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THE PROBLEM WITH CROR RULE 112 Here is CROR Rule 112 which specifies the train securement procedure that should have been used on the MM&A oil train left at Nantes.  I have highlighted two sections in red for further reference:   112. Securing Equipment (a) When equipment is left at any point a sufficient number of hand brakes must be applied to prevent it from moving. Special instructions will indicate the minimum hand brake requirements for all locations where equipment is left. If equipment is left on a siding, it must be coupled to other equipment if any on such track unless it is necessary to provide separation at a public crossing at grade or elsewhere. (b) Before relying on the retarding force of the hand brake(s), whether leaving equipment or riding equipment to rest, the effectiveness of the hand brake(s) must be tested by fully applying the hand brake(s) and moving the cut of cars slightly to ensure sufficient retarding force is present to prevent the equipment from moving. When leaving a cut of cars secured, and after completion of this test, the cut should be observed while pulling away to ensure slack action has settled and that the cars remain in place. (c) Application of hand brakes must not be made while equipment is being pulled or shoved.   *************************************************************** Regarding the first section highlighted in red:  The special instructions would be those of the individual railroad companies which they may formulate and adopt.  I do not know if such special instructions are required by the TSB or must be approved by the TSB if they are adopted by an individual railroad company.  I have not seen any news report saying whether the MM&A has such special instructions, or what they are if they do have them.  However, the frequently reported reference to a need to set 11 handbrakes may be quoted from MM&A special instructions.  In any case, Rule 112 stands on its own in completely covering the trains securement requirement, and it must be complied with. Regarding the second section highlighted in red:  This is the so called “push-pull test” which is an essential procedure in order for Rule 112 to be complied with.  I have not seen any news report saying whether the engineer claimed to have performed the push-pull test, or whether he was asked whether he performed it.    Here is what the TSB has said about the push-pull test which is a necessary component of Rule 112: “Furthermore, because it is impossible to verify hand-brake effectiveness by pulling or pushing cars on high grades, locomotive engineers cannot accurately know that management's expectations have been met every time cars are secured in accordance with CROR Rule 112.”   If it is “impossible to verify hand-brake effectiveness” with a push-pull test, then Rule 112 cannot be complied with.
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