Didn't intend it to be a hosing, but it bugs me when folks guess at numbers when the real numbers are right there, so I provided a link for the fellow to check his assumption against.
2009 had 2.75 accidents per million miles, 2008 had 3.31 accidents per million miles.
The totals in the link include yard derailments, which every railroader here knows is simply gonna happen no matter what.
Trust me, some where right now, in some ones yard, there is a car on the ground...like the Muddy One said, it depends on how good a pencil whipping the roadmaster and trainmaster can cook up as to it being reportable.
Yes, miles for the reporting period January thru August, 2009 were down.
2009 had 444,143,188. miles, 2008 had 520,896,082 miles for a loss of 76,752,894 miles, which I am sure had some impact on the totals.