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| FRA 224 and Historic Equipment https://www.rypn.org/forums/viewtopic.php?f=1&t=30093 |
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| Author: | Ed Kapuscinski [ Wed Sep 08, 2010 12:09 pm ] |
| Post subject: | FRA 224 and Historic Equipment |
The Conrail Historical Society is currently getting some quotes on having our caboose, CR 21165 (http://thecrhs.org/PreservationProjects/Caboose21165), repainted. The car currently meets all federal interchange guidelines, and we'd like to keep it that way, so that we can ship it via rail to various events (such as Conrail Days at the Railroad Museum of PA). FRA 224 (aka, the Moron Mark Mandate) requires cars (I believe) to have those obnoxious yellow scotchlite strips on them (in the next few years). We now have a problem, we want to keep the car's paint scheme accurate for its time in CR's service (pre 1984), but want to keep it interchangeable. How have other organizations walked this line? Have you just punted and waited for the regulation to be mandatory? Have you made magnetic scotchlite strips and applied them only when traveling (that's what we do with our RPCX reporting mark)? We'd love to hear your experiences here so we can come up with a good solution. |
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| Author: | Stationary Steam [ Wed Sep 08, 2010 2:55 pm ] |
| Post subject: | Re: FRA 224 and Historic Equipment |
I think you have already found your solution. Just make them magnetic. |
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| Author: | nickbnwd [ Wed Sep 08, 2010 7:13 pm ] |
| Post subject: | Re: FRA 224 and Historic Equipment |
You can request a waiver of any FRA rule (even the 'moron marking' rule) through their waiver process. That said, it is time consuming to write the request and you will likely receive only limited (in route, or in time, or both) relief. Also, I understand that they are permitted nine months to render a decision... 60 days after putting in a waiver request for a group I belong to, I still do not have any acknowledgement or a docket number. Applying the markers on magnetic stripes may be the best approach as it also eliminates the possibility of the car being considered out-of-compliance by any car inspectors, road foreman, etc. who does not know of the waiver. Nick |
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| Author: | SZuiderveen [ Wed Sep 08, 2010 9:52 pm ] |
| Post subject: | Re: FRA 224 and Historic Equipment |
nickbnwd wrote: 60 days after putting in a waiver request for a group I belong to, I still do not have any acknowledgement or a docket number. Nick Nick, Go to http://www.regulations.gov In the search box type FRA-2010-0121 You will find a copy of your waiver petition and a copy of your receipt, which was mailed out on September 2; they were both posted to the Docket in the past two days. If things go to form, your request will probably be published in the Federal Register tomorrow, and the public will have 45 days to comment on your petition. Here is a bit of advice for anyone who has business with the Federal Railroad Administration. Since the loss of two Federal postal workers in the Brentwood facility several years ago, any USPS correspondence sent to a Federal office will go to a special facility for irradiation and other security measures before it will be delivered to the intended. These measures not only delay your post about 30 days, but if your stationery is a fancy color laser printed (not litho) design, it will melt everything and make your letter unreadable. Also, any CDs or hard photos will be melted. If your correspondence is timely or fragile, it needs to be sent by courier, such as UPS or FedEx. Nick's petition was written on June 30, by the way the timeline has worked out, I am pretty sure it was mailed in. Protocol somewhat restricts me from freely stating how I know all of this, but several dozen members of RyPN know! "Thank you for your interest in railroad safety. . . .” Regards, Steve |
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| Author: | Howard P. [ Fri Sep 10, 2010 11:57 am ] |
| Post subject: | Re: FRA 224 and Historic Equipment |
With all due respect Mike, do you really think the next two election cycles will change anything? Regulation has increased in the last 20-30 years regardless of which "party" has controlled the White House and/or Congress. The push for more and more regulation is partly driven by the nanny-statism you mention (which results in part from our litigious society/jury system) and partly by the self-perpetuating nature of any governmental agency. Frankly, those things are non-partisan, because both Elephants and Donkeys feed at those troughs. And let's not forget the cries of "We MUST do SOMETHING!" any time there is a "incident". Usually results in more rules, and eventually there is yet another "incident" and yet more rules.... As for reflectorization, someone sent me a great on-line pic of a fully-reflectorized TTX flat at a crossing. The side sill was bent up about 12" by the Porsche jammed at speed right under the reflectorized side sill. Yup, those glow-in-the-dark stick-ons sure worked that time. Howard P. Darwin, NY |
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| Author: | Alexander D. Mitchell IV [ Fri Sep 10, 2010 12:08 pm ] |
| Post subject: | Re: FRA 224 and Historic Equipment |
For the record, I can't really get bent out of shape about the reflector rule. I was a first-hand witness to the aftermath of one accident where I remain convinced the reflectors would have spared someone the horror of her car skidding under a covered hopper between the hoppers and being dragged nearly a half-mile by the local freight. Everything that COULD go wrong, did. Heavy fog. No crossing flashers. Operating late at night, very unusual for that line. Driver unfamiliar with the area. The other hoppers were gray and un-reflectored at the time. She ran under the only hopper on the train that did NOT have bracing between the hoppers, which might have kept the car from jamming under the train. The only reason she didn't die was that the train stopped just up the track to switch a local feed mill, and the crew discovered the car then. I still shudder at what I saw that night. |
