Several weeks ago, I talked about some of the challenges of railroading in the fall. Since the weather has gotten colder since then, I thought I would share a few of the adventures we have had now that winter has arrived. It always seems that winter time brings more break downs, equipment failures, and other problems. It also seems that when things do go wrong, everything happens at once.
For the last few weeks, I have been working as a Conductor, since traffic levels have dropped and they do not need me as an Engineer. On my first trip working as a Conductor again, we had a pretty normal trip up to Forsyth, but coming back things got a little more interesting. We got called on duty before the train had actually arrived in Forsyth. When it did finally arrive, the crew told us that the second locomotive had died on them about a half hour earlier, and they were unable to restart it. The temperature outside was about 14 degrees, so if we could not get it running again, we would have to drain the cooling water out of it. Locomotives on BNSF do not have any antifreeze in the water, so when it is cold out, and the engine is not running, the locomotive has to be drained to prevent it from freezing.
When we got on the train, we immediately went back to look at that second locomotive, and see if we could get it running. We also called BNSF Mechanical on the radio to alert them of the dead engine. In the cab, the computer said the engine had been shut down due to low cooling water, so that was the first thing we checked. The water appeared to be full. Actually, it was higher than the full mark, and the person at BNSF Mechanical told us that overfilled was as bad as being low, and we would need to drain some of the water out of it, until it got below the full mark. So, that is exactly what we did. I am not sure how much water a locomotive holds, but it is a lot. It took a while to get it below the full mark, and when it did finally get down to that level, the computer still said the water was low. We called mechanical back and reported that we had drained some water but the engine still would not start. He suggested we cycle the computer control breaker, to shut down and restart the computer, which is exactly what they tell you to do every time they cannot figure out what else to do. When the computer came back on, the low water warning was still there, and the engine still would not start. We tried cycling the breaker once more, at the instruction of BNSF Mechanical, with no luck. Since the engine would not start, and by this time the water had already cooled to a temperature below the lowest mark on the thermometer, we decided we had better drain the engine. We drained the engine, tagged the locomotive as being bad ordered, and then departed eastbound.
For the next couple hours, the trip went pretty smoothly, although the temperature continued to drop outside. We had a meet at Marsh, about 20 miles west of Glendive, and that would be the last westbound train for quite a while. The plan was to send us into Glendive after that meet. We stopped at the west switch, so I could push the button and line us into the siding. Normally it takes about 30 seconds after the button is pushed for the switch to line and the signal to change. By that time, I was back on the locomotive, but nothing had happened. We figured the switch must be frozen, because the last detector had said it was minus seven outside. The switches are equipped with propane heaters, but they only come on when moisture is detected. Since it had been dry most of the day, we figured the heater was probably off. I grabbed a bottle of water, to dump on the heater and turn it on, and went out to line the switch by hand. It had filled up with snow somehow, probably from the wind, and since the heater had been on earlier, but then shut off, causing all the snow that it had melted to refreeze and coat the entire switch in a layer of ice, beneath the snow that had blown in.
While I was chipping ice off the switch, something weird happened. The Engineer kept flashing the headlights at me. Normally, at night, that would be to let the Conductor know that we had gotten the signal into the siding, but since I had the switch on hand, and the points were floating while I swept it out, it was impossible to have the signal. I was a bit confused, but got the switch cleaned out and lined for the siding, and then gave the Engineer a hand signal to proceed. He stopped on the switch, and I put it back to power and locked it all up, and hopped back on. When I opened the door to the cab, it smelled like something was burning in there. He had the headlights off, but since our meet was sitting right there, that was not unusual. As it turned out, they were not off by choice, and that had to do with the flashing earlier. He had tried to turn the headlights on so that I would have more light while cleaning the switch. When he did that, the headlight switch shorted out, which resulted in the burning smell that filled the cab with enough strength to make anyone gag. He demonstrated this to me several times. Turning the headlights on made them come on for about a second, then go out, with an accompanying crackling sound from the control stand. We used a couple of flashlights to see ahead of us in the siding, and let the dispatcher know that we had no headlights, and until we could get some, we could not leave Marsh. Seeing as the second unit was dead and completely shut down, we could not move that up front and use it, because the headlights would not have worked on it either.
