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 Post subject: Re: ASTM to Study Park Trains Standards
PostPosted: Sat Dec 31, 2011 1:10 am 

Joined: Sun Aug 22, 2004 8:35 pm
Posts: 374
Ron,

It has been my personal goal while involved in discussions on RYPN to stray away from discussisons that may be in litigation or could be in litigation. Of the over 20 documented accident reports that are public record, three, dating in the past three years are under or could be involved in some manner of litigation, to which I remain on my soap box pleading that we do not discuss in detail these cases on this forum. As such, I hesitate to offer all of the sitations that I have. However, if you want to back door me, I will show a link that lists all of them and you can dig through each one and read for yourself.

Of the twenty on the link that I have, I know of well over 20 more that have not been made public, or the records have to be requested in order to obtain a public copy (most of which were private operations where the public was not a plaintiff or defendant). The formal reports range in age from 1950 to current day.

As I have read and studied accident reports from the ICC (known to us now as the FRA) the FRA and the amusement park accident reports that are public I can share my opinion that machinery is not the culprit. In fact, I know of only two reports that I have read where the root cause of the accident was purely mechanical.....no human error involved. The two accidents are lap seam boiler explosions where the seam simply unzipped itself under pressure. The Steam Traction industry has a ton (figuratively speaking) of these reports.

At any rate, my findings and my personal observations are that the root cause of 99% of the accidents that we incur in any industry are human error accidents. In most of these cases, the human error was a result of lack of vigilance or lack of knowledge. When you pare down the lack of vigilance and or lack of knowledge you find that a lack of training or lack of standard or enforced rules. When you shave off the lack of training, standards and enforced rules you find a lack of oversight or zero oversight at all. I am not a proponent of big government. I am a proponent of self regulating industry. I commented above, the negligent part of this discussion is.......the industry as a whole.

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 Post subject: Re: ASTM to Study Park Trains Standards
PostPosted: Sat Dec 31, 2011 7:02 am 

Joined: Thu Nov 22, 2007 5:46 am
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Location: S.F. Bay Area
EVERYBODY is regulated by SOMEBODY. There are no gaps in regulatory coverage.

All non-transit railroads of 24" or above are in the jurisdiction of the FRA. PERIOD - NO EXCEPTIONS. That is why the FRA man comes a-knockin'. Congress requires FRA to ease regulations on tourist railways, so FRA waives parts of the regulation book (49 CFR 2xx). They still do walk-throughs to make sure you are not being insanely stupid.

Every state has an agency that regulates amusements (often PUC, Occupational Safety, or Agriculture departments). And another that regulates transit agencies. Every tourist railroad in the U.S. would be under the jurisdiction of one of those... if they weren't already regulated by the FRA.

Thus, the FRA serves as a "Ward". Other, less competent agencies leave you alone.

So you're the Napa Valley Wine train, general system. Every FRA part applies except 238 and 239, so California DOSH leaves them alone.

OK now what about a 15" amusement park ride. FRA is barred from regulating it by Congress, that is, it does not have jurisdiction. This definitely creates a regulatory "vacuum" which the state amusement park people must fill. Everybody is regulated by somebody.

What about Western Railway Museum, "not insular, not general system". FRA has full jurisdiction but waives all but about 10 parts of the reg book. Do the waived parts (e.g. 213, track) create a "regulatory vacuum" which the California DOSH or PUC must fill? In practice the answer is "no".

Here's the tricky part. Henry Ford museum. Entirely insular. FRA has jurisdiction, but they waive every part of the reg book except 230. Does that blanket exemption of every reg create a regulatory vacuum? I do not know, and I think it could be argued either way.


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 Post subject: Re: ASTM to Study Park Trains Standards
PostPosted: Sat Dec 31, 2011 10:24 am 
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Location: Northeastern US
Disney and Busch are aiming to separate themselves (at the very least in terms of public perception), from the small-time operators.
Standards set forth by the ASTM may be voluntary, but following them will be an expense only the larger park operators can afford.

Also, here is a "place holder" page on the ASTM web site that will include a yet unfinished set of standards on park train steam locomotives.
ASTM WK31185 - New Practice for Amusement Ride Steam Locomotives
http://www.astm.org/DATABASE.CART/WORKITEMS/WK31185.htm

Stephen


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 Post subject: Re: ASTM to Study Park Trains Standards
PostPosted: Sat Dec 31, 2011 11:26 am 

Joined: Mon Sep 27, 2004 6:17 pm
Posts: 514
Location: Scranton, PA
As Ron had asked earlier, and without getting into specifics or speculating on cause, within the last year or so there was:

- The SC Derailment discussed here previously.
- A derailment and roll over at the Louisville Zoo.
- Derailment at Tiny Town in Colorado.

