SMART Transportation Division President Jeremy Ferguson has requested that the Federal Railroad Administration issue an emergency order to carriers that train car valves prone to leakage during cold temperatures be replaced and/or repaired immediately.
“The FRA and the AAR have known about this issue for too long and have done too little to address it in a timely fashion. The safety of the public and all railroaders should never be compromised for the sake of productivity,” he said. “Our organization will not tolerate such behavior, nor will it go unchecked.”
The DB-60 II control valve manufactured by New York Air Brake is shown in this image from the manufacturer’s website. This model uses the DB-10 as one of its components.
The malfunctioning main air brake control valves on cars prevent trains from going into emergency braking mode during cold weather.
In a letter to FRA Administrator Ron Batory sent Dec. 20, President Ferguson expressed his strong disappointment that a known safety issue has not been addressed by the agency or the carriers for more than six years.
“It is unacceptable that the malfunctioning valves remain in service after the better part of a decade without proper oversight and enforcement,” Ferguson wrote. “It is equally unacceptable that the carriers, rather than fix the problem, issue stopgap remedies to solve what we have been informed is a basic issue of preventive maintenance that costs approximately $200 and as little as two hours to repair.
“It is our opinion that your agency has not done enough to ensure that the safety of rail workers and the public is protected by enforcing its own regulations.”
SMART-TD informed FRA of suspected valve failures in a letter that was sent to FRA’s Region 8 in February 2019 by Dakotas State Legislative Director Jim Chase. Former National Legislative Director John Risch followed up with a series of communications on the issue as well.
FRA advised SMART-TD that it is examining the issue and has made recommendations to carriers as to how to rectify the situation.
“I’m not real satisfied with what’s been done here,” Chase said, saying that a pair of FRA rules appear to not have been stringently enforced for six years.
It should be noted that the FRA rule §232.103(i) states:
“(i) All trains shall be equipped with an emergency application feature that produces an irretrievable stop, using a brake rate consistent with prevailing adhesion, train safety, and brake system thermal capacity. An emergency application shall be available at all times, and shall be initiated by an unintentional parting of the train line or loss of train brake communication.”
Also not being enforced, Chase said, is:
§232.105 General requirements for locomotives.
(a) The air brake equipment on a locomotive shall be in safe and suitable condition for service.
(g) When taking charge of a locomotive or locomotive consist, an engineer must know that the brakes are in operative condition.
New York Airbrake valve DB-10 was initially approved for a finite useful life by FRA. At the behest of carriers, who raised concerns about the cost of replacing these valves on thousands to tens of thousands of private cars, the valve’s use has been extended, with a number of the valves in service having components being used beyond their useful period.
Each affected train car has a single valve on it that consists of two chambers, one that supplies air for service brake application for the train and one that supplies air for an emergency brake application. Any failure of this valve could conceivably affect a train’s stopping power while it is in motion.
Swapping out of the valves used to be a regular occurrence, according to a representative from the SMART Mechanical Department (SMART-MD).
“They used to change these valves along with all air components every eight years,” said Larry Holbert, a SMART-MD international representative.
Changing the service or emergency portion of the valve involves the removal of three bolts and replacing gaskets, Holbert said. But now, according to reports Holbert’s been getting from the field, this maintenance is done on a catch-as-catch-can basis, rather than as a preventive measure, and a leaky valve is a tricky malfunction to track down, he said. The lubricants used for the pistons in the valves dry up over time, and the gaskets also can become brittle, leading to air escaping.
“One of the main concerns is the valve will fail in the winter months. The car will be brought into the shop and pass an air test as the O-rings and seats have warmed up,” Holbert said.
SMART-TD members, who operate trains in cold-weather states, indicate that weather below 40 degrees F brings increased instances where these valves possibly fail. As a result, trains in an incident where cars have separated may not go into emergency. And, an emergency brake application by the crew during such an incident may fail because of insufficient air pressure.
In one instance, Chase said, a coal train broke in two near Dengate, N.D., and the detached cars rolled backward for miles because the rear of the train did not go into emergency mode. He said another incident in Hettinger, N.D., also involved a train splitting and cars rolling backward for a substantial distance after emergency mode failed.
Chase said he has experienced two occasions just this month in North Dakota where emergency capability has been lost on trains he has operated.
“The public and employees have the right to be safe,” Chase said. “I can think of nothing more important than having emergency capability.”