We decided the idea situation would be to move the distributed power locomotive, on the rear, up to the front, and just use that as the new leader, because it was the only locomotive we had with everything working. However, being as it was seven below zero outside, cooling off, and windy, neither one of us wanted to walk back to that locomotive, which was over a mile away. The dispatcher agreed that walking was not a good idea and told us he would see about getting someone out there to give us a ride. The only problem with that is that Marsh is 45 minutes from Glendive, by car, on dirt roads, and since it had snowed the night before, it was somewhat questionable whether Marsh was even accessible by road. Eventually the dispatcher told us that one of our Trainmasters was on his way out, from Miles City.
Nearly five hours later, we saw headlights on a vehicle, coming our way. For the last four hours, we had been wondering where the Trainmaster was, and if he could even get to us. Turned out he had a story of his own. He had originally tried to get to Marsh, by way of Fallon, and found snowdrifts as high as the truck he was driving. From there, he turned around, drove to Glendive, and then tried to backtrack to Marsh. He told us that he got a few miles out of town, to where the road turns to dirt, and the low tire pressure light came on. He got out to check on the tires and said he could hear air leaking, so he turned around and drove back to Glendive. When he got to town, he left the truck and borrowed the yard van and driver, and headed back out to us. When they arrived, we hopped in the van for the ride back to the DP locomotive, and briefed the Trainmaster on what had happened so far.
When we got to the DP, we found that there was no FRED on it. Technically, trains operating with distributed power on the rear, do not need a FRED, because the DP locomotive can monitor the brake pipe pressure and serve as a marker. However, when a DP can no longer run on the rear, such as in our situation, there is nothing to monitor the brake pipe or serve as a marker, unless there is a FRED on the train. At any rate, we needed headlights more than we needed a working engine on the rear, so we took the DP off the train anyway. I managed to find a red flag on the DP locomotive, so I stuck that in the coupler, to serve as a marker. We would be limited to 30mph without a FRED or device to monitor the brake pipe, but we only had 20 miles to go.
When we got the DP off the train, I had to clean out the west switch again, because the heater had turned back off and everything had frozen. I have no idea how cold it was by this point, but it felt a lot colder than the first time I had cleaned that switch out! Once we got out, we ran alongside the train on the main track, and then put the DP on the head end. Fortunately, before the Trainmaster had arrived, I had gone and checked out the east switch, so it was thawed out and working properly for us when we got down there with the DP. We put the DP on, did our air test, and headed east, finally! When we got to Colgate, which is the last siding before Glendive, we had only a few minutes before we hit out 12 hour limit. As we went over the west switch, we got a call from a dog catch crew, who was on their way out to meet us, there at Colgate, so we stopped at the crossing there and waited just a couple minutes for them. I guess BNSF decided they did not want to fines associated with making a crew work over 12 hours! Dog catch crews are significantly cheaper!
We hopped in the van and that ended an eventful day for us. Most crews were getting from Forsyth to Glendive in well under six hours, and it took us over 12, so we were quite happy to be home. And the thermometer on the bank in Glendive said -12 degrees out, so it certainly had cooled off more since the first time I cleaned out the west switch at Marsh!