As John pointed out, we should refrain from any speculation here on the above incidents.

More than a dozen years ago there was a park train derailment in the Mid-West in which the train was found to be in extremely poor condition, operated by "kids" who would try to see how fast they could get around the loop of track. There was even a Nightline/Dateline segment on it, noting the lack of any recognized standards.

I've been a big fan of park trains for years and have seen operations that operate on (or above) the level of full size railroads. The Riverside & Great Northern is an example. There are also the "big time" operators like Disney, Busch, Six Flags, Hershey that appear, to me, to have a first class operation. There are smaller operations like Knoebels here in PA that also have excellent track records.

On the other side of the coin, I've seen some miniture trains where I've thought "oh dear God", and walked away.

Dave

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 Post subject: Re: ASTM to Study Park Trains Standards
PostPosted: Sat Dec 31, 2011 2:04 pm 

Joined: Sun Apr 29, 2007 11:39 am
Posts: 54
Location: California desert
This is a very interesting discussion. About 8 years ago the museum where I volunteer restored a RR motor car to operating condition as a part of a larger project. About 3 years ago it was time to begin giving rides. The museum and the car are county property, however it is operated by agreement by the local historical society. Both parties are in agreement that it's a good idea to give rides, in fact, one county person pointed out that a term in the grant funding required giving demonstration rides to the general public.

The County Counsel office was directed to draw up the necessary paperwork. Their first question was, “who has jurisdiction on this type of ride?” That set off an interesting journey through the regulatory agency jungle. Surprisingly, after a couple of false starts, it wasn't that hard. You do need to first find that person in each agency that is making the actual decisions. That person knows somebody in nearly every other agency you need to talk to, and their direct telephone number.

In my former life I was a corporate bureaucrat, a regulation compliance specialist, and familiar with the Code of Federal Regulations, CFR for short. All regulations of the Federal Government are here. I made a list of all the sections of the CFR that might apply. It's a long list, but in most cases the authority is passed on to more local jurisdictions. The up shot of this is in our case, no agency has singular jurisdiction. Toward the end of our journey a field inspector for the PUC made a courtesy call to look over what we were trying to do. He was very knowledgeable and didn't find any safety issues. He pointed out some things that would cause maintenance problems and ways to handle then. Since it was a courtesy call he couldn't give us a letterhead report, but did leave a copy of his notes. His final words to us was if we had an accident, especially with a reportable injury, every agency you can think of and a few you didn't know existed will descend on you and rake you over the coals with a fine tooth comb. Keep records and be prepared to defend every thing that you do.

It's during the proceedings like we went through that organizations like ASTM are very beneficial. When it was time to write our Operations Book, it was then a simple task to say, “we conform to CFR Title xx, article xx, as applicable and amended.” Throughout the CFR are scattered references that say "must conform to ASTM xx" without elaboration. We also adopted the “Code of Operating Rules” as applicable and amended. These are the same rules that most, if not all, railroads adopt. When ASTM finally issues a Standard, the FRA can, and likely would, choose to add a short section saying the affected shall conform to that standard. The actual standards remain under industry control with little government agency control.

If you are worried about the ASTM organization, remember you are in contact with the results of similar organizations every moment of your life; think UL, NSF, SAE, etc.

One last word. It's your Liability Insurance Underwriter that really has the final say whether or not you can operate. We did our homework, satisfied the insurance folks, and increased our coverage at very little additional cost.

Max


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 Post subject: Re: ASTM to Study Park Trains Standards
PostPosted: Wed Jan 04, 2012 11:47 am 

Joined: Mon Feb 22, 2010 5:06 pm
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robertmacdowell wrote:
All non-transit railroads of 24" or above are in the jurisdiction of the FRA. PERIOD - NO EXCEPTIONS.

I do not believe this to be the case. I am fairly certain that the Disney steam locomotives, for instance, are not annually inspected by the FRA.

Their insurance adjuster, however...

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 Post subject: Re: ASTM to Study Park Trains Standards
PostPosted: Wed Jan 04, 2012 2:05 pm 

Joined: Sat Aug 21, 2004 11:31 pm
Posts: 295
Location: TEXAS
John E. Rimmasch wrote:
Ron,

It has been my personal goal while involved in discussions on RYPN to stray away from discussisons that may be in litigation or could be in litigation.

