AAR: Class I’s On Board With C3RS; FRA Data Points to ‘Strong Safety Record’Written by William C. Vantuono, Editor-in-Chief
All seven North American Class I railroads have agreed to join the Federal Railroad Administration’s voluntary Confidential Close Call Reporting System (C3RS), Association of American Railroads President and CEO Ian Jefferies said in a March 2 letter to U.S. Transportation Secretary Pete Buttigieg, who had requested this in Feb. 27 letters to the individual railroads. Additionally, following the FRA’s release of 2022 safety data, the AAR issued a statement saying how that data confirms that “U.S. railroads continue to maintain a strong safety record.”
“The industry absolutely shares your commitment to establishing effective mechanisms to help prevent future accidents like the derailment in East Palestine,” said Jefferies. “You will hear from each of the railroads individually in response to your letter as well. I write to provide important history and context regarding railroad use of close call reporting, hopefully to pave the way for working with you, FRA, and our employees to develop an even better system.
“[U]nion Pacific and Canadian Pacific … actually initiated the first C3RS pilot programs with FRA in 2007. All Class I railroads have longstanding programs in place that allow employees to provide confidential feedback on safety issues. These programs range from establishing and using anonymous reporting hotlines to processes that incorporate peer review teams and root cause analysis, much like C3RS. The railroads value receiving this type of close call information in a timely manner because it allows them to act quickly and proactively to address safety issues before they lead to an accident. The Class I railroads expect to continue to operate these internal confidential reporting programs in addition to their voluntary participation in C3RS.
“As you know, some railroads currently participate in FRA’s C3RS program while others that formerly participated dropped out of the program because it was viewed as less effective than their existing programs. We want to work with FRA to make the C3RS program better and more effective. In that spirit, we are identifying certain aspects of the current FRA program that have historically led to railroads declining to participate in favor of their own internal programs. We believe these matters can and should be improved. Our interest is in seeing a streamlined process that maintains important confidentialities for both reporting employees and carriers while also efficiently sharing high quality safety information so that railroads can quickly take appropriate action to address legitimate safety issues. More specifically, areas for improvement include:
- “Quality of reporting: The information provided by employees is currently routed through NASA’s reporting system. As noted by the U.S. Government Accountability Office (GAO), often the information received is insufficient for railroads to act on because it does not contain enough detail to develop practical corrective actions. NASA staff, who are understandably not familiar with railroading, face difficulties with gathering the needed additional information. We believe these issues can be easily addressed.
- “Speed of reporting: Feedback on a close call that did not result in an accident takes a long time to reach the railroad. Indeed, NASA’s procedure requires it to wait at least 30 days before it reports to the railroads, which makes a quick response impossible. This, too, should be addressed.
- “Confidentiality: There are concerns that FRA may have not always kept close call reporting data confidential. Protocols that protect the confidentiality of the information will ensure continued and robust participation. The Federal Aviation Administration has such protocols in its Aviation Safety Reporting Program (ASPR), and we believe similar protocols should be adopted by FRA.
- “Addressing repeated unsafe conduct: Typically, the person reporting a close call is exempt from the internal disciplinary process that would otherwise apply in the case of a violation of safety rules. AAR recognizes that protection as a necessary feature of the program in the vast majority of circumstances. However, the rare situation in which an employee is misusing the system to prevent his or her unsafe decisions or actions from being addressed by the railroad, the program should permit the railroad to address that repeated misconduct with the employee. This is needed for the safety of the railroad, its other employees, and the public.
- “Sharing of information: To the extent the information collected by the program is useful in improving safety practices and policies, it should be shared with the wider industry and in a timely fashion. GAO has made this recommendation, and AAR agrees.
“As you know, FRA has already scheduled a Railroad Safety Advisory Committee (RSAC) meeting for March 14, 2023 to address this program. AAR members look forward to participating in that meeting to provide their perspectives on the opportunities and challenges related to close call reporting. We are committed to continuing the 20-year trend of continuous safety improvements in the rail industry. We look forward to working with you and with FRA on these critical issues.”