A local chairperson from the Brotherhood of Locomotive Engineers and Trainmen recently reported Dec. 9 that a locomotive failed to go into emergency as well.
The malfunctioning valves, when discovered, are trucked out by carriers and taken to be rebuilt by Wabtec, a Pittsburgh, Pa.-based company, at an estimated cost of just over $180, Holbert said. Holbert estimates that if the necessary parts were in hand once a failing valve was identified, a properly equipped shop could service the valves in a half-hour or less with “minimal” time spent for carriers to swap the bad valves out.
“It’s frustrating to see this occurring. They used to do the preventative maintenance,” Holbert said.
To SMART-TD leadership’s knowledge, carriers operating in cold weather have not issued any warnings about potential valve failures. With the coming onset of winter, the potential for failures could become more prevalent.
Chase said that carriers have been reluctant to allow valves to be tested, because of potential delays to their ability to serve customers, given that there are possibly tens of thousands of private cars equipped with the DB-10 valves that could fail.
In-cab personnel are advised:
Evidence of the symptom begins with increased brake pipe air flow from the controlling (lead) locomotive after a brake application has been initiated. Increased head-end air flow is caused by leakage from the bottom cover exhaust port of the DB-10 service portion on the brake control valve.
When the air is set during an air test, if air is heard leaking out of the bottom of the valve, it is defective. If the person at the controls of the locomotive notes excessive air flow during application of the train brake, pay particular attention to an audible blow of air coming from the vent of any DB-10 service portion that may be in the consist.
A workaround that has been advocated by carriers is not safe, Chase tells SMART-TD members.
“We have been instructed now to draw the train down to zero brake pipe pressure before we separate the train to set out a bad ordered car, thus circumventing the process by which we are able to determine if the train will make an emergency application should we actually need to do so after we leave the terminal,” he said in his alert memo.
“I cannot overstate how dangerous this new procedure is. The ability of the train to go into emergency is paramount.
“We didn’t initially realize the scope of this issue. We need to start documenting emergency brake failure incidents. It’s important that somebody other than the carrier is notified. Please contact your local SMART-TD safety leadership so that we can develop a database to document this issue,” Chase said.
Members should reach out to their state legislative directors, local legislative representative, or to the SMART-TD National Rail Safety Team to report safety concerns surrounding this issue and any others that may come up. These representatives are here to work for you and to help protect you on the job.
WASHINGTON – The U.S. Department of Transportation’s Federal Railroad Administration (FRA) Nov. 25 issued a safety advisory to the rail industry to better protect rail employees working on active tracks, or right-of-ways, under the supervision of a dispatcher.
“Clear communication is critical to keeping employees out of harm’s way,” said U.S. Transportation Secretary Anthony Foxx. “I want railway workers to return home safely to their families after their shift and it is the responsibility of the railroads and their employees to keep the work environment as safe as possible.”
Safety Advisory 2014-02 Roadway Worker Authority Limits, highlights the need for railroads to ensure that appropriate safety redundancies are in place in the event an employee fails to comply with existing rules and procedures. The advisory describes several related incidents and stresses the importance of clear communication and the need for railroads to monitor their employees for compliance. This Safety Advisory satisfies one National Transportation Safety Board (NTSB) safety recommendation related to dispatchers and partially addresses another related to redundant signal protection.
There are three safety measures in the advisory designed to reduce incidents that FRA expects railroads to take action on immediately:
Increase monitoring of their employees for compliance with existing applicable rules and procedures.
Examine train dispatching systems, rules, and procedures to ensure that appropriate safety redundancies are in place.
If a railroad determines that appropriate safety redundancies are not in place, adopt electronic technology—such as the Enhanced Employee Protection System, Hi-Rail Limits Compliance System, and the Train Approach Warning System—that would provide appropriate safety redundancies.
Until such technologies are in place, railroads should stress importance of dispatchers being advised of roadway workers’ whereabouts and work plans; forbid student dispatchers from removing blocking devises until confirmed by a supervisor; and that, prior to passing any absolute signal, a roadway worker should verify the limits of his or her authority.
FRA believes positive train control, a system for monitoring and controlling train movements to enhance safety, would have prevented the incidents described in the Safety Advisory.
However, where Positive Train Control is not in effect, FRA recommends that railroads adopt one or more electronic technologies that may serve to fill the technology gap and safeguard roadway workers.