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| Author: | Mike Tillger [ Sat Sep 11, 2010 7:57 am ] |
| Post subject: | Re: FRA 224 and Historic Equipment |
This post refers back to 2 posts that have been deleted by the moderator Gentlemen, RYPN is not the place to discuss your political views, please continue this discussion via some other means. Thank you, Mike Tillger |
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| Author: | SZuiderveen [ Sat Sep 11, 2010 8:25 am ] |
| Post subject: | Re: FRA 224 and Historic Equipment |
Thanks, Mike T. Steve "OUT Of CONTROL" in Sykesville, MD. |
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| Author: | SZuiderveen [ Sat Sep 11, 2010 8:38 am ] |
| Post subject: | Re: FRA 224 and Historic Equipment |
Nick, Your caboose waiver petition was posted to the Federal Register this morning. http://edocket.access.gpo.gov/2010/pdf/2010-22726.pdf Steve |
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| Author: | tomgears [ Sat Sep 11, 2010 10:01 am ] |
| Post subject: | Re: FRA 224 and Historic Equipment |
Friends, A reminder: • The INTERCHANGE'S primary purpose is to facilitate the exchange of information, advice, and suggestions, not to serve as a forum for debate. We are only about preservation; political rants and "throw the bums out of office" posts will be deleted. Tom Gears Moderator |
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| Author: | robertmacdowell [ Thu Sep 16, 2010 11:01 am ] |
| Post subject: | Re: FRA 224 and Historic Equipment |
Folks, read: http://www.fra.dot.gov/downloads/counse ... elines.pdf http://www.fra.dot.gov/downloads/counse ... onTree.pdf Many of us fall into "Non-insular, but not part of the general railroad system". This is your typical railway museum line, traditionally demarced by turning over a rail. In that category, the reflectorization rules apply only to a few pieces of your equipment. Turning the rail isn't necessary, but that's another chat. Alexander D. Mitchell IV wrote: For the record, I can't really get bent out of shape about the reflector rule. I was a first-hand witness to the aftermath of one accident where I remain convinced the reflectors would have spared someone the horror... I know of another incident where the driver caught the side sill of the gon square-on. I'm sure all these went into the making of the rule. Here's the problem with the reflector rule. FRA is EXTREMELY SPECIFIC about the shape and positioning of the reflective strips. This rapes and pillages any aesthetic of industrial design to the point of outright vandalism. It is wildly incompatible with the purpose of railway museums. Which is WHY they quasi-exempted us. So we are unhitched from the duty to apply reflectorization at all, we are ALSO unhitched from the duty to do it their particular way. So go forth and do it your way. Hang 'em under the car, use reflectorized lettering instead, use black reflectors on black cars etc. http://www.shop3m.com/75346696877.html |
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| Author: | dinwitty [ Thu Sep 16, 2010 8:31 pm ] |
| Post subject: | Re: FRA 224 and Historic Equipment |
When the South Shore had its new double decker cars delivered, they had different railroad markings placed on them, magnetized or whatever, I think it got around some rule or red tape, then removed them when delivered. You could easily have magnetized or screw down posts to place high reflective visibility tape or surface, and when you want to display the car historically correct just remove them. |
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| Author: | superheater [ Thu Sep 16, 2010 11:25 pm ] |
| Post subject: | Re: FRA 224 and Historic Equipment |
Gentlemen, RYPN is not the place to discuss your political views, please continue this discussion via some other means. Thank you, Mike Tillger Sorry Mike, you're only expressing a personal preference, not a fact that can be posited with such certitude. Railroads operate in a political environment as do museums, heritage lines, etc. Politics explains: (just a few problems) Why there's no Class 1 excursions Why its so hard to move stuff. Why its getting harder to maintain your 501c3. Why you can't get a tour of Juniata anymore. It may not be to some people's liking, and political discussions can erupt, but you can't declare it irrelevant. |
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| Author: | Mike Tillger [ Fri Sep 17, 2010 5:31 am ] |
| Post subject: | Re: FRA 224 and Historic Equipment |
Superheater, It is unfortunate that you could not read the deleted offending posts. Sorry to have to correct you, but if you and others were to read the Interchange Guidelines you would find why it is not the place to discuss personal political views and why the moderator deleted the offending posts. In my opinion discussing the legislation behind regulations is not discussing personal political views and is applicable to our industry. It is the legislation or lack there of regarding liability, not the personal political views that have affected 3 of the items you mentioned, the IRS actions are also based in legislation. I guess the UP and NS (newly announced) excursions do not fit your personal preferences of a class 1 excursion program. My 2 cents, Mike Tillger |
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| Author: | Mr. Ed [ Fri Sep 17, 2010 8:49 am ] |
| Post subject: | Re: FRA 224 and Historic Equipment |
Two topics that are sure to start a fight are politics and religion. I for one am glad that one is not alowed here. Later! Mr. Ed |
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