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[The following information was subsequently received for the record:]


Question 1. To what extent has the rail industry become more sophisticated and knowledgeable in the area of rail safety? Have its goals changed in this regard? What are the present goals of the industy in the area of safety, and how are its activities being geared in that direction? What are the problem areas to which the industry what to pay close attention in an effort to monitor its own safety, outside the realm of regulation?

Answer. As in every heavy industry, the business of operating a railroad is not free from risk of personal injury. Our goal is to continue to reduce that element to an absolute minimium to the employee as well as the public.

Modifications in the design of rolling equipment including locomotives and cabooses are constantly underway to improve both safety and comfort.

Continuing improvements in the method and design of right-of-way both in regard to installation and maintenance are being made.

Techniques designed to monitor the reliability of the operating environment are constantly being progressed. These include devices designed to detect oveheated journals, broken and loose wheels, dragging equipment on rolling equipment, and instrumented cars to monitor track and rail conditions such as alignment and metal flaws.

Improvements in braking systems are constantly being made which include removing potential enviromental hazards such as eliminating the use of asbestos in the manufacture of brake shoes.

Exhaustive studies are being made to determine the most appropriate manner to distribute the tonnage in a freight train over various terrain for safe transportation. Improved glazing materials are to be used in locomotives, cabooses, and passenger cars to provide additional protection to passengers and employees from stoning and shooting by vandals.

These are only a few of the ongoing efforts by the railroad industry with the cooperation and support of the supply industry to improve safety.

A concern which the industry is attempting to address at the present time comes under the general heading of "Human Behavior" or the "Human Element." This covers a broad area which includes physical qualifications, ergonomics, training, aging, rehabilitation, and drug and alcohol counseling just to name a few.

A joint government, labor, industry study is presently being conducted which addresses these issues. We also believe that this study will assist in determining those factors which influence the success of employee safety programs.

Question 2. Does the AAR maintain an individual carrier safety profile, and, if so, how is it obtained? Does the AAR have a program to work with specific carriers on an individual basis if specific problems are found? To what extent can the AAR motivate a carrier to make necessary changes in the area of safety, thereby ensuring that the industry is policing itself?

Answer. The Association of American Railroads compiles a statistical profile known as "The Frequency Severity Report of Employee Casualties and Occupational Illness" (FS Report). The AAR also produces periodic analyses and reports on the frequency and severity of employee casualties by job craft, cause, and type of injury for the industry and for individual carriers. These analyses and reports are based on the cases reported to the Federal Railroad Administration as required by their regulations.

The AAR has several programs which are used to work with individual railroads. Our Safety Section Steering Committee is comprised of eighteen Chief Safety Officers from major railroads which account for approximately 90 percent of the U.S. railroad work force. This Committee sponsors and participates in a wide range of projects and activitites which address specific safety problems.

Ther AAR Bureau of Explosives performs safety audit inspections on railroad facilities and at the production and shipping sites of the Bureau's over 500 member plants. During the course of a visit to, for instance, a member plant's tank car loading rack, the Bureau inspector will not only verify compliance with applicable DOT regulations, the inspector will meet with the loading rack personnel to explain new regulations and to stress the importance of following the safest possible practices, whether or not codified in the regulations.

These visits also occur between the Bureau inspectors and railroad employees working in yards, stations, stores, departments, and in train and engine service. Because of their special proximity to hazardous materials cars, a special tape/slide show was developed by the Bureau of Explosives Steering Committee for train and engine service employees. The program is designed to make it easier (and therfore safer) for operating employees to understand and follow the rules on inspecting, switching, handling, and train placement of cars of dangerous chemicals. Several major railroads used the format and content of the Bureau program to produce their own, in order to meet the unique circumstances-whether by reason of special carrier fuels, yard layout, traffic patterns or geography and climate-on individual railroads.

The AAR Mechanical Division monitors safety problems involving locomotives and freight cars. As a problem is identified, the "Division" issues directives which require owners of equipment to take action. If a situation calls for modification or retrofit of equipment, railroads must comply with the AAR directive or the equipment in question will not be allowed to interchange between railroads.

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Question 3. The Office of Technology Assessment has stated that, * individual railroads have conducted safety analyses of their specific operations. The transfer of information of from these types of analyses of other railroads could be improved." What is your response to this statement? In this regard, do you believe that the flow of information among the carriers and between the regulatory agencies and the industry is adequate.

Answer. The AAR serves as a clearinghouse for the collection and distribution of safety information. Railroads that have developed effective safety training programs are more than willing to share such information. The AAR Safety and Special Services Division maintains a catalog of safety training manuals and audiovisual programs that have been developed by individual railroads and are available to all railroads. Another example of information transfer is a survey and evaluation of safety programs which is being conducted through the corporation and participation of the AAR Safety Section Steering Committee. This project includes a survey of individual railroads to determine the effectiveness of their safety programs. A major objective is to identify the most effective programs and make this information available to all railroads. The AAR, with the corporation of the Chemical Manufactures Association and the Railway Progress Institute, is also examining the special operating practices railroads use to improve the safe handling of hazardous materials shipments. Again the objective is to identify the most effective of these operating practices and provide this information to all railroads.

Such programs and activities are the basis for our belief that the flow of safety information among carriers is adequate. Information flow between regulatory agencies and carriers could be improved, however. More effective ways of informing the industry of Federally-sponsored rail safety research projects would be desirable. Greater awareness of and participation in these studies by the industry would increase their value.

Question 4. You have mentioned the changes which were made in the accident reporting system of the FRA. Do you feel that this system is adequate and accurate and, if so, why?

Answer. Dramatic changes were made in the FRA reporting regulations effective as of 1975. They were too numerous to mention in this correspondence but of a magnitude that FRA agrees that statistics resulting since 1975 may not be compared with any period prior to 1975.

The new FRA reporting regulations, definitions, and interpretations were designed for the most part to comply with those of OSHA which provide the basis for our concern. OSHA uses the terms "Work-Related" and "Job-Related." The FRA states that the purpose of reporting is to disclose the hazards arising from the operation of a railroad. Our basic concern regarding the system is that it is not confined to "Work-Related" or "Job-Related" cases. The data being collected includes such examples as an employee going to a cigarette machine in the main lobby of the office building and because he does not receive correct change, injures himself by striking the machine or, during the lunch period engages in (baseball, horse-shoes, basketball, etc.) and allegedly injures his back, ankle, wrist, etc.

The purpose of accident reporting should be to identify work-related hazards to aid in achieving the objective of minimizing or even eliminating the potential exposure to work-related injuries. The current system requires reports on too broad a basis and thus inhibits the ability to isolate "Work-Related" or "Job-Related" cases. The system is unnecessarily broadened and consequently unduly burdened by the requirement that all injuries be reported.

Until the injury data reflects those hazards related only to industry activity, the "System" will continue to be inadequate and inaccurate.

Question 5. The AAR has stressed the need for research and development in the safety area. What do you believe are the key areas for future research at the present time, and do you believe the FRA is doing enough in these areas? In this regard, you have mentioned the appropriateness of “special studies.” Are there any such studies which you would recommend at this time?

Answer. This question addresses the issue of how to identify those research programs which have the greatest potential for improving rail safety. The identification and ranking of key research areas must be based on program costs and estimated effectiveness in terms of reduced casualties and property losses. Such effectiveness measures must be weighted by the probability that the program will result in practical, implementable results. Too frequently systematic approaches to the identification of priorities and execution of the most promising safety programs are subverted by reactions to highly visible accidents. Such reactions can delay progress in safety, as these accidents are usually unique, and their causes and circumstances may bear little relationship to the significant rail safety problems

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