WASHINGTON – The U.S. Department of Transportation May 7 issued an emergency order requiring all railroads operating trains containing large amounts of Bakken crude oil to notify State Emergency Response Commissions (SERCs) about the operation of these trains through their states.
Additionally, DOT’s Federal Railroad Administration and Pipeline and Hazardous Materials Safety Administration issued a safety advisory strongly urging those shipping or offering Bakken crude oil to use tank car designs with the highest level of integrity available in their fleets. In addition, PHMSA and FRA advise offerors and carriers to the extent possible to avoid the use of older legacy DOT Specification 111 or CTC 111 tank cars for the shipment of Bakken crude oil.
“The safety of our nation’s railroad system, and the people who live along rail corridors is of paramount concern,” said Transportation Secretary Anthony Foxx. “All options are on the table when it comes to improving the safe transportation of crude oil, and today’s actions, the latest in a series that make up an expansive strategy, will ensure that communities are more informed and that companies are using the strongest possible tank cars.”
Effective immediately, the emergency order (Docket Number DOT-OST-2014-0067), requires that each railroad operating trains containing more than 1,000,000 gallons of Bakken crude oil, or approximately 35 tank cars, in a particular state to provide the SERC notification regarding the expected movement of such trains through the counties in that state.
The notification must include estimated volumes of Bakken crude oil being transported, frequencies of anticipated train traffic and the route through which Bakken crude oil will be transported. The Emergency Order also requires the railroads provide contact information for at least one responsible party at the host railroads to the SERCs. The Emergency Order advises railroads to assist the SERCs as necessary to share the information with the appropriate emergency responders in affected communities.
FRA and PHMSA also issued a joint Safety Advisory 2014-01 to the rail industry strongly recommending the use of tank cars with the highest level of integrity in their fleet when transporting Bakken crude oil.
The Department of Transportation continues to pursue a comprehensive, all-of-the-above approach in minimizing risk and ensuring the safe transport of crude oil. FRA and PHMSA have undertaken more than a dozen actions to enhance the safe transport of crude oil over the last ten months. This comprehensive approach includes immediate and long-term steps such as: launching “Operation Classification” in the Bakken region to verify that crude oil is being properly classified; issuing safety advisories, alerts, emergency orders and regulatory updates; conducting special inspections; moving forward with a rulemaking to enhance tank car standards; and reaching agreement with railroad companies on a series of immediate voluntary actions they can take by reducing speeds, increasing inspections, using new brake technology and investing in first responder training.
The Association of American Railroads issued the following statement in response to the emergency order: “Freight railroads have for years worked with emergency responders and personnel to educate and inform them about the hazardous materials moving through their communities. These open and transparent communications will continue as railroads do all they can to comply with the Department of Transportation’s Emergency Order.”
WASHINGTON – The U.S. Department of Transportation’s Federal Railroad Administration (FRA) Dec. 11 issued an industry-wide Safety Advisory to help ensure railroads adhere to federal regulations regarding maximum authorized train speed limits. The advisory contains four recommendations to ensure railroads comply with speed restrictions through appropriate operating policies, procedures and effective implementation.
“Safety is our highest priority, and the Metro-North crash illustrates how important it is for railroads to follow speed limits,” said U.S. Transportation Secretary Anthony Foxx. “This Safety Advisory, along with the other enforcement measures we’ve taken, will remind all employees of the need to follow speed limits and will help improve safety across all rail lines.”
The Safety Advisory provides guidance on four recommended measures FRA expects railroads to take action on immediately. Among them are:
Review the circumstances of the Dec. 1, 2013, Spuyten Duyvil derailment with their operating employees.
Provide instruction to employees during training classes and safety briefings on the importance of compliance with maximum authorized train speed limits and other speed restrictions.
Evaluate results of operational data regarding speed testing.
Reinforce the importance of communication between train crewmembers located in the controlling locomotive, particularly during safety-critical periods when multiple tasks are occurring and during extended periods of inactivity.
“Although the industry’s overall safety record is good, the Metro-North accident is a stark reminder of the need to remain vigilant in ensuring compliance with operational speed limits,” said Federal Railroad Administrator Joseph C. Szabo. “Over the last decade, train accidents have declined by 43 percent nationally, a result of our rigorous safety regime, but we must always do better as we drive continuous safety improvement.”
