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All through the media discussion of the rules, it is indicated that the authorities rely on the push-pull test as the ultimate indicator of proper securement, but at the same time, the authorities lament that a specific number of handbrakes is not stated in rules.  They say this leaves trainmen guessing.  Even though the push-pull test is supposed to eliminate the guesswork, its result can vary according the amount of force applied.  There might be a tendency to use too little force because too much force will break a knuckle or jackknife the train.  Using too little force might leave the test passing with too little safety margin.  The TSB has come right out and said that it is impossible to confirm the securement with the push-pull test.  So they don’t like relying on the test.  Instead they want to specify a specific number of handbrakes to apply.  They say that takes the guesswork out of the operation.  They have complained that CROR Rule 112 does not require a specific number of handbrakes.  But there is a problem with relying only on a requirement for setting a specific number of handbrakes.  It is a two-part problem.  One part is that the condition of handbrakes varies, so two brakes applied to the same tightness might not provide the same holding power.  The second part of the problem is that there is no way to control how tightly a person applies the handbrakes.  Because of these variables in handbrake performance and operation, the actual effect of a given number of handbrakes cannot be determined.  The only way to overcome this problem with calling for a specific number of handbrakes is to set that number much higher than it needs to be to actually do the job.  The high number will provide a massive safety factor that is likely to overcome the performance variables.  But the problem with that is that the massive safety factor requires a lot of extra time and money for the labor to set the excess brakes. So, according to this latest information, the remedy to the excess labor is to allow an alternative to it.  The alternative is that a person can disregard the high number specified in the rules if he does a push-pull test that indicates a lower number will get the job done.  But isn’t this right back to where we started?  Who is going to set an excess of handbrakes if they don’t have to?  If you don’t have to set the high number specified in the rule, why specify it?
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