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It is a bit strange, although understandable, that the TSB sees the lack of an absolute number of handbrakes to apply as a defect.  It seems that they want to give orders to employees that are absolutely specific, and the only way to accomplish that is with a specific number.  The push-pull test does yield an absolute number, and it is a number proven to work by the very test that provides it.  Yet the TSB seems not to trust that approach of letting the employees find the number.  They seem to feel the testing method is a little too organic.  In a way, it empowers the employees to make their own rule by performing a practical experiment.  The number dictated by the test is also a number that nobody can dispute after the fact.  If the train runs a way, obviously the number was too low.  Yet, if the employee says the push-pull test showed the number to be sufficient, it is their word against the company’s word.  However, if the rule called for a specific number, there would be solid evidence of the rule compliance if cars ran away after securement.  The evidence would simply be finding and counting handbrakes set on the runaway cars.  If the cars happen to derail, some of the evidence might be obliterated, but still, there is a fair chance of evidence.  Another point to consider is that rule compliance testing in the field could check handbrake securement after it had been completed by simply counting the number of set handbrakes.  This compliance testing would not be possible if the number of handbrakes had been determined by a push-pull test.  Therefore if the rule called for a specific number of handbrakes, thus making compliance testing possible; the threat of discipline would encourage more compliance.
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