Subject: FRA Regulations (2/06/1995)
[3/2/87] FRA Requirements - Amtrak has been besieged with FRA inspectors since the Baltimore wreck. All kinds of supposed wrongs are being penalized. For example, the Sunset was held up for over 40 minutes to repair one of the locomotive's sanders. The San Diegan was held up until a new locomotive could be sent down from Los Angeles, because "the bell wasn't loud enough". So far as private car owners are concerned, the FRA regulates the power brake law, safety appliances, the glazing requirements, and the rear end markers. The amount of the fine which they may impose for your infraction will astound you. For example, if you have no rear end marker present, the fine is $1500. If it is an intentional violation, the fine is $3,000. I hope to have a list of approved suppliers, costs, and sketches next time.
[6/19/87] FRA - SAFETY APPLIANCE ACT - As I have mentioned previously, we are subject to the regulations of the Federal Railroad Administration (FRA) in four general areas: the Safety Appliance Act, the Power Brake Law, the glazing requirements, and rear end marking devices. These regulations are enforced by FRA field inspectors, and are also enforced by railroad company inspectors.
I have reported incidents to you where trains have been delayed because private cars did not meet these requirements. For example, FRA inspectors recently took exception to a modified private car at Chicago because required handholds on the end sill of the car were missing. The car was removed from the train until the handholds could be installed at a shop.
Your car may be inspected by FRA at any time it is on railroad property. Any violation found by an FRA inspector will be reported to the railroad, the car may be prohibited from moving, and the railroad company may be fined amounts up to $2500 per day if the violation is particularly serious or the car is operated with an uncorrected defect after notice has been given. The railroad is responsible for determining and completing the action which must be taken to correct any defects found. Of course, for a private car, the railroad will refer the matter to you for correction or will bill you for repairs.
Fines are not always assessed for every defect found by an FRA inspector. In the majority of cases, FRA inspectors will only notify the railroad of defects so that corrective action can be taken. The FRA inspector has considerable discretion regarding whether fines are assessed or only warnings issued. His decisions will be influenced by factors such as whether the defect was so serious that it should have been detected by the railroad, whether the car was operated despite knowledge of the defect, and whether many similar defects had been found at that location.
However, you must also recognize that the railroads are extremely sensitive about FRA inspections, and most companies require reports to their headquarters whenever FRA inspections are made on their property. Therefore, the fact that a private car was found defective is reported to the top management of the railroad, even if no fine is assessed. It is in all of our best interests to make sure that FRA inspections of our cars get reported as "No defects found."
The original Safety Appliance Act was passed by Congress in the 1880's. The Act was to protect trainmen who had to board and ride moving cars, often at night in bad weather. The standardized handholds and step arrangements prevent many employees from suffering catastrophic falls underneath moving cars, and provide handholds while making or breaking brake hose or steam pipe couplings.
The Act was originally enforced by the ICC, until the responsibility was transferred to the FRA. Required appliances for passenger cars are specified in the Code of Federal Regulations, 49 CFR Part 231.12 through 231.14. Unfortunately, the official regulations are not models of clarity, and they do not include diagrams to help you interpret them. However, the Car Builders Cyclopedia contains the requirements along with diagrams, and I have attached them for your information. Several explanations are in order.
The Safety Appliance Act contains separate sections for each general type of car which was in use when the Act was passed in the 1880's. Variations occurring since then have been accommodated as special cases, under Section 231.18. The fundamental requirement is that there must be a reasonable place for trainmen to board and ride each end of every car, with appropriate handholds to support himself while riding.
Note that these rules require that every passenger car must have an efficient handbrake, usable while the car is in motion, and proper uncoupling levers. Also, all required grab irons must be fastened with bolts, rivets or screws. Welding of grab irons is not allowed. This is because welds can suffer hidden cracks, leading to sudden failure under the load of a man swinging aboard a car. The mechanical fasteners which are allowed can be easily inspected to prevent failures. The "Huck" type of fastener can be checked, and is now allowed for mounting grab irons.
The first set of specific regulations for passenger equipment concerns cars with wide vestibules. The term "wide vestibules" has been used since the Act was passed in the 1880's, and applies now to the end of any car which has a standard vestibule. Note that the rules reflect the number of handholds for both ends of a car, although modern usage applies the "wide vestibule" section to the vestibule end of a car, and the "no end plat-forms" section to the "blind" end. This is one result of the interpretations allowed by Section 231.18.
