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made, its arrival time can be predicted. The potential for beneficial management of hazardous materials traffic took a major leap forward with the institution of STCC and the railroad industry believes that the benefits have only begun to flow. Against the proven success of the Standard Transportation Commodity Code, the Materials Transportation Bureau has proposed adoption of a United Nations numbering scheme, a four digit method of identifiers which supposedly has as a benefit the fact that the numbers don't mean anything.
The regulations as proposed by MTB would require that a 4-digit number (the UN-Code) become part of the shipping name, appear on all shipping documents and be attached to tank cars separately from the placards. The alleged purposes of these proposals are two-fold: first, the United States would be brought back into line with the rest of the world and, second, the numbers would provide access to an MTBdeveloped emergency guide book.
According to information AAR has been able to gather, the UN-Code is not a universal, international identification at all. Canada is still in the early stages of regulatory consideration, Great Britain has adopted a different system, as has Switzerland, and the majority of the European common market countries are nowhere near mandating the UN-Code as the answer to perceived hazardous materials identification problems.
While members of the Bureau of Explosives' staff screened MTB's emergency guide book for technical accuracy-their commitment to the safety of railroad personnel and firefighters compelled it-the proposed format, in their opinion and in the opinion of other industry experts, could mislead the user to the detriment of safety. The proposed guide is not commodity specific but it "lumps" groups of materials under a UN-Code number for reference to a common page within the guide. The proposed guide is subject to misuse if any of the numbers are transposed and, while this is a fault common to any numeric system, it is especially so with a system which has no internal logic (where the numbers do not "mean" anything but merely point to an index).
Serious doubts should be cast on MTB's proposed UN-Code both because it does not represent the best the state of the art has to offer and because in an era of soaring inflation it simply does not make economic sense for a government agency to attempt to duplicate what the private sector already has in place and functioning.
After commodity identification, one of the most vexing problems at a transportation accident involving hazardous materials is finding the answser to the question, "Who's in charge here?" Several entities typically present themselves and, depending upon such factors as the personality of the individuals involved and the state of knowledge each believes the other has, a central focus may emerge which may or may not represent the best solution.
The three most common entities on site-at least at a derailment-are the railroad (including, often, a wreck clearing contractor, several representatives of shippers who have responded to the request of the railroad and the Bureau of Explosives district inspector augmented by such of the headquarter's professionals as are appropriate and available), the local emergency response forces (typically, the fire department, but often the Civil Defense forces and, increasingly, the state police) and the Federal on-scene-coordinator.
The railroad's role as a common carrier means that, at least initially, it is responsible for the cars and commodities damaged. This unique legal status does not determine third-party rights or liabilities and it exists as a means of effecting the restoration of vital transportation services. Any change in this role must be seriously examined in order not to disrupt the nation's rail network.
The role of emergency response forces is primarily one of protection of lives and adjacent property. They cannot be expected to have the sophisticated knowledge of chemistry necessary to effect a complete clean up, nor can they be expected to be aware of the multiple differences between types of rail cars and their cargoes. The Federal on-scene coordinator is an official pre-designated under the Clean Water Act to focus and coordinate the Federal response to the scene. In the event of the threat of serious environmental damage, and if the railroad for some unknown reason takes no action in mitigation, the on-scene coordinator has certain powers to "take over" and apply Federal resources to reduce the threat.
Experience has shown-and remember that, with a good accident record, there has not been (fortunately) an overwhelming amount of experience—that most often these three units with different training and different missions achieve a consensus approach to the handling of the situation and, with no particular drama, the damage is cleared and the transportation services restored.
The railroad industry is unanimous in the opinion that, in the event of conflict about "Who's in charge?", the best single person is the senior railroad official present. First, this person is intimately familiar with the railroad environment and knows where to go to ensure himself of the particular expertise needed; second, the railroad will have primary fiscal and legal responsibility and so has the greatest incentive to take the right actions and make the right decisions about clean up and mitigation and third, speaking again from actual experience, history shows that when anyone else steps in, more often than not decisions are made which are not the optimum. Shifting to a more positive side, experience has also demonstrated that senior railroad officials have made the right decisions almost always and that there is no demonstrable need to alter the present system.
