Tuesday, May 13, 2014

Safety appliance evolution

Written by  By Richard W. Dawson, Chairman, AAR Safety Appliance Task Force
UTLX tank car with AAR S-2044 safety appliances installed. Compare the application of handholds  and steps with the existing arrangement (below). UTLX tank car with AAR S-2044 safety appliances installed. Compare the application of handholds and steps with the existing arrangement (below).
In 2011, the FRA established a process in Part 231.33 of Title 49 of the Code of Federal Regulations for industry organizations like the AAR to submit new safety appliance standards to the FRA for review and approval. On Feb. 10 of this year, the FRA approved an AAR petition requesting approval of major portions of the new AAR safety appliance standard S-2044.

To improve the safety of railroad employees in train and engine service, Congress enacted the Safety Appliance Acts of 1893, 1903, and 1910. Among other things, these acts required all cars to be equipped with secure sill steps and efficient handbrakes and required all cars needing secure ladders and running boards to be equipped with them. The 1910 act further required the Interstate Commerce Commission to designate the specific safety appliances required for freight cars, passenger cars, and locomotives. It did so in 1911 when it issued the safety appliance regulations now found in Part 231 of Title 49 CFR. These regulations spell out the required safety appliances for boxcars, open-top hopper cars, gondolas, flatcars, and tank cars, as well as passenger cars and locomotives.

Around 1960, new requirements were established for tank cars without continuous underframes, the type of construction used today. New requirements that became effective in 1966 were also established for boxcars that eliminated roof running boards. For the first time, separate requirements were set for covered hopper cars. Both required crossover platforms at the ends, which had not been used previously.

Other than some interpretations of the existing regulations, no significant additions to freight car safety appliance regulations have been made since then by the ICC or (after 1966) by the Federal Railroad Administration.

UTLX Tank car photo - old arrgt. 3772Since the ICC and FRA safety appliance regulations were originally published, however, a variety of new freight car configurations have been developed, including bulkhead flatcars, doublestack well cars, spine-type intermodal cars, multi-level vehicle-carrying cars, aggregate hopper cars with recessed carbody ends, and coil steel cars. In addition, the vertical-shaft, horizontal-wheel handbrakes on which almost all the federal safety appliance regulations are based have been replaced by geared vertical-wheel or lever brakes.

The AAR has specifications for some individual safety appliances, like handholds, ladder treads, sill steps, and running boards, and has established safety appliance arrangements for a few car types not specifically covered by the FRA safety appliance regulations, like bulkhead flatcars.

Its safety appliance requirements, however, are much less extensive than those of the FRA, which include the primary requirements. Around 1980, the AAR attempted to have some updates made to FRA safety appliance regulations, but FRA never approved them.

Thus, someone developing a new safety appliance arrangement for a freight car, especially a car of a type not specifically addressed by the FRA or AAR regulations, may encounter difficulties interpreting exactly how the safety appliance requirements should be applied to the car.

The present FRA regulations do provide some guidance for cars not specifically covered. Title 49, Part 231.18, “Cars of Special Construction,” states that cars not specifically addressed elsewhere in the regulations “shall have, as nearly as possible, the same complement of handholds, sill steps, ladders, handbrakes, and running boards as are required for cars of the nearest approximate type.”

This naturally leads to the question, “What is the car of the nearest approximate type?” Not surprisingly, differences of opinion sometimes arise between car designers and the FRA over whether the proposed safety appliance arrangement on a new car design is based on a correct interpretation of the safety appliance regulations, or whether it does not comply with the regulations.

Finding out after production has started that the proposed arrangement is not acceptable can be very disruptive, so carbuilders often submit safety appliance arrangements in advance to the FRA Office of Safety for an interpretation. But it is not always possible for the FRA to reply in as timely a manner as the carbuilder would like.

Early in 2002, I was responsible for new car engineering at TTX, and had become frustrated with attempts to resolve safety appliance issues on several new car types under development. Since I also happened to be a member of the AAR’s Equipment Engineering Committee (EEC), I proposed, first to the FRA and then to the EEC, that the AAR establish a group incorporating FRA participation that would investigate ways to eliminate as much uncertainty as possible from the existing safety appliance requirements of both organizations. The result would then be submitted both to the FRA and to the AAR for approval.

Both agreed with the concept, and the AAR established the Safety Appliance Task Force (SATF), reporting to the EEC. The SATF included representatives of operating railroads, private car owners like TTX and GE Railcar, railcar manufacturers, and the FRA Office of Safety. I am the current chairman; Norfolk Southern’s Tom Glasscock is vice chairman.

At the first meeting, the FRA representative requested that Transport Canada, the Canadian regulatory agency comparable to the FRA, and railroad labor unions also be represented on the SATF. The AAR agreed and representatives of three unions plus Transport Canada have participated in SATF activities ever since. The SATF also includes shippers and trained ergonomics professionals.