Showing posts with label Hours of Service. Show all posts
Showing posts with label Hours of Service. Show all posts
Saturday, January 5, 2013
Wednesday, January 25, 2012
Prototype Railroading: Rest Cycles
In 2008, Congress voted into law the Railroad Safety Improvement Act (RSIA), which we have talked about before. It is severely flawed, and was obviously written by people with no experience railroading. Driving a desk is completely different from moving trains. Without getting into all the details and problems again, I will just say that it is still in effect, and still frustrating to everyone who is subject to it. Today we are going to talk about how things were before that though. Before RSIA was in effect, railroaders were not subject to monthly limitations on work, and could work as much as they wanted without days off. They were required to have eight hours off between jobs, and they were allowed a maximum of twelve hours on the job. Many railroads had a system of rest cycles in place, where employees would work six or seven days typically, and then have the option of taking two or three off. This gave them the advantage of having somewhat predictable and reliable days off, in an otherwise unpredictable occupation.
For many railroads, RSIA did away with rest cycles, because it supposedly had days off built in. RSIA days off require starting work a certain number of days in a row. Since they are based on calendar days, and the railroad runs 24 hours a day, they do not work well. In fact, it has been over three months since I had my last RSIA days off. According to RSIA however, an employee was required 48 hours off after six consecutive starts, of 72 hours off after seven starts. A "start" is when an employee goes to work during a calendar day in train service. Only one start per calendar day counts towards the total consecutive starts, and working in deadhead service does not count as a start. This means, if you go to work at 10:00am on Monday, and move a train, you have a start for the day. It also means if you go to work at 11:59pm on Monday, you have a start for Monday, but not Tuesday, even though most of the shift will obviously be during Tuesday. This is how the railroad uses the system designed for days off to avoid days off! If they send you to work at 11:59pm on Monday, you will probably get off around 8:00am Tuesday. Well, that gives you a Monday start, so if they wait until 12:01am Wednesday to put you back on duty, you did not have a start on Tuesday, and therefore your consecutive start count resets. However, many railroads did away with rest cycles because most of the upper management thought this system was working. A few months ago the Chief Operating Officer if the BNSF held a town hall meeting locally and he honestly thought we were getting two days off every six days.
Rest cycles operated a little differently. They were not based on starts at all. If you were available for seven days, meaning marked up on a working board, with an assignment, you were eligible for the rest days. If the railroad only called you for work three times in those seven days, you were still eligible as long as you had been available for work the whole time. When the rest days came around, there was an option to take them, which for most people was the obvious choice, and there was the option to purge some or all of them, and work through the rest days. It was based on whether or not the employee felt that they needed rest days. I've found that, for the most part, people are better at judging their own fatigue, and need for rest, than the government. The reason rest cycles were done away with was partly due to the RSIA promised days off, and partly due to the situation with "starts," making it hard to work all the days between rest cycles. The starts and work days would have to line up perfectly to allow a person to get to their rest days without hitting their RSIA limit, and since train schedules often do not line up perfectly with that, scheduling presents a challenge.
Recently, at least locally, the BNSF has come up with a way to give us our rest cycles back, and a I write this, bids are being awarded on rest cycles. They have added a feature called "Smart Rest," which allows a person to reset their RSIA start count on their own, so they they will not hit their RSIA limit for starts. "Smart Rest" makes a person unavailable for work until the 12:01am that comes more than 24 hours after their last start. For example, if I went to work at 10:00pm on Monday, got off at 6:00am Tuesday, and then selected the "smart rest" option, it would make me unavailable until 12:01am Wednesday, meaning I would not get a Tuesday start, and therefore reset myself. By using the "smart rest" option, employees can ensure that they will be available for the seven days, and get their rest cycle days off. If they do not use "smart rest" to reset themselves when necessary, and they hit the RSIA days, the rest cycle days are forfeited. It is a little adjustment that is required to make seven on-three off rest cycles work properly.
The really nice thing about having three days off is it gives railroaders a proper weekend, even if it is not on weekend days. Three days is 72 hours for the railroad, and while most people think of the weekend as two days, it is actually longer than that. If a person with a regular schedule gets off work at 5:00pm on Friday and returns to work at 8:00am Monday, they have had 63 hours off, so our 72 hours off really is not much longer of a weekend. With the 48 hours off that RSIA requires after six starts, you spend the first eight to ten hours asleep, and usually you only really end up with about a day to yourself, where you are not asleep, trying to get rested for work, or adjust back to a normal schedule for the day you have. The seven and three rest cycles will be really nice. I should know what my rest cycle is by this afternoon, which will finally make working for the railroad more predictable!
