RULE CLARIFICATION ISSUES



RULE CLARIFICATION ISSUES

Eliminate Ambiguity and Misunderstandings Through Standardization of Interpretation and Application of the Rules

• Attended versus Unattended definition as it applies to rules

3 Step Rule TS-15 also must comply with Power Brake (232.103) – Blue Signal (218)

Power Brake – FRA interprets as the locomotive engineer must be in a position to take immediate action should a locomotive roll.

IF NOT AN OPERATOR CONTROLLED LOCOMOTIVE HAND BRAKES HAVE TO BE SECURED AND TESTED ON THE TRAIN OR CARS.

(3 Step from NORAC)

• Does a locomotive engineer making a walk around inspection of his consist on the ground constitute unattended? FRA interpretation NO. CSXT and committee to develop a definition to comply and mirror Part 232 definition of unattended.

Three Step Protection - Safety Rule TS-15

• Leaving locomotive cab during 3 Step Protection (Power Brake-Blue Flag)

232.103 CFR language applies. If the engineer leaves the cab for any reason 3 step ends. Engineer must remain in the cab to prevent any unintentional movement. Hand brakes must be applied and tested on all locomotives in the consist when leaving cab to MU. Write white paper distinguishing 3 Step from 103 and distribute. Use FRA 103 interpretation.

• Do employees require 3 Step Protection when crossing tracks in front of a locomotive or equipment to line a switch? If over 50 feet? If within 25 feet YES over 50 feet NO.

• Must the employee requesting Three Step and the Employee providing Three Step in addition to the locomotive number provide their names over the radio? Rule 411 requires crew to initially provide positive communication with names and must re-establish if interruption occurs.

• Develop a precise definition for the Operating Rule Book Glossary for Operator Controlled Locomotive. Work on with 3 Step Rule-Have a Draft ready for the July Meeting

• Safety Rule TS-15 Is it mandatory that 3 Step Protection be communicated over the radio? No

• Is it permissible to give 3 Step during the job briefing inside of the locomotive cab? Yes (If not amended by General Division Bulletin)

Operating Rule 34-A

• Not being required to announce in the controlling cab the presence of a fussee in Dark territory. (If train has clear block of all trains and banner test is performed-crew may not see fussee) Operating Rule 34-A (Pick up sandwich, etc.) Should not occur as a test anyway. No application. Not with a banner. Banner can be within a Form W in a clear block at controlled speed. If EIC gives higher speed relieves controlled speed. Use for 100-J, Stop Signal in emergency in Form W. OK in Rule 193 territory - ½ the range of vision.

Operating Rules 89, 405 and A-4

Discuss language to eliminate the conflict between Rules 89 and A-4 as it pertains to the locomotive engineer requesting permission to enter a work authority

Within Rule 89 need to identify with the exception of A-4 and 405? Do we need A-4 as written? A-4 applies to designating other promoted crew members? Is FRA looking at writing 220? (EO-26 concerns within FRA?) Review these 3 rules and clarify to re-write. The BLET will explain rationale behind the rule to its members.

Equipment Handling Rule 4400

• Equipment handling Rule 4400-Add Speed designation for W military trains carrying loaded or empty long flats-to distinguish them from intermodal

Can we flag designated military equipment cars on the work order with military train speed? What are all of the equipment reporting marks? Is it the commodity or type of car (maintenance) that limits the intermodal car to 50 MPH when hauling government equipment? Do we want to show military train designation –Homeland Security Issues-or just mandate speed in documentation. Do we want military equipment running 50?

Mark as false positive until resolved.

Equipment Handling Rule 4466-B

• Equipment Handling Rule 4466 B- Add Designated Speed for IPPX Military Equipment Cars Yes add to rule 4400

Operating Rule 103

• How can a one man remote control job protect the shove and comply with 103 rules? If not in an RCO zone must protect shove in accordance with Rule 46 and 103 same as if not in remote be at lead end or visually determine shove or utility employee in the proper position. Operating the box is connected to the shove.

• When the employee protecting the shove can see down a clear straight track is it permissible to place a “stick-man” in the track without any light attached after the crew just traversed the adjacent track and it was known to be clear? Rule 103 Track must be continuously be observed in compliance with Rule 46 ½ the range of vision. On-About-Ahead. Visual determination. March 31, 2009 Re-issue Notice Obstruction Device.

• 2009 Operating Rule 103-D refers to utilizing chocks and chains?(System Bulletin 001 Dated December 29, 2008 Section 8(a) supersedes) Complete-System Bulletin 004 Resolved and Complete

• Need clarification in Hazmat Book and by CSXT regarding proper number of cars required to bury loaded ethanol cars in a unit train. Flammable Class 3 CFR 147.85. When train length (consist) permits, placarded car may not be nearer than the sixth car from the engine or occupied caboose. When train length does not permit, a placarded car must be placed near the middle of the train, but not nearer than the second car from an engine or occupied caboose.

