Have you every missed something so completely that you question your own connections to reality? Like maybe missing the year or more of notices and communications from the Federal Railroad Administration regarding its “Miscellaneous Amendments to Brake Systems Safety Standards and Codification of Waivers” (Docket FRA-2018-0093)?
well, I did. I missed it all, except for the issue of the final rule, which is when I noticed that I had missed it all. completely .
I know I slept through a set of 2020. I figured it was deoxyadenosine monophosphate good a time as any to work on my rest deficit, the one accumulated through the years of dutiful railway overhaul. But I didn ’ deoxythymidine monophosphate sleep that much. Besides, can you actually accumulate a deficit ? chew over that one on your direction out, Mr. Mnuchin .
I could blame it on my advancing years, but that means I would have to acknowledge getting older, something I have systematically refused to do. I hold to the uncertain belief that ceaseless emotional immaturity will provide forcible benefits. indeed far, so well, and then to the matter at hand.
Bạn đang đọc: Consistency Conspicuous in its Absence
FRA explains in its drumhead :
FRA is revising regulations governing brake inspections, tests and equipment. The changes include the internalization of stand-in from diverse provisions provided in long-standing waivers related to single car atmosphere brake tests, end-of-train devices, benefactor service and brake alimony. FRA is besides extending the prison term that freight rail equipment can be “ off-air ” before requiring a new brake inspection … FRA expects the revisions will benefit railroads and the public by reducing unnecessary costs, creating consistency between U.S. and canadian regulations and incorporating the use of new technologies demonstrated to maintain or increase safety. The rule will reduce the overall regulative burden on the railroads .
Who ’ sulfur going to argue with that ? Benefiting railroad and the populace, reducing unnecessary costs, maintaining or increasing safety ? Sounds bang-up. Creating consistency between U.S. and canadian regulations ? Just perfect. Except in its extension of the time freight equipment can be “ off-air ” from 4 hour to 24 hours before requiring a new classify 1 brake examination, FRA isn ’ metric ton creating consistency, because … good, first Canada ’ s No. 1 brake test international relations and security network ’ deoxythymidine monophosphate coherent with the U.S. Class 1 test. The canadian test requires that 95 % metric ton of the air brakes on the cars of a freight train be private detective before a caravan departs a destine safety inspection location .
The U.S. Class 1 test requires that 100 % of the air travel brakes function properly prior to the educate ’ s departure from its initial terminal, or after 1,000 miles, or after being off-air for now 24 hours. canadian regulations actually extend the “ off-air ” time to 48 hours ( with proper presentment ) .
thus, “ consistency ” is a morsel conspicuous in its absence .
twenty-four hours off-air does not, in and by itself, increase the likelihood of air brake failure. One hundred and thirty cars off-air for 23 hours in extreme weather conditions—-extreme cold, big bamboozle, freezing rain—might .
The critical factor here is the environment. Railroads acknowledge this when they place size restrictions on trains due to weather conditions. Distributed Power ( DP ) can mitigate a sealed abasement of train line air out effectiveness in signaling for a bracken application in extreme weather conditions. DP can overcome air supply problems to brake reservoirs .
But DP can not mitigate the defects in the design or function of the brake reservoirs themselves. It ’ s precisely those defects that the Canadian TSB ( Transportation Safety Board ) examined in its composition on a fugitive train on the CN. here ’ s an concern statement from TSB ’ sulfur administrator compendious :
wear rubber seals from the bottom cover exhaust port of the DB-10 servicing portions of the air brake see valves experienced shrinkage in the extreme cold temperatures that resulted in auxiliary reservoir escape and the unintended release of brakes on 27 freight cars following service air brake applications. even though previous performance issues with the DB-10 service helping control valves had manifested themselves in cold weather and resulted in an Association of American Railroads ( AAR ) Circular in 2013, the failure mood that was previously identified was repeated in this occurrence. If performance issues involving rubber components in atmosphere brake control valves are not in full analyzed when they occur, degradation in the efficacy of the control valve, particularly during cold upwind conditions, may not be identified and addressed in a timely manner, increasing the gamble of a loss of control consequence .
The cars involved in this uncontrolled motion were not off-air for four hours. They weren ’ thyroxine “ off-air ” at all .
FRA in its section-by-section discussion on the new rule concludes that :
The technical improvements to the vent brake systems introduced and proliferated both before and subsequent to FRA ’ randomness 2001 rule have been beneficial in improving the overall health of brake systems .
