This article from RYPN Flimsies talks about the FRA increasing its oversight of the Georgetown Loop.
http://www.clearcreekcourant.com/cgi-bi ... .Lead+News

The article speaks like the FRA is increasing oversight at many or all museum and tourist operations. Is that another reporter getting it wrong, or is there truth to it?

If such is the case, small operations or struggling ones, like EBT and C&TS are going to be facing hard times ahead.

I believe CATS and EBT are not insular already.

GLRR would benefit from having one clearly stated and understood set of regulations, rather than the bunch of sets of regulations which affect it now - not all of which agree. If FRA regulations prevail, not a bad thing. Apart from some minor variations, FRA standards were being followed during my more recent tenure there.

dave

It seems FRA is "stepping up" involvment with tourist railroads. Many old local FRA inspectors used to take a hands off approach if you were somehow "insular." Our local inspector recently retired and we had a visit from someone from the regional office. He was not looking for an adversary relationship, quite the opposite. They just want us to know what regs apply to us and wants us to start filing monthly / annual reports. He have our president a CD with all the info on it. We have always followed the regs that apply to us, but never filed reports.
Bill

Actually by what was written in the article it sounds like the FRA has needed to swing by the place for a while. Derailment not reported, boiler not ultrasounded until FRA showed up, multiple breakdowns in the same season, etc... By that info alone it would have me wondering if they had been maintaining their equipment properly. While I know breakdowns can happen for many reasons outside the control of proper maintenance and inspections, many times it will also happen due to delayed or overlooked repairs. Also since the nature of the breakdowns are not listed I cannot even start to assume how good their maintenance is/was.

One thing that really worries me about their maintenance policy is that they had a boiler company replace the tubes in #12 over the winter and there was no ultrasound done. Last I heard even for static boilers that see pressure above 10 psi, it is required by most state boiler codes.

I guess a lot of people forget that `incidents' on a railroad, whether insular or connected to the mainline tend to get the attention of the FRA, especially when they find out about it via a citizen report in the newspaper and not the railroad itself. More so when it involves a rolling bomb, which no matter how you feel it is what a steam locomotive is when it is not properly fired or maintained. For proof of this ask any insurance agent or look at what happens when someone lets the pressure climb too high or when someone lets the crown sheet get dry. Large pieces of a boiler have been know to land up to 5 miles away after a boiler shreds itself. I forget the date but it was between 1910-1940 that a major section of a locomotive boiler landed 5 miles away cleaving a cow in half less then 500 feet from a farmhouse in Texas. Imagine what would of happened if it went a few yards further??? Also IIRC this piece weighed multiple tons and went a few feet into the ground.

Does anyone remember how far away, pieces were recovered when that steam tractor let go, a few years ago, in the midwest and killing the owner and all the local experts that was trying to get it to run right at a gathering, and that was a low pressure unit IIRC??? If I remember the report correctly it was a vertical tube boiler that had a clogged relief valve and an appreciable quantity of thin boiler plate.

When the FRA is asking you to only do what they have the other steam tourist railroads do then be glad, after all they have the ability to probe a whole lot deeper and forcefully than what this article is alluding to, just think about it. Sure the timing could be better, but when is it a good time to be visited by the government?

I digress,

Rich C.

So, how onerous is the paperwork requirement? Easy to dismiss as "just fill out some forms" - but in practice, what's that like?

Could something be done to ease it, say someone in preservation built applications for doing it on the Web or on PDA's?

To clear up some misconceptions:

The derailment (caused by ancient ties giving way on a sharp curve) was reported to all concerned, which did not include FRA at the time. FRA did respond to a mysterious call from somebody and inspected the track, equipment and opeprating conditions and found no exceptions at the time, and did not choose to involve themselves further.

I personally ultrasounded the boiler shell, firebox and FTS in February and March of 2007. No idea what has been done since last operating season regarding tubes and NDT. I found nothing of concern when I ran the numbers I found, not unexpected in a boiler built in 1988.

An outside contractor rebuilt the locomotive between April and end of May 2007. The operator had no control over the standards, practices, or quality of the contractors work. It continued to break down. No more needs to be said.

Two highly qualified and respected outside contractors were brought in to find problems with the operators conduct during 2007. Nothing of any consequence was discovered. Other outside (mostly) influences of dubious qualification are also involving themselves pursuing agendas of their own.

I don't believe any less influential body than FRA could provide a broad enough oversight and specific enough expertise in the industry to overcome the difficulties inherent in the situation as it is, so good for them being there, and may everybody get on the same page and run a prosperous and reliable railroad as a result.