For many railroads, RSIA did away with rest cycles, because it supposedly had days off built in. RSIA days off require starting work a certain number of days in a row. Since they are based on calendar days, and the railroad runs 24 hours a day, they do not work well. In fact, it has been over three months since I had my last RSIA days off. According to RSIA however, an employee was required 48 hours off after six consecutive starts, of 72 hours off after seven starts. A "start" is when an employee goes to work during a calendar day in train service. Only one start per calendar day counts towards the total consecutive starts, and working in deadhead service does not count as a start. This means, if you go to work at 10:00am on Monday, and move a train, you have a start for the day. It also means if you go to work at 11:59pm on Monday, you have a start for Monday, but not Tuesday, even though most of the shift will obviously be during Tuesday. This is how the railroad uses the system designed for days off to avoid days off! If they send you to work at 11:59pm on Monday, you will probably get off around 8:00am Tuesday. Well, that gives you a Monday start, so if they wait until 12:01am Wednesday to put you back on duty, you did not have a start on Tuesday, and therefore your consecutive start count resets. However, many railroads did away with rest cycles because most of the upper management thought this system was working. A few months ago the Chief Operating Officer if the BNSF held a town hall meeting locally and he honestly thought we were getting two days off every six days.
Rest cycles operated a little differently. They were not based on starts at all. If you were available for seven days, meaning marked up on a working board, with an assignment, you were eligible for the rest days. If the railroad only called you for work three times in those seven days, you were still eligible as long as you had been available for work the whole time. When the rest days came around, there was an option to take them, which for most people was the obvious choice, and there was the option to purge some or all of them, and work through the rest days. It was based on whether or not the employee felt that they needed rest days. I've found that, for the most part, people are better at judging their own fatigue, and need for rest, than the government. The reason rest cycles were done away with was partly due to the RSIA promised days off, and partly due to the situation with "starts," making it hard to work all the days between rest cycles. The starts and work days would have to line up perfectly to allow a person to get to their rest days without hitting their RSIA limit, and since train schedules often do not line up perfectly with that, scheduling presents a challenge.
Recently, at least locally, the BNSF has come up with a way to give us our rest cycles back, and a I write this, bids are being awarded on rest cycles. They have added a feature called "Smart Rest," which allows a person to reset their RSIA start count on their own, so they they will not hit their RSIA limit for starts. "Smart Rest" makes a person unavailable for work until the 12:01am that comes more than 24 hours after their last start. For example, if I went to work at 10:00pm on Monday, got off at 6:00am Tuesday, and then selected the "smart rest" option, it would make me unavailable until 12:01am Wednesday, meaning I would not get a Tuesday start, and therefore reset myself. By using the "smart rest" option, employees can ensure that they will be available for the seven days, and get their rest cycle days off. If they do not use "smart rest" to reset themselves when necessary, and they hit the RSIA days, the rest cycle days are forfeited. It is a little adjustment that is required to make seven on-three off rest cycles work properly.
The really nice thing about having three days off is it gives railroaders a proper weekend, even if it is not on weekend days. Three days is 72 hours for the railroad, and while most people think of the weekend as two days, it is actually longer than that. If a person with a regular schedule gets off work at 5:00pm on Friday and returns to work at 8:00am Monday, they have had 63 hours off, so our 72 hours off really is not much longer of a weekend. With the 48 hours off that RSIA requires after six starts, you spend the first eight to ten hours asleep, and usually you only really end up with about a day to yourself, where you are not asleep, trying to get rested for work, or adjust back to a normal schedule for the day you have. The seven and three rest cycles will be really nice. I should know what my rest cycle is by this afternoon, which will finally make working for the railroad more predictable!