If there is no vestibule and the end sill of the car projects outward so that a shelf exists on the end of the car, additional grab irons are required so that a person using that shelf as a step can support himself. Similarly, at folding steps a sill step and handholds are also required so that a place to board the car is provided regardless of whether the steps are open or closed. If the steps do not fold, so that the steps are always available, the additional sill step is not required.
The diagram showing the passenger car with open end platforms shows a typical car of the 1860's. Here there was no trap door, and no enclosing "brass railing", so the additional horizontal and vertical handholds are required to assist a person using the steps. However, if "safety gates" are provided, such as the gates on a typical office car, the additional handholds are not necessary since the gate itself provides a handhold when the trap door is open to the steps. However, vertical handholds on either side of the trap are required, for occasions when the trap and gates are closed.
In summary, the Safety Appliance Act was passed to protect the safety of people working around railroad equipment. Having the proper handholds, handbrakes, and other safety appliances makes good sense, as well as assuring compliance with railroad and Federal rules. Railroad and FRA inspectors continually work around the equipment themselves, and are usually alert to situations where the required appliances are loose, missing, or defective. If FRA defects are found, reports to railroad top management are likely, and fines of $250 to $2500 are possible. Check your car now!
[The following is quoted from a Car-Builders' Cyclopedia]
Safety Appliances for Passenger-Train Cars Passenger-Train cars with Wide
Vestibules
HAND BRAKES
Number.-Each passenger-train car shall be equipped with an efficient hand brake, which shall operate in harmony with the power brake thereon.
Location.-Each hand brake shall be so located that it can be safely operated while car is in motion.
SIDE HANDHOLDS
Number.-Eight (8).
Dimensions.-Minimum diameter, five-eighths (5/8) of an inch, metal.
Minimum clear length, Sixteen (16) inches.
Minimum clearance, one and one-fourth (1-1/4), preferably one and
one-half (1-1/2) inches.
Location.-Vertical: One (1) on each vestibule door post.
Manner of application.-Side handholds shall be securely fastened with
bolts, rivets or screws.
END HANDHOLDS
Number.-Four (4).
Dimensions.-Minimum diameter, five-eighths (5/8) of all inch, wrought
iron or steel.
Minimum clear length, sixteen (16) inches.
Minimum clearance, two (2), preferably two and one-half (2-1/2),
inches.
Handholds shall be flush with or project not more than one (1) inch beyond vestibule face.
Location.-Horizontal: One (1) near each side on each end, projecting downward from face of vestibule end sill. Clearance of outer end of handhold shall be not more than sixteen (16) inches from side of car.
Manner of application.-End handholds shall be securely fastened with bolts or rivets.
When marker sockets or brackets are located so that they can not be conveniently reached from platforms, suitable steps and handholds shall be provided for men to reach such sockets or brackets.
UNCOUPLING LEVERS
Uncoupling attachments shall be applied so they can be operated by a person standing on the ground.
Minimum length of ground uncoupling attachment, forty-two (42) inches, measured from center line of end of car to handle of attachment.
On passenger-train cars used in freight or mixed train service, the uncoupling attachments shall be so applied that the coupler can be operated from left side of car.
Passenger-Train Cars with Open End Platform.
HAND BRAKES
Number.-Each passenger-train car shall be equipped with an efficient hand brake, which shall operate in harmony with the power brake thereon.
Location.-Each hand brake shall be so located that it can be safely operated while car is in motion.
END HANDHOLDS
Number.-Four (4).
Dimensions.-Minimum diameter, five-eighths (5/8) of an inch, wrought
iron or steel.
Minimum clear length, sixteen (16) inches.
Minimum clearance, two (2), preferably two and one-half (2-1/2),
inches.
Handholds shall be flush with or project not more than one (1) inch beyond face of end sill.
Location.-Horizontal: One (1) near each side of each end on face of platform end sill, projecting downward. Clearance of outer end of handhold shall be not more than sixteen (16) inches from end of end sill.
Manner of application.-End handholds shall be securely fastened with bolts or rivets.
END PLATFORM HANDHOLDS
Number.-Four (4). [Cars equipped with safety gates do not require end platform handholds.]
