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PROBLEMS WITH CROR RULE 112 As I understand it, train securement in Canada is governed by CROR Rule 112, which was produced by the TSB of Canada and/or Transport Canada.  The rule includes a requirement for a push-pull test as a means of confirming whether the securement called for in the rule has been accomplished.  And yet the TSB has also stated that such confirmation is “impossible” by the use of a push-pull test.  That seems like a classic Catch-22 to me.  So I find it interesting that the Lac-Megantic accident investigator is asking the Transport Canada to check their Rule 112 to see if the push-pull test is an adequate indicator of proper securement, while the TSB has already answered that question by saying that it is not.  Moreover, the accident investigator says, “It has been demonstrated” that the push-pull test is unreliable.  If it has been demonstrated, what is there to review?   What I sense that the accident investigator is asking the TSB is for an explanation of why the TSB has concluded that it is impossible to confirm train securement by the use of the push-pull test.  Clearly, the accident investigator is shifting a burden onto the TSB/TC in the sense that their Rule 112 may be defective, and therefore part of the cause of the runaway oil train.  That is huge.  The basic national railroad rule that is supposed to prevent runaways may not always do the job.     Note that as a private observer, I am not asserting this alleged problem with Rule 112 to be a fact.  I have only offered it as a possibility as item #5 in my FIVE POSSIBLE CAUSES FOR THE RUNAWAY posted above.  And also note that other private observers here in the forum insist that the rule is 100% sufficient as is the similar rule governing U.S. rail operations.  Nevertheless, the preeminent rail safety regulation authorities in Canada have said that the rule leaves employees with no way of knowing how many handbrakes to apply in order to secure a train.    Here is what the accident investigator, Robert Johnston has said in a letter to Luc Bourdon, Transport Canada’s director general, rail safety: CROR Rule 112 ensures that hand brakes are applied to prevent unwanted movement of the train while providing flexibility for a railway’s operational needs.  However, CROR Rule 112 is not specific enough in that it does not indicate the number of hand brakes necessary to hold a given train tonnage on various grades and it continues to be left up to the operating employee to determine the number of hand brakes to apply.  Furthermore, it has been demonstrated the push-pull test is not always a good indicator of whether an adequate number of hand brakes have been applied and not handbrakes are effective even when properly applied.  Considering all these risks, Transport Canada may wish to review CROR Rule 112 and all related railway special instructions to ensure that equipment and trains left unattended are properly secured in order to prevent unintended movements. Yours sincerely, Original signed by Robert Johnston Acting Director Investigation Operations Rail/Pipeline   Refer to this link for full article: <a href="http://www.canadianunderwriter.ca/news/transport-canada-may-wish-to-review-rail-rules-agency-investigating-lac-megantic-derailment/1002482141/">http://www.canadianunderwriter.ca/news/transport-canada-may-wish-to-review-rail-rules-agency-investigating-lac-megantic-derailment/1002482141/</a>
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