The question came up on a email list, the FRA regulates Locomotives including Steam Locomotives, what about other steam powered equipment: Rotary Snowplows, Pile Drivers, Locomotive Cranes, etc.

I can easily make a case that Steam Locomotive Cranes could be covered.

-Hudson

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Interesting,

I've wondered myself also how a fireless locomotive would fit in the scheme of things inspection wise. Are there any operating in the United States? I don't know of any off the top of head.

Tom

Hearsay about the Virginia & Truckee has the reason for a snowplow on one of the old steam locos that M of W equipment doesn't fall under locomotive regulations. However, some jurisdictions might claim that that position eliminates Federal preemption, so that state or local boiler inspectors, etc. can now rule. A recent runaway contract rail grinding train on the ex-Southern Pacific (Baxter, California, November 9, 2006) may be causing the Federal Railroad Administration to take notice of this "loophole".
http://www.ntsb.gov/publictn/2009/RAB0903.htm or http://www.ntsb.gov/publictn/2009/RAB0903.pdf
I'm not a lawyer and your experience may vary.

Ask them if they want to regulate your MOW stuff on a case by case basis. I'm pretty sure they'd prefer to have as little to do with it as possible.

dave

When I moved the American Locomotive Crane now at Travel Town over the Sante Fe Harbor Sub/Branch (insert current correct term) from Torrance to Amtrak's 8th street yard, and then subsequantly from there to Glendale over the UP with a Metrolink pilot, I was told it was MOW equipment and would not move as a locomotive or train, even though it was running on its own wheels and under its own power. Even though it was almost 60 years old at the time and had plain journal bearings, the railroad said no notification to the FRA was necessary. I did talk to the FRA later, and they confirmed they had no interest in regulating it. It is diesel powered, but I can't see that adding a boiler to it would have changed FRA's interest.

Greg

There may be one thing about regulation, then there is the "smartitude" about boiler safety despite not fitting under the "required" regulation.

If you have/operate such equipment I would give it that checkover even if there isn't the regulations in place. I tend to think of the Steam Traction engine that exploded not too long ago. A lot of these equipment are slowly reaching 100 years of age.
I would not just because it would not be regulated is not an excuse to not still be careful.

Recently the water tanks on concrete trucks have come under scrutany. These tanks are pressurized by the truck's air system to push the water out when cleaning the truck. Due to an explosion and injury, the question was asked concerning inspection and regulation of these tanks. All of the state boiler and pressure vessel offices didn't regulate them, thinking that they fell under Federal DOT. The DOT said since the tank does not have any use related to the actual function of the truck (brakes, etc.) and is only carried by the truck, it is not regulated by DOT. It is considered part of the truck's "load".

I can see a parallel where the FRA could look at any piece of RR equipment, and if any machinery (boiler, engine, plow, crane, etc.) is not a direct part of the mechanical system of the railcar, it similarly could be considered a "load".

Just something to think about.

With respect to fireless steam locos, when used in industry they would probably come under state inspection rules as a "non-fired pressure vessel" and thus be subject to the same sort of rules and regs as compressed air tanks, etc.

I am not aware of any fireless loco currently being used commercially in North America.

A few fireless locos did operate in common carrier service (C&O and ATSF come to mind) and those would certainly have come under some degree of ICC/FRA inspections.

Didn't one see use rather late at a BN-owned tie treatment plant?

Steve

Two, actually. S-1 and S-2 at the Somers, MT tie plant.

One has to be careful in assuming that just because a piece of equipment is classified as "Maintenance of Way" that it is exempt from regulation. FRA has specific rules governing such equipment under 49 CFR 214 subpart D. Further, if you employ a self propelled crane to move a freight car, it is now considered a locomotive. For FRA's guidance on this, see the MP&E inspector's manual or this memo: http://www.fra.dot.gov/downloads/safety/mpe/tb_1998/98_25.pdf. While there are no specific regulations governing power plants, steam or otherwise, note in particular that FRA has broad authority to ensure that any such equipment is "safe".

Remember too that rolling stock is rolling stock, regardless of type of use; air brake and safety appliances must be in compliance, even if confined to "Maintenance of Way" service, snow plow duty, etc.

Alan Maples
Everett Railroad