Dimensions.-Minimum clearance, two (2), preferably two and one-half (2-1/2), inches, metal.
Location.-Horizontal from or near door post to a point not more than twelve (12) inches from corner of car, then approximately vertical to a point not more than six (6) inches from top of platform. Horizontal portion shall be not less than twenty-four (24) inches in length nor more than forty (40) inches above platform.
Manner of application.-End-platform handholds shall be securely fastened with bolts, rivets or screws.
UNCOUPLING LEVERS
Uncoupling attachments shall be applied so they can be operated by a person standing on the ground.
Minimum length of ground uncoupling attachment, forty-two (42) inches, measured from center of end of car to handle of attachment.
On passenger-train cars used in freight or mixed train service, the uncoupling attachments shall be so applied that time coupler can be operated from left side of car.
Passenger-Train Cars Without End Platforms
HAND BRAKES
Number.-Each passenger-train car shall be equipped with an efficient hand brake, which shall operate in harmony with the power brake thereon.
Location.-Each hand brake shall be so located that it can be safely operated while car is in motion.
SILL STEPS
Number.-Four (4).
Dimensions.-Minimum length of tread, ten (10), preferably twelve (12),
inches.
Minimum Cross-sectional area, one-half (1/2) by one and one-half (1-1/2) inches or equivalent, wrought iron or Steel.
Minimum clear depth, eight (8) inches.
Location.-One (1) near each end on each side, not more than
twenty-four (24) inches from corner of car to center of tread of sill step.
Outside edge of tread of step shall be not more than two (2) inches inside of face of side of car.
Tread shall be not more than twenty-four (24), preferably not more than twenty-two (22), inches above the top of rail.
Steps exceeding eighteen (18) inches in depth shall have an additional tread and be laterally braced.
Manner of application.-Sill steps shall be securely fastened with not less than one-half (1/2) inch bolts with nuts outside (when possible) and riveted over, or with not less than one-half (1/2) inch rivets.
SIDE HANDHOLDS
Number.-Four (4).
Dimensions.-Minimum diameter, five eighths (5/8) of an inch, wrought
iron or steel.
Minimum clear length, sixteen (16), preferably twenty-four (24), inches.
Minimum clearance, two (2), preferably two and one-half (2-1/2), inches.
Location.-Horizontal or vertical: One (1) near each end on each side of car over sill step.
If horizontal, not less than twenty-four (24) nor more than thirty (30) inches above center line of coupler.
If vertical, lower end not less than eighteen (18) nor more than twenty-four (24) inches above center line of coupler.
Manner of application.-Side handholds shall be securely fastened with bolts, rivets or screws.
END HANDHOLDS
Number.-Four (4).
Dimensions.-Minimum diameter, five-eighths (5/8) of an inch, wrought
iron or steel.
Minimum clear length, sixteen (16) inches.
Minimum clearance, two (2), preferably two and one one-half (2-1/2)
inches.
Location.-Horizontal: One (1) near each side on each end, projecting downward from face of end sill or sheath- ing. Clearance of outer end of handhold shall be not more than sixteen (16) inches from side of car.
Manner of application.- Handholds shall be flush with or project not more than one (1) inch beyond face of end sill.
End handholds shall be securely fastened with bolts or rivets.
When marker sockets or brackets are located so that they cannot be
conveniently reached from platforms, suitable steps and handholds shall be provided for men to reach such sockets or brackets.
END HANDRAILS
Number.-Four (4). [On cars with projecting end sills.]
Dimensions.-Minimum diameter, five-eighths (5/8) of an inch, wrought
iron or steel.
Minimum clearance, two (2), preferably two and one-half (2-1/2) inches.
Location.-One (1) on each side of each end, extending horizontally from door post or vestibule frame to a point not more than six (6) inches from corner of car, then approximately vertical to a point not more than six (6) inches from top of platform end sill; horizontal position shall be not less than thirty (30) nor more than sixty (60) inches above platform end sill.
Manner of application.-End handrails shall be securely fastened with bolts, rivets or screws.
SIDE-DOOR STEPS
Number.-One (1) under each door.
Dimensions.-Minimum length of tread, ten (10), preferably twelve (12),
inches.
Minimum cross-sectional area, one-half (1/2) by one and one-half (1-1/2) inches or equivalent, wrought iron or steel.