Last week, the FRA issued Emergency Order 29 (EO 29) to Metro-North Commuter Railroad (MNCW) directing it to take specific, immediate steps to ensure its train crews do not exceed speed limits. EO 29 requires Metro-North to modify its existing signal system to ensure that operators obey speed limits, and to provide two qualified railroad employees to operate trains where major speed restrictions are in place until its signal system is modified. The FRA also issued a letter calling on Metro-North to launch a safety stand-down with all employees and to fully implement the confidential close-call reporting system, which has helped improve rail safety on other lines. Metro-North has written the FRA to outline its plans to comply with the directives, and the FRA will continue working directly with Metro-North staff as they implement the provisions.
The FRA had already increased its oversight and enforcement of Metro-North’s rail lines following the May 2013 crash, including additional inspections of its lines and audits of Metro-North’s operations and compliance with federal regulations. FRA is also planning to conduct an extensive investigation of the carrier’s safety compliance with all regulated railroad safety disciplines.
To read the complete Safety Advisory 2013-08, click here.
WASHINGTON – The U.S. Department of Transportation’s Federal Railroad Administration (FRA) August 2 issued an emergency order and safety advisory to help prevent trains operating on mainline tracks or sidings from moving unintentionally. The FRA’s announcement was made in response to the July 6, 2013, derailment in Lac-Mégantic, Quebec, Canada, as it awaits additional data once the investigation into the crash is complete.
The actions announced today build on the success of FRA’s rigorous safety program, which has helped reduce train accidents by 43 percent over the last decade, and made 2012 the safest year in American rail history.
The emergency order is a mandatory directive to the rail industry, and failure to comply will result in enforcement actions against violating railroads.
“Safety is our top priority,” said U.S. Transportation Secretary Anthony Foxx. “While we wait for the full investigation to conclude, the department is taking steps today to help prevent a similar incident from occurring in the United States.”
The emergency order outlines measures that all railroads must undertake within the next 30 days:
•No train or vehicles transporting specified hazardous materials can be left unattended on a mainline track or side track outside a yard or terminal, unless specifically authorized.
•In order to receive authorization to leave a train unattended, railroads must develop and submit to FRA a process for securing unattended trains transporting hazardous materials, including locking the locomotive or otherwise disabling it, and reporting among employees to ensure the correct number of hand brakes are applied.
•Employees who are responsible for securing trains and vehicles transporting such specified hazardous material must communicate with the train dispatchers the number of hand brakes applied, the tonnage and length of the train or vehicle, the grade and terrain features of the track, any relevant weather conditions, and the type of equipment being secured.
•Train dispatchers must record the information provided. The dispatcher or other qualified railroad employee must verify that the securement meets the railroad’s requirements.
•Railroads must implement rules ensuring that any employee involved in securing a train participate in daily job briefings prior to the work being performed.
•Railroads must develop procedures to ensure a qualified railroad employee inspects all equipment that an emergency responder has been on, under or between before the train can be left unattended.
•Railroads must provide this emergency order to all affected employees.
For guidance on Emergency Order 28 implementation, click here.
“Today’s action builds upon a comprehensive regulatory framework we have had in place for some time,” said FRA Administrator Joseph C. Szabo. “The safe shipment of all cargo is paramount and protecting the safety of the American public is fundamental to our enforcement strategy and we are encouraged by the industry’s willingness to cooperate with this approach going forward.”
“This is an important step being taken by the FRA as the issue of the consists of crews is now in the public debate,” said SMART Transportation Division President Mike Futhey. “As a result of the actions taken by the FRA, coupled with the legislation entered by U.S. Reps. Michael Michaud (D-Maine) and Chellie Pingree (D-Maine), this provides our organization with the opportunity to ensure that train operation, as it pertains to the consists of crews, is performed in correlation with public safety.
In addition to the emergency order, the FRA, together with the Pipeline and Hazardous Materials Safety Administration (PHMSA), issued a safety advisory detailing a list of recommendations railroads are expected to follow.
U.S. DOT believes that railroad safety is enhanced through the use of multiple crew members, and the safety advisory recommends railroads review their crew staffing requirements for transporting hazardous material and ensure that they are adequate. Other recommendations in the safety advisory include: conducting system-wide evaluations to identify particular hazards that may make it more difficult to secure a train or pose other safety risks and to develop procedures to mitigate those risks. A copy of the safety advisory can be viewed here.
