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Jeff, Thanks for your comments.  I am not sure what you are referring to regarding a means to get a handbrake really tight.  I know of one, but it is dangerous and prohibited.  I agree that the TSB’s reasoning about setting a prescribed number of handbrakes without a test is unreliable.  But it sounds as though they think they can get around that problem by requiring a number of handbrakes that is far in excess of what would be actually necessary.  So, while the securement would still be unreliable, they could reduce the probability of it failing to near zero.      It raises the question of how the TSB will find how many handbrakes are actually necessary.  They could make calculations based on pure physics.  Or they could conduct their own practical tests at each location with a variety of cars and tonnage.  But they have not actually announced their ideas, so we are left with only many fragments of their reasoning to anticipate where they are headed.  In one article, it was presented as though crews would be given the option of either applying the high number of handbrakes required for a fixed number securement rule; or doing a push-pull test and using the number of handbrakes that the test determined.  If that is what they intend, it seems really bizarre.  It seems like a version of having your cake and eating it too—at the expense of not solving the problem.
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