Minimum clear depth, eight (8) inches.
Location.-Outside edge of tread of step not more than two (2) inches
inside of face of side of car.
Tread not more than twenty-four (24), preferably not more than twenty-two (22), inches above the top of rail.
Manner of application.-Steps exceeding eighteen (18) inches in depth shall have an additional tread and be laterally braced.
Side-door steps shall be securely fastened with not less than one-half (1/2) inch bolts with nuts outside (when possible) and riveted over, or with not less than one-half (1/2) inch rivets.
A vertical handhold not less than twenty-four (24) inches in clear length shall be applied above each side-door step on door post.
UNCOUPLING LEVERS
Uncoupling attachments shall be applied so they can be operated by a person standing on the ground.
Minimum height of ground uncoupling attachment, forty-two (42) inches, measured from center line of end of car to handle of attachment.
On passenger-train cars used in freight or mixed train service, the uncoupling attachment shall be so applied that the coupler can be operated from the left side of car.
Cars of construction not covered specifically in the foregoing sections, relative to handholds, sill steps, ladders, hand brakes and running boards, may be considered as of special construction, but shall have, as nearly as possible, the same complement of handholds, sill steps, ladders, hand brakes and running boards as are required for cars of the nearest approximate type.
"Right" or "left" refers to side of person when facing end or side of car from ground.
To provide for the usual inaccuracies of manufacturing and for wear, where sizes of metal are specified, a total variation of five (5) per cent below size given is permitted.
[8/31/87] Air Brakes Out of Date - In the past, it has been possible to move freight cars under Rule 88, and passenger cars under AAR Standard 2.1.2.1 when the air brakes are out of date, providing that the brakes do, in fact, work. Generally, this was done in connection with a movement of a car to a repair shop, or to be scrapped. Thus, you have seen the placard on the side of cars reading "Home Shop for Repairs" and generally citing one of the above-mentioned AAR rules.
Effective approximately one month ago, such cars are not suitable for movement on the Southern Pacific, either in freight or in passenger (Amtrak) service. This is because the Federal Railroad Administration has advised Southern Pacific that it will no longer recognize these AAR rules. Instead, a written waiver must be applied for, and obtained from the FRA, if you desire to move an out of date car. The FRA advises that this rule will be applied by their inspectors to all railroads. Apparently the problem is being caused by an exceedingly large number of freight cars whose air dates have expired, and there is otherwise insufficient capacity to properly clean these brakes. Rather than allow these cars to be operated, and cause potential safety problems, the FRA is requiring the railroads to seek written exceptions for each movement. If you need a waiver from the FRA, you should write to:
Joe W. Walsh, Associate Administrator for Safety
United States Department of Transportation
Federal Railroad Administration, Room 8222
400 7th Street, S.W.
Washington, DC 20590
Your letter should include the beginning and ending points, the routes to be taken, the mileage on each carrier, the interchange points, a complete identification of the car and known problems, and the dates you wish to make the move. You should allow at least a week for your request to be processed. The FRA will probably send an inspector to look at your car. If approved, the FRA will send you a letter advising you of the conditions under which you may move the car, and of the fact that they will take no exception to the particular movement. You will need to provide a copy of this letter to the NRPC officer of each carrier railroad, and send a copy to Laddie Shrbeny and to Ed Laird.
[12/26/89] FRA Rules for the Protection of Camp Cars - The Federal Railroad Administration has published new rules, effective January 1, 1990, 49 C.F.R. 218.71 concerning the protection of camp cars. A "camp car" means any on-track vehicle, including outfit, camp, or work cars or modular homes mounted on flat cars used to house rail employees, except wreck trains. The new protection required is a white disk with the word "occupied camp car" in black lettering during daylight hours and an illuminated white signal at night, plus spiked switches and perhaps derails. This probably means that the business car track, if it houses rail employees staying on a business car, or an Amtrak dormitory or occupied sleeper, probably falls within the new required protection. Private cars are exempt, since they do not have "rail" employees, but you may be hassled by the carriers who have not read the fine points. You may ask why this new and expensive additional procedure, was necessary, in light of the existing "blue flag" rules, and the answer is simple: bureaucracy.