“When PHMSA talks about the transportation of hazardous materials, safety is a prerequisite to movement,” said PHMSA Administrator Cynthia Quarterman. “We are taking this action today and we will be looking hard at the current rail operating practices for hazardous materials to ensure the public’s safety.”?
As FRA continues to evaluate safety procedures following the recent crash, it will convene an emergency meeting of its Railroad Safety Advisory Committee to consider what additional safety measures may be required. FRA plans to develop a website that will allow the public to track industry compliance with the emergency order and safety advisory issued today. FRA has developed a plan that outlines six major actions that have occurred or will occur to further ensure that our regulatory response to the Canadian rail accident remains transparent.
Under current DOT regulations, all freight railroads are required to develop and implement risk assessments and security plans in order to transport any hazardous material, including a plan to prevent unauthorized access in rail yards, facilities and trains carrying hazardous materials. Railroads that carry hazardous materials are required to develop and follow a security protocol while en route; railroad employees are subject to background checks and must complete training. Training programs and protocols are reviewed and audited by the FRA routinely and generally designed to be progressive so as the level of risk increases so does the level of security required. A description of past, present, and proposed FRA actions on this issue can be found here.
The Federal Railroad Administration June 3 issued a safety advisory on the importance railroad safety procedures to ensure the safety of the traveling public and railroad employees when highway-rail grade crossing warning systems and wayside signal systems are temporarily removed from service for purposes of testing, inspection, maintenance, or repair.
Safety Advisory 2013-04 also notes that “under certain circumstances, particularly where human error is involved, the fail-safe features [of warning systems] can be deactivated or circumvented, creating the potential for an accident. FRA has found that serious highway-rail grade crossing accidents and false proceed signal failures have occurred due to human error.”
According to the FRA, the most effective practices to prevent this include requiring railroad employees to obtain proper authority from the train dispatcher or other appropriate personnel responsible for the movement of trains through the territory before disabling a warning or signaling system, and a requirement that all disabled systems be properly inspected and tested to ensure they operate as designed before being restored to service.
The list of recommended actions include:
1. Each railroad responsible for the proper operation of a highway-rail grade crossing warning system or wayside signal system review and evaluate its specific railroadwide instructions for the proper method for temporary removal of these systems from service. These instructions should address the following items:
a. The manner in which the deactivation is authorized.
b. The personnel designated to authorize deactivation.
c. The protocols for notifying appropriate persons, especially personnel responsible for the movement of trains, that a grade crossing warning system or wayside signal system has been temporarily removed from service.
d. The appropriate methods of providing for the safety of train movements while the grade crossing warning system or wayside signal system is temporarily removed from service.
e. The requirements necessary to perform an inspection and operational test of the pertinent system components before restoring the grade crossing warning system or wayside signal system to service.
f. The protocols for documenting and notifying appropriate persons that the grade crossing warning system or wayside signal system has been properly tested and restored to service.
2. Each railroad provide regular periodic training to all affected employees to ensure their understanding of instructions for the proper procedures for the temporary removal from service of grade crossing warning or wayside signal systems, including the proper use of jumper wires.
Highway-rail grade crossing warning devices and wayside train signals are among the most important safety systems in the railroad industry for preventing train collisions and highway-rail grade crossing accidents. Despite the high degree of reliability of these systems, failures occasionally do occur.
FRA previously made related recommendations to railroads regarding the importance of clear safety procedures to ensure the safety of highway-rail grade crossing warning systems and wayside signal systems in Safety Advisory 2002–01.
To read the complete advisory and background, which was published June 3 in the Federal Register, click here.
WASHINGTON – The Federal Railroad Administration, in response to inquiries about when it is permissible for an employee directing the movement to operate a motor vehicle in the context of a pushing or shoving movement, has issued the following advisory:
The central concern in each situation is whether the practice violates the prohibition in the Railroad Operating Practices regulations at 49 CFR 218.99(b), which states, in part:
No unrelated tasks. During the shoving or pushing movement, the employee directing the movement shall not engage in any task unrelated to the oversight of the shoving or pushing movement.
Factual circumstances may dictate whether an operation is safe and in compliance with the regulations.
Question 1: Do the Railroad Operating Practices regulations allow an employee to make an initial determination that the track is clear from a motor vehicle in which the employee is operating prior to the initiation of the shoving or pushing movement?
