For those of you who are required to complete the 92 day and annual FRA inspections on your locomotives, I believe it's an unnecessary burden on the small operators who run maybe 100 miles a month vs the class 1's who run 100+ miles a day to have the same requirements.What support do I have in seeking relief on these based upon mileage, with a minimum of an annual inspection?Several years ago, the steam regulations were modified to reflect today's operations. Should we try to do the same with diesel-electric locomotives?

Well for starters, as the FRA is all about safety, any proposal that suggests cutting corners with respect to safety will certainly be frowned upon. In my opinion, this doesn't buy us much. You still need to be doing regular checks or inspections of brushes, traction motor support bearings, confirming air brake gauges are within spec, making sure the electrical system is free of grounds, making sure there's no oil leaks, water leaks, etc, etc. The benefit to doing regular 92 day maintenance is catching things before they can become a serious problem.The only benefit that I can see for relief of FRA scheduled maintenance is, if your operation is very small, has only one locomotive which is relied upon for every job and your workforce is weekend only, all volunteer. Then yes, I can see the need for relief from 92 day maintenance cycles. However, if your not a common carrier or part of the general railroad system, then you should be exempt from these FRA regs anyway.At the RMNE, we have only two operable locomotives (currently), so at the beginning of the year before the season starts, I plan out a schedule for locomotive assignments such that we are able to meet all our goals for the year -- regular and special trains, DOWT, EFH, etc. This allows me to maximize out of service credit and stretch out 92 day maintenance cycles. Hence, each locomotive sees a minimum of 2 maintenance cycles per year, sometimes 3 depending on amount of usage.Best advice is to develop a plan for locomotive usage before the start of your season. Maximize out of service credit and stretch out your maintenance cycles.Andy KromerRailroad Museum of New England

"The only benefit that I can see for relief of FRA scheduled maintenance is, if your operation is very small, has only one locomotive which is relied upon for every job and your workforce is weekend only, all volunteer. Then yes, I can see the need for relief from 92 day maintenance cycles. However, if your not a common carrier or part of the general railroad system, then you should be exempt from these FRA regs anyway.Andy KromerRailroad Museum of New England"==========================Yes, the weekend only, all volunteer, small operator is exactly what I'm talking about.FRA takes jurisdiction if you connect to the general system or have 1 (one) highway at-grade crossing.I see alot of benefit here to those of us who are small operators.

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No - we use our locomotives twice a week for about 35 miles each day.You might be right on the hours - but - I can try. Now that steam is done, MAYBE we know how to do it.

Another good trick is to have as many operable locomotives as possible. The more engines you have in rotation, and the fewer you use at once, the longer you can fudge the 92 days on each unit. Just don't do what our mechanic at SCRM did and let all your inspections wait and come due at once -- we're currently down to just one certified unit and taking a financial hit to get the other three back up to the regs so we have back-up power. As soon as a 92-day comes due, take the unit out, do the inspection, then let it "sleep" on a fresh inspection until you need it.This is a great excuse for collecting operable locomotives, BTW! :o)

The American Short Line & Regional Railroad Association (ASLRRA) has been trying to address this issue with FRA, as a number of small short lines also find the present 92-day rule burdensome. I don't know the present status of their efforts, but you might want to check with them before starting a new initiative.Alan Maples

In reviewing the history of the rule it is clear that the FRA "Rules Committee" tried very hard to establish a balance between those operators that run more than 32 days in a year and those who operate closer to 200+ days per year. The evidence of their efforts to strike a balance is found in the rule related to the "full inspections" which are to be done every 1472 days or 15 years.......which ever comes first. For those operating over 200+ days per year, you find locomotives that are due for full inspections every 7-8 years, half the time required otherwise.Your question however, relates to 92 day inspections. A comment has been made below that I agree with full heartedly. If your operation is limited to volunteers and part time staff, arrange your steam schedule to include only so many days of operation. For example, with steam, if you perform one annual inspection, you can run a total of 32 operating days "service days" before you do any other inspection.....period. A number of locomotives in the US run such schedules. This rule, as opposed to the old rule is far more lenient to operations with limited recourses and people. Like wise, you can run up to 92 days before you have additional work, this is 92 "service days" as defined by the rule. Running weekends only, for the summer months, you have less than 92 days. Working most weekends for the year, you can still squeeze it in...... (almost)Another comment that is found in this line is that of the time it took to get the rule we have. Kelly Anderson and I as well as a number of others have spent time observing the "FRA Rules Committee" at work. They hold two meetings per year and as far as I know, the meetings are open to the industry. I support the idea of the industry being involved in the process; however, I honestly feel that the best minds in our industry have exploited a very large amount of time in creating a rule that is as fair and balanced as possible.Is there room for change? Yes, and I must say, the committee knows what changes need to be made and are working on improving the system even more. If you feel strongly enough to want to change a rule, I would suggest first that you involve yourself in the process and get a good idea of how full the current plate is. AS I have said before, my hat is off to all of the members of the committee for their past and current efforts to preserve our industry.John E. RimmaschWasatch Railroad Contractorswww.wasatch-rr-contractors.com

Last I knew, the big railroads were still pushing the FRA to eliminate daily and 92-day inspections altogether. Although they use the word safety in every other sentence, it is a different story when they have to pay people for things like daily locomotive inspections. Here in Saratoga, we're down to just one machinist and one electrician, with the engineers getting an extra five dollars per locomotive for doing a daily trip inspection. Most of them think this means just checking the cooling water (sometimes) and signing the book. Some don't believe me when I tell them that signing that book makes them the official inspecting party, subject to heavy FRA fines if defects (which most have not been trained to recognize) are caught. Previously, the carriers got most of the inspection rules changed for freight cars, so that unless crippled for some reason, no maintenance is done on the cars. Some hand brakes have gone so long without oil, it takes two hands just to turn the wheel - not tighten the brake, but just turn the wheel. Likewise, car inspection forces have been cut to the bone, as have many track departments. The almighty dollar is the most important, and "just getting by" has become the norm.As for 92-day tests (we used to call them washouts), they really don't take that long or take that much work. As mentioned previously, with out-of-service credits, an engine can go quite a while between them. I think following the sleazeball no-maintenance tactics of the big roads is a mistake here.

GREAT idea - 92 service days or some time period (like annual).Thanks for the idea.

I'll contact them - thanks.