Of the twenty on the link that I have, I know of well over 20 more that have not been made public, or the records have to be requested in order to obtain a public copy (most of which were private operations where the public was not a plaintiff or defendant). The formal reports range in age from 1950 to current day.

As I have read and studied accident reports from the ICC (known to us now as the FRA) the FRA and the amusement park accident reports that are public I can share my opinion that machinery is not the culprit. In fact, I know of only two reports that I have read where the root cause of the accident was purely mechanical.....no human error involved. The two accidents are lap seam boiler explosions where the seam simply unzipped itself under pressure. The Steam Traction industry has a ton (figuratively speaking) of these reports.
.


Since, I assume, these "unzipping" lap seam boilers are no longer under litigation, could you share these reports, the type of service these boilers were in, ect.? I have looked for this "ton" of reports in the "traction engine industry, " for years, and all I have ever seen were the results of grooving in a seam, not cracking. Please elaborate. Please provide said reports.


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 Post subject: Re: ASTM to Study Park Trains Standards
PostPosted: Thu Jan 05, 2012 12:54 am 

Joined: Sun Aug 22, 2004 8:35 pm
Posts: 374
Jim,

You bet, no problem on that. Being real honest with you, I leave tomorrow for five days in the field doing bids.....so I will not have time or the equipment to do a whole lot on this. The clue however is;

If you search on the web past ICC accident reports through nation archives you will end up in a whole raft of PDFs that range in age from early 1900's on up. You can also go to the National Board Web page and call or search their system for the same reports. Jim, I am not in my office and I do not have at my finger tips the paper copies that I have with the web links. Help me remember if I forget when I get back next week. I am happy to get you where you need to be.

Come to think of it...Kelly Anderson at Strasburg or Matt Austin may be able to provide some links.....if either is watching any of this. If not, I will send them as I have time the next few days.

Thanks for asking,

Always,

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 Post subject: Re: ASTM to Study Park Trains Standards
PostPosted: Thu Jan 05, 2012 1:17 am 

Joined: Sat Aug 21, 2004 11:31 pm
Posts: 295
Location: TEXAS
Huh, thats kinda what I thought. You said that you had stuff from the 1950s onward...now we go back to the early 1900 with ICC reports and NBIC stuff. BTW I am a commisioned inspector, and have looked thought A LOT of old reports of boilers blowing up, at lap seams even. I have also looked at a lot of boilers. I have found old boilers of both lap seam, butt strap, and welded that have grooving. Haven't found one, NOT ONE, of an internally fired locomotive type boiler cutting loose at the long seam, except in cases of grooving...and in most of those cases the grooving was in the sheet proper, and not at the seam. If you really, really want to annoy the crap out of me, start trotting out the old saw "them lap seams are just aching to blow up". The NBIC archives are chock full lap seam failures OF EXTERNALLY FIRED boilers of 42" and above diameter. Further more, they were built in the era of plain punching. Mark Jordan and others have also done extensive research into lap seam failures as an inherent design flaw, and found none. I am just tired of the Make Work Itinerant steam community and boiler makers always trying to make work.

John, you would certainly help your street cred by not making a blanket statement that would indicate you had chapter and verse at your fingertips, and then telling us all to go do our own research because you need to head out on a trip, or try to get someone else to support your position.


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 Post subject: Re: ASTM to Study Park Trains Standards
PostPosted: Thu Jan 05, 2012 12:12 pm 

Joined: Mon Aug 23, 2004 3:01 pm
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Location: SouthEast Pennsylvania
Steve DeGaetano wrote:
robertmacdowell wrote:
All non-transit railroads of 24" or above are in the jurisdiction of the FRA. PERIOD - NO EXCEPTIONS.

