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[quote user="Bucyrus"] My concern is with this sentence:  “Special instructions will indicate the minimum hand brake requirements for all locations where equipment is left.”[/quote] In order to analyze GROR Rule 112, one would need to see those special instructions that the TSB says may accompany Rule 112.  As I understand it, those special instructions can vary from one company to another.  So you would have national Rule 112 and private special instructions working together to define the terms of train securement.  While Rule 112 is public information, special instructions are often not disclosed to the public.  The special instructions may stipulate a minimum number of handbrakes to secure a train on various grades, with various tonnages.  Whereas, Rule 112 requires a push-pull test to prove the number of handbrakes set is adequate.  In order for this to work, the special instructions would have to include a statement like this: “All conditions of GROR Rule 112 must be met.”  If that were not included, the special instructions alone might be assumed to completely cover the issue of train securement.  Any time a minimum is specified, it comes with the natural implication that the minimum is sufficient.  Therefore, without the special instructions calling for the full requirements of Rule 112, it might be interpreted to mean that the special instructions are an alternative to Rule 112, or take precedence over the rule.  And if that were the case, the minimum number of handbrakes required by the special instructions might be deemed adequate without a push-pull test which is a requirement of Rule 112. One might ask why a crew would go to the trouble of applying the minimum number of handbrakes and then not bother to do a push-pull test.  The answer is that the test might indicate that more brakes need to be applied, and then tested a second time.  This is more work, and if the crew believes that the minimum number of handbrakes is the full requirement, they might just leave it at that.
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