The railroads and the communities they serve have, by and large, enjoyed superb cooperation during emergency situations from the shippers of hazardous materials. When a train carrying chemicals goes on the ground, the railroads have been able to call the shippers involved-even in the middle of the night-and to receive advice and an on-scene response when necessary.
No entity better typifies this than the chemical industry's Chemtrec service. The Chemical Transportation Emergency Center is staffed by trained communicators 24 hours a day. When a call is placed to the Chemtrec 800 number (800-424-9300) the person who answers can supply information on particular commodities and can contact the shipper to relay additional information. For a transportation emergency involving chemicals, Chemtrec can bring to bear a host of talent and expertise. Chemtrec's services are so reliable and its lines of communications so fast that a number of railroads even use it to contact the Bureau of Explosives-thus saving a harried railroad dispatcher for communications directly with the derailment site. Other than the Bureau, Chemtrec can trigger a response from organizations like the Chlorep teams. The chlorine producers, realizing that they were shipping one of the deadliest and yet one of the most vital of the gases, created Chlorep to provide regional "go-teams" who could respond to chlorine emergencies regardless of the identity of the producer/shipper.
In today's litigation-prone society there is some fear that voluntary actions-like Chemtrec, Chlorep or even the on-scene response by an individual shipper-could lead to potential legal liability. The current costs of litigation are so astronomical that even being named as one of the defendants in a law suit is a severe economic burden.
One way to encourage all concerned-shippers, carriers, Chemtrec, the Bureau of Explosives and others—to continue to provide their very beneficial services is to grant such volunteers protection from litigation. Often termed "Good Samaritan Laws," there are plans and model acts that should be considered for adoption on a nationwide basis. AAR believes that affording this kind of protection is so important that it should not be tied to other legislation—such as that now being considered in the environmental spills area ("Superfund")—but that it should represent a clear national statement of encouragement to those who step forward to help in times of emergency.
The Tank Car Safety Test and Research Project proved the industry's ability to recognize problems and to find and implement solutions to them-as long as it can act freely. (Shelf couplers for pressurized uninsulated tank cars were developed and ready for several years before the DOT would permit their installation.) The recent successes with the reduction in the occurrence of leaks and splashes on shipments of corrosive fertilizers from the southeast demonstrates the industry's ability to fine tune what is already a good system and the drastic decline in hazardous materials related injuries for 1979-plus the fatality record over the past decade-adds further testimony to the proposition that no drastic cure is needed for an illness that hasn't struck.
This does not mean that the Congress need not carefully exercise its oversight process in the area of hazardous materials. One such problem-the proposal by the Materials Transportation Bureau for the adoption of the UN-Code-has already been explained. Another exists in the proposal by MTB to adopt standards for intermodal portable tanks that are significantly less strong than those now in force in the railroad industry; even more alarming is the DOT policy, despite the objections of AAR and others in the industry, of granting special permits for the transportation of dangerous goods in intermodal container tanks prior to the adoptionunder the correct administrative rulemaking procedure-of any standard for these instruments of transportation at all.
The rail industry's standard for intermodal tanks in container-on-flat-car service was adopted with corrections designed into what became the standard proposed by MTB. While the precise details of the railroad's objections are on file with MTB,
they can be highlighted in two areas: first, rigidity and crush resistance are significantly less under the MTB proposal than under the AAR Standard; second, nowhere in the AAR Standard are non-reclosing safety vents permitted. (The effect of allowing them is to invite massive product leaks if the portable tanks ever turn over.) Representatives of MTB have argued that the balance of payments on overseas chemical traffic is so favorable to this country that the shippers should not be discouraged by requiring tanks to meet the admittedly more expensive AAR standard. Very recently, it came to the attention of the Bureau of Explosives that about 95 percent of the exemptions granted for intermodal tank traffic have been granted to foreign shippers!