Wednesday, July 27, 2011
Prototype Railroading: Hours of Service
For safety reasons, train crews are limited in how long they can work, how much rest they need between shifts, and when they get days off. In 2008, Congress passed a bill called the Railroad Safety Improvement Act, which drastically and unnecessarily complicated all of this, but for now it is what we must live with. Ironically, though not surprisingly, railroad safety has not improved as consequence of this bill. Congress has little experience managing railroads, and even less managing them well.
Before the Railroad Safety Improvement Act, or RSIA, went into effect, railroaders were allowed to work a 12 hour shift. They then had to have eight hours off before their next tour of duty. Once they hit that 12 hour limit, the train had to stop and be secured, regardless of its location. A van would come out and get the crew. They would continue to get paid until they went home. There was no federal regulation on days off. Most railroads had policies in place giving people time off after a certain number of days worked. On the BNSF, an engineer or conductor would be on call for seven days. At the end of the seven days, they got 72 hours, or three days off. If they were on duty when the seventh day ended, their three days off started as soon as their tour of duty ended. People tell me it was a great system, and you always knew when your days off would be. If you decided you did not need the days off, you could work all or some of them, and there was no penalty.
That all came to an end with RSIA. Train crews are still permitted a maximum of 12 hours on duty. At the end of 12 hours, just as before, the train stops and the crew secures it and a van picks them up. Instead of then getting eight hours of rest time, they are now required to have ten hours off duty before the next shift. That is nice at the home terminal, but away from home, we would rather just get back to work and go home. Additionally, a crew may receive rest in the middle of their shift as well. If they receive less than four hours of rest, then their rest time also counts towards the 12 hour limit. However, if they get between four and ten hours of rest, it does not count towards the 12 hours. When they go back on duty, the time starts again where it left off. Of course, anything over ten hours is considered "Rested" and the clock starts back at zero upon going on duty.
Prior to RSIA, the amount of time spent waiting for the van, after the 12 hour limit, had no limit. A train crew could spend 12 hours moving a train, and then another 12 sitting on the train waiting for the van to show up. That time, after the on duty limit has been reached, but before a crew goes off duty, is called "not on-duty, not off-duty" time. Yeah, Congress even came up with an original name! Most of us call it Limbo time. That is now limited to 30 hours per calendar month. Typically the van shows up in just a couple of hours now, rather than within a couple of days! Even with that limit, I have sat on a train for 16 hours. Just as before, the railroad does continue to pay the crew for the time waiting for the van to show up. Additionally, if you have to wait for the van and you go over 12 hours during the wait, then any additional time beyond 12 hours must be added to the rest time. So if you "go dead" as we say, and then it takes an additional hour for the van to arrive and get you home, you get an additional hour added to your rest time, making it 11 hours of required rest. This is to encourage the railroad to plan ahead a little and get the van out to you sooner. This 30 hour limit is allowed to be broken in the event of "casualty, derailment, Act of God, major equipment failure, or cause unknown and unforeseeable." So if you do not foresee an unknown cause, you can sit in the van longer!
The seven days on, three days off cycles were done away with. Now, there is a rather complicated system of "starts." When a person has six consecutive starts, they are required to get 48 hours off at their home terminal. If they have seven consecutive starts, then they are required to have 72 hours off at their home terminal. Getting six starts is rather common, but seven is unusual. Typically a person gets a seventh start when their sixth one takes them away from home. A start is when a person reports for duty, except when it is for a deadhead movement or when it is their second tour of duty beginning on the same calendar day. Basically, when you go to work, it is a start. The next day, when you go to work again, it is another start. However, if you went to work at 12:01am, and then you went off duty at 11:00am, got rested, and went back to work at 23:59pm, you still only get one start for the day. If you went to work and you were deadheaded, it does not count as a start, unless you immediately get a train at the end of your deadhead, without any rest of any length. If you start work at 11:30pm on Monday, and go off duty at 11:00am Tuesday, it only counts as a start for Monday. In order to get a start for Tuesday, you would need to get rested and then go back on duty by 11:59pm. This is how the starts can be manipulated to prevent days off from ever being reached. If a person has five starts, and they are not rested until late in the evening, around 10:00pm, for example, it is very easy to push their duty time back to 12:01am, and make them miss a start. Since the requirement only applies to consecutive starts, when they miss a start like that, they are farther from days off.