I do not believe this to be the case. I am fairly certain that the Disney steam locomotives, for instance, are not annually inspected by the FRA.
There is a difference between "being in the jurisdiction" and being "annually inspected". Sometimes, the F.R.A. says that they might not exercise their jurisdiction in certain situations. The 2 quotes below mention some exceptions:
Quote:
Code of Federal Regulations
Title 49 - TransportationVolume: 4Date: 2010-10-01Original Date: 2010-10-01Title: Section 230.2 - Applicability.Context:
Title 49 - Transportation. Subtitle B - Other Regulations Relating to Transportation (Continued). CHAPTER II - FEDERAL RAILROAD ADMINISTRATION, DEPARTMENT OF TRANSPORTATION. PART 230 - STEAM LOCOMOTIVE INSPECTION AND MAINTENANCE STANDARDS. Subpart A - General.
§ 230.2
Applicability.
(a) Except as provided in paragraph (b) of this section, this part applies to all railroads that operate steam locomotives.
(b) This part does not apply to:
(1) A railroad with track gage of less than 24 inches;
(2) A railroad that operates exclusively freight trains and does so only on track inside an installation that is not part of the general system of transportation;
(3) Rapid transit operations in an urban area that are not connected to the general system of transportation; or
(4) A railroad that operates passenger trains and does so only on track inside an installation that is insular, i.e., its operations are limited to a separate enclave in such a way that there is no reasonable expectation that the safety of the public—except a business guest, a licensee of the railroad or an affiliated entity, or a trespasser—would be affected by the operation. An operation will not be considered insular if one or more of the following exists on its line:
(i) A public highway-rail crossing that is in use;
(ii) An at-grade rail crossing that is in use;
(iii) A bridge over a public road or waters used for commercial navigation; or
(iv) A common corridor with another railroad, i.e., its operations are conducted within 30 feet of those of any other railroad.
(c) See appendix A of part 209 for a current statement of the FRA's policy on its exercise of jurisdiction.
Quote:
Code of Federal Regulations
Title 49 - TransportationVolume: 4Date: 2010-10-01Original Date: 2010-10-01Title: Appendix A to Part 209 - Statement of Agency Policy Concerning Enforcement of the Federal Railroad Safety LawsContext:
Title 49 - Transportation. Subtitle B - Other Regulations Relating to Transportation (Continued). CHAPTER II - FEDERAL RAILROAD ADMINISTRATION, DEPARTMENT OF TRANSPORTATION. PART 209 - RAILROAD SAFETY ENFORCEMENT PROCEDURES.
Pt. 209, App. A
Appendix A to Part 209—Statement of Agency Policy Concerning Enforcement of the Federal Railroad Safety Laws
(snip)
Insularity is an issue only with regard to tourist operations over trackage outside of the general system used exclusively for such operations. FRA considers a tourist operation to be insular if its operations are limited to a separate enclave in such a way that there is no reasonable expectation that the safety of any member of the public'except a business guest, a licensee of the tourist operation or an affiliated entity, or a trespasser'would be affected by the operation. A tourist operation will not be considered insular if one or more of the following exists on its line:
•A public highway-rail crossing that is in use;
•An at-grade rail crossing that is in use;
•A bridge over a public road or waters used for commercial navigation; or
•A common corridor with a railroad, i.e., its operations are within 30 feet of those of any railroad.
When tourist operations are conducted on the general system, FRA exercises jurisdiction over them, and all of FRA's pertinent regulations apply to those operations unless a waiver is granted or a rule specifically excepts such operations (e.g., the passenger equipment safety standards contain an exception for these operations, 49 CFR 238.3(c)(3), even if conducted on the general system). When a tourist operation is conducted only on track used exclusively for that purpose it is not part of the general system. The fact that a tourist operation has a switch that connects it to the general system does not make the tourist operation part of the general system if the tourist trains do not enter the general system and the general system railroad does not use the tourist operation's trackage for any purpose other than delivering or picking up shipments to or from the tourist operation itself.
If a tourist operation off the general system is insular, FRA does not exercise jurisdiction over it, and none of FRA's rules apply. If, however, such an operation is not insular, FRA exercises jurisdiction over the operation, and some of FRA's rules (i.e., those that specifically apply beyond the general system to such operations) will apply. For example, FRA's rules on accident reporting, steam locomotives, and grade crossing signals apply to these non-insular tourist operations (see 49 CFR 225.3, 230.2 amd 234.3), as do all of FRA's procedural rules (49 CFR parts 209, 211, and 216) and the Federal railroad safety statutes themselves.
(snip)


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 Post subject: Re: ASTM to Study Park Trains Standards
PostPosted: Thu Jan 05, 2012 12:40 pm 

Joined: Fri Dec 03, 2004 9:42 pm
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I've got a question about this. Sorry if it's been covered and I missed it...

Are the proposed ASTM standards going to cover boilers/locomotives, or all facets of park trains?

Much of the discussion seems to think they're going to be creating some kind of generic rulebook, maybe like the GCOR. I had the impression this was more directly related to boilers.

I can totally understand how they can create useful and meaningful regulations for boilers. No matter what railroad it's running on, the stresses on a boiler all follow the same laws of physics. So that seems like it would be easy to quantify.