The railroad industry has demonstrated a remarkable ability to bring about a safety record that rightfully inspires pride and it has evern more importantly demonstrated an ability to keep improving on that record no matter how good it gets. As long as dangerous chemicals are vital to America's economy and as long as the railroads provide the most economic and safest way to move them on the surface, there will be a hazardous materials concern. The members of the Association of American Railroads believe that now is the appropriate time for that concern to mature from a crisis atmosphere to one of recognition of the worth of what has been, is being and will be done by the shippers and carriers of these materials.
I would like to end my presentation as I began it, by stating that railroading is a safe industry. There are areas which can be improved, and we are working to improve them. But we are not looking at a problem which can be addressed in a sweeping general way by new laws or new rules. Rather, it is a matter of addressing specifically each of the disparate causes of rail accidents and applying to them the appropriate specially-tailored remedy.
APPENDIX A.-SAFETY STATISTICS
All railroads are required to report certain classes of accidents and employee casualties to the Federal Railroad Administration. The Research and Test Department of the AAR maintains continuing surveillance of these data and conducts analysis of them so as to identify and rank the comparative importance of the causes of accidents, injuries, and fatalities.
The FRA categorizes accidents into three groupings for reporting purposes: train accidents, train incidents, and non-train incidents. Train incidents refer to occurrences in which there was relatively little financial loss but which resulted in death or injury. Non-train incidents relate to injuries or deaths not involved in the movement of trains. An accident is classified a train accident if it involves at least $2,900 damage to railroad property whether or not it involved any injuries. In January 1975 the FRA reporting requirements for both train accidents and incidents were significantly changed making most of the earlier data not comparable to 1975 through 1978 data.
Figures 1 and 2 show the percentage of fatalities and injuries by type of accident for 1978. Also shown are fatalities and injuries to employees. (In these figures, train incidents and non-train incidents have been combined into the category, incidents). Grade crossing accidents accounted for the largest percentage of railroad-related fatalities, 61 percent. Train incidents accounted for 35 percent of all railroad fatalities, most of which involved trespassers. Only 3.7 percent of reported fatalities were related to train accidents, and only 2.3 percent or reported injuries occurred as a result of a train accident.
There has been a downward trend in fatalities since 1966, as shown in Table 1. From 1966 through 1978 there has been a decrease of over 1,000 fatalities. Preliminary data for 1979 show the number of fatalities to be an all-time low.
Train accidents receive the most public attention, especially track-caused train accidents. However, as shown in Figure 3, only 5 percent of fatalities and 11 percent of the injuries were the result of train accidents in 1978.
Figure 4 presents the 1975-1978 trends in train accidents at various damage thresholds adjusted for the levels of traffic. The FRA reporting threshold is adjusted bi-annually to remove the effects of inflation. In 1975 and 1976 the threshold was $1,750, and in 1977 and 1978 it was $2,300. In January 1979 it was increased to $2,900. When the inflation factor is applied yearly, the upward trend in accidents is lessened. The curves in Figure 4, stated in terms of 1975 dollars, show that as the damage threshold is increased, the number of accidents is significantly reduced. Over 60 percent of reported accidents have damages below $10,000; and major
accidents, those in which damage to track and equipment was greater than $100,000, have remained constant over the last four years.
TABLE 1.-NUMBER OF TRAIN ACCIDENTS BY THRESHOLDS (1975 DOLLARS)
Table 2 shows the number of major accidents-those involving the most property damage. As can be seen, these accidents have not increased over the last four years. And, when adjusted for levels of traffic, the most costly accidents have decreased. As shown in Figure 5, the primary types of reported train accidents were mainline and yard derailments which accounted for 70 percent of total train accidents (40 and 30 percent, respectively). Figure 6 shows the damage trends for these accidents in constant 1975 dollars. As can be seen, mainline derailments alone accounted for almost 70 percent of total reported costs while yard derailments only accounted for 10 percent. As is also shown in Figure 6, reported damages have not substantially increased over the last four years indicating that while accidents have increased, the severity of accidents has decreased.
Figure 7 shows mainline derailments by major cause category. The same breakdown is shown for yard derailments in Figure 8. Equipment-caused derailments decreased in both mainline and yard derailments. Track was the leading cause of both mainline and yard derailments. These derailments increased 17 percent on mainlines and 40 percent in yards over the last four years. But, as mentioned earlier, these yard derailments are much less significant in terms of damages than mainline derailments.
