads, is a mistake. They will lead you terribly wrong. Many don't even believe FRA-Lite exists or could exist. It does. Really.
Author:  hotbox [ Sat Jan 28, 2017 11:03 am ]
Post subject:  Re: Preservation, Safety, and Compliance
This is the FRA's "Decision Tree." Hopefully this will be helpful to organizations that are unsure what applies to them.

Attachment:
Tourist Tree and Decision - USC Codes for NON INSULAR operations 130325.pdf [140.23 KiB]
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Author:  MD Ramsey [ Sat Jan 28, 2017 4:10 pm ]
Post subject:  Re: Preservation, Safety, and Compliance
This is a good discussion and it is good to have an understanding of what regulations apply and do not apply to various types of tourist/excursion operations. In most cases, the FRA will help as much as they can and should be able to answer questions and clarify. Always start with the FRA region that you are in, and if not sure, visit the FRA webs site at FRA.dot.gov in the Railroad Safety Section. Most FRA regions have a Chief Inspector that is assigned to be a liaison with short line and tourist railroads in their assigned district. They are their to help. I am also available to assist and point you to the appropriate FRA regional office and answer any questions that I can. Other good resources besides those mentioned above are Heritage Rail Alliance (formerly ATRRM) and the American Short Line and Regional Railroad Association (ASLRRA).

During my 15 years of experience in the tourist railroad industry and 20 years with the FRA, I have found that all the FRA regulations, applicable or not too a specific operation, are minimum standards. Even if one wouldn't have to comply with a particular applicable regulation, it is still good to use it as a standard. It can't hurt.

My 2 pennies

Mike Ramsey
Passenger Rail Specialist
FRA
michael.ramsey@dot.gov
Author:  hotbox [ Mon Jan 30, 2017 11:31 pm ]
Post subject:  Re: Preservation, Safety, and Compliance
CN notes dangerous vandalism.


Attachment:
Notice-bulletin901-2017_01_27-Safety flash - railway car vandalism.pdf [293.69 KiB]
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Author:  Randy Hees [ Tue Jan 31, 2017 12:15 pm ]
Post subject:  Re: Preservation, Safety, and Compliance
At the Nevada State Railroad Museum, Boulder City and its associated Nevada Southern Railway, we see the Nevada PUC and FRA frequently.

After a year of interaction as Director, and noting that at my last museum we were completely insular and essentially un-regulated (a horse drawn narrow gauge railroad with no public grade crossings) the FRA and PUC are welcome, friendly, and help rather than hinder. In general,they are more likely to try to find a way for us to be compliant rather than "enforce".

As the director, they are the big hammer when having discussions with volunteers who want to cut corners.

There are only a couple of areas where they become burden-sum...

1) the Bridge Management plan... which I fully understand, but which requires an engineering staff (as of Sept 2017) which as a 5 mile long railroad we don't have. As a result I have to hire a bridge engineer or convince Ndot to inspect the bridges annually, in a way that is compliant with FRA instead of bi-annually as they currently do to highway standards... I would also note that the bridge rules include turntables, even on highly insular railroads (but not on transit lines so SF cable cars are exempt) and is the first FRA rule enforced at our sister museum.

2) Rules do not allow particularly recognize "museum" equipment as a special class, so a photo freight is an expensive proposition, with each car needing a waiver (over 50 years old) a bi-annual air-brake test (not just a apply and release... a full test with certified equipment). We outsource ours for the passenger equipment... the cost of doing the freight is "not in the budget") and recently, a bi-annual "comprehensive inspection" including lifting the car and pulling the trucks for inspection (this makes sense for the freight based cars used in passenger service, but is hard to justify for a box car that will move less than 25 miles in two years and will never leave our railroad.)

How do others operate rules compliant photos freights?

Randy
Author:  JimLundquist [ Tue Jan 31, 2017 8:19 pm ]
Post subject:  Re: Preservation, Safety, and Compliance
Randy: excellent question. Might it be that some inspectors use the "reasonable man" approach - a freight train moving at 10 MPH on tracks not used for any other purpose at that time - what is actually needed vs what is required?????
Author:  robertmacdowell [ Tue Jan 31, 2017 8:33 pm ]
Post subject:  Re: Preservation, Safety, and Compliance
The "reasonable man" approach is largely baked into FRA's regulations, regarding treatment of off-general-system tourist roads.

You will run into people who have a set of core beliefs in which the government is always harshly authoritarian and unreasonable, and tend to shape their presumptions and experience to fit their beliefs. Because of this, you must treat any such information with a grain of salt.
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