In addition to all these restrictions, Congress decided we were working too hard, and imposed a monthly limit of 276 hours. This limit includes all the on duty time, as well as any "not on-duty, not off-duty" time we may have. Any or all of these limits can be waived if needed by the Secretary of Transportation or one of his delegates. This does occur, but only occasionally.
Now the really ironic part about all of this is that none of it applied to passenger train crews. These new hours of service regulations do not apply to people assigned to work on regularly scheduled intercity or commuter passenger trains. There is a clause in there indicating that if the Secretary of Transportation deems necessary and if no other hours of service law is in place, then this can go into effect on passenger trains in October 2011. I find that very interesting. Obviously we do not want anyone getting hurt, and one way to make that happen is to make sure crews are fully rested an alert. The thing that gets me is that there are a lot more people on a passenger train. Sure, a freight train could potentially derail and wipe out a community, but a passenger train could derail and kill the equivalent of a small community as well. It seems that Congress was worried more about protecting coal than passengers. I just find it interesting. Every cargo we carry is replaceable. People on the other hand, are not, yet these rules do not apply trains carrying people.
My opinion of RSIA is that this was not that well thought out and left quite a lot of loopholes open, such as the consecutive "starts" thing. Most railroads had a pretty good system in place to give their crews days off, and Congress managed to ruin that, and give the railroad an easy loophole to allow their crews to work every day, with no days off. Because of that system of "starts," I managed to work nearly a month before I finally decided to lay off fatigued. Who knows how much longer I would have gone. My "start" count just kept getting reset though, and so I was constantly available for work. Hopefully amendments are made and the Railroad Safety Improvement Act sees some improvements of its own.
Before the Railroad Safety Improvement Act, or RSIA, went into effect, railroaders were allowed to work a 12 hour shift. They then had to have eight hours off before their next tour of duty. Once they hit that 12 hour limit, the train had to stop and be secured, regardless of its location. A van would come out and get the crew. They would continue to get paid until they went home. There was no federal regulation on days off. Most railroads had policies in place giving people time off after a certain number of days worked. On the BNSF, an engineer or conductor would be on call for seven days. At the end of the seven days, they got 72 hours, or three days off. If they were on duty when the seventh day ended, their three days off started as soon as their tour of duty ended. People tell me it was a great system, and you always knew when your days off would be. If you decided you did not need the days off, you could work all or some of them, and there was no penalty.
That all came to an end with RSIA. Train crews are still permitted a maximum of 12 hours on duty. At the end of 12 hours, just as before, the train stops and the crew secures it and a van picks them up. Instead of then getting eight hours of rest time, they are now required to have ten hours off duty before the next shift. That is nice at the home terminal, but away from home, we would rather just get back to work and go home. Additionally, a crew may receive rest in the middle of their shift as well. If they receive less than four hours of rest, then their rest time also counts towards the 12 hour limit. However, if they get between four and ten hours of rest, it does not count towards the 12 hours. When they go back on duty, the time starts again where it left off. Of course, anything over ten hours is considered "Rested" and the clock starts back at zero upon going on duty.