Answer: While there may be some risk involved when an employee is both determining that the track is clear and operating the motor vehicle, the regulation does not strictly prohibit the same person from doing these tasks simultaneously when the movement has not been initiated and oversight of the movement is not required. However, if the terrain is uneven or the view is obstructed, the person may occasionally have to operate the vehicle at a slower speed or even stop the vehicle in order to accurately determine that the track is clear.
Question 2: Do the Railroad Operating Practices regulations allow an employee to determine that the track is clear from a motor vehicle in which the employee is operating while simultaneously directing a shoving or pushing movement that is in motion?
Answer: Although there is no strict prohibition, the FRA is concerned that an employee who operates a motor vehicle while the shoving or pushing movement is in motion may not be adequately overseeing the train movement.
One of the stated purposes of the prohibition against engaging in any task unrelated to the oversight of the shoving or pushing movement was that it “increases the probability that the controlling employee will be in a position to reduce the severity of any accident that might occur.” (73 Fed. Reg. 8442, 8476) The cited language in the preamble to the rule immediately follows a recap of the fatal accident in Manlius, N.Y., which led to the issuance of FRA Safety Advisory 2007-01.
That fatal accident involved a carman whose vehicle was dragged a considerable distance before the employee directing the movement was contacted to stop the movement. The preamble language clarified that the “no unrelated task” provision was added as a compromise in exchange for the FRA giving up the proposed requirement that the leading end of the movement be continuously kept in sight by the employee directing the movement.
The FRA recognized that “a ‘continuous observation’ requirement would force more employees either to walk or ride the point – creating an even greater vulnerability that someone could get hurt.” (73 Fed. Reg. 8476) The same type of argument could be made regarding an employee directing the movement who is instructed or elects to drive a vehicle while the shoving or pushing movement is in motion.
With these concerns in mind, the FRA determined that an employee must not simultaneously direct a shoving or pushing movement while operating a motor vehicle of any type, except as follows:
* An employee may operate a motor vehicle to a point where he or she can visually determine that the track is clear, pursuant to 49 CFR 18.99(b)(3)(i). After stopping the motor vehicle and determining that the track is clear for a specified distance, the employee directing a shoving or pushing movement may give an initial instruction to the engineer to start a shoving or pushing movement for the specified distance.
* After giving the initial instruction, the employee may operate the motor vehicle while the shoving or pushing movement is in motion.
* After visually determining that the track is clear for an additional specified distance, the employee directing a shoving or pushing movement must stop the motor vehicle in order to provide any additional instructions to the engineer. This process may be repeated until the shoving or pushing movement is completed.
* The FRA recognizes “that employees can safely make shoving or pushing movements without continuously observing the leading car (i.e., the leading end of the movement) for the entire distance of the movement.” (73 Fed. Reg. 8477) However, to the extent possible, the FRA would expect an employee to observe a shoving or pushing movement in progress and be able to take appropriate action to minimize the severity of any unexpected derailment or accident that might occur.
* Under all circumstances, the engineer must stop the movement in one-half the specified distance, unless additional instructions are received. (49 CFR 220.49)
Question 3: Do the Railroad Operating Practices regulations allow an employee directing the shoving or pushing movement that is in motion to determine that the track is clear while riding in a motor vehicle as a passenger?
Answer: There is no strict prohibition on an employee determining that the track is clear while riding in a motor vehicle as a passenger. Of course, if the terrain is uneven or the view is obstructed, it may not be factually possible to make the determination that the track is clear. As always, the FRA will consider enforcement action when the circumstances show that the person could not make an accurate determination.
A safety advisory on autorack cars has been issued by the Association of American Railroads.
Some of these cars have been found to have cut convenience handles, ladder rungs and/or fasteners missing from these devices.
Convenience handles are those handles mounted on end doors, sides of autorack cars or the underside of the roof canopy, and are used by workers when entering and exiting autoracks. Some autoracks have been found with multiple handles cut and others with only one cut handle. The cuts have all been a very fine line smooth cut that is difficult to see without careful inspection.
Ladder rungs have been reported cut at the bottom of the ladder and some at the top of the ladder.
Most of the missing fasteners have been from the convenience handle on the underside of the roof panel.
Workers are advised to make a thorough visual inspection of all convenience handles, steps, ladder rungs, grab handles and other hand holds prior to use.
Upon coming in contact with any cars with these problems, the car initial and number, location, date and other pertinent information should be provided supervisors.