BLUE SIGNAL PROTECTION OF WORKERSPart 218 – Subpart B(Including Utility Employees)

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Module Objectives
        - Recall the definitions necessary to apply blue signal regulations
        - Explain the scope of the blue signal regulations
        - Apply the utility employee regulations
        - Define blue signal display 
        - Illustrate the blue signal protection requirements for workers under all conditions specified in 218.25 through 218.30
        - Influence compliance with the requirements in his/her district

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Influencing Compliance

The blue signal regulations are one of the most notable successes in railroad safety.  Prior to their implementation, there were between 20 and 25 employee fatalities annually resulting from non-compliance with railroad Operating Rule # 26, which covered blue signal protection.  

Since implementation, we quickly reduced this to zero.  That came through vigorous enforcement by inspectors, including zero tolerance for non-compliance.  The lesson is:  You should never tolerate non-compliance.  

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We’re going to spend a fair amount of time on the blue signal regulations, because it’s critical that inspectors thoroughly understand them.  

It’s also critical that we achieve uniform compliance throughout the industry.  If you know of differences in opinion within your region, or between the MP&E and OP disciplines, we all have an obligation to resolve them.  

Railroads are known for “shopping around” for an answer when they know of internal disagreements.  We can’t afford to let them do that.

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Railroad Operating Rule

In order to ensure that railroad employees are properly trained and tested, FRA cross-referenced Part 218 with Part 217.  

This means railroads must have a railroad operating rule on “blue signal protection”, and the rule is subject to all of the provisions of Part 217.  Reference: 218.11

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Blue Signal Requirements

	You can’t correctly apply the blue signal regulations unless you have a thorough understanding of the definitions, the scope, the meaning of the term “blue signal display”, and particularly what we’ll term “key definitions”. 

	We’re going to introduce you to the scope and the term “blue signal display” now, but we’ll get back to it again after we cover the definitions. 

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Scope 

For regulatory purposes, the scope is defined as an area in which something acts or operates or has power or control.  

Inspectors should always be familiar with the scope of the regulations they enforce.

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Scope 

The scope of the blue signal regulations is to provide protection for railroad employees engaged in the:
        -  Inspection, testing, repair, and servicing of rolling equipment, while 
        -  On, under, or between such equipment and subjects them to the danger of personal injury posed by any movement of such equipment.

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Blue Signal Display

	Blue signals displayed in accordance with §§218.25, 27, or 29, signify that workers are on, under, or between railroad rolling equipment.  When so displayed:
        - The equipment may not be coupled to.
        - The equipment may not be moved (see exceptions in §218.29).
        - Other rolling equipment may not be placed on the same track so as to reduce or block the view (see exceptions in §218.29).
        - Rolling equipment may not pass a displayed blue signal.

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Key Definitions
        - Blue Signal – a clearly distinguishable blue flag or blue light by day, and a blue light by night.  When attached to the controls of a locomotive...
        - Car shop repair track area means one or more tracks within an area in which the testing, repair, etc., is under the exclusive control of mechanical department personnel.
        - Controlling locomotive means a locomotive arranged as having the only controls over all functions for one or more locomotives.  You have to be careful with this one.
        - Effective locking device means it’s vandal and tamper resistant, and capable of being locked and unlocked only by the particular group of employees being protected.

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Key Definitions
        - Locomotive servicing track area has the same meaning as car shop area.
        - Rolling equipment includes locomotives and cars, whether or not coupled to make a train.
        - Switch providing access means a switch which if traversed by rolling equipment could permit that rolling equipment to couple to equipment being protected.
        - Worker means any railroad employee assigned to inspect test, repair, or service rolling equipment and components.  There are several exclusions, as you’ll see.

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 Worker

Any railroad employee who is assigned to inspect, test, repair, or service railroad rolling equipment, or their components, including brake systems.  This excludes a member of a train crew working on their own train.

Note: The rule does not include contractors, non-railroad employees loading auto racks, or special agents checking car lading.  FRA is sponsoring an RSAC Working Group to deal with the contractor issue, but, to date, there’s been no consensus reached with industry.  