Discuss cycle train air slips out of Sewarren NJ – Rules Department to Discuss with the Albany Division

• When a locomotive engineer is instructed to stay on his lead locomotive by management and the conductor performs the MU responsibilities, does this relieve the engineer of responsibility if something is not multipled or coupled properly? If the answer is no, what does he do? If proper locomotive tests are performed and brakes work properly should not be an issue?

• Are handbrakes required to be applied and tested on the locomotive consist when changing ends? Rule 103-E Attended-Unattended No

• Are handbrakes required when MUING locomotives? Setting trailing locomotives to haul within the yard environment? Rule 103-E Yes

• What is the proper procedure for testing handbrakes on equipment? Rule 103-C-D (Louisville Division Cincy Terminal Gen Bulletin 408 dated 1-16-08) System Bulletin 004 Rule 103-I

o How is this test performed on grade? Special Instructions put out to divisions to develop location specific special instructions.

o What if the other cars and locomotives weight is such that the brake appears to be good but the car moves anyway? See Above

o After brakes are released and the crew begins to wait for one minute, does the crew wait for the air flow to come down prior to commencing the one minute wait? Yes

o When testing hand brakes on dead locomotives Couple to another locomotive or equipment to test

• Rule 103-E – When testing locomotive handbrakes when consist is on a descending grade can merely releasing the independent brake without applying any throttle power and ascertaining that the consist did not move or drift be accepted as a proper test? Must apply power and depict so on the download.

• When handbrakes are tested by shoving against the cars to determine they are functioning properly is an employee required to position themselves at the end of the train to watch the shove against them even if it is only 2-4 feet? Rule 103-C- No however employee should be knowledgeable of the position of the rear car in relationship to the end of track, derails or other equipment, clearance points.

• When working a continuous flat switching operation with the proper end of the track secured in a bowl or yard scenario, does a piece of equipment that does not couple after being kicked have to be secured immediately? Rule 103 Employees need to know any special instructions. In lieu of special instructions while progressing switching no. Before next cut is switched all must be secured.

• If locomotive engineer dismounted their engine to assist conductor in chipping ice off of industry crossing 50 feet away, is he/she in close proximity or are handbrakes required prior to dismounting? Rule 103-D Handbrakes are required. Attended versus Unattended Engineer is engaged in an unrelated task.

• What is the accepted clearance point when yellow ties are buried under snow and ice? (A strong position has been taken that no part of equipment can be foul of the yellow tie even when the placement is not entirely consistent at some locations) Rule 103 System Bulletin 004 Item 2

• Can another crew other than your own crew member re-line a crossover back to normal position or do you have to utilize your own crew member who would then re-walk the length of the train to proceed? Rule 104-F applies. An employee can leave a switch in charge of another employee at the or in close vicinity to the switch.

• General Discussion of Operating Rule 421 – emphasis on unwritten requirement to stop the movement when transferring watching the shove to another employee on the crew (hierarchy) A job briefing by all of the crew members involved in the move must be performed prior to the move being made. If the entire line of sight route of the movement can not be seen, the movement must stop when passing off for the other employee to pick up. We need something to emphasize focus on planning your stop in ½ the distance-not start stopping if you don’t hear anything in ½ the distance. We need to look at the rule.

o Scenario: A crew is shoving equipment and/or a shoving platform on the main track in signaled territory properly calling signals. This move traverses several miles with an employee in place watching the movement. Why would the crew be required to give car counts on a long continuous move of this duration? Rule 421 (2) applies. This is a train movement and unless you are in the initial block prior to viewing the first signal running prepared to stop within ½ range of vision.

• What is the proper storage location for a cell phone while in the locomotive cab? Can it be in the employee’s pocket and be turned off? EO26 – GS28 In the grip or suitcase. FRA finalizing Q&A’S

• EO26 - GS28Locomotive Engineers who have previously purchased accurate GPS units to check their speed and want them allowed Will be covered in FRA updated Q&A’S per Ron Lutton-FRA

• What is the definition of close proximity as it applies to use of brake sticks in a non yard environment? TS-6 FRA will work out uniformity on use with all Class Ones-Safety and Rules Dept. working with System Safety

• Operating Rule 100-J, Is the engineer required to blow for the highway crossing even though he has his train under control and is stopping prior to reaching the crossing? Yes is going System Rules to be added to the rule. There is no application to banner test on a 100-J Crossing. Remember “Stopped in the Block”

• System Re-Issue Bulletin 001 Dated December 29th, 2008 Item 8 – 2 A, Securement of Trains (Hierarchy) System Bulletin 008 Item 3

• Is laying a brake stick down next to you while in your control to line a switch and then picking it back up and carrying it with you a violation of Rule GS-8? STF –No unless you leave the brake stick in the walkway and leave.

• Develop a separate column on the DTC Block sheet in addition to the Dispatcher Time Authorized and Time Released to include Turned Over to the Dispatcher Rule 167 (3) DTC Block form to be modified to include this column. This has to be done through software modification with the CAD System within the dispatching center. The form will also include other modifications. Will work on the format as a committee with Rules Department. Mike Adams will provide a draft for discussion at the next meeting.

