jeffhergert Bucyrus Any time a minimum is specified, it comes with the natural implication that the minimum is sufficient. Therefore, without the special instructions calling for the full requirements of Rule 112, it might be interpreted to mean that the special instructions are an alternative to Rule 112, or take precedence over the rule. And if that were the case, the minimum number of handbrakes required by the special instructions might be deemed adequate without a push-pull test which is a requirement of Rule 112. One might ask why a crew would go to the trouble of applying the minimum number of handbrakes and then not bother to do a push-pull test. The answer is that the test might indicate that more brakes need to be applied, and then tested a second time. This is more work, and if the crew believes that the minimum number of handbrakes is the full requirement, they might just leave it at that. In the real world, minimum means just that. What the powers that be have decreed must be applied. For some trains/cuts of cars it might be overkill, for others not enough. That's why the securement rules also specify a "sufficient number" and require (for us) a release test to verify. Even in those known cases leaning towards overkill, a release of the air brakes is still done. I will agree to a point, that some may start with the minimum required by local instructions. But they will do a release test and if it doesn't hold, they tie more brakes and do another release test. This is done until they are satisfied nothing is going to roll away. We do have a chart that shows the number of brakes to set without releasing the air brakes to verify, but it is (or at least has been) for those times when a release test was impractical. It's a good bet that the chart in most cases has a good safety factor built in, that the number is more than a "sufficient number." I see nothing wrong with the CROR securement rule as written and quoted. Jeff
Bucyrus Any time a minimum is specified, it comes with the natural implication that the minimum is sufficient. Therefore, without the special instructions calling for the full requirements of Rule 112, it might be interpreted to mean that the special instructions are an alternative to Rule 112, or take precedence over the rule. And if that were the case, the minimum number of handbrakes required by the special instructions might be deemed adequate without a push-pull test which is a requirement of Rule 112. One might ask why a crew would go to the trouble of applying the minimum number of handbrakes and then not bother to do a push-pull test. The answer is that the test might indicate that more brakes need to be applied, and then tested a second time. This is more work, and if the crew believes that the minimum number of handbrakes is the full requirement, they might just leave it at that.
Any time a minimum is specified, it comes with the natural implication that the minimum is sufficient. Therefore, without the special instructions calling for the full requirements of Rule 112, it might be interpreted to mean that the special instructions are an alternative to Rule 112, or take precedence over the rule. And if that were the case, the minimum number of handbrakes required by the special instructions might be deemed adequate without a push-pull test which is a requirement of Rule 112.
One might ask why a crew would go to the trouble of applying the minimum number of handbrakes and then not bother to do a push-pull test. The answer is that the test might indicate that more brakes need to be applied, and then tested a second time. This is more work, and if the crew believes that the minimum number of handbrakes is the full requirement, they might just leave it at that.
In the real world, minimum means just that. What the powers that be have decreed must be applied. For some trains/cuts of cars it might be overkill, for others not enough. That's why the securement rules also specify a "sufficient number" and require (for us) a release test to verify. Even in those known cases leaning towards overkill, a release of the air brakes is still done.
I will agree to a point, that some may start with the minimum required by local instructions. But they will do a release test and if it doesn't hold, they tie more brakes and do another release test. This is done until they are satisfied nothing is going to roll away.
We do have a chart that shows the number of brakes to set without releasing the air brakes to verify, but it is (or at least has been) for those times when a release test was impractical. It's a good bet that the chart in most cases has a good safety factor built in, that the number is more than a "sufficient number."
I see nothing wrong with the CROR securement rule as written and quoted.
Jeff
Jeff,
I understand your points, and agree with them. Like you, I also see nothing wrong with Rule 112. It is the STB of Canada who has stated that they have found a problem with Rule 112. They say that it is impossible to verify securement with a push pull-test on high grades.
My point posted on the previous page is only about a possibility of misinterpreting Rule 112 by viewing it through a layer of special instructions. Specifically, such a possibility would be developing a routine of setting a certain number of handbrakes (the minimum) thought to be sufficient without testing.
Such a problem might arise from the language of the special instructions and/or improper interpretation of them. MM&A has been asked by the news media to reveal their special instructions for train securement at Nantes, but I understand they have refused to do so.
.
Bucyrus Murphy Siding jeffhergert We do have a chart that shows the number of brakes to set without releasing the air brakes to verify, but it is (or at least has been) for those times when a release test was impractical. It's a good bet that the chart in most cases has a good safety factor built in, that the number is more than a "sufficient number." I see nothing wrong with the CROR securement rule as written and quoted. Jeff And coming from someone who is a working railroader, I'd give your opinion a lot more weight than that coming from any non-railroader. Thanks for giving this some real-world perspective. What makes you think that Jeff and I disagree on this point?
