Greg Hynes, SMART-TD national legislative director

It’s difficult to imagine trying to pass off reducing the braking power of a freight train as a safety precaution, but that is exactly what BNSF attempted to do recently in a request to the FRA for a variance to increase the allowable amount of flow from 90 CFM to 120 CFM.

In their request, BNSF states that in order to reduce the slip/trip/fall risk that goes along with conductors and carmen walking a consist looking for leaks in a brake line, that they think it’s safer to depart the train with up to 120 CFM of flow and assume it will be able to stop when it has to.

FRA put out a Notice of Proposed Rule Making (NPRM) requesting public comments on BNSF’s request, and SMART-TD’s National Legislative Department was happy to oblige them. Below you can read SMART-TD’s response to FRA from Brother Greg Hynes, SMART-TD’s national legislative director.

The Federal Railroad Administration published a safety bulletin Dec. 29 regarding an unintended release of a train’s air brakes while stopped at a signal. The text of the advisory as published in the Federal Register is reproduced below.

FRA is issuing Safety Advisory 2022-02 to make the rail industry aware of a recent issue encountered by a train crew that experienced an unintended brake release of a train’s automatic air brakes while stopped at a signal, and to recommend steps addressing the unintended release of train air brakes.

Background

On June 22, 2022, during a significant thunderstorm, a crew consisting of a locomotive engineer and conductor operated a conventionally powered, intermodal train with 3 head-end locomotives, 47 loaded cars, and 6 empty cars, totaling 9,204 feet in length and 7,392 tons in weight. The engineer stopped the train on a downhill grade of 0.9-1.18% near the signal governing the train’s movement, set the train’s air brakes at approximately 12 pounds, and fully set the locomotive consist’s independent brakes. After being stopped for approximately 3 hours, the engineer and conductor, located in the lead locomotive cab, observed the train roll towards the signal interlocking displaying a stop indication. This train experienced an unintended automatic brake release. The locomotive consist’s independent brakes remained fully applied but due to the grade, tonnage and wet rail could not solely hold the train without the automatic air brakes also being applied.

At that time, an opposing train on the same track was preparing to cross through the interlocking in front of the rolling train. The locomotive engineer of the rolling train applied full-service airbrakes and full dynamic braking but was not satisfied that the brakes were working effectively or fast enough. The conductor operated the emergency brake valve and stopped the train short of the signal and the train that was preparing to cross through the interlocking.

The crew then contacted the dispatcher and railroad management to report the unintended brake release and the conductor set a sufficient number of car handbrakes to hold the train on the grade.

FRA’s investigation of the rolling train’s event recorder, positive train control (PTC) system, and engine data logs, revealed: the PTC system had operated properly and would have initiated an emergency brake application upon reaching the signal; the Trip Optimizer was off; and the lead locomotive and consist did not cause the unintended brake release. Instead, FRA determined that, after approximately three hours with the air brakes set, the air pressure slowly bled down from some of the cars’ auxiliary reservoirs, likely causing localized brake releases.[1] The initiation of the brake release would enable the accelerated release functionality by taking some air from the emergency brake reservoirs and directing it back into the brake pipe resulting in a substantial number of adjacent car brakes releasing. Potentially contributing factors causing the train’s unintended movement included the downhill grade, wet rail, and the train’s tonnage.

Due to the potential for air brake system leaks, FRA prohibits unattended trains from depending solely on air brakes to hold equipment.[2] While the aforementioned rolling train was attended, it nevertheless engaged in an unintended movement.

Based on FRA’s review of this incident, and its awareness of other train incidents involving an unintended air brake release under similar circumstances, FRA believes operating guidance is warranted to help reduce the likelihood of similar unintended air brake releases, and therefore makes the following recommendations.

Recommendations

1. Train crews should not expect a service rate or emergency brake application to indefinitely maintain application of a train’s air brakes.

2. If a train is stopped with air brakes set, and the train begins moving, the crew should immediately apply the emergency brake. After the train is stopped, the crew should set a sufficient number of handbrakes to secure the train from further unintended movement before releasing the brakes and recharging the train’s air brake system.

