Subject: Safety Appliances & End Handholds (10/23/00)
Amtrak Inspector Ponicki has refused to accept end handholds which are not in strict conformance with the FRA rules. Usually, the violation is that the handhold is turned over, and thus is sort of extending upwardly from the bolt holes, rather than downward. In addition the FRA rules require that the handholds be flush with or project not more than 1" beyond the face of the end sill or vestibule face, depending upon which rule is applicable, see 49 CFR 231.12 et seq. It seems to make no difference that Amtrak itself turns the end handholds over so as to clear the HEP connection receptacles when the lids are open. In one instance Amtrak was written up by the FRA inspector, and the following confusing correspondence shows how the "rule" was reinterpreted to avoid a violation. If you thought you knew where the vestibule face was on a wide vestibule car, you were wrong. It is now the plane of the external collision post to which the diaphragm is bolted, and the end sheet is now a vestibule partition. Thus the vestibule face is an imaginary structure, and the rule is avoided, at least in part. Then the rest of the rule is simply ignored. The real answer is to get the rule rewritten, which is apparently an exceedingly hard thing to do.
Editors note: Paul has mailed a set of diagrams to accompany this posting which will be added once they arrive
Paul L. DeVerter II
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