Be sure to review your processes and physical set up so you’re not setting yourself up to fail.
Darell Luther
Montreal, Maine & Atlantic, for immediate release, Saturday July 6, 2013
Derailment in Lac-Megantic, Quebec
At approximately 1:15 am EST, an eastbound Montreal, Maine & Atlantic Railway train with 72 carloads of crude oil and five locomotive units derailed at the Rue Frontenac road crossing in Lac-Megantic, Quebec.
Early reports indicate that the train was stopped and tied down by the locomotive engineer at 11:25 pm on the mainline at Nantes, a station approximately 6.8 miles west of Lac-Megantic, where the derailment occurred. The engineer was not on the train … (see the following link for the entire press release:www.mmarail.com/sections/news/files/MMA_7.6.2013_Press.Release.pdf )
How Do Such Events Occur?
According to the Federal Railroad Administration (FRA) (Federal Register/Vol. 78, No. 152/Wednesday, August 7, 2013/Notices page 48221) nearly one-half of all accidents are related to railroad human factors or equipment defects. From 2009 through 2012, 35.7 percent of train accidents were human factor-caused. With regard to the securement of unattended equipment FRA accident data indicates that approximately 8.5 percent of human factor-caused train accidents from 2011 until April 2013 were the result of improper securement.
As a result of the July 6 accident and the statistics above, the FRA issued FRA Emergency Order No. 28, Notice No. 1 and Transport Canada (TC) issued an Emergency Directive pursuant to Section 33 of the Canadian Railway Safety Act. The Emergency Order and Directives provided the following guidelines to all railroads:
- No train or vehicles transporting specified hazardous materials can be left unattended on a mainline track or side track outside a yard or terminal, unless specifically authorized.
- In order to receive authorization to leave a train unattended, railroads must develop and submit to FRA a process for securing unattended trains transporting hazardous materials, including locking the locomotive or otherwise disabling it, and reporting among employees to ensure the correct number of hand brakes are applied.
- Employees who are responsible for securing trains and vehicles transporting such specified hazardous material must communicate with the train dispatchers the number of hand brakes applied, the tonnage and length of the train or vehicle, the grade and terrain features of the track, any relevant weather conditions, and the type of equipment being secured.
- Train dispatchers must record the information provided. The dispatcher or other qualified railroad employee must verify that the securement meets the railroad’s requirements.
Railroads must implement rules ensuring that any employee involved in securing a train participate in daily job briefings prior to the work being performed. - Railroads must develop procedures to ensure a qualified railroad employee inspects all equipment that an emergency responder has been on, under or between before the train can be left unattended.
- Railroads must provide this Emergency Order to all affected employees.
Lessons Learned to Apply
The TC and FRA emergency orders, rules and directives are simply application of a lot of statistical research applied to a common sense approach. This approach is governed by two railroad administrations is simply to work safe.
Taking the TC and FRA advice and applying it to private track in yard and terminal operations one would want to consider the following:
- Gradient is not your friend. Park all railcars whether single or in groups on as flat a track as possible. Develop rules that are required to tie handbrakes on specific group sizes of railcars, e.g. tie off a handbrake on every other railcar not connected to a locomotive.
- Training insures safe and effective operations. An ongoing repetitive training regime is more than important, it’s a life saver. Train your employees on what to do in all aspects of railcar movement, loading and unloading in yards and terminals. Effective training is simple and easy to understand yet inclusive enough to address situations from daily operations to emergencies. Training should be included in daily job briefings and in cases where there are crew changes to be sure a smooth handoff of job duties occurs.
- Documentation is paramount but shouldn’t be burdensome. A massive amount of documentation when it isn’t required is worse than no documentation at all. Simple checklists that cover the process of tying down a railcar(s) or spotting railcar(s) for loading or unloading should be just that … simple.
- Accountability drives results. Giving employees the tools and training to operate safe and effectively is important. Holding them accountable to effective and safely using those tools and training is a key requirement to obtaining the results you desire.
If you’re at a loss on where to start or want to revise a current rail operations yard and terminal program consider that it’s okay to model your program after successful ongoing operations. Consider a version of the FRA/TC guidelines modified to your operations or conducting a process review internally by simply writing down the steps and then presenting them to peers for their review and input.
Anticipated Impacts in the Waste-by-Rail Arena
To obtain a sense of expected impacts in the waste-by-rail arena, we conducted an informal survey of waste-by-rail transporters, rail yard operators and trans-load operators. Our survey was general so as not to restrict response and consisted of two questions: 1) What impacts do you expect from the MM&A derailment and 2) What will you do different in your own operations as a result of the derailment? To protect the identity of respondents we summarized the results below.
What Impacts Do You Expect from the MM&A Derailment?
The overwhelming response was that rail rates are expected to rise across the board primarily for hazardous shipments and secondarily for non-hazardous shipments that are classified in the general waste category. Reasons given for the anticipated increase are to cover expected insurance premium requirements to offset transport risks, to cover increased operating costs of having not less than two man crews on all “hazardous” shipments and increased documentation process costs. Interestingly the majority of operators/shippers believe that the set of rules and regulations that govern most hazardous and non-hazardous waste shipments are more than sufficient to insure a safe operating environment and don’t believe at the shipper/receiver/trans-load level there will be many changes, if any.
What Will You Do Different in Your Own Operations as a Result of the Derailment?
The overwhelming response was that the implications of the derailment will drive a formal review of internal operations procedures and documentation. However, all respondents were very comfortable that their operations procedures and documentation processes are more robust than actually required by government and private entities.
The details of what went wrong on the Montreal, Maine & Atlantic are still being sorted out and there will be a long time spent in the discovery phase before every detail is flushed out. However the application of lessons learned from the first review, if not already in operation at private track and terminal operations, should be applied. Remember Train – Document – Hold Accountable and most importantly review your processes and physical set up so you’re not setting yourself up to fail.
Darell Luther is president of Forsyth, MT-based Tealinc Ltd., a rail transportation solutions and railcar leasing company. Darell’s career includes positions as President of DTE Rail and DTE Transportation Services Inc., Fieldston Transportation Services LLC, managing director of coal and unit trains for Southern Pacific Railroad and directors positions in marketing, fleet management and integrated network management at Burlington Northern Railroad. Darell has more than 24 years of rail, truck, barge and vessel transportation experience concentrated in bulk commodity and containerized shipments. He can be reached at (406) 347-5237, via e-mail at [email protected] or visit www.tealinc.com.