Murphy Siding jeffhergert We do have a chart that shows the number of brakes to set without releasing the air brakes to verify, but it is (or at least has been) for those times when a release test was impractical. It's a good bet that the chart in most cases has a good safety factor built in, that the number is more than a "sufficient number." I see nothing wrong with the CROR securement rule as written and quoted. Jeff And coming from someone who is a working railroader, I'd give your opinion a lot more weight than that coming from any non-railroader. Thanks for giving this some real-world perspective.
jeffhergert We do have a chart that shows the number of brakes to set without releasing the air brakes to verify, but it is (or at least has been) for those times when a release test was impractical. It's a good bet that the chart in most cases has a good safety factor built in, that the number is more than a "sufficient number." I see nothing wrong with the CROR securement rule as written and quoted. Jeff
What makes you think that Jeff and I disagree on this point?
Thanks to Chris / CopCarSS for my avatar.
BucyrusTree, You are taking some of my comments out of their context, then assigning your own meaning to them, and then disagreeing with that meaning.
You are taking some of my comments out of their context, then assigning your own meaning to them, and then disagreeing with that meaning.
I'd ask you to explain further, but I'm afraid that we'd get dizzy.
Larry Resident Microferroequinologist (at least at my house) Everyone goes home; Safety begins with you My Opinion. Standard Disclaimers Apply. No Expiration Date Come ride the rails with me! There's one thing about humility - the moment you think you've got it, you've lost it...
Bucyrus Tree, You are taking some of my comments out of their context, then assigning your own meaning to them, and then disagreeing with that meaning.
Tree,
Don't know about y'all, but I think I need a map to follow that line of reasoning.
It's been fun. But it isn't much fun anymore. Signing off for now.
The opinions expressed here represent my own and not those of my employer, any other railroad, company, or person.t fun any
It's CROR. GCOR covers most railroads in the US, at least in the western portion of the country.
BucyrusRule 112 overrides the special instructions...
No - the special instructions supplement Rule 112.
BucyrusI agree that it would be essential to make it clear that special instructions cannot supplant GROR rules...
That's already been made clear:
CROR B - Special Instructions will be found in time tables, general operating instructions, operating bulletins or GBO. They may be appended to or included within copies of the Canadian Rail Operating Rules but do not diminish the intent of the rule unless official exemption has been granted.
BucyrusOne might wonder why they would have special instructions calling for a minimum number of handbrakes if that minimum is likely to be overridden by the push-pull test required in Rule 112, which calls for more than the minimum. Why not just let Rule 112 govern alone?
You're making this more difficult than it is. CROR sets a baseline standard, sufficient under "normal" circumstances. Special instructions may modify that by requiring more brakes be set under certain circumstances. Once that number of brakes is set, the ability of the brakes to hold the train can be tested and, if it is insufficient, more brakes will need to be set and the hold tested again.
The special instructions are going to be based on experience. If a given site has shown that it normally requires X more brakes than the minimum to prevent problems, the special instructions will reflect that.
Really. It's that simple. Railroaders understand how it works. It's not a new concept.
Rule 112 overrides the special instructions by requiring push-pull proof; and the special instructions override Rule 112 by calling for a minimum number of hand brakes; even if that minimum number is greater than what the push-pull test calls for. Therefore, in an odd way, the special instructions are a safety factor for the Rule 112 with its push-pull test; and rule 112 is a safety factor for the special instructions.
I agree that it would be essential to make it clear that special instructions cannot supplant GROR rules established by Transport Canada, even though the special instructions can override the results of the push-pull test of Rule 112 as explained above. But how this clarification might be stipulated I don’t know. Logically it would be stipulated in the special instructions and not in GROR because it goes without saying that GROR simply means what it says. There is no need to additionally stipulate that GROR must not be preempted by something else.
Therefore, the place to restate the supremacy of the GROR is in the special instructions. Without that clarification, the special instructions might be assumed to be the sole authority. The special instructions set the minimum performance and GROR either confirms that minimum is adequate or calls for a higher number until the push-pull test is satisfied.
The danger is that Rule 112 is ignored because the special instructions are interpreted to be adequate; due to the fact that the term minimum implies adequate.
One might wonder why they would have special instructions calling for a minimum number of handbrakes if that minimum is likely to be overridden by the push-pull test required in Rule 112, which calls for more than the minimum. Why not just let Rule 112 govern alone?
The only plausible explanation that I can see for that is that the minimum set in the special instructions is intended to be a number higher than the number established by a push-pull test. That way, the minimum includes a safety factor for the push-pull test. So, in other words, you might find that a push-pull test shows the train secured with 10 handbrakes applied, and yet the special instructions call for 15 minimum. That would provide a safety factor of 5 extra handbrakes.