The SATF soon concluded that the best way to accomplish its objective would be to establish a new AAR safety appliance standard that would replace the existing FRA and AAR requirements for new cars. It was decided to make the new standard applicable to new cars only and not have it apply retroactively to existing cars. When developing the new standard, the SATF did not want to be limited to changes that could be readily applied to existing cars.

When the SATF concluded that the present requirements of the FRA regulations were adequate, it repeated them, but restated them so as to be less ambiguous. However, it found a number of areas where the present regulations could be improved upon, and in those cases it either revised the requirements or created new ones.

The resulting document, AAR Standard S-2044, incorporates a base standard, with definitions and requirements common to all car types, and a series of appendices with the specific requirements for individual car types. There are appendices for 16 car types, most of which were not specifically addressed in the FRA regulations. The car types covered are boxcars, covered hopper cars, bulkhead flatcars, plain flatcars, chain-tie-down flatcars, cars of well and spine construction (both with side-mounted handbrakes and end-mounted handbrakes), tank cars with side ladders, tank cars with end ladders, open-top hopper and high-side gondola cars, low-side gondolas, coil cars, cars with recessed carbody ends (like aggregate hopper cars), side-dump cars, enclosed vehicle-carrying cars, and rail-compatible vehicles (like RoadRailer and Rail Mate).

Relatively few changes were made to the requirements for boxcars and covered hopper cars, but the requirements for the other car types were either new or incorporated significant differences from the existing FRA regulations. Locating hand brakes low enough that they can be operated from the ground eliminates the need for employees to climb on or off freight cars to apply or release hand brakes.

The FRA, however, requires that hand brakes be located so that they can be safely operated while the car is in motion. This eliminates the possibility of placing hand brakes low at the center of the sides of cars, as is often done in Europe. However, other locations are possible where the hand brakes are low enough to be operated from the ground, but can also be operated while standing on a sill step. S-2044 requires the hand brakes on many car types, including flatcars, well and spine cars, low-side gondolas, and coil cars, to be located so that they can be operated either from the ground or the sill step.

The present tank car safety appliance arrangement calls for a single vertical handhold at the sides of the end platform plus a horizontal handhold over the sill step. When standing on the sill step the horizontal handhold is awkwardly located and the FRA-mandated arrangement provides only a single vertical handhold for a person to climb onto the end platform.

S-2044 improves the arrangement by requiring two vertical handholds, one on either end of the sill step. The difference between the two arrangements can be seen in the photos. S-2044 also provides requirements for the running boards on top of the tank on cars with end ladders rather than side ladders. Tank cars that carry low-density commodities are built with large interior volume. They often use end ladders, so that the diameter of the tank can extend all the way out to the clearance limits without having to leave room for side ladders.

Another car with a safety appliance arrangement that has disadvantages is the centerbeam car. Because the end bulkheads are braced by the center beam, they can be made much thinner than the bulkheads on a flatcar with conventional free-standing bulkheads.

Consequently, early centerbeam cars had only a low horizontal handhold and a single vertical handhold over each sill step. This arrangement is similar to the single vertical handhold on tank cars and, even though recent centerbeam cars have generally had two vertical handholds, they are still so close together that there is little difference from the single handhold. The SATF now requires that all bulkhead flatcars, including centerbeams, have four horizontal handholds over the sill steps. Although handholds above the deck can be 12 inches long instead of the usual 16, they will still require the end bulkhead to be thicker on center beam cars than they would otherwise be for purely structural reasons.

FRA regulations for open-top hopper cars and high-side gondolas call for ladders at the corner of the car adjacent to the handbrake and at the diagonally opposite corner with a short brake step beneath the handbrake. The other two corners of the car only have two handholds and there are no end platforms to enable a person to cross from one side of the car to the other.

In recent years, many open-top cars have used safety appliances similar to those on boxcars and covered hopper cars, with four or more handholds on the sides and ends at every corner of the car and with a crossover platform at each end. S-2044 requires this arrangement on all open-top hoppers and high-side gondolas.

The requirements for 11 of the 16 car types covered by AAR Standard S-2044 were completed by the SATF, approved by the EEC, submitted to the FRA in a petition, and approved by the FRA on Feb. 10 of this year. Although freight cars may be built to its requirements immediately, compliance with S-2044 will be mandatory for all cars of the 11 approved types built new on or after Jan. 1, 2015. Existing cars are not required to be modified to comply with S-2044 and will continue to be subject to existing FRA and AAR requirements.

Of the five car types not yet approved, requirements for plain flatcars, enclosed vehicle-carrying cars, and cars with recessed carbody ends have been completed and will soon be submitted to the FRA for approval. Requirements for side-dump cars and rail compatible vehicles are under development.