I got dinged on our tank car for not having foot guards, it's under part 231. Does anyone have a picture of what they are talking about?

Here is what was on the report.
A AND B ENDS LEFT AND RIGHT #1 AND & #2 HANDHOLD / LADDER TREADS DO NOT HAVE FOOT GUARDS

Jason Annen
HVRM

Jason -

I have no idea what foot guards are for the ladder treads. When Tom Travis and I worked on restoring WCHX # 1114, we only painted the ladders. We removed nothing. This is a riveted tank car that was built in 1917 and the ladders to the dome these days are for appearances only. No one is going to be using them! My guess is that foot guards are for working ladder treads. But maybe someone knows exactly what they are.

A shame if the car can't be used on a photo freight because of no foot guards.

Les Beckman (HVRM)

Photos of your situation would help, but in general, foot guards are fabricated into hand holds that may also double as foot rests/ ladders. This is a regular hand hold:


This is a hand hold that incorporates a foot guard:

Additional guidance on safety appliances may be found here: http://www.fra.dot.gov/downloads/safety ... 10-231.pdf

Steve

Steve -

Thanks for posting the photos of a regular hand hold vs. one that incorporates a foot guard. Our 1917-built tank car definitely does NOT have these foot guards. But again, I question why they would be needed since we do not use the ladders. WCHX # 1114 has short ladders that incorporate only two "rungs" going up to the wood platform next to the dome (I'm sorry I don't have a photo that I could post; perhaps Tom does). Could we make a couple of new rungs to the ladder that incorporates this feature? Probably. Would it change the appearance of the car? Slightly. But again, I can't see the reason for it. It would be interesting to find out what other operators of vintage tank cars that are run over FRA track for photo freights have on their cars. I know that Illinois Railway Museum has a large collection of tank cars. Perhaps 10 or more. Do these cars have foot guards on their ladders? But maybe they aren't under the FRA. What about other museums? I have seen photo freights that incorporate old tank cars in their consists. Some comments would certainly be welcome.

Les

Make your case to FRA and ask for a variance.

dave

I have been in the tank car business for over 43 years working for a tank car builder/lessor, both in the office and in the repair shops, and also managing a large fleet of tank cars for 25 years and have never heard the term "foot guard" as a part used on a tank car. I volunteer at the IRM restoring old freight cars. None of the 9 tank cars in the IRM collection, which spans 1910 to the 1960 have these "footguards." The car that would come the closest to having one is a GATX car, built in 1960 that has a handhold that angles down at around forty-five degree; however, I believe that this was done to meet height requirements on the handhold. I believe that the FRA inspector may be incorrect in his sighting the need for "foot guards" at the locations he cited. On a tank car, there is is step at each corner, with a handhold positioned in a horizontal postion above the step. Every drawing that I have ever seen has called these handholds and not "foot guards." Above this handhold, attached to the tank or a bracket atached to the running board supports on later cars, is a vertical handhold. These horizontal handholds are not meant to be used to step on. They are meant to be used to assist in getting onto the sillstep. There is not adequate clearance between the handhold and the sidesill to stand on safely. When using the corner steps, one should step from the sillstep to the running board. For ladders on cars of this type, AAR or ICC 103 or ARA II or ARA III class designation cars, which yours is, the side ladders, and occasionally end ladders in place of side ladders, attach to the running boards and again, there is no "foot guard" used. When climbng the ladder, you go from the running board to the first stile of the ladder. I would contact the inspector and review the citation with him.

Attached is a photo I took of a modern 25k gallon tank and the only places that I see the foot guard grabs are on the corners. The ladder rungs are still standard straight grabs and this seems common on most modern tanks that I've seen. Perhaps the inspector just needs to be familiarized with older equipment and what the desired use really means. For comparison I've also attached a photo I found on rrpicturearchives.net of WCHX 1114 at North Judson.




Kevin O

Wouldn't it help to have a conversation with the inspector?

Jason, the key to the issue is evident in the report comment and is illustrated nicely in the two photos provided by KevinO. While the inspector's nomenclature is different that what I would expect and know, he is not referencing the ladders on the side of the car going up to the dome platform from the running boards.

It seems the inspector is making reference first, to the grabs or "handholds" mounted on the end sills on the left and right sides, and second, to the side sill handholds above the sill or "stirup" steps, at the A-end, Left and Right sides and B-end, Left and Right sides. In terms of the positions of the side handhold "ladders", they would be at the corners, but in terms of axle position they could be described (I suppose, though it's not the way I am accustomed to it) as No. 1 (B-end L & R) and No. 4 (A-end L & R) axle positions, so maybe the inspector mistakenly wrote "1 & 2" while meaning "1 & 4"?

The stirup steps and grabs or "handholds" above them make a sort of "ladder", but as pointed out above these handholds are not really intended to be used as a step. You go from sill step to running board. The side sill and end sill handholds are straight grabs, not drop grabs or "foot guard" grabs (which I also have never heard the term). Whether the inspector was in error or not, the straight grabs provide no safety to prevent one's foot from slipping off to the side and causing a fall if used for that purpose. This is easily seen in comparing the two tankcar photos posted above by KevinO.

Do talk with the inspector to make sure you understand the issue and then apply for a waiver if it makes sense, or change out all 8 handholds if not.

The photo above was what I needed. I have spoke with the inspector today in person. I know what I need to do, and it will be corrected in the morning. Thanks for the info.

Jason