Sources: Fatality and injury statistics for years 1966 through 1978 from FRA Accident/Incident Bulletin: Summary and Analysis of Accidents on Railroads in the United States; for 1979, from Preliminary Report of Railroad Accidents/Incidents and Resulting Casualties, FRA.
The next three figures relate to train accidents involving hazardous materials. The presence or release of hazardous materials is not a basis for reporting. These accidents were reported based on a dollar damage threshold. Figure 9 shows the types of accident for hazardous materials releases and for total accidents. As can be seen, mainline derailments were much more significant for accidents involving a hazardous materials release than for accidents in general.
The percentage of total accidents that resulted in a release of hazardous material has remained relatively constant over the last four years, as shown in Figure 10. About 4 percent of reported accidents involved damage or derailment of hazardous materials cars. Only about 1 percent of accidents resulted in a release of hazardous material.
The mainline derailment cause tree shown in Figure 11 presents the percent of mainline derailments which resulted in a release of hazardous material. This cause tree shows the cause subgroups within major categories of track, equipment, and human factors. Each of these cause subgroups shown represent many specific causes. For example, rail and joint bar defects include almost 20 individual causes, such as bolt hold crack or break, horizontal split head, worn rail, joint bar broken, etc. The analysis grouped cause codes because no one cause code accounted for significant percent of total mainline derailments or release derailments.
Causes of release derailments were varied and did not appear significantly different than the causes of derailments in general. This points out that the elimination of derailments from any one individual cause would have little impact on derailments involving the release of hazardous materials or overall safety.
As mentioned earlier, railroad casualty data are filed monthly with the Federal Railroad Administration. The most current data available covers the period from 1975 through 1978. The AAR completed an analysis of employee casualty data in December 1979. Some of the more significant findings are discussed below.
As shown in Figure 12, there are over 56,000 casualties reported annually. Of these, about 110 or 0.2 percent are fatalities. As a result of these casualties, over 450,000 mandays are lost annually. This alarming figure is equivalent to an annual loss of over 1,700 manyears. The associated costs of insurance, payroll compensation, claims, law suits, and direct injury costs have been estimated by some railroads to average nearly $400 per lost work day. Using this figure, employee casualties cost the industry over $176 million annually. This estimate would be much higher if all hidden costs, such as those associated with maintaining productivity, could be accurately quantified.
The majority of these injuries are not associated with train accidents as discussed earlier. Therefore, research on employee safety must consider factors other than the causes of train accidents if they are to have a significant impact on employee injuries.
Interestingly, the majority (50 percent) of the reported injuries do not involve lost work days (Figure 13). Nevertheless, the cost in terms of human suffering is significant. Over 40 percent of all injuries which result in lost work days are sprains and strains. The majority of these involve the torso, leg, or foot. And, 50 percent of all injuries involving lost work days require more than seven days of recovery before the employee returns to work.
The overall frequency and severity rates may be increasing. Figure 14 shows that the number of injuries per million manhour and the number of lost work days per million manhour have increased by 64 and 29 percent, respectively, since 1975. However, industry officials believe that a large percentage of this increase is due to improvement in reporting. Until 1975, under Federal requirements, reports were filed in each case of fatality or injury involving more than one lost work day. Starting in 1975, loss of time of a day or a medical treatment were established as the minimum threshold for reporting. Thus, a certain amount of time was required for the industry to "learn" the new reporting requirements, change record-keeping procedures, and begin to file accurate counts of casualties. It is important to note that this change in reporting requirements doubled the number of cases being reported.
The most critical craft categories were identified by use of a frequency/severity index. Road trainmen were identified as the most critical craft, followed by yardmen, trackmen, carmen, shop workers, skilled laborers, signal workers, and equipment operators. Figure 15 shows the percentage of injuries associated with each of these crafts. Trainmen accounted for 18 percent of the injuries but only 9.5 percent of the manhours. Yardmen accounted for 22 percent of the injuries but only 9 percent of the manhours. Trackmen accounted for 19 percent of the injuries but