Brake System Safety Standards for Freight

Subpart C – Inspection & Testing Module 3

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Module Objectives
        - Differentiate between Qualified Mechanical Inspector and Qualified Person
        - Summarize Class I, IA and II brake test requirements during a role play exercise
        - Summarize Class III, Extended Haul and Transfer train brake test requirements during a role play exercise

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Subpart C
        - Scope – 232.201
        - Training requirements –232.203
        - Class I brake tests - initial terminal inspection – 232.205
        - Class IA brake tests - 1,000-mile inspection – 232.207
        - Class II brake tests - intermediate inspection – 232.209
        - Class III brake tests - trainline continuity inspection –232.211
        - Extended haul trains – 232.213
        - Transfer train brake tests – 232.215
        - Train brake tests conducted using yard air –232.217
        - Double heading and helper service – 232.219

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Training requirementsNew

	Each railroad and contractor shall adopt and comply with a training, qualification, and designation program for its employees that perform brake system inspections, tests, or maintenance (ITM). 

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Training requirementsTraining & testing details

	The training program requires that each task related to ITM be identified along with the necessary level of skills, knowledge and proficiency required by the employee to perform each task.

	The following elements shall be included in the program that relate to all identified tasks:

Classroom and “hands-on” training curriculum to impart relevant information including applicable Federal regulations.

Successfully completion of  training curriculum.

Pass a written or oral exam.

Demonstrate "hands-on" proficiency to the satisfaction of the supervisor or instructor.

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Railroad only need to train and test to those tasks that are performed in connection with day to day railroad operations.  In other words one size does not fit all. 

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Training requirementsExisting employees

	An employee hired and working prior to 6/1/01 will be considered as meeting all or part of the training and testing requirements provided:

The employee receives training and testing on applicable Federal regulations relating to the tasks for which he/she is responsible.

The railroad or contractor determines that training, testing and efficiency testing previously received by the employee meets part or all of the requirements discussed in the previous slide and such training or testing can be documented.

The employee passes an oral, written, or practical, "hands-on" test to ensure the employee possesses the required skills and knowledge meeting the requirements discussed in the previous slide and the test is documented.

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Training requirementsExisting employees continued

	In cases where a railroad or contractor certifies a group of employees as having previously received training and testing and no records of such training are available, the following requirements shall apply:

A certification document containing a brief description of the training provided and the approximate date(s) on which the training was provided shall placed in the employee's training records.

The employee shall be given a diagnostic oral, written or “hands-on” test covering the training previously received at the time he/she receives first periodic refresher training.

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Mention that training on Federal regulations (new PB rule), is required here as well.

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Training requirementsSupervisory oversight

	Supervisors are required to exercise oversight to ensure that all the identified tasks are performed in accordance with the railroad's written procedures and the specific Federal regulatory requirements.

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Training requirementsRefresher training

	Periodic refresher training is required at intervals not to exceed three years and shall contain the following elements;

Classroom.

“Hands-on”.

Testing, oral or written.

	Exception: Employees that have completed their initial training (discussed in the previous slides) prior to 4/1/04, shall not be required to complete their first periodic refresher training until four years after the completion of their initial training, and every three years thereafter. Observation and evaluation of actual performance of duties may be used to meet the "hands-on" portion of this requirement, provided that such testing is documented. 

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Training requirementsAdditional training requirements

Railroads also required to train on new brake systems prior to its introduction to revenue service.

Railroads that are required to equip its trains with a two-way end-of-train telemetry devices, and each contractor that maintains such devices shall adopt and comply with a training program which specifically addresses the testing, operation, and maintenance of two-way end-of-train devices for employees who are responsible for the testing, operation, and maintenance of the devices.

Railroads that operate trains under conditions where the setting of retaining valves are required shall adopt and comply a training program which specifically addresses the proper use of retainers for employees who are responsible for using or setting retainers.

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Training requirementsRecords

	A railroad or contractor shall maintain adequate records to demonstrate the current qualification status of all of its personnel assigned to inspect, test, or maintain a train brake system. 

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Training requirementsRecords - Details

	Records can be maintained electronically or in writing, but shall be furnished to FRA upon request and shall contain the following information:

The name of the employee and dates that each training course was completed.

The content of each training course successfully completed.

The employee's scores on each test taken to demonstrate proficiency.

A description of the employee's "hands-on" performance applying the skills and knowledge the employee needs to possess in order to perform the tasks required by  Part 232 of which the employee will be responsible for performing and the basis for finding that the skills and knowledge were successfully demonstrated.