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Worker – Exceptions
        -  There are exceptions for servicing, when supplying locomotives and passenger equipment with certain commodities.
        -  Testing also carries exceptions, and you have to learn them before you can properly apply the rule.  (See the definitions, and §221.16.)
        -  Utility employees are also special cases.  You should apply this separately from the requirements of §§218.25, 27, and 29. 

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 Worker – Train Crew Exception

Members of train and yard crews are excluded from blue signal protection when assigned certain work on equipment that is part of the train or yard movement they have been called to operate (or have been assigned to as “utility employees”).  The following slides detail the exclusions.

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 Worker – Train Crew Exceptions

The Train and Engine crew exclusion applies only to: 
        - Setting or releasing handbrakes.
        - Coupling or uncoupling air hoses.
        - Preparing rail car couplers for coupling.
        - Setting blocks or wheel chains.
        - Conducting air brake tests.
        - Inspecting, testing, installing, removing or replacing a rear marker or EOT.
        - Conducting daily visual inspections of the locomotive consist.

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 Worker – Utility Employee Exception

FRA listed the six functions a utility employee could perform within the exclusion.  They match the first six on the previous slide.
        -  This list was intended to be inclusive of all jobs traditionally performed by T & E crews.
        -  AAR petitioned FRA to expand the list, but FRA declined to do so.

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 Worker 

Train & yard crews are not excluded from blue signal protection when:
        -  Repairing a rear marker or EOT 
        -  Changing a battery is considered a repair
        -  Changing a knuckle or drawbar (could use emergency provision)

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 Worker
        -  Hostlers & helpers are excluded, outside of a locomotive servicing area, if hostler is at controls of locomotive (adding locomotives to a train)
        -  Train/yard crews are protected from other trains by rules requiring an understanding of movements to be made between crews working on the same track

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 Worker

Hostler and helper may engage in sanding or refueling activities in a locomotive servicing track area without a blue signal displayed on the controlling locomotive as long as:
        -  Visual contact is maintained between these two employees, and
        -  The area is properly protected by blue signals.

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 FRA Inspectors

The blue signal regulation is NOT applicable to FRA Inspectors, but inspectors must ensure that equipment will not be subject to movement.  

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Scope - Revisited

Protection of railroad employees engaged in the:
        -  Inspection, testing, repair, and servicing of rolling equipment, while 
        -  On, under, or between such equipment and subjects them to the danger of personal injury posed by any movement of such equipment.

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Blue Signal Display - Revisited

	Blue signals displayed in accordance with §§218.25, 27, or 29, signify that workers are on, under, or between railroad rolling equipment.  When so displayed:
        - The equipment may not be coupled to.
        - The equipment may not be moved (see exceptions in §218.29).
        - Other rolling equipment may not be placed on the same track so as to reduce or block the view (see exceptions in §218.29).
        - Rolling equipment may not pass a displayed blue signal.

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Types of Protection
        - Main Track (§218.25) – has it’s own emergency provision.
        - Other Than Main (§218.27) – includes switches & blue signals, alternate protection (derails), remotely controlled switches (references §218.30), special requirements for crossover switches, and has it’s own emergency provision.

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Types of Protection
        - Alternate methods in car shops and locomotive servicing areas (§218.29) – Tricky, requires detailed understanding of the regulations.  Essentially, FRA gave railroads the ability to use managerial controls in lieu of the absolute protection afforded by the protection requirements of §218.27. 
        - Remotely Controlled Switches (§218.30) – Detailed requirements for remote locking devices, recording the information, and recordkeeping requirements.  This can get tricky because you’ll find this method used for car and locomotive facilities as well as on other than main tracks.

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Traditional Blue Signal (§§218.25 to 30)

Blue signal inspections were complicated enough before we added the conditions for utility employees.  We’re going to focus on what we’d call “traditional blue signal protection” first, so that the issue doesn’t get clouded.

This includes protection on a main track, other than a main track, shop areas, and remotely controlled protection. 