Norfolk Southern President and CEO Alan Shaw said NS “was already actively participating in the C3RS Working Group that is part of the RSAC. By joining the program, the company is building upon its own long-standing Close Call Experience Program. We encourage our railroaders to speak up if they see something that is unsafe. It’s through their daily work and coaching of their team members that we become a safer railroad. Joining the FRA’s C3RS marks another step we are taking to further our commitment to safety at NS and throughout our industry. Today, NS has its own Close Call Experience Program that encourages employees to report instances they consider to be close calls confidentially through an online portal. The company’s Safety and Environmental Department, along with local safety committees, review the reports to capture teachable moments, which are then shared with employees to improve safety and encourage additional reporting.”
“CSX is fully committed to a positive employee experience, and that includes ensuring every employee feels safe in our work environment,” said Joe Hinrichs, CSX President and CEO. “Like every aspect of our ONE CSX culture, our focus on safe behaviors must be shared by all employees. Across our entire network, we are continually delivering coaching to ensure we are protecting ourselves, our teammates and our neighbors; complying with laws and regulations; and speaking up about safety concerns. The safety of our employees and the communities we serve will always be our top priority.
“The FRA’s C3RS will supplement CSX’s already robust employee safety reporting programs. The company has multiple initiatives in place through which employees can anonymously report safety concerns or potentially unsafe conditions, without fear of reprisal. The programs offer various options for submitting information to make it convenient for employees—including email, voicemail and webforms. CSX acts promptly to address the information submitted through its existing employee safety reporting programs. Changes are made where applicable, and details of incidents that could have resulted in life-changing events are often leveraged by the company to implement modifications to training or the work environment.”
“UP is proud to join the FRA’s close-call reporting program, enhancing the already robust opportunities to anonymously report concerns,” the Class I railroad reported via Twitter on March 3. “As the original participant in the FRA’s 2007 pilot, nothing is more important than the safety of employees, customers & the communities we serve.”
AAR also pointed to new FRA safety data as confirming that “U.S. railroads continue to maintain a strong safety record. The train accident rate is down 28% since 2000, and the past decade was the safest ever.”
AAR highlighted the following “notable statistics,” calculated per million train-miles:
- “The Class I railroad main line accident rate is at an all-time low and down 49% since 2000. For all railroads, that rate has declined 44% since 2000.
- “For all railroads, the derailment rate is down 31% since 2000, but despite that longer-term positive trend, it was up by 3% year-over-year (from 2021).
- “Track-caused accidents are down 55% since 2000 and are at their lowest-ever rate across the entire rail industry.
- “Equipment-caused accidents were down 21% since 2000 but increased by 15% compared to 2021.
- “Per Class I railroad employee, the casualty rate has dropped 63% since 2000 and is at an all-time low.
- “Per carload, the hazardous materials (hazmat) accident rate is down 78% since 2000 and the lowest ever based on preliminary Bureau of Explosives data.
“Last month, we all saw the devastating impact a train derailment can have on a community, and we are committed to continuing our industry’s efforts to prevent what happened in East Palestine from happening elsewhere,” said Ian Jefferies. “This data makes clear that our employees’ strong safety culture paired with the sustained, disciplined investments in maintenance and technologies that target the primary causes of accidents deliver meaningful safety results. There is more work to do, but FRA’s data clearly reflects railroads’ steadfast safety commitment.
“U.S. railroads also continue to make strides in workplace safety. The employee casualty rate across all railroads is down 49% since 2000. Additionally, workplace fatalities have dropped 54% since 2000.
“Railroad workers are among the hardest-working and most dedicated workers in this economy and keeping them safe on the job is paramount. We know there is more work to do to keep getting better in all aspects of rail safety, but the progress we continue to make demonstrates that we will do what it takes to meet that challenge.
“The newly released FRA data also demonstrated areas where additional work is necessary to drive down risk and enhance safety such as equipment-caused accidents noted previously. Additionally, while human factor-caused incidents are down 15% compared to 2000, the rate of these types of accidents increased 13% compared to last year, which also drove the yard accident rate up year-over-year.
“More than 95% of rail-related fatalities are trespassers or grade crossing users. The combined total of trespasser and suicide fatalities for 2022 increased by 4% from 2021. Grade crossing collisions were down 23% last year compared to 2000, but along with trespass incident, these preventable accidents remain persistent challenges across the rail industry.”