[cute popcorn-munching smiley GIF the moderators don't seem to like]

This should be fun........

I would like to see someone compile a list of organizations that they feel don't meet up to safety expectations. Really guys???

The number of operators is limited and most all the major players in steam operation utilize the same pool of talent. The "shade tree" operators haven't been able to stay in operation due to the economy or their locations, etc.

Even the most reputable operators are going to have occasional mishaps...unfortunate...but YES they will happen.

Why can't we focus on things of true relevance and interest here?

Like...I want to know...where the feedwater heater is being mounted on the 4501 myself. See...that is interesting...smokebox, under the running boards...where is it going boys?

Pictures are more titilating than all this hot air.

:-)

I have to agree. The discussion, of a voluntary nature, can be illuminating and educational.

I write about the craft beer brewing industry. One of the big complaints we have in the trade is that we are under Federal and state regulations, and in the interests of whatever reasons the political process has for regulating the alcohol trade, it becomes a meticulous cat-and-mouse game of law-following and violations. From the perspective of regulators, they can come up with laws covering 4,982 ways of doing business, and someone will come up with ways 4,983 through 5,073 next month. From the perspective of microbreweries, they can ask an idiotically arcane question ("can I make a gluten-free 'beer' from honey and buckwheat for my brewpub?" or "can we keg this winery's hard cider and sell it on draft for them?"), and they'll get six different answers from five regulators/inspectors, then get cited on an entirely different interpretation by a seventh inspector. Or, do you just go ahead and do it on the premise that it's easier to beg forgiveness than ask permission?

The microbrew industry, like the tourist railroads, is routinely doing things that may technically violate the letter of the law but not the spirit. One example: Using refillable half-gallon bottles ("growlers") to take beer to go. For years, brewpubs have routinely looked the other way with a wink and nod and filled up any growler from any brewpub that someone brought in, especially handy if you have plenty already and are traveling. But some alcohol officials have deemed that this is a violation of beverage labeling laws (written to keep the bartenders from topping up premium wine/spirits bottles with rotgut), and are now cracking down on the practice, mandating that growlers must be labeled for the place for which it was purchased. Then some places started sticking adhesive labels on "foreign" growlers when they showed up, to fulfill the technicalities of the law..... Idiotically trivial, to be sure, until someone gets slapped with a $5,000 fine for a violation. (I've had an official in one state openly tell me "I have &%(*# better things to do with our time than enforce that rule--I'm more worried about bars that are a front for drug selling, that fail health inspections, harbor gangs and the like!")

Tourist/heritage railroads routinely, almost as a mission statement, violate well-intentioned regulations and rules that a moment's common sense will tell you have no applicability to the circumstances in question. We also do things that just aren't covered by these regs, or are outside the "radar" of enforcement in a vague sense. I have a feeling that a thorough "round-table" discussion in this forum would reveal a similar situation as I've heard from the craft brewers: a wide variation in enforcement, scrutiny, interpretation of rules, and the like in spite of utterly impressive efforts by the FRA, "Surf Board," and the like to be understanding and inclusive of the avocation/hobby/trade within the Code of Federal Regulations and state-level regulations.

[reaches for the popcorn again]

Sounds like you're asking for a lot of hearsay and rumored stories. You are always going to find someone with a woodie for some other organization who will be glad to tell you much more than you want to know.
The FRA isn't going to release this kind of information.
An organization's best defense is to keep meticulous records, maintain a good relationship with the FRA and keep them in the loop. That worked well with me plus when you tell the truth you don't have as much to remember.
As in any undertaking there are shade tree guys and charlatans out there, but if you keep your own house clean you're safe. If you see another group doing something egregious, then report it to the proper authority instead of gossiping about it.
We all are in this together and one calamity can affect everyone.

Frisco, from my reading of the original post that is NOT what Jeff is asking or implying. My take is that he wanted a discussion of how various operations comply with regulations and meet recordkeeping requirements.

So far two separate people have looked at these innocent questions with derision. That in itself is rather curious.

Hang out on the Internet long enough, and you'll learn that people only read/see what they WANT to read/see in a statement, article, or website, regardless of what it actually says/shows.

I worked in the regulatory department of a company that made materials that are used as thickeners/suspending agents in water-based products. These ranged from foods (FDA-regulated), food-contact packaging, (regulated by another part of the FDA), drugs (regulated by a third part of the FDA), meat and poultry products (USDA-regulated), beer (BATF-regulated), and various industrial products (EPA-regulated). The exact, same material could be used in any of the above mentioned uses, yet there was a different set of regs we had to comply with. The highest use level was around 0.5%, some uses down in the ppm range. Talk about a regulatory zoo! At least a tourist railroad/museum usually has to mainly comply with FRA, and not a multitude of other agencies for the same thing.

I know the place where I volunteer does our best to be compliant with all applicable FRA regs. We keep records to show compliance with the applicable parts of 49 CFR 213, 217, 218, 219, 228, 229, 230, 240, and 242, among others. And, yes, the FRA does come around once in a while to check on the record-keeping. I'm not directly involved with this, so I can't comment on how the records are kept. However, as far as I know, we haven't have any serious problems with the FRA.

From my experience in the specialty chemical industry, the best way to avoid problems with the regulatory authorities is to keep your paperwork in order. If they come in and find issues with that, then they really start looking deeper into what you are doing. And if the inspector comes in and tells you you'd better correct something, DO IT! If he comes back at a later date, and you haven't corrected it, watch out.

...pours a cup of coffee...sits back and watches the men discuss the same topic they discussed last weekend while grandma milly cooks up breakfast...

...and while they criticize others intentions and opinions...followed with how to save everyone and solve the world's problems...they missed life's scenery...ever changing and becoming something different than they knew before...

You guys missed my point. The FRA regulations are needed and observed by every reputable organization that operates consistent steam. I suppose my point is...this isn't late 1970's or early 1980's operations...it is 2012. The "shade tree" steam operator...does it really exist in our 21st Century?

Just because the regulations are Federal and exist does NOT mean that they are consistently imposed or enforced.

I'm not going to get anyone in trouble here, but I spoke to one company head who relocated from a "blue" state to a "red" state some years back. What he did basically didn't change, only the location. (Imagine, in this case as a made-up example, moving the Napa Valley Wine Train to Arkansas and replacing the Bramson Scenic RR.) He said the inspection/certification process was "night and day" between the two. In the "blue" state the process was described as onerous and supposedly smacked of corrupt officials looking for bribes, he said; in the "red" state they were thorough but almost deferential, simply looking to head off potential trouble. The state/local officials with oversight--building inspectors, licensing, etc.--were even more extreme in that difference.

This is not meant to be a "red/blue state" diatribe, but simply a point that just because we're all supposedly under the same regulations doesn't mean it's all the same to all of us. Maybe it should be, but I'd be amazed if that's reality. I mean, most of us have probably seen the several YouTube videos of a certain short line with trains creeping at three miles an hour and cars rocking wildly as they creep like the worst days of the Penn Central/CNJ/etc., and wondered "how in #(*&!@ has that line not been shut down, and why aren't the inspectors who ride MY posterior shutting down THOSE guys?!?" (Please don't name that railroad if you know what I'm talking about--they give our industry a bad enough name already as it is, and they don't need more publicity.)

I apologize, I must have read something into the post that really wasn't there.
I blame it on this damned election and bombardment of commercials and robocalls.
That's my story and I'm sticking to it.

I may be a bit belt-and-suspenders, but even when working for insular lines I maintained logs of daily, monthly, semiannual and annual inspections as well as documentation of every washout, alteration, and other than running maintenance procedure peformed. I found it helped me keep things running more reliably, anticipate defects in time to prepare for them or head them off, budget, and generally know a lot more than I'd be aware of otherwise. Daily reports were filed by the engineer of record.......which also taught me a lot about the different engineers on staff.

No matter who fills out reports, somebody should be primary contact and responsible party for assuring they are completed and filed, which means some level of authority over operating and mechanical crews is necessary to assure compliance.

The different inspectors I've dealt with were all different....but none were unreasonable about being hardassed or nitpicky if they were satisfied you were working hard on keeping your operation safe and your documentation up to date. If there was a general evident slipshoddiness or your paperwork looked obviously like it was all done for the whole year last night, then you would be very likely to be visited frequently and looked over with a greater degree of attention to detail......moreso if attitude was also evident. I don't think it has as much to to with color of state as state of inspector's mind.........

FRA guys hate unpleasant surprises and like to be asked for input and clarification early in process. It helps you plan as well, and contributes to a general professional appearance. People who work with you don't work against you. Make sure you do your homework and due diligence first, asking stupid questions destroys that professional appearance thing.

Your mileage may vary.

dave

I think this is a great topic and one I have silently wondered about as well. My experiences are very limited to working on the floor of the shop. Have never kept records of boiler washouts, repacking of sellers, maint to air pumps. Just did what was needed or told to do. Fast forwarding to the present I have wondered who and how the records if any are kept. For some it might be inspirational to start or shore up record keeping. I am with Dave on the idea of not only doing it for FRA inspection type of reasons, but it can double as a way to keep up with repairs coming at you in the future. Kind of a preventitive maint program, but with better record keeping. Serves dual purposes.

Before becoming a nurse by vocation I drove interstate semi as a truck driver for 24 years. As the world became more and more complicated {goverment regulated}, drivers and trucking companies had to start dancing to stricter regulations, not a much different form then tourist or museum type railroads. As a driver, you can avoid much trouble and expense if you play ball instead of being stupid. The time it takes to update your log book, do your safety check before you start your day and before you approach a scale where you can be inspected {not any different than having the FRA come inspect your locomotive or operation} pays off. They are looking for major problems, but inspections can become big problems if you don't have your ducks in a row or be stupid towards them. Common sense should pervail, but some folks just never get it. Dropping the attitude, having your paper work in order immediatedly when asked for it, and being upfront and honest will pay dividends. "by the way I know my left marker lights are out on top of my trailer, I have the maint report already made out for the shop to fix.........". They are looking for bigger fish to fry, bigger problems to address. The form is not the same, but form is not causal. Cooperation and integrity goes a long way even in todays world. Then sometimes nothing works and you just have a real bad day!

Cheers, John.

While it can seem like the FRA regs are designed to keep bureaucrats employed, most of them are based on solid principles and practices. Take Class 1 track for example. Whether or not you're covered by the FRA, the standards are useful. 5 good ties per 39 feet, or just less than 1 tie every 8 feet? If you can't meet that, do you really have track good enough to haul passengers safely?

So even if the regs don't apply by regulation, it is probably sound operating practice to adopt them, at least the ones that are applicable to your operations.

I just realized that while the FRA discussion is relevant...we can go round and round on this board.

Politics, red vs. blue, give me a break! Politics and political following hasn't an ounce to do with anything about following FRA rules, adhering to inspectors direction, etc.

You know it boils down to this....so let's say tomorrow an engine blows it's boiler. Everyone on here will crucify the organization and somewhere in there will blame the regulators for not catching the issue....BUT...you let the regulators try to reign in on operations...and they become the bad guy.

Kind of like the people that gripe about hand-outs, welfare society, etc...but as soon as their diabetes kicks in, and their weight becomes a problem...they will line right up to that nation's purse and ask the regulators for their "Fair Share".

Spare me...clearly regulation/regulators can't win on either side...and hypocrisy continues.