The tasks required to be performed under this part which the employee is deemed qualified to perform.

Name of the person(s) determining that the employee has successfully completed the training necessary to be considered qualified to perform all applicable tasks.

The date that the employee's status as qualified to perform all applicable tasks expires due to the need for refresher training.

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Training requirementsValidation

	A railroad or contractor shall adopt and comply with a plan to periodically assess the effectiveness of its training program. One method of validation and assessment could be through the use of efficiency tests or periodic review of employee performance.

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QMI vs. QP
        - For the purposes of Part 232, a Qualified Maintenance Inspector (QMI) is the only individual that is permitted to perform Class I brake tests on an Extended Haul trains.  
        - In addition, QMI shall be a person whose primary responsibility includes work generally consistent with the definition previously discussed, i.e., maintenance , repair, troubleshooting, inspection, etc.
        - A Qualified Person (QP), is permitted to perform every brake test under Part 232 except on Extended Haul trains.
        - Both QMI and QP are required to meet “Training requirements” previously discussed.
        - A QMI or QP can make the determinations necessary for moving a car for repair under §232.15.

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Class I brake test – initial terminal inspectionSignificant changes from the former regs. 

	Requires:

Person performing test to be trained in accordance with previous discussion  “Training requirements.”

Another Class I brake test on unit or cycle trains traveling 3,000 miles.

Charging the train at the pressure at which the train will be operated and the pressure at the rear shall be within 15 psi of the pressure at which the train will be operated, but not less than 75 psi at the rear.

An inspection (viewing), of brake components on both sides of train sometime during the brake test.

Brakes to remain applied on all cars until release of the brake is initiated by controlling locomotive. 

A written or electronic record of the Class I brake test to be retained in the cab of the controlling locomotive until train reaches its destination.  Train operator must also note results of release portion of inspection on this record in cases where a roll-by inspection of the release portion of the test is employed.

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Mention about multiple blocks ok if originally from one block, but separated due to limited space

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Class I brake test – initial terminal inspectionSignificant changes - continued

	Permits: 

Adding and removing only a single car or single block of cars.

Adding a previously tested block of cars to a train received at interchange without retest.

The removal of defective cars without retest.

Using ETD (front unit display) to ascertain brake pipe pressure on rear car.

AFM in lieu of traditional leakage test.

Waiting 45 to 60 seconds after cutting-out maintaining feature (if equipped), to determine brake pipe leakage.

Retest of car(s) that fail to apply during test provided brakes apply and hold for a period of not less than three minutes during retest. 

Roll-by inspection during release portion of test provided qualified person doing roll-by inspection communicates results of inspection and train speed does not exceed 10 MPH.

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Class I brake test – initial terminal inspectionSignificant changes - continued

Explicit language requiring retest if train off air for more than four hours.
        - Explicit language requiring 100 percent operative brakes in train.

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Train oper

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Class I brake test – initial terminal inspectionDiscussion

	Refer to matrices

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Class IA brake test – 1,000 mile inspection Significant changes from the former regs. 

	Requires:

Person performing test to be trained in accordance with previous discussion  “Training requirements.”

1,000 mile test and inspection based upon the most restrictive car or block of cars in the train.

Charging the train at the pressure at which the train will be operated and the pressure at the rear shall be within 15 psi of the pressure at which the train will be operated, but not less than 75 psi at the rear.

An inspection (viewing), of brake components on both sides of train sometime during the brake test.

Brakes to remain applied on all cars until release of the brake is initiated by controlling locomotive.

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Class IA brake test – 1,000 mile inspectionSignificant changes - continued

	Permits:

 AFM in lieu of traditional leakage test.

Waiting 45 to 60 seconds after cutting-out maintaining to determine brake pipe leakage.

The retest of car(s) that fail to apply during test provided brakes apply and hold for a period of not less than three minutes during retest.
        - Prohibits railroads from arbitrarily changing 1,000 mile inspection locations without giving FRA 30 days of advanced notice in writing, except in an emergency situation such as a derailments or other unusual circumstances if the railroad provides the Regional Administrator notification and reason of change within 24 hours.  

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Class IA brake test – 1,000 mile inspectionDiscussion

	Refer to matrices

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Class II brake test – intermediate inspection Significant changes from the former regs. 

	Requires:

Person performing test to be trained in accordance with previous discussion  “Training requirements.”