Prior to RSIA, the amount of time spent waiting for the van, after the 12 hour limit, had no limit. A train crew could spend 12 hours moving a train, and then another 12 sitting on the train waiting for the van to show up. That time, after the on duty limit has been reached, but before a crew goes off duty, is called "not on-duty, not off-duty" time. Yeah, Congress even came up with an original name! Most of us call it Limbo time. That is now limited to 30 hours per calendar month. Typically the van shows up in just a couple of hours now, rather than within a couple of days! Even with that limit, I have sat on a train for 16 hours. Just as before, the railroad does continue to pay the crew for the time waiting for the van to show up. Additionally, if you have to wait for the van and you go over 12 hours during the wait, then any additional time beyond 12 hours must be added to the rest time. So if you "go dead" as we say, and then it takes an additional hour for the van to arrive and get you home, you get an additional hour added to your rest time, making it 11 hours of required rest. This is to encourage the railroad to plan ahead a little and get the van out to you sooner. This 30 hour limit is allowed to be broken in the event of "casualty, derailment, Act of God, major equipment failure, or cause unknown and unforeseeable." So if you do not foresee an unknown cause, you can sit in the van longer!
The seven days on, three days off cycles were done away with. Now, there is a rather complicated system of "starts." When a person has six consecutive starts, they are required to get 48 hours off at their home terminal. If they have seven consecutive starts, then they are required to have 72 hours off at their home terminal. Getting six starts is rather common, but seven is unusual. Typically a person gets a seventh start when their sixth one takes them away from home. A start is when a person reports for duty, except when it is for a deadhead movement or when it is their second tour of duty beginning on the same calendar day. Basically, when you go to work, it is a start. The next day, when you go to work again, it is another start. However, if you went to work at 12:01am, and then you went off duty at 11:00am, got rested, and went back to work at 23:59pm, you still only get one start for the day. If you went to work and you were deadheaded, it does not count as a start, unless you immediately get a train at the end of your deadhead, without any rest of any length. If you start work at 11:30pm on Monday, and go off duty at 11:00am Tuesday, it only counts as a start for Monday. In order to get a start for Tuesday, you would need to get rested and then go back on duty by 11:59pm. This is how the starts can be manipulated to prevent days off from ever being reached. If a person has five starts, and they are not rested until late in the evening, around 10:00pm, for example, it is very easy to push their duty time back to 12:01am, and make them miss a start. Since the requirement only applies to consecutive starts, when they miss a start like that, they are farther from days off.
In addition to all these restrictions, Congress decided we were working too hard, and imposed a monthly limit of 276 hours. This limit includes all the on duty time, as well as any "not on-duty, not off-duty" time we may have. Any or all of these limits can be waived if needed by the Secretary of Transportation or one of his delegates. This does occur, but only occasionally.
Now the really ironic part about all of this is that none of it applied to passenger train crews. These new hours of service regulations do not apply to people assigned to work on regularly scheduled intercity or commuter passenger trains. There is a clause in there indicating that if the Secretary of Transportation deems necessary and if no other hours of service law is in place, then this can go into effect on passenger trains in October 2011. I find that very interesting. Obviously we do not want anyone getting hurt, and one way to make that happen is to make sure crews are fully rested an alert. The thing that gets me is that there are a lot more people on a passenger train. Sure, a freight train could potentially derail and wipe out a community, but a passenger train could derail and kill the equivalent of a small community as well. It seems that Congress was worried more about protecting coal than passengers. I just find it interesting. Every cargo we carry is replaceable. People on the other hand, are not, yet these rules do not apply trains carrying people.
My opinion of RSIA is that this was not that well thought out and left quite a lot of loopholes open, such as the consecutive "starts" thing. Most railroads had a pretty good system in place to give their crews days off, and Congress managed to ruin that, and give the railroad an easy loophole to allow their crews to work every day, with no days off. Because of that system of "starts," I managed to work nearly a month before I finally decided to lay off fatigued. Who knows how much longer I would have gone. My "start" count just kept getting reset though, and so I was constantly available for work. Hopefully amendments are made and the Railroad Safety Improvement Act sees some improvements of its own.
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