Following the catastrophic derailment in East Palestine, Ohio, Secretary of Transportation Pete Buttigieg addressed a more or less open letter to each of the Class I railroads, “urging” them to voluntarily enlist in the FRA-endorsed, NASA-run close call confidential reporting system (C3RS) … while the Secretary, ably assisted by his able assistants, worked up a plan to make enrollment mandatory.
In response to the Secretary’s urgent request, the AAR, speaking for the Class I’s as a group, quickly affirmed the willingness of the Class I railroads to participate in C3RS and C3RS-type programs as soon as practical, the practical depending on when certain concerns regarding the current C3RS functions could be resolved by all the parties committed to better, safer railroading. So while the oven is hot and the dough has risen, it isn’t quite bread yet.
Far be it from me to question the Secretary’s authority to order the Class I’s to enlist in the C3RS program. As The Who sang in 1965, “It’s a Legal Matter,” and I’m happily not qualified, although qualification in general seems to be heavily discounted lately. Far be it from me to question anybody’s motives in promoting C3RS programs, or for not participating in C3RS programs. But …
I think it’s only fair to investigate the data and use that analysis to guide us in making an evaluation of the effectiveness of C3RS programs in reducing railroad accidents not occurring at highway-rail crossings at grade.
It’s a difficult task, evaluating the effectiveness of such programs in the railroad operating environment, because only 14 of the approximately 800 U.S. railroads regulated by FRA participate. Of those 14, six (6) are major commuter services: Long Island Rail Road (LIRR); Metro-North (MNCW); New Jersey Transit Rail Operations (NJTR); Southeastern Pennsylvania Transportation Authority (SEPTA); and Northeast Illinois Regional Commuter Rail–Metra (NIRC); and Massachusetts Bay Transportation Authority (MBTA).
These six participants accounted for 70% of the train accidents not at grade crossings reported by the entire commuter rail sector between 2014 and 2022. Check my math, please. Go to FRA’s Office of Safety Analysis and fill in the blanks on the query page for 1.12 Ten Year Accident/Incident Overview by Calendar Year.
All is not good in any sector of the industry: In the period 2014-2022, for the entire industry, the rate of train accidents (calculated per million train-miles) not at grade crossings (RTANGC) increased almost 27%; human factor (employee error)-caused increased 12.5%. In the same period, the RTANGC for Class I railroads (which account for 75% of the total train-miles and about 65% of total employee-hours recorded in the industry) increased33.6%; human factor-caused increased 17.8%. In the commuter sector, the RTANGC increased 63%; human factor-caused increased 31%.
First thing: Congratulations to New Jersey Transit Rail Operations. Then, I repeat: Something has gone horribly wrong. C3RS does not seem to be an effective countervailing force.
What is it that has gone wrong, across the board? I don’t know, but take a look at the rates of yard switching accidents during this same period for all our sectors. For the entire industry, it’s up by a lot. For the Class I’s, it’s up even more. For the commuter operations, it has reached abominable levels. And for our C3RS participants, well, there’s not enough reported data.
If the yards are being neglected, then you as a railroad entity have a problem with your field officers. Either you don’t have enough to properly oversee your train makeup and switching operations, or you have them doing the wrong thing.
As for C3RS, before we load eggs into a basket, you need an actual basket. C3RS doesn’t seem to qualify. But as railroad safety expert Bill Keppen pointed out on Sept. 5, “When Will Class I’s Fulfill Their C3RS Commitment?”
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 railroad 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, dispatcher, supervisor of train operations, trainmaster, superintendent, and deputy chief of field operations. “Better railroading is 10% planning plus 90% execution,” he says. “It’s simple math. Yet, we also know, or should know, that technology is no substitute for supervision, and supervision that doesn’t utilize technology isn’t going to do the job. That’s not so simple.”