Brakes to remain applied on all cars until release of the brake is initiated by controlling locomotive.

The operator of the train to know that the air brakes function as intended on the remotely controlled locomotive if an electronic or radio communication link between a controlling locomotive and a remotely controlled locomotive attached to the rear end of a train is utilized to determine that brake pipe pressure is being restored.

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Class II brake test – intermediate inspectionSignificant changes - continued

Permits:

AFM in lieu of traditional leakage test.

Waiting 45 to 60 seconds after cutting-out maintaining feature (if equipped), to determine brake pipe leakage.

Retest of car(s) that fail to apply during test provided brakes apply and hold for a period of not less than three minutes during retest. 

Roll-by inspection during release portion of test provided qualified person doing roll-by inspection communicates results of inspection and train speed does not exceed 10 MPH.

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Class II brake test – intermediate inspectionDiscussion

	Refer to matrices

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Class III brake test - trainline continuity inspectionNew

	This test contains elements from the former intermediate brake test (§232.13(c)(1)).

	This test requires:

The person performing test to be trained in accordance with previous discussion  “Training requirements.”

A set and release on the rear car when locomotive(s) or car(s) are removed from the train or when a adding a car or solid block of cars from one previous train that has previously received a Class I brake test and that has not been off air for more than four hours.

Confirmation of restoration of air on rear when brake pipe continuity is interrupted.

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Class III brake test - trainline continuity inspectionDiscussion

	Refer to matrices 

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Extended haul trainsNew

	Requires:

Class I brake test to be performed by Qualified Maintenance Inspector (QMI).

Freight car inspection for Part 215 defects by designated inspector under §215.11.

Train to be free of all FRA defects.

FRA notification, (see matrix for details).

Inbound inspection of train by QMI of set-outs and at locations not exceeding 1,500 miles.

QMI to identify all brake related defects as well as defects under Parts 215 & 231 at inbound inspection. 

A record to be maintained of the inbound inspection as well as any defects on cars associated with extended haul trains for a period of one year.

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Extended haul trainsNew - continued

	Permits:

Designated trains to move up to but not exceeding 1,500 miles between inspections and tests.

No more than one pick-up or set-out en route, (excluding set-out of defective equipment).
        - Prohibits the movement of cars for repair from initial terminal under §215.9.

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Extended haul trainsDiscussion

	Refer to matrices

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Transfer train brake tests Significant changes from the former regs. 

	Requires:

Person performing test to be trained in accordance with previous discussion  “Training requirements.”

Brakes to remain applied on all cars until release of the brake is initiated by controlling locomotive.
        - Permits retest of car(s) that fail to apply during test provided brakes apply and hold for a period of not less than three minutes during retest. 
        - Clarifies issue pertaining to cars picked-up enroute.

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Transfer train brake testsDiscussion

	Refer to matrices

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Train brake tests conducted using yard air Significant changes from the former regs. 
        - Requires:

Railroad to adopt and comply with written procedures to avoid overcharging of train brake systems.

Minimum yard air pressure of 60 psi at the end of the consist or block of cars opposite the yard test device and within 15 psi of the regulator valve setting on yard test device.

Leakage test or air flow test on train once locomotives are attached if yard air pressure is less than 80 psi.

Mechanical and electronic yard air test gauges to be calibrated every 92 days and annually respectively.  

Yard air test gauges to be accurate within + 3 psi.
        - Permits the connection of yard air to the train at any location in the train provided railroad complies with its own written rules to prevent overcharging.

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Double heading and helper service  Significant changes from the former regs. 

	Requires:

Visual observation of brake application (20 psi reduction), when helper locomotive(s) are added to train.

Helper locomotive(s) with inoperative or ineffective brakes to be repaired or removed from the train prior to use.

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Double heading and helper serviceSignificant changes continued

	Locomotive(s) utilizing with Helper Link device technology shall be equipped, designed, and maintained as follows:

Locomotive operator notified by a distinctive alarm during loss of  communication between device and 2-way EOT of more than 25 seconds.

A method to reset the device shall be provided in the cab of the helper locomotive that can be operated from the engineer's usual position during operation of the locomotive. Alternatively, a automatic retest may be employed,  provided the reset occurs within the same time permitted for manual reset.

The device shall be calibrated according to the manufacturer's specifications and procedures every 365 days. Calibration procedures shall include testing radio frequencies and modulation of the device. A legible record of the date and location of the last test or calibration shall be maintained with the device.

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End of Module 3

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