However, knowing the minimum requirement of 15, a person would not stop at 10 and perform a push-pull test. It would be pointless. A person would set 15 handbrakes because that is the minimum required by the special instructions. But then knowing that 15 is intended to be more than enough, it would be easy to rationalize that once 15 handbrakes had been set, no push-pull test would be required because the minimum number of 15 has been designed to exceed the requirement of the push-pull test. That reasoning could seem logical and adequate even though it is against the rules. It would be like a high wire act performing without a net.
If crews became accustomed to that flawed reasoning, they might routinely ignore the push-pull test and rely on the minimum number of handbrakes called for in the special instructions. But that number varies according to tonnage and grade. Error might creep into that calculation. Error might also enter because some of the handbrakes are not working properly. Then without the confirmation of the push-pull test, the error might go undiscovered, leaving the train on the razor’s edge of securement. Then just a little thermal expansion or contraction might break the inertia and start the train rolling.
Bucyrus: I am sure there is a statement (rule) in the codified rules that says the railroad is not allowed to create a rule that is less restrictive than the GCOR rules.
Thus Rule 112 may call for a certain number of brakes to be set, and the RR can issue special instructions that set forth additional brakes to be set in various circumstances of higher tonnage or on various grades, but in no case may the RR override the minimum safety standard set by any GCOR rule..
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Bucyrus My concern is with this sentence: “Special instructions will indicate the minimum hand brake requirements for all locations where equipment is left.”
My concern is with this sentence:
“Special instructions will indicate the minimum hand brake requirements for all locations where equipment is left.”
In order to analyze GROR Rule 112, one would need to see those special instructions that the TSB says may accompany Rule 112. As I understand it, those special instructions can vary from one company to another. So you would have national Rule 112 and private special instructions working together to define the terms of train securement. While Rule 112 is public information, special instructions are often not disclosed to the public.
The special instructions may stipulate a minimum number of handbrakes to secure a train on various grades, with various tonnages. Whereas, Rule 112 requires a push-pull test to prove the number of handbrakes set is adequate. In order for this to work, the special instructions would have to include a statement like this:
“All conditions of GROR Rule 112 must be met.”
If that were not included, the special instructions alone might be assumed to completely cover the issue of train securement.
Just a reminder that if you wish to discuss the topic try to remain somewhat civilized with each other please.
It is getting tiring deleting posts that just end up being Kindergartenklopperei fodder...ok?
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I thought I posted the evidence of second oil train found on the main line without conformance to the rule (only locomotive handbrakes applied, no tankcar brakes) as enough evidence that MM&A lacked a "Safety Culture" and the higher the rank the greater the responsibility. Possibly my putting a good portion of the blame on Ed Burkhardt is the result of "My having been there," in his position, made the same kiind of mistake, but in a non-life-threatening situation. Before moving to Jerusalem 17 years ago, I did some work in Israel, usually having an Israeli coworker. A particular performance hall had a good sound system I designed, as well as the rest of the acoustical design, and I often attended performances there, once I moved to Jerusalem.. On occasion some of the performers were USA who were old friends. So attending performences was often a bit of heaven on earth. As time went on, I noticed a bit of deterioration in the sound system operation. Not bad enough to make speech unintelligible anywhere in the room, but just not really optimum. But I hesitated to say anything, because I was outside the structure of the building management, and neither the managers nor the workman were ethnically the same "tribe." (Several "tribes" are represented, but none mine, as far as I know.) But one day I could not enjoy the show because the sound was so bad that I had great trouble with intelligiblity in the corner seat where I sat. So, after the show. in the lobby I approached the head manager offering to help. He said, "David, we have a new system, and it will probably be some time before operations settle in to be satisfactory. " I went back into the hall and looked at the front of the ceiling and was shocked to see a staligtite with loudspeakers obviously not custom fitted for the purpose . Needless to say I don't attend shows there nearly as often. The system is operated a bit better now as I observe when I do attend, but there are seats where the sound system really reduces intelligibility instead of improving it. I have been asked a few times why I don't come as often, and I just reply, "because I feel insulted." I should have found a friendly way to criticize when the first deterioration occured. I feel Ed Burkhardt may have felt it was wise to let local people "do their thing" and not interfere. I may be wrong, but that is a possible explanation. Knowing Ed's history, to me it is a better explanation than greed.
