I was reading the Summer 2002 NBIC Bulletion and was troubled a bit by one of the features. On page 32, Robert Schueler begins a feature titled "New Rules for Old Locomotives: Reverse Engineering Required". I am not going to debate the reverse engineering instead, I am bothered by what he states on page 33. It may be in the way I am reading it. Here is what he states:

"Rule 49CFR230 provides that all repairs and alterations to an operating steam locomotive be performed in accordance with an American National Standard. Any "R" certificate holder using the NBIC for repairs and alterations is permitted to do this work."

It is my understanding, and I learned this directly from FRA officials, that the intent of the rule is not to require any shop performing such repairs or alterations to have an "R" stamp. I almost feel that Mr. Schueler is stating that anyone performing such repairs or alterations must have an "R" stamp. The rule only requires that the repairs or alterations be performed in accordance with a national standard of which the NBIC is one.

Could I get an Amen on this?

G. Mark Ray - TVRM

TVRM Shop Updates
aw90h@cs.com

I think the word permitted is the key. R stamp holders are permitted, and without saying it, so are others. If it was restricted, I think you would see the word "must" or "shall" in there somewhere. The rule makers are very precise in their language. Also, remember the audience he was aiming at with his statement. They would raise a question if it was worded differently.

> It is my understanding, and I learned this
> directly from FRA officials, that the intent
> of the rule is not to require any shop
> performing such repairs or alterations to
> have an "R" stamp. I almost feel
> that Mr. Schueler is stating that anyone
> performing such repairs or alterations must
> have an "R" stamp. The rule only
> requires that the repairs or alterations be
> performed in accordance with a national
> standard of which the NBIC is one.

> Could I get an Amen on this?

I don't know about an Amen but I agree with your intereretation. Our FRA inspector also concurs.

JCG

johncgra@locl.net

what I was told by our FRA man, and what should be construed from the new rules is that repairs are to be done to (a)National Board/ASME accepted practice or (b)in accordance with "established railroad shop practice. He also said that we could do any and all repairs ourselves, as long as it met those criterion and passed inspection. Basically, we were told that the FRA doesn't care who does it, as long as it is done right.

Having read it time and again, it says NOTHING about requiring an R stamp shop to do the work. Actually, doesn't specifially say anything about any type of pressure vessel certification for anyone working on a boiler, although a liscensed welder still is the only way to go, IMHO.

You have to remember, the ASME and National Board are industrial associations that have been given the force of law, and if truth be told, not for any altruistic, public safety issues, but to insure a monopoly on the ability to perform boiler work by its members. I heard over a year ago that they wanted any repairs, including flues and even non-pressure related plumbing to be done by an R stamp shop.

That being said, it may not be in the too distant future that anyone who thinks about working on a boiler will have to pony up the several thousand doller per year annual fee in order to work on an engine. So much for volunteer staffed shops.

>

> The rule only
> requires that the repairs or alterations be
> performed in accordance with a national
> standard of which the NBIC is one.

> Could I get an Amen on this? AMEN - and Halleluia!!!



Martyhuck@aol.com

Mark - my understanding is identical to yours as it was explained to me in more than one presentation at ARM and TRAIN conventions. From a liability POV at least a certified welder is probably a good idea, however.

Given the junk created by an R stamp holder in a small northeastern state in the past few years I am not at all encourcged to consider it a guarantee of quality.

Dave

irondave@bellsouth.net

You are reading too much into it, Mark. An R stamp is not required. Kelly's explanation of that is good. This questions was asked repeatedly at all the FRA seminars about the new rule and the answer was always the same. An R stamp shop can do the work if you want them to do it, but an R stamp is not required to do the work.

"Established railroad practice" means those old, dusty shop practices and standards manuals each indivdual railroad had. The AAR and other trade entities also had such manuals of standards. If you have a particilar task to do, and can locate a relevant practice or standard that was used by a railroad that outlines and covers the repair to be done and the methods and materials to be used, and you follow it when doing the repair, you have met the requirement in 230. You must be able to document it, though. You can't just say, "old Bill remembers it was done this way."

> Given the junk created by an R stamp holder
> in a small northeastern state in the past
> few years I am not at all encourcged to
> consider it a guarantee of quality.

> Dave

I'll give an "Amen" to that!
Tom

ironbartom@aol.com