From: Gil Gore [mailto:gilgore@bletsr.org]
Sent: Monday, September 18, 2006 3:36 PM
To: All BLET UP Southern Region Local Chairmen
Cc: Western General Chairmen’s Association
Subject: FW: Simulator for qualifying - xing bulletin
Brothers,
Below are some questions that Brother Briggs and I were wrestling with regarding the use of simulators to qualify engineers as well as violating a XG “stop and protect” bulletin before occupying a crossing. The FRA’s response and attached documents are provided by Brother Briggs for your ready reference and review.
If you have any questions, please feel free to contact me.
To view bulletin OP414 click HERE
To view bulletin OP421 click HERE
Fraternally,
Gil Gore
From: Terry Briggs [mailto:tslbchair@sbcglobal.net]
Sent: Monday, September 18, 2006 2:17 PM
To: Gil Gore
Subject: FW: Simulator for qualifying? xing bulletin
FYI Brother.
Here is the link to two technical bulletins on certification, which are also attached. http://www.fra.dot.gov/us/content/1470
It appears you are right. The carrier may use a simulator to re-qualify. Op0421 has six questions and answers that further explain the FRA position on qualifying.
Regarding the answer to question 4, which says occupying a crossing without complying with a stop and protect bulletin is a decert; op0414 defines a main track below. Under this definition, the stop and protect bulletin would be a “mandatory directive”. Occupying the crossing without complying with the directive is a violation.
If you have any questions let me know.
Terry
Op0414:
Definition of Main Track
The Interim Final Rule adds the following definition of Main Track at 240.7: “Main track means a track upon which the operation of trains is governed by one or more of the following methods of operation: timetable; mandatory directive; signal indication; or any form of absolute or manual block system.” Questions have been raised regarding the term “mandatory directive” and its decertification implications under 240.117 (e) (4).
Policy: This term is used in Part 240 as it has historically been used in Part 220: “authority for the conduct of a railroad operation.” It includes all situations where a segment of main track is occupied without permission or authority in accordance with the railroads’ operating rules. It does not include occupying a segment of track contrary to advisory information, such as that from a yardmaster relative to which track to use in a yard.
-----Original Message-----
From: melvin.smith@dot.gov [mailto:melvin.smith@dot.gov]
Sent: Monday, September 18, 2006 12:23 PM
To: tslbchair@sbcglobal.net
Subject: RE: Simulator for qualifying? xing bulletin
I consulted with John Conklin who is our Part 240 Subject Matter Expert in Washington to get the latest rulings that apply to your questions.
Here are the answers:
1. Can a railroad use a simulator, in lieu of actual train trips, to initially qualify an engineer over a particular territory?
Answer: No. The engineer can use the simulator as a tool when qualifying on new territory. However, the engineer would at some point need to make one or more runs over the territory before he/she in qualified. 49 CFR 240.123(c)(5)(ii) requires that a student be placed at the controls of an actual locomotive during the on-the-job training phase of a training program. This provision was added to prevent railroads from training and certifying engineers exclusively on simulators. Since qualifying over a new territory is OJT, this provision would also apply.
2. Can a railroad use a simulator, in lieu of actual train trips, to require an engineer to re-familiarize over a territory the engineer has previously operated on?
Answer: Yes, except for special circumstances such as heavy grade territory. In this situation, the engineer has previously qualified on the territory and would know the grades and track configurations since these items do not ever change (an exception would be a major track construction project). The engineer could use a simulator to refresh his/her memory on methods of operation, siding, detector, CP locations, etc. Most railroad qualification procedures require the engineer to contact a DSLE who is qualified on the territory to determine if qualification trips are necessary. In some instances, a phone call may be all that is needed, i.e., experienced engineer states to DSLE that he is comfortable to go, no changes on the division, the engineer has only been off the division a short time, DSLE verbally quizzes the engineer about the territory, etc.
3. Does engineer skill monitoring and operational monitoring, which are conducted in a simulator, carry the same consequences for failure as skill and operational monitoring done on board a train?
Answer: “Yes” for a skills performance test (check ride) and “No” for an operating rule efficiency test (dark signal, banner, etc.). Final skills tests for student engineers are often conducted on simulators. If the student fails the test(s), the student cannot be certified as an engineer. An operating rule efficiency test failure on a simulator, that would normally result in a decertification in the field, is not treated as a decertifiable event. While simulators provide a subjective means of determining an engineer’s train handling skills, the simulators are not ideal where vision is critical. Colors and depth perception are difficult to determine.
4. Also, does failure to comply with a crossing protection malfunction train order bulletin that states “stop and protect before occupying crossing” constitute a de-certifiable event?
Answer: Yes. A “stop & protect” order requires a crew to fulfill certain conditions before their train can occupy the track on the crossing, i.e., either flag the crossing or determine that the crossing is flagged by properly equipped flaggers. If these conditions are not met, the train cannot occupy the crossing. If it does, the train is occupying a segment of main track without authority or permission, which is a decertifiable event for the engineer who is operating the train. Another example would be to open up in 251 (ABS) territory and occupy the main track without waiting the required five (5) minutes. This would also be a decertifiable event because the crew did not fulfill all the required conditions before occupying that segment of main track.
You can also find information about qualification on FRA’s website. Go Click on Safety, then Operating Practices, then Engineer Certification, then click on Technical Bulletin 2000-01and print it.
Thanks,
Melvin Smith
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