[7/10/90] Protection of Camp Cars - In my last bulletin I mentioned the new FRA rules which require a sign stating "Occupied Camp Car" in daylight and an illuminated white signal at night on cars used to house rail employees. I saw my first example of this in Houston when the CSX ran a shipper's special into the SP station. The white signal was jury rigged by taking the blue lens off a flashing carman's blue lantern. This will work fine until a raindrop shatters the bulb. Power Parts has a combination sign, white blinker, and rail clamp available for $97.
[10/2/90] FRA Inspections - The FRA has made a point of inspecting the Houston/Galveston and the Texas Southern trains rather rigorously. You should understand that the FRA will inspect your private car, without prior notice, when the mood strikes them. They are looking for safety violations of the three or four acts which are committed to the FRA. These are the power brake law, rear-end marking devices, glazing, and safety appliances (grab irons). The violations found by the FRA inspectors usually concern the placement and adequacy of safety appliances. Often the inspector will require that bolts which hold grab irons have their threads hammered over, so that the nuts will not come off. There is nothing in the regulations which require this. It is, however, good practice. However, the problem occurs when the owner has used elastic stop nuts on the bolts, or has used lock washers. In these instances, there is no mechanical need for hammering over the threads. Nonetheless, several instances of cars being bad ordered have been reported to me, and I can only warn you that you should be prepared to hammer over, or chisel over, threads to make an otherwise happy inspector even happier.
[5/31/91] Railroad User Fees - The Budget Reconciliation Act of 1990 has required the Federal Railroad Administration to establish a fee schedule to recover the costs of implementing the various Federal Railroad Safety Acts, an amount that reaches approximately $40 million per year. Diane Elliott can provide you with additional details of this new tax, but suffice it to say that it does not apply to private car owners, per se. It does, however, apply to all railroads over which the FRA has safety oversight, and the FRA has chosen only to exclude "plant railroads". It thus intends to tax short lines, tourist railroads, commuter lines, etc. We will undoubtedly be hearing more about these user fees in coming months.
[12/27/91] FRA Regulation - Earlier this year we wrote a letter to those of our members who operate railroads concerning proposed regulations of the Federal Railroad Administration to recover the costs to administer the Federal Railroad Safety Act. We also filed a response to a proposed regulation by the FRA requiring "event recorders" on all locomotives which handle passenger equipment, with the exception of steam engines. We understand that nothing further has occurred with respect to event recorders, but with respect to increased regulation, the FRA has issued regulations which will require the payment of a user fee by the various railroads which will reimburse the FRA for the cost of FRA inspections. The minimum fee is $500 per year, and goes up substantially from there, because apparently the cost of all FRA inspections is about $40 million. The Train organization protested the imposition of these user fees on railroads, particularly museum, short line, and excursion train operators. It is my understanding that the FRA has decided to go forward with the imposition of these fees on all railroads except plant switching operations, and as we learn more about the situation, you will be advised.
[8/31/92] FRA Users Fees - I reported a bulletin or two ago that the Federal Railroad Administration was about to impose its jurisdiction on a wider variety of railroads, and according to an article in the Trainline Magazine of the Tourist Railroad Association, this last April the FRA has made all railroads, whether or not part of the general railroad system liable to comply with the hours of service rules, pay a minimum $500/year user fee, comply with boiler inspection and requirements, keep accident reports, and equip freight trains which operate over 35 mph with event recorders as well as all passenger trains which operate over 20 mph, but has excluded steam locomotives. In support of their authority over all railroads, including tourist lines and roads not connected to the general system, the FRA has produced a 9 page letter and legal brief, which it supplies to senators and congressmen who intervene on behalf of their constituents.
[2/6/95] FRA - At 3 p.m. I met with Thomas Herrmann about the proposed Power Brake law regulations. We still have until the end of February to submit comments. The proposed scheme is to do away with COT&S, and instead rely solely on single car tests every 6 months, or oftener.
Mr. Herrmann advised that the rules were written without knowledge of our equipment, and potential problems, such as the need for us to get to a facility where a single car test could be run. Also we discussed the general lack of passenger car test devices in the field; and the relatively low utilization of our equipment, which might lead to longer COT&S intervals. It is my understanding that Amtrak averages about 500,000 miles each year, whereas our highest running car was only 30,100 miles last year.
Paul L. DeVerter II
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