By Karl (Fritz) Edler - Railroad Music, July 15, 2016

Oral comments on Train Crew Staffing

Docket Number FRA-2014-0033

RIN 2130-AC48

Good Morning,

My name is Fritz Edler. I recently retired after more than 37 years working for railroads, the last 25 years on the engine. I’m here for the literally millions of passengers who entrusted their safety to me and the other members of my train crews. I’m also here as a Special Representative for Railroad Workers United, an international cross-craft solidarity and advocacy organization. Our membership extends over most major and many lessor railroad systems in North America, passenger and freight. Nobody cares more about train safety than the men and women who work on the railroad.

I feel obliged to mention a third group as well. I just returned from the small town of Lac-Mégantic, Quebec. I was one of the speakers at the 3rd anniversary commemoration of the rail tragedy. Three years ago this month, 47 people died when a runaway oil train crashed and burned. I can’t presume to speak for them, or for the 27 Lac-Mégantic orphans.

But the truth is, this hearing is happening because of that train tragedy. The Lac-Mégantic wreck was the biggest international exposé of the dangers of single crew operations, although there was a long history leading to that incident. Lac-Mégantic is why there is FRA consideration of a Train Crew Staffing rule. The evidence is now clear from multiple investigations that single crew operation at Mégantic was a proximal cause of that wreck.

Safety rules are sadly often forged in fire. Fire safety rules in tall buildings came after 146 garment workers perished in the 1911 Triangle Shirtwaist Fire in New York City. Now new Train Crew Rules will come from 47 graves in Lac-Mégantic in 2013.

I have appended the full statement submitted by Railroad Workers United to my remarks here. Let me summarize. One-person train operations are NOT safe.

The FRA should not be in the business of making rules for the unsafe operation of trains. The FRA should not be telling carriers that there might be some circumstances that would allow more risky operation of trains. The FRA should not be producing a roadmap or a manual on how to get “special” approval to run unsafe trains. That is a specific lesson of Lac-Mégantic.

No carrier promises or new operating rules and procedures change the basic fact that one-person trains are LESS SAFE. The FRA should not be working with the carriers to make them just a little bit less unsafe. The record is clear. The rail industry is incapable of self-regulating to eliminate the real risk of death from single crew operation. There are no credible authorities that support single crewmember operations as being as safe as multiple crewmember operations over time. Every time a one-person train goes out it is a high-risk gamble.

Former FRA Director Szabo was right when he said, “… safety dictates you never allow a single point of failure.” Not rarely allow, NEVER.

The FRA already has all the evidence demonstrating beyond any reasonable doubt that one-person trains are more unsafe. All railroaders know it. The airlines use co-pilots. Nobody would fly on a 777 that had a one-person crew. Freight trains are twenty times longer than the biggest 777. They are often longer than the airport runway and there is no autopilot for trains.

Even the carriers will say they don’t plan to run many one-person crew trains, but they want the flexibility, just in case. Just in case of what? A tight deadline? A drop in stock prices? Upcoming negotiations with the unions? Failure to fill vacant jobs?

There are already too many commonplace problems in regular rail operations that require more than one crewmember. At Lac-Mégantic single crew operations were accompanied by a simultaneous reduction of qualified backup crewmembers available for safety assurance. Carrier cost cutting and lax regulatory enforcement are a recipe for disaster

I wish I could have told the Lac-Mégantic survivors that the United States government has commemorated this tragedy by making sure no one-person train runs on any US railroad. We could even call it the “Lac-Mégantic Rule.”

It is not too late. The final FRA rule should not be a yellow light with an arrow saying, This Way To 1-Person Crew Trains. It should be a bright red light, a Stop Signal. If sometime in the future there is some new development in train operation that meets a strong scientific standard for train safety, the FRA should convene a new hearing and develop new rules. But today there is no safe way to operate trains with one-person crews. So the only rule called for is no one-person trains.

If the FRA fails, as did their Canadian counterparts, to guarantee minimum crew standards that prohibit single crew operations, it is absolutely certain that more people will die. In Canada in the aftermath of the disaster, the Trudeau government is scrambling to try to make up for the industry self-regulation that led to an industry that has reported more runaway trains each year since 2013, the year of the wreck. Communities and rail workers across the continent are watching and expecting the FRA to act to prevent even more deaths from such risky operations.

Thank you,

Respectfully submitted,

Karl (Fritz) Edler

Special Representative,

Railroad Workers United

Washington DC

Disclaimer: The views expressed here are not the official position of the IWW (or even the IWW’s EUC) and do not necessarily represent the views of anyone but the author’s.