• Define Car with a safety rail as noted in Rule GS-13 This is a Shoving Platform or Aggregate type car with a platform walkway and railing. A tank car does not satisfy this requirement.

• GS-21 Add EOT’S may only be transported in the locomotive knuckle not on the locomotive walkway (FRA) Barry Morton to report back.

• Rule 411 – When stopped on the main or other tracks employees are required to make a positive identification radio transmission every 15 minutes as an added safety precaution. How does this apply or what can be done to protect trains that are manned but under HOS? Can not perform service under the FRA HOS. On duty an extra safe guard to protect the train. This only happens due to poor planning with the relief crew. (Authority for Movement-Signals protect when under HOS)

• If you leave the rear portion of your train to set off or pick up cars along the line of road, do you need permission to recouple to the train you left standing on the main if no signals are involved? Rule 272 Track Warrant or DTC no unless you’re moving your marker-Signaled back against as long as there is no switch in power must have sharp job briefing. Signal only shows your train is in track circuit. (Shove Rule 103 applies to shove back)

• Operating Rule 14 – What is the CSXT rule or policy in regard to blowing the locomotive horn at crossing that are identified as “private crossings?” These crossings do not have cross bucks, lights, gates and in some cases only small stop signs. In many areas these are known as farm crossings and state Stop, Private, or Cross at Own Risk, etc. These are not DOT State Crossings or signs but are numbered with a CSXT identification plate for emergencies through the CSXT police. Are Locomotive Engineers required to blow at these crossings? Engineer has the discretion to blow at private crossings. Mandatory at public crossings. If it is a private crossing with cross bucks, why? If has cross bucks not a private crossing. Whistle posts not in rule book or required anymore. PTC will program in. If we have private crossings with cross bucks need to ask the local supervisor and Road Foremen why and what are the expectations at this crossing?

• At what speed should a train be operated whose train messages contain Look Out Orders that are not Severe Weather Alerts that do not have a speed attached to them. (some for many miles) Progress update on resolution - Engineering and Network Operations being told MP limits and Speed

• Discuss various issues regarding Bulletins, Notices and Train Documents

o Printer technology - clarity

o Requirement to carry bulletins that do not apply to your territory

o Add the weekly safety incident insights to a location within the train documents for vast distribution Suggestion go out as a weekly System Notice

ADDENDUM

• Review Rule 224-A (2a) Stopped or delayed in block as it applies to “after passing a distant signal” As it applies to this rule: The signal that precedes the next signal. (Approach signal to the home signal) Should be special instructions addressing time within block between distant signal-home signal-railroad crossing at grade?

• Designated clearance points (yellow tie) does the clearance area include all portions of the knuckle? YES

• Can cars being switched be left on the ladder while switching? YES as long as you’re switching but you can not leave and go somewhere else and leave them

• ABTH 5556 Part B, Conditioning brakes; states that after a full service reduction, cut away and then secure equipment per Operating Rule. Which rule is to be followed? Cut away, re-couple and then test the brakes? When cutting away from cars after secured. Can not secure and test equipment if you are not attached to it. Correction being made to new rule book.

• Great Lakes Bulletin 405 states cars left unattended must be secured and brakes tested. What is the definition of unattended? Done with them, leaving cars standing.

• How are handbrakes tested on locomotives in a push pull operation after cutting away on one end and the other locomotive is 20-30 car lengths away? Not applicable. The Rule and Regulation applies to the Lead consist only. Except for DP all HB shall be fully applied on all locomotives in the lead consist of an un attended train 232.103 N-3 (1) Locomotives on the rear of a push pull service are not he lead consist.

• What is the proper conditioning for a locomotive dead set off alone in the yard or at a location? Set locomotive in lead and follow CSXT rules of securement. Angle cocks closed. (Dennis Merrell will address DIT locomotives)

5352 clarify definition of DIT and DIC in Glossary. DIC engine left standing left according to ABTH 5357 lead locomotive. (Review with Mechanical leaving ABV in release versus handle off)

• How much more re-numbering of locomotives is going to occur?

Pass this item to the Locomotive Cab Committee to discuss with John Rimer.

• Are switch locks required on all switches within a RCO Zone? Must be addressed by terminal special instructions. (Lined and locked if required-language of rule 913-A) Locks (or unique designated device) are required if absent special instruction language.

• How are high alert cars set off at a location enroute due to a bad order, etc. handled? If not in a designated high urban threat area can be set-off. Must notify dispatcher. In a high threat urban are required to contact dispatcher who will dispatch appropriate person. Appendix A Hazmat Book. Locations identified in System Bulletin 006

• Who has the authority to instruct a train crew to pick up cars on an interchange that have high alert cars?

Normal instructions apply. Regulation requiring transfer of custody changed by TSA-where the form says railroad representative, write unattended since there is no railroad representative.

Next Meeting Week of July 6th in conjunction with the Locomotive Cab Committee-Huntington WV

Note:

Some of the above listed items were discussed at the initial Cumberland Meeting and need additional discussion and resolution.

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