That sounds great, except FRA does not identify the specific technological improvements ; does not state if those improvements have been applied to the bracken systems on all cars in manipulation over the general railroad track system ; and doesn ’ t make the unspecified technical improvements a compulsory prerequisite to the activation of the new dominion.
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The coal cars involved in the CN runaway were built post-2001—in 2006 to be accurate. Despite the modernity, after the runaway, the CN implemented new air brake testing procedures for cold weather operations to verify that car air brakes practice .
back to FRA :
furthermore, the supporting information comparing canadian and U.S. operations provided in Appendix 7 to AAR ’ s Petition clearly demonstrates the base hit of extending the allow off-air limit to 24 hours. In favor of the dependability of these data is the fact that they include same-railroad results ( based on CN and CP data ) showing fewer undesired and unintended hand brake bracken applications occurring in Canada than in the U.S .
You can examine Appendix 7 in the FRA-2018-0093 agenda available on the government regulations website. When you do, I ’ molarity pretty sure you will be as amused and annoyed as I was that this alleged “ study ” of off-air brake performance is not a study of off-air brake operation at all, but just the comparison of undesired emergency brake applications occurring on road freight trains on U.S. and canadian railroads .
now as debatable and insecure as an undesired emergency brake application may be, the brake application itself is designed to be a failure into the safe mode. That is specifically not at exit with the question of dependability of the brake application as a function of time off-air .
The issues are 1 ) if the functions of the tune brake system are in conformity with the minimum safe standards set by union rule, and 2 ) if the complaisance with those standards is compromised by time off-air. Unintended hand brake applications that occur when the train is en-route have nothing to do with importance, or lack thence, of time off-air .
In my time on the cargo side of the industry, I dealt with any issue of road trains with kicker cars, but never once did I always encounter a kicker during the Class 1 brake test after train constitution. Just lucky ? That ’ s me, all correct. Mr. Lucky .
The mechanical component of the Class 1 quiz, requiring ocular inspection of brake rig and equipment, has always been necessity to safe train operations, given the banging about the cars take during classification and train makeup. The problem is that the “ pneumatic part ” of the Class 1 brake test has always been inadequate for determining the true function of the air travel brake system .
Our canadian friends, again, seem to have identified this vulnerability during their probe into the 2019 runaway incident in British Columbia, and they have linked their investigation bet on to a 2015 articulation research project conducted by Transport Canada, the National Research Council and Canadian Pacific. That project, the Automated Train Brake Effectiveness ( ATBE ) study, measured air brake potency on unit granulate trains by examining steering wheel temperatures at the bed of long descending grades. Prolonged brake applications were required to control the train ’ s amphetamine on the descents. The wheel temperatures were indexed to determine which wheels were actually being braked .
The results of the ATBE study are—how to put this ? —startling but not surprising. In a Rail Safety Advisory Letter 617-04/20, the TSB reported that ATBE testing of 44 granulate trains identified 695 cars with ineffective tune brakes. The No. 1 brake tests for these trains had identified alone 5 cars with defective brakes .
Based on these results, the TSB concluded that :
The ATBE quiz results and the luck notifications of coach braking anomalies on Field Hill both suggest that the No. 1 brake test does not reliably identify ineffective brakes in railcars. Given this data, Transport Canada is advised that an alternate approach to determining the potency of cargo car tune brakes is required to ensure that departing trains have sufficient effective brakes to operate safely .
Those are the Canadians with whom I ’ d like to establish consistency.
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The challenge is to apply the technological advances of recent years to measure the real potency of string air brakes before and after dispatch .
PTC dependability, its enforcement capability, depends on braking algorithm. effective “ full-bodied ” algorithm necessitate accurate measurement of real—not presumed—forces. Without that accuracy, we ’ ve tethered an advanced engineering to our antediluvian and blind practices .
David Schanoes is Principal of Ten90 Solutions LLC, a consulting firm he established upon retiring from MTA Metro-North Railroad in 2008. David began his dragoon career in 1972 with the Chicago & North Western, as a brakeman in Chicago. He came to New York in 1977, working for Conrail ’ s New Jersey Division. David joined Metro-North in 1985. He has spent his entire career in operations, working his way up from brakeman to conductor, block operator, starter, supervisory program of train operations, yardmaster, overseer, and deputy foreman of field operations. “ Better rail technology is 10 % planning plus 90 % execution, ” he says. “ It ’ s dim-witted mathematics. Yet, we besides know, or should know, that technology is no substitute for supervision, and supervision that doesn ’ thyroxine utilize technology international relations and security network ’ thyroxine going to do the problem. That ’ s not so elementary. ”