Operating standards seem like they'd be far more difficult. A safe speed on line "A" may be excessive on line "B". Even on the same line, you have to know the track and govern yourself accordingly. Unless you're running something like a G12 on a circle of track, you probably don't just hit "go" and run the train at the same speed for the entire trip.

Just curious if anyone has some better idea of what they hope to cover?


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 Post subject: Re: ASTM to Study Park Trains Standards
PostPosted: Thu Jan 05, 2012 1:05 pm 

Joined: Sun Aug 22, 2004 8:35 pm
Posts: 374
Jim,

Thanks for the note. I sent you a PM. I have never and will never post in an effort to create work or annoy people. I kindly ask that you go back and re-read my original comment. This thread is not about failed seems, assembly practices, drumming up work or criticizing lap seams, nor debating every accident that has ever occurred. I am not interested in and will not debate in the manner that you have chosen above. I am sorry. The demeaning nature of your note is not the way I function on this very respectable page.

Bob H.

From what I understand of the amusement park F24 group and having been a roller coaster operator and having seen other sections of the ASTM standards, the book works much like the ASME code. For example: If you need to design such and such, use section such and such as guidelines for compliance. As such, you are correct, the speed of operation A may be this and such, but for operation B, it would be such and thus. The ASTM standards would present guidelines for establishing that safe speed, not actually dictating that safe speed.

Same would apply for rail: If using size 20 lbs rail, the rail head dimensions should be maintained at such and such. If using .......do you see where I am coming from?

I am under the impression that it includes inspection, maintenance and training guidelines for all aspects of amusement park trains and locomotives, steam or otherwise. I would assume.....I don't know yet, that the ASME/NBIC would be referenced as the prevailing document in pressure vessels, the same as it is for compressed air reservoirs for roller coasters.

I have been in contact with ASTM about the committee and I am trying to learn more. I will keep my focus and attention on that matter while I travel.

Kindly submitted,

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 Post subject: Re: ASTM to Study Park Trains Standards
PostPosted: Thu Jan 05, 2012 4:03 pm 

Joined: Mon Aug 23, 2004 11:07 am
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"From what I understand of the amusement park F24 group and having been a roller coaster operator and having seen other sections of the ASTM standards, the book works much like the ASME code. For example: If you need to design such and such, use section such and such as guidelines for compliance. As such, you are correct, the speed of operation A may be this and such, but for operation B, it would be such and thus. The ASTM standards would present guidelines for establishing that safe speed, not actually dictating that safe speed."

Most of the ones I worked with (and in some cases helped write) described test methods and procedures where you do this, this and that in the lab ... and then somewhere else the results of the test / acceptance points get specified.

The idea (and I'm sure you know this, but others might not) is to get everyone to agree that the results would be the same if someone else performed the same test.

Slightly unrelated content -- year's ago I was working on a "round robin" where a number of labs ran the same new ASTM test on the same set of samples -- and met someone on an NRHS excursion who was working on the same round robin. It was semi-blind because only the organizers of the round robin knew everyone involved.

Bob H


and some where else there's a


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 Post subject: Re: ASTM to Study Park Trains Standards
PostPosted: Fri Jan 06, 2012 12:16 pm 

Joined: Mon Feb 22, 2010 5:06 pm
Posts: 122
JimBoylan wrote:
There is a difference between "being in the jurisdiction" and being "annually inspected". Sometimes, the F.R.A. says that they might not exercise their jurisdiction in certain situations. The 2 quotes below mention some exceptions...
I think we are in agreement that the FRA does not have authority in certain situations, contrary to what robertmacdowell wrote stating that the FRA had jurisdiction over all railroads 24" gauge and up, no exceptions. It appears there are, in fact, exceptions:

Quote:
(a) Except as provided in paragraph (b) of this section, this part applies to all railroads that operate steam locomotives.
(b) This part does not apply to:

(...)

(4) A railroad that operates passenger trains and does so only on track inside an installation that is insular...


The Disneyland/Disney World Railroads meet this exclusion, do they not? Therefore, the FRA cannot exercize any authority over them, at least in terms of steam locomotives.

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 Post subject: Re: ASTM to Study Park Trains Standards
PostPosted: Fri Jan 06, 2012 7:16 pm 

Joined: Mon Aug 23, 2004 3:01 pm
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Location: SouthEast Pennsylvania
Since we are quoting Regulations written by the Federal Railroad Administration and published in the Code of Federal Regulations, instead of Laws written by Congress and published in the United States Code, it might be possible for the F.R.A. to revise their Regulations to agree with the stricter members of this Group. But, for now, we may be forced to live with the less restrictive wording that is in effect today.


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