Bucyrus People here have mentioned the parsing of Rule 112 with the implication that the rule is so nebulous that it only means whatever a person thinks it means. And therefore, when an official statement by a regulatory body finds a flaw in Rule 112, this can be rejected because nobody can say for certain what Rule 112 means. I don’t see the rule as being open to interpretation. It seems to me that it says exactly what it means if we can accept the fact that words have specific meanings. I know that some see the world in relative shades of gray where a person’s words mean only what the user intends them to mean. But, railroads are notorious for not looking at the world that way. The railroad world communicates in black and white. Otherwise things go bump in the night. The fact that railroads invented train orders is a powerful testimony to their belief in the fidelity of words with fixed definitions. Railroad rules are the same way. On a railroad, words have fixed, pre-determined meanings, and are used in language that is often uncommonly terse. Here again is GROR Rule 112: 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. For those who like to parse words and sentences, what are some examples of multiple meanings or ambiguities in Rule 112? I can see one small question, but I am wondering if others see anything.
People here have mentioned the parsing of Rule 112 with the implication that the rule is so nebulous that it only means whatever a person thinks it means. And therefore, when an official statement by a regulatory body finds a flaw in Rule 112, this can be rejected because nobody can say for certain what Rule 112 means.
I don’t see the rule as being open to interpretation. It seems to me that it says exactly what it means if we can accept the fact that words have specific meanings. I know that some see the world in relative shades of gray where a person’s words mean only what the user intends them to mean. But, railroads are notorious for not looking at the world that way. The railroad world communicates in black and white. Otherwise things go bump in the night.
The fact that railroads invented train orders is a powerful testimony to their belief in the fidelity of words with fixed definitions. Railroad rules are the same way. On a railroad, words have fixed, pre-determined meanings, and are used in language that is often uncommonly terse.
Here again is GROR Rule 112:
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.
For those who like to parse words and sentences, what are some examples of multiple meanings or ambiguities in Rule 112? I can see one small question, but I am wondering if others see anything.
cp8905 You are reducing the whole question to a technical issue, of whether or not it is technically possible for one person to set sufficient brakes, without any other presumptions.
You are reducing the whole question to a technical issue, of whether or not it is technically possible for one person to set sufficient brakes, without any other presumptions.
You do know that on a two man crew, usually only one person sets handbrakes, right? So not only is it technically possible for one person to set suffcient brakes, it is done thousands of times every day.
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Murphy Siding Will multiple, extended threads badmouthing a railroad executive cast poorly on Trains Magazine and hinder the ability to get interviews in the future?
Will multiple, extended threads badmouthing a railroad executive cast poorly on Trains Magazine and hinder the ability to get interviews in the future?
It's nice to see something other than labor taking some criticism for once.
Please folks, I just removed a whole page of off topic posts that shouldn't have have been posted here to begin with. Now please keep your postings on topic as per the title of this thread.
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The parsing and dissection of Rule 112 brings two things to mind for me.
The first is a complaint about my rugby officiating from one of the players, who I knew was an attorney in real life. He took a sentence from the rule book and removed it from all context in his complaint about a call that he thought I should have made. The context of the situation and other parts of the rules supported my non-call.
The second is the thought processes of Sheldon Cooper, PhD on "The Big Bang Theory". He goes through life with agreements (the roommate agreement and friendship agreement) that have a stipulation for every possible contingency and a few others that can't occur, leaving no room for flexibility, improvisation or judgment calls.
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:
***************************************************************
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.
bottom line is if they are not where u left them there was a need to set more brakes
Dakguy201,
The objective is to set enough handbrakes to hold the train with air brakes fully released.
An empirical test is used to determine whether enough handbrakes have been applied to hold a train on a grade. One version of such testing is to apply enough handbrakes expected to hold the train, and then release the air brakes. If the train does not move, it is considered to be adequately secured with handbrakes.
Another version of the test is to apply enough handbrakes expected to hold the train, then release the air brakes, and push and pull on the train. If the train does not move, it is considered to be adequately secured with handbrakes. This is the actual push-pull test. I do not know if the term is also applied to the test where no pushing or pulling is done.
Doing the test with the push-pull component gives some sense of measure of a safety factor by feeling the train’s resistance. Without the push-pull component, if the handbrakes hold the train, it may be only by the tiniest margin, and offer no indication of that.
I do not know if special instructions indicate how much force to apply when pushing or pulling to see if the handbrakes are sufficient.
Bucyrus I am not convinced that there is a problem with Rule 112. Nobody has explained why the push-pull test is unreliable in Canada while it seems to be reliable in the U.S. <snip>
I am not convinced that there is a problem with Rule 112. Nobody has explained why the push-pull test is unreliable in Canada while it seems to be reliable in the U.S. <snip>
Could someone explain what exactly is a push-pull test is? Are there any standards for which a push-pull test must comply? Or do you put the locos in run 8 and note that all you are getting is massive wheel slip from the engines, or perhaps something more precise involved?
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