3. Each railroad should adopt and implement an air brake procedure consistent with Recommendations 1 and 2 that addresses unintended brake releases.

4. Each railroad should have an operating supervisor conduct a face-to-face meeting with each locomotive engineer and conductor to explain and reinforce the contents of this advisory.

FRA may modify Safety Advisory 2022-02, issue additional safety advisories, or take other appropriate necessary action to ensure the highest level of safety on the Nation’s railroads.

Issued in Washington, DC.

John Karl Alexy,

Associate Administrator for Railroad Safety, Chief Safety Officer.

Footnotes

1.  FRA notes this type of prolonged pressure release would likely not be identified during a periodic single car air brake test. Back to Citation

2.  49 CFR 232.103(n)(2). Back to Citation



December 18, 2020
 
 
Brothers and Sisters:
As we find ourselves amid what is historically the most dangerous season of the year, I must unfortunately caution you of new additional intensified dangers borne from the Federal Railroad Administration’s (FRA) most recent Final Rulemaking. On Friday, December 11, 2020, the FRA granted an extensive and exhaustive list of regulation changes, the vast majority of which served to lower the bar of safety and increase the profit margin for this nation’s rail carriers. This is evidenced in the no less than two dozen references of cost savings to the carriers as a result of this rulemaking. Not only has the FRA once again vacated its role as the country’s chief safety regulator, but it has also failed in its own mission statement, vision, and purpose.
As you are aware, a known unsafe condition exists with the DB-10 brake valves in cold weather conditions. In fact your Union, on December 15, 2019, petitioned the FRA to issue an Emergency Order that would prioritize safety over productivity by requiring the replacement of the defective valves and disallow the railroads’ attempts to apply stopgap procedures that only camouflage and exacerbate the seriousness of the situation. That petition was unfortunately denied by the FRA muzzling our request for the safest course of action.
Due to the FRA’s reckless action, rolling stock is now permitted to be off-air for 24 hours before requiring a new brake inspection. This means that the only true method of identifying the faulty brake valves has been reduced immeasurably, if not eliminated altogether on certain properties. As a result, the regularity of brake inspections has now been reduced to a fraction of the previous standard, and, thus defective brake valves will be permitted to remain in service longer and be more apt to adversely affect a train’s braking capabilities. Given the consequence of these faulty valves remaining in place is that they render a train’s emergency brake feature inoperative, I am asking all to please remain diligent in your daily duties and to take nothing for granted. This includes railroad workarounds designed to mask flawed brake valves like drawing the brake pipe pressure down to zero before making a separation. Should a carrier official ask you to perform such a task, please notify my office as soon as it is safe and proper to do so, so that we may address it with the carrier and applicable government agencies.
The railroads have historically had trouble maintaining an accurate record of when a train or car(s) initiates its “off air” status (and that was with the four-hour limit). I highly anticipate major complications regarding the determination of actual time off air when going on-duty or making a pick-up. If you feel as though you are being instructed to move equipment that has been off air greater than twenty-four hours, please report it to your supervisor and to my office. Do not be insubordinate, but also do not allow the instance to go unreported or undocumented. We will progress the report accordingly.
In addition to the time off-air regulation, the FRA has also made changes to regulations regarding single-car air brake tests, end-of-train devices, helper service, brake maintenance, additional brake-related items, utility employee duties, and various other rules and/or processes.
It is clear the intent of these changes was not to improve safety, but rather to widen the avenue in which railroads can operate without oversight or guidance – a devastating scenario we just experienced with the Boeing 737 Max. As such, please rest assured that our legal department is currently in the process of filing a formal appeal and petition of reconsideration to overturn this extremely dangerous and egregious action. However, until a recourse can be achieved, it is on all of us to have our brothers’ and sisters’ backs. It is clear that the FRA and carriers do not.
Fraternally yours,
 

 
 
 
 
Jeremy R. Ferguson
President – Transportation Division
 
Click here to view this letter as a PDF.