In February 2019, Norfolk Southern Railway (NS) petitioned the Federal Railroad Administration (FRA) for a waiver of compliance from certain provisions of the Federal railroad safety regulations regarding refresher training for all NS craft personnel responsible for performing freight air brakes tests. Specifically, NS proposed to create a 3-D simulation using web-based software to satisfy the “hands-on” portion of the training required by 49 CFR 232.203(b)(3), in connection with periodic refresher training. Refresher training is required at intervals not to exceed three (3) years, and must consist of classroom and “hands-on” training, as well as testing.
In response to the NS’ request for relief, the Brotherhood Railway Carman (BRC) filed comments opposing the waiver. Among other things, we specifically complained to FRA that simulated testing should be used only as a supplement to, and not a replacement for, the “hands-on” training that railroad employees currently receive in the field.
In May, 2019, FRA granted NS’s petition for waiver. Now, both the Canadian Pacific Railway (CP) and CSX Transportation, Inc. (CSX) have filed petitions for similar relief from 49 CFR 232.203(b)(3) to allow a substantial amount of their workforce to receive periodic refresher training from 3-D simulation in place of in the field training. In response, BRC has filed comments opposing the CP and CSX petitions for waiver on the same grounds as we did for the NS request for relief.
“This is a very important issue in the railroad industry,” says BRC General President Richard A. Johnson. “Training in the field provides variating challenges such as weather or incidents where an inspector’s olfactory senses are useful in conducting inspections, factors that a computer cannot simulate. In the face of evolving technology, it is important for both the FRA and the carriers to remember that not everything in the railroad industry should be changed. This most certainly applies to periodic refresher training, as it helps to ensure the highest level of safety to mechanical inspections.”
Click here to read the BRC comments opposing the CP Petition.
Click here to read the BRC comments opposing the CSX Petition.