Rear-End Markers Part 221

Subparts A & B – General & Marking Devices

Module 13

Module 13

*

Module 13

Module 13

*

Module Objectives
        - Apply FRA Safety Standards
        - Recall the required hours of operation
        - Be Aware of the association with yard limits

Module 13

Module 13

*

Subparts A & B - Overview

	Subpart A - General:
        - 221.1 - Scope
        - 221.3 - Application
        - 221.5 - Definitions 
        - 221.7 - Civil penalty
        - 221.9 - Waivers
        - 221.11 - State regulation 

	Subpart B – Marking Device:
        - 221.13 - Marking device display 
        - 221.14 - Marking devices
        - 221.15 - Marking device inspection
        - 221.16 - Inspection procedure 
        - 221.17 - Movement of defective equipment

Module 13

Module 13

*

Inspection Activities

	MP&E Inspectors have the primary responsibility for enforcement of Part 221.  

	However, this does not preclude OP Inspectors from reporting deficiencies and filing violations for noncompliance with Part 221 when discovered while conducting work in the OP discipline. 

Module 13

Module 13

*

Scope
        - This part prescribes minimum requirements governing highly visible marking devices for the trailing end of the rear car of all passenger, commuter and freight trains. 
        - So long as these minimum requirements are met, railroads may adopt additional or more stringent requirements for rear end marking devices. 

Module 13

Module 13

*

Applicability 

	The regulations apply to passenger, commuter and freight trains when operated on a standard gage main track which is part of the general railroad system of transportation. 

Module 13

Module 13

*

Exemptions

	The regulations do not apply to:
        - A railroad that operates only trains consisting of historical or antiquated equipment for excursion, educational, or recreational purposes. 
        - A train that operates only on track inside an installation which is not part of the general railroad system of transportation.
        - Rapid transit operations in an urban area that are not connected with the general railroad system of transportation. 
        - A railroad that operates only one train at any given time. 

Module 13

Module 13

*

History

Like Blue Signal, this is another regulation that FRA was required to write by Congress.  While there were some who thought lighted markers on trains enhanced safety, there were just as many who didn’t think so.  

Regardless of those differing views, the regulation came to pass because rail labor believed the requirement would save cabooses, thus jobs, and successfully petitioned Congress to require FRA to write the regulation.

This turned out to be an incorrect assumption, because we all know that technological advances still eliminated cabooses, with the corresponding reduction in jobs.

Module 13

Module 13

*

Application

When this regulation was first published, there was substantial opportunity for inspectors to ensure compliance, and there was a lot of non-compliance.  

Now, non-compliance is rare, and inspecting the devices has become somewhat frustrating.  That doesn’t mean you shouldn’t perform the inspections, but you probably won’t be personally satisfied when you do.  Why?

Module 13

Module 13

*

Application

Because:
        -  Rear end markers have migrated technologically into two-way EOT devices, and both FRA and the railroad industry consider that to be a good thing.
        -  The major loophole for yard movements makes the entire thing aggravating.  What is a yard movement?  FRA says it’s a yard train operating entirely within yard limits.  Let’s discuss it.

Module 13

Module 13

*

Application

We’re not going to spend much time on this, so let’s talk quickly about how you perform an inspection.  

Since the requirements are “one hour before sunset to one hour after sunrise”, those are the only times you could find non-compliance.  

What do you do if you perform an inspection two hours before sunset, and the train is getting ready to depart on an eight hour trip?

Module 13

Module 13

*

Application

If you’ve already tried, without success, to get the marking device repaired or replaced, then you better get ready to “chase the train”.  Go down the road a ways, wait until the required hours, observe the train pass without a lighted marker, and file a violation.  

What do you do if a road train doesn’t have an operative marker, but it’s going to operate for the first 30 miles “within yard limits”?

Module 13

Module 13

*

Application

It depends on the time of day.
        -  If the train operates on the main track outside of the required hours, it’s a non-issue unless you’re prepared to chase the train.
        -  If it operates on the main track during the required hours, the railroad is in violation as soon as the train clears the yard.  The exclusion for yard movements doesn’t apply for trains that are going to operate both inside and outside yard limits.

Module 13

Module 13

*

Application

One final rub.
        -  If a road train with an inoperative marker reaches the limits of a terminal (as defined by yard limits), and the terminal has the capability to make the repairs specified in Part 221, guess what?
        -  The railroad has to stop the train and make the repairs as soon as the train reaches the “terminal limits”.  Ask yourself:  How much time am I going to devote to this, given the other safety issues I have in my district?

Module 13

Module 13

*

Application

Bear this in mind:
        -  MP&E Inspectors do relatively comprehensive inspections of End of Train Devices, as specified in Part 232.  When they’re doing those inspections, they also determine whether or not the marking device is functioning.  
        -  Since both the EOT and marker share a power source, it’s very rare to see one function and the other not.
        -  The MP&E people aren’t going to get excited about the yard limits issue.  Are you?  Maybe if there’s a complaint?

Module 13

Module 13

*

Learning Objectives Review

	Let’s review the learning objectives that were stated at the beginning of this module:
        - Apply FRA Safety Standards.
        - Recall the required hours of operation.
        - Be Aware of the association with yard limits.

Module 13

Module 13

*

End of Module

Module 13