While I can't speak as to what conditions have been when I was not present, I will answer any private inquiries as to what the real conditions were when I was there. No offense to Rich, who admittedly knows nothing but what opinions were expressed in the article in question, not entirely by those with any base of qualifications from which to have worthy opinions.

dave

It is NOT "just fill out some forms" - the forms are reports of inspections. The inspections, done properly, are what takes time. When I was at the Huckleberry RR I had figured to do the required inspections and fill out the forms it took right around four hours every day we operated; 28 hours for a seven day week. And the HRR is non-system, non-insular - what has been referred to as 'FRA Lite'. This included inspecting the track, the locomotive - both pre-departure and at the end of the day, the cars, and the initial terminal brake test. This did not include the 31 service day, 90 day, and annual inspection of the locomotives, the monthly accident and incident report, or the annual inspection of the cars. It did include the weekly and monthly track, signal, and bridge inspection.

The boiler that blew up in Ohio was a Case. That boiler was condemned and should have never been fired.

http://www.doli.state.mn.us/boilerohio.html

Everyone here is assuming that the FRA is just coming in to look at locomotives. We recently had the FRA come in to our museum concerning signals and road crossings. We were basically told that this is just the beginning. They are gradually going to expect all parts of a groups operation to live up to the FRA standards. This will mean doing all inspections and recording information correctly that they will require. We are already investigating the replacement of our antique road crossing gate mechanisms with more modern fail safe systems. Our problem is that when we are closed we shut down power to many systems on our property to reduce expenses. If we shut down a fail safe system we are expecting the gates will drop. We are obviously concerned that they will force us to modify our antique straight air trolleys to meet more modern requirements.

Chris - might see if you can't defer to APTA standards for historic cars.

dave

Regarding straight-air brakes on streetcars: Both San Francisco and New Orleans run single-unit streetcars with (as far as I know) the original brake equipment. These are in daily service, on public streets, with revenue passengers. I would suspect SF Muni and NO RTA would be the first to be required to update the brakes if this were determined to be a necessary improvement in safety.

Please refer to Title 49 of the Code of Federal Regulations, especially subsections between 207 and 245. You can find links to the on-line version at gpo.gov. (Government Printing Office) Looking is free, but you may have to pole around a bit.
Note that there are many Federal Regulations under the Federal Railroad Administration, and they have different rules about applicability. Even if the F.R.A. determines that according to law or regulation, they can regulate you for a particular standard, some of the other regulations may not apply to you in your particular case. The F.R.A. also exercises discretion about if it will enforce some of the regulations in some particular cases. There are also procedures for getting an exemption for various regulations.
There are also Federal, State, and local laws other that the F.R.A. regulations that may apply to you in your particular case. Sometimes (but not always) there is Federal Preemption, like if you are forced to abide by something Federal, some State thing may not be allowed to apply. In other cases, the State or locality is allowed to be stricter, if it wants to be.
For trolley museums, there might be a time that if you do get exempted from the F.R.A., that it is because you are regulated by the Federal Transit Admistration!

First, the paperwork for insular tourist line railroads is not very difficult at all. I have no issue at all with doing it.

Second, the FRA already provides web-based methods to do most of the filings. Any line can be certified for online filings.

Third, I fail to understand why this is seen as such a "problem" by those around the fringe of the tourist line industry. Frankly, most of it is based on a concern for safety, and safety should be of the utmost importance at all times. Just because we are preserving historic and heritage equipment is no excuse for giving up on safety.

The FRA is concerned with the equipment used for operation. If a piece of equipment cannot pass the safety requirements, it should be on static display instead of hauling passengers.

In case you haven't seen it, the FRA actually has a number of publications that address their jurisdiction regarding tourist railroads. They're pretty specific:
With regard to locomotive inspection standards (which includes blue cards)
http://www.fra.dot.gov/downloads/safety ... apter2.pdf
Go to page 2-8

With regard to Engineer Certification and the insular / non-insular issue:
http://www.fra.dot.gov/us/content/1632

Obviously there is also the steam locomotive issue addressed elsewhere, and of course they have the authority to "step in" anywhere under emergency conditions.

Those of you who have associates involved with railway preservation in either the UK or Australia know that they already face a far steeper regulatory burden than we do. All the more reason to keep running things safely here........

Those of you interested in following up on the reference in the previous post to the APTA Heritage Trolley Equipment Standard, you can find it at: http://www.railwaypreservation.com/vint ... 001_05.pdf
You will note that it specifically excludes railway and trolley museums, but it certainly provides an appropriate starting point for discussion. It also gives you a glimpse into how a public transit agency might view operation of a heritage car- what the areas of concern are and thus the priorities for any safety program.