Brake System Safety Standards for Freight – Part 232

Subpart B – Movement of Defective Equipment

Subpart C – Brake Tests

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Module Objectives
        - Apply FRA Safety Standards
        - Recognize deviations from the standards

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

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QMI vs. QP
        - For the purposes of Part 232, a Qualified Mechanical 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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	Except as provided in §232.209, a Class I brake test required on each car or solid block of cars added to train at the location added unless:
        - Car or solid block added are comprised of cars from one train and previously received a Class I brake test and have remained continuously and consecutively coupled with the train line remaining connected, except for the setting out of defective equipment since being removed from its previous train, and have not been off air for more than four hours; or
        - The solid block of cars is comprised of cars from one train, but were separated into multiple blocks due to space or track constraints.  Under this scenario cars must have previously received a Class I brake test, have not been off air for more than four hours, have remained continuously and consecutively coupled with the train line remaining connected, except for the setting out of defective equipment, and added to the train in the same relative order as when removed from the previous train.

Class I Brake Test – Adding cars

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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 Mechanical  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 and one 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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Movement of defective equipment§232.15

	Permits for the conditional movement of defective locomotive(s) or car(s) with one or more air brake related defects, except from locations where Class I brake tests are required to be performed on the entire train.

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Movement of defective equipmentConditions for movement

The equipment is properly equipped to begin with.

The equipment becomes defective while it is being used by the railroad on its line or becomes defective on a connecting railroad and properly accepted in interchange for repairs in accordance with item 7 on the next slide.

The railroad has knowledge of the defect prior to moving it for repairs.

The movement of the defective equipment for repairs is from the location where the equipment is first discovered defective by the railroad.

The equipment cannot be repaired at the location where the railroad first discovers it to be defective.

The movement of the equipment is necessary to make repairs to the defective condition.

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Equipment = Car or locomotive

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Movement of defective equipmentConditions for movement – Continued

The location to which the equipment is being taken for repair is the nearest available location where necessary repairs can be performed on the line of the railroad where the equipment was first found to be defective or is the nearest available location where necessary repairs can be performed on the line of a connecting railroad if:

The connecting railroad elects to accept the defective car or locomotive for such repair; and

The nearest available location where necessary repairs can be performed on the line of the connecting railroad is no farther than the nearest available location where necessary repairs can be performed on the line of the railroad where the car or locomotive was found defective.

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Movement of defective equipmentConditions for movement – Continued

The movement of the defective car or locomotive for repairs is not by a train required to receive a Class I brake test.

The movement of the defective car or locomotive for repairs is not in a train in which less than 85 percent of the cars have operative and effective brakes.

The defective car or locomotive is tagged, or information is recorded, as required.

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Movement of defective equipmentDeterminations for movement

	A qualified person* shall determine:

That it is safe to move the defective equipment, and

The maximum safe speed and other restrictions necessary for safely conducting the movement.

*	May be qualified mechanical inspector as well

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Movement of defective equipmentNotification to crew
        - The person in charge of the train in which the defective equipment is to be moved shall be notified in writing and inform all other crew members of the presence of the defective equipment and the maximum speed and other restrictions imposed. 
        - A copy of the tag or card described in the following slides will meet the notification of crew requirements.

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Special Notice movement restrictions may apply. 

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Movement of defective equipmentTagging
        - At the location where the defect is first discovered, a tag or card shall be placed on both sides of the defective equipment, except when a locomotive, a card or tag can be placed in the cab.
        - Automated reporting if approved by FRA is also acceptable.

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Movement of defective equipmentTagging - Information Required 

	The tag, card or automated (electronic) tracking system shall contain the following:

The reporting mark and car or locomotive number.

The name of the inspecting railroad.

The name and job title of the inspector.

The inspection location and date.

The nature of each defect.

A description of any movement restrictions.

The destination where the equipment will be repaired; and

The signature, or electronic identification, of the person reporting the defective condition.

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Movement of defective equipmentTagging – Retention, Removal & Documentation
        - An electronic or written record or a copy of each tag or card attached to or removed from a car or locomotive shall be retained for 90 days and, upon request, shall be made available within 15 calendar days for inspection by FRA.
        - Each tag or card removed from a car or locomotive shall contain the date, location, reason for its removal, and the signature of the person who removed it from the piece of equipment.

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Movement of defective equipmentAutomated Tracking System (ATS)
        - An FRA approved ATS shall contain the elements previously discussed and shall be capable of being reviewed and monitored by FRA at any time to ensure the integrity of the system. 
        - FRA's Associate Administrator for Safety may prohibit or revoke a railroad's authority to use ATS in lieu of tagging if FRA finds that ATS is not properly secure, is inaccessible to FRA or a railroad's employees, or fails to adequately track and monitor the movement of defective equipment. 

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Bullet two: FRA will record such a determination in writing, include a statement of the basis for such action, and provide a copy of the document to the railroad.

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Movement of defective equipmentPurging or unloading Haz-mat

	If a defective car is loaded with a hazardous material or contains residue of a hazardous material, the car may not be placed for unloading or purging unless unloading or purging is consistent with determinations made and restrictions imposed by the qualified person and the unloading or purging is necessary for the safe repair of the car.

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Movement of defective equipmentComputation of % operative brakes

	Calculating the percentage of operative brakes shall be determined by dividing the number of control valves that are cut-in by the total number of control valves in the train. A control valve shall not be considered cut-in if the brakes controlled by that valve are inoperative. Both cars and locomotives shall be considered when making this calculation.

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Movement of defective equipmentOther brake related defects

	Do not consider the following when calculating percentage of operative brakes:

Inoperative secondary brake systems.

Inoperative hand or parking brakes.

PT in excess of Class I limits but not in excess of limits contained on stencil/badge plate.

Overdue Single Car Test-SCT.

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Movement of defective equipmentTrain placement – Equipment w/ Inop Brakes
        - Never at the rear of the train.
        - Never more than two adjoining.
        - Multi-unit articulated car with more than two control valves c/o if the brakes controlled by the valves are inoperative.

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Movement for Repair Discussion

Refer to matrices

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End of Module 3

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