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What is Blue Signal Display?
        - A Clearly distinguishable blue flag or blue light by day & a blue light at night.  If it’s not clearly distinguishable to you, then it doesn’t meet the requirements.
        - When attached to the operating controls of a locomotive, it need NOT be lighted if the inside of the cab area is sufficiently lighted so as to make the blue signal clearly distinguishable
        - Visible to employee “seated” at controls of a locomotive.

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When Blue Signals are Displayed

The equipment may not be coupled to.

Rolling equipment may not pass a displayed blue signal.

The equipment may not be moved.

Other equipment may not reduce or block the view of a blue signal.

	There is an exception for items 3 and 4 in car shops or locomotive servicing areas.

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Removal of Blue Signal Protection

	Protection may only be removed by the same craft or group that displayed them.  This craft or group must be:

Assigned to work together under a common authority.

In communication with each other.

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Workers Do Not Require Blue Signal Protection When ...
        - Inspecting along-side equipment
        - Bleeding air brake system on cars
        - Oiling journal boxes
        - Interior cleaning not requiring ladder
        - Sweeping out locomotives
        - Fueling
        - Washing exterior of equipment
        - Evacuating and recharging soil holding tanks
        - Derailment situations
        - Mechanized track maintenance operations
        - Occupied camp cars

Why not?  

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Blue Signals - Industries
        - The use of blue signals and derails by industries comes under the hazmat and OSHA regulations, and is not part of FRA’s blue signal regulation.
        - However, railroad employees must respect these signals and may not remove them.

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Main Track Protection

	BLUE SIGNAL:
        - Displayed at each end of the rolling equipment, and
        - Attached to the controlling locomotive.

	Question: What’s the risk if railroad employees place portable derails on a main track, and what should you do if you see this?

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Protection on Other Than Main Track
        - Blue signal displayed at or near each manually operated switch providing access to that track;
        - Each switch lined against movement and locked with an effective locking device; and
        - Blue signal attached to controlling locomotive.

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Effective Locking Device

	To meet the definition of effective, a locking device must be:
        - Vandal resistant.
        - Tamper resistant.
        - Capable of being locked & unlocked only by the class, craft or group of employees for whom the protection is being provided.

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Effective Locking Device

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Effective Locking Device

	Train crews could use a standard switch lock if performing duties requiring blue signal protection.

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Protection on Other Than Main Track
        - Blue signal must be displayed no farther into the track than the fouling point.
        - Rolling equipment may enter or depart the protected track only after all work activity has ceased, and the workers have been notified to stand clear, and blue signal protection has been removed from the switch through which the equipment will move.

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Other Than Main Track(Crossover Switches)
        - Both switches of each crossover must be lined against movement through the crossover toward that rolling equipment.
        - The switch of each crossover that provides access to the rolling equipment must have a blue signal displayed and be lined against movement & locked with an effective locking device (for manual switches).

	This seems simple enough, but it can get tricky.  When you evaluate crossover switches, be careful.

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Other Than Main Track(Alternate Protection)
        - Derail will fulfill requirements of a manual switch when positioned no less than 150 feet from the end of the equipment;
        - Derail must be locked in a derailing position; and
        - Blue signal must be displayed at each derail.

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Other Than Main Track(Remotely Controlled Switches)
        - Person in charge of workers notifies operator.
        - Operator lines against movement & applies effective locking device.
        - Operator advises protection has been provided.
        - Effective locking device may be a plug or key.
        - A written tag that does not prevent a lever or button from being manipulated would NOT comply.
        - Operator maintains for 15 days a written record of each notification.

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Emergency Provision(Main Track)
        - When emergency repair work is to be done on, under, or between a locomotive or one or more cars coupled to a locomotive, and blue signals are not available.
        - The engineer must be notified and effective measures must be taken to protect the workers making the repairs.

	Note:  We are strict on this.  In many cases, we would say that if blue signals are available they must be used.

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Emergency Provision(Other Than Main Track)
        - When emergency repair work is to be done on, under, or between a locomotive or one or more cars coupled to a locomotive, and blue signals are not available.
        - The engineer must be notified and effective measures must be taken to protect the workers making the repairs.

	Same thing: We are strict on this.  In many cases, we would say that if blue signals are available they must be used.

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Locomotive and Car Shop Areas

	When the blue signal regulations were originally implemented about 1976, it was quickly ascertained that there were problems associated with shop areas.  It was virtually impossible for car and locomotive shops to comply and perform their mission.  

	FRA issued a new rule soon afterward, and we essentially “gave up” absolute protection for a combination of good protection and “managerial control” within these areas.  

	With this in mind, let’s review the requirements for shops.

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Locomotive Servicing Track Area

	One or more tracks within an area in which the testing, servicing, repair, inspection, or rebuilding of locomotives is under the exclusive control of mechanical department personnel.

	This can be tricky sometimes, particularly when the railroad employs “inside/outside” hostlers.

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Locomotive ServicingTrack Area
        - Blue signal at or near each switch providing entrance to or departure from the area. 
        - Area switches lined away & locked.
        - Blue signal attached to controlling locomotives (those being worked on).

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Locomotive ServicingTrack Area
        - If speed in area is 5 mph or less, a locked derail (with blue signal) may be used instead of switch if at least 50 ft. from equipment. 
        - A locomotive may be moved into the area after the blue signal has been removed from the entrance switch, but must stop short of coupling.

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Locomotive ServicingTrack Area
        - A locomotive may be repositioned after removing its blue signal and workers on the affected track have been notified, if operated by authorized employee under direction of person in charge of workers.

	What about inside/outside hostlers?

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Controlling Locomotive
        - Locomotive arranged as having the only controls over all electrical, mechanical and pneumatic functions for one or more locomotives, including controls transmitted by radio signals if so equipped.
        - It does NOT include two or more locomotives coupled in multiple which can be moved from more than one set of locomotive controls.

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Non-Controlling Locomotive

	Independent brake valve - MU control valve is in the trail position, the automatic brake valve is in the handle off position, and the valve cut-out.

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Car Shop Repair Track Area

	One or more tracks within an area in which the testing, servicing, repair, inspection, or rebuilding of railroad rolling equipment is under the exclusive control of mechanical department personnel.

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Car Shop Repair Track Area

1) Blue signal at or near each switch  providing entrance to or departure from the area. 

2) Area switches lined away & locked.

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Car Shop Repair Track Area

3) If speed in area is 5 mph or less, a locked derail (with blue signal) may be used instead of switch if positioned at least 50 ft. from equipment.

4) A car mover may be used to reposition rolling equipment after workers on the affected track have been notified, but work on the track must cease until the movements have been completed.

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Derails Used in Lieu of Switches

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Remotely Controlled Switches/Derails in Shop Areas

	There is no requirement for a written record if the person controlling switches/derails is of the same craft, and an effective locking device is established.

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Remote Control Panel in Shops 

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Types of Protection
        - Utility Employee (§218.22) – Train service type duties for employees assigned to more than one crew during a duty tour.  Difficult to ensure compliance because some of the criteria aren’t absolute (hours of service, random drug testing pool).

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Utility Employees

	A railroad employee assigned to and functioning as a temporary member of a train or yard crew, whose primary function is to assist the train or yard crew in the assembly, disassembly or classification of rail cars, or operation of trains, and is subject to the conditions in §218.22.

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Utility Employees

	Subject to:
        - Hours of service law. 
        - Hours of service recordkeeping (Part 228).
        - Program of instruction (§217.11).
        - Efficiency testing (§217.9).
        - Alcohol and drug testing (Part 219).

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Utility Employees(Train or Yard Crew)

	One or more railroad employees:
        - Assigned a controlling locomotive (under charge & control of one crewmember).
        - Called to perform covered service (T&E).
        - Involved with train or yard movement they are to work with (operating crew).
        - Reporting & working together as a unit.

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Utility Employees
        - Shall perform service as a member of only one train or yard crew at any given time.
        - Service with more than one crew may be sequential, but not concurrent.

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Utility Employees(Conditions)

	Train or yard crew must be assigned a controlling locomotive that is under the actual control of the assigned locomotive engineer of that crew.

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Utility Employees(Conditions)
        - The locomotive engineer shall be in the cab of the controlling locomