Something I have been meaning to ask that was spurred by the FRA & Record Keeping topic.

Since most RR Museums with trackage and equipment fall in the grey 'Insular operator' FRA classification. Has anyone invited the local FRA inspector out to advise what could & should be done better and more in line with FRA rules, or is this just inviting the proverbial fox into the hen house?

This fall along the same lines as inviting the police and fire inspectors down every few years to familiarize them with our equipment, and buildings and to gather any suggestions they have to keep the place safe, which the museum I am involved with does.

Thanks,

Rich C.

It is always great to get advice to improve safety and compliance with rules, etc.

I believe you a tad bit mistaken that most museums are insular operations...in fuzzy area. If your railroad track crosses a public street and/or connects to the national railroad network...the FRA requirements/inspections must be satisfied. Each musuem must follow rules on everything from clearance, to boiler repair, air brake rules, speed rules, well....just RULES. The same as the big boys.

I see IC382 beat me to the punch.

The "active public highway grade crossing" rule means that unless you're operating a small demonstration loop, or landlocked in a place like Disneyland, you're covered by at least some of the FRA regs.

That means that most (but not all) tourist railways are covered.

http://traininc.org/regulatory/document ... ISTRRs.pdf

The question here, is whether or not the tourist operation is "part of the general system of transportation." The tourist operation's track can be physically connected to the outside world, but if that railroad does not have joint operations with another carrier, nor originate or receive any traffic (no on-line customers), then it is not part of the general system and therefore may be relieved from certain parts of the CFR. This is best determined by the FRA Regional Administrator to avoid confusion.

Brian Wise

Based on TRAIN's discussions with the FRA and their interpretations of the rules, there are 3 classifications.

http://traininc.org/regulatory/document ... ISTRRs.pdf

Helpful guide to TRAIN's interpretation of which rules apply to which operations. As Brian says, consult your local FRA office for the final say, it's certainly not unheard of for different offices to have different interpretations of the regs.

Quoting the document I linked to above:

1) General Railroad System - Same rules as the big guys.
Operations on track that is part of the general railroad system.

2) Non-Insular - Some, but not all FRA regs apply.
A "non-insular" tourist railroad is a tourist, scenic, historic or excursion passenger rail operation which:
1. Does NOT operate on trackage which is part of the general railroad system, AND
2. Has ONE OR MORE of the following characteristics:
> An active public highway-rail crossing,
> An active grade crossing with another railroad,
> A bridge over a public road or waters used for commercial navigation, or
> A common corridor with another railroad (i.e. its operation are within 30 feet of those of any railroad)


3) Insular Railroad - Not under FRA jurisdiction.
An "insular" tourist railroad is a tourist, scenic, historic or excursion passenger rail operation which:
1. Does NOT operate on trackage which is part of the general railroad system, AND
2. Does NOT have ANY of the characteristics of a "non-insular" operation described in '2' above

These operations *may* fall under some other jurisdiction, for example the state Department of Agriculture. Yes, Department of Agriculture, since they often inspect amusement park rides, apparently due to the early connection of carnivals and county agricultural fairs. OSHA and your state's Safety and Health Admin may also apply.

Steam operations may also fall under state boiler rules, ask the live steam guys about the whole complex web of state boiler codes and regs etc.

I should think that if you are an "insular" railroad that operates a steam locomotive under whatever local jurisdictions apply, it would be in your interest to pay close attention to the FRA CFR49 Part 230 regulations, especially where boiler certification is concerned. If you were to be unlucky enough to have to sell your locomotive or lease it to a NON INSULAR railroad, you would need to provide all of the neccessary documentation to the new owner or lesee to ensure that your locomotive has a chance to pass the required FRA inspection. Without a current FRA ticket your locomotive has far less value, no matter how carefully you have maintained it. Whether you could ask the FRA to come and inspect your locomotive when is is not under their jurisdiction is probably a question for your regional FRA office.

I don't think I'd let the idea of Fair Market Value justify my record keeping and maintenance standards....but I sure would want to be able to point to compliance with some official standard when my insurer drops in, and I've already mentioned the benefits of good documentation from an operating POV. Valueing steam locomotives doesn't work that way............

A few years ago, i had occasion to do a very low budget resuscitation of a steam locomotive that was long retired for a very insular place. I did most of the surveying and calculations that FRA would require, without removing the tubes for a full interior inspection since they were in good shape and all the thickness tests and visuals came in very favorably. Hydroed to 1.25% "ticket" operating pressure, operated it at about 80% of that.....while the boiler was uncovered, I offered the FRA (as a professional courtesy) both a heads Up on a new steam locomotive on an insular facility in their region, and an invitation to look over my calcs and witness the hydro test. They didn't choose to review or attend, which makes sense, but nothing would catch them completely unprepared should a question have been raised.

The state inspector........didn't know what a hydro test was much less want to see one, and had no idea about the calcs or the construction of a HFT boiler. Hammered a few rivet heads, signed off, disappeared.

Take a larger view than just FRA if you're insular, but don't leave them ignorant even if you are insular. They don't want to take on something they don't have to but it is good to keep everybody who might want to know informed. Work with your insurer and state inspectors, whichever department they might be, expecting them to be ignorant but might be best to not tell them how ignorant they are....or they could create many irrelevant reasons to ruin your day.

Be demonstrably safe. Document your work is done in demonstrably safe ways. Deal with everybody in regulatory capacities in a professional way. Find opportunities to be proactively courteous to any potentially interested stakeholder.

It's common sense. It works.

dave

crij> Since most RR Museums with trackage and equipment fall in the grey 'Insular operator' FRA classification. Incorrect

IC382> If your railroad track crosses a public street and/or connects to the national railroad network...the FRA requirements/inspections must be satisfied. Each musuem must follow rules on everything from clearance, to boiler repair, air brake rules, speed rules, well....just RULES. The same as the big boys. Incorrect

Bobharbison> The "active public highway grade crossing" rule means that unless you're operating a small demonstration loop, or landlocked in a place like Disneyland, you're covered by at least some of the FRA regs. Correct

speeder3> The question here, is whether or not the tourist operation is "part of the general system of transportation." The tourist operation's track can be physically connected to the outside world, but if that railroad does not have joint operations with another carrier, nor originate or receive any traffic (no on-line customers), then it is not part of the general system and therefore may be relieved from certain parts of the CFR. Quite close

Bobharbison> Based on TRAIN's discussions with the FRA and their interpretations of the rules, there are 3 classifications. Correct

If you're going to invite FRA, understand the rules first. We're getting better, but this is still an area of great confusion for many. If you're not tight with this stuff, it can cause a lot of trouble for your organization. You could get misled by an FRA field guy who inspects freight RR's every day a year but the one he spends at museums. He may not know how the rules apply to you, so if you don't either, you're really up a creek. I've seen it happen.

Now, I said "quite close" above because you can interchange as many cars as you like as long as you're the customer. Historic car delivery, ballast, coal... all good. And you're not relieved from "certain parts", you're relieved from the lion's share. Some call that "FRA Lite".

By "relieved" I mean you still have to possess, and display, some level of basic competence, or FRA will shut you down with an Emergency Order. That doesn't happen very often.

There's one other wrinkle which arises largely for transit museums. If a car was never in their jurisdiction before (e.g. PCC cars, subway cars, BART trains) they tend to be exceptionally light-handed with it, especially since their freight man really wouldn't know what he's looking at on a PCC. If your fleet is mostly like that, they will tend to treat the whole museum like that despite a few similar cars (e.g. a South Shore car) that would have been in their jurisdiction back in the day. So a substantially-transit museum tends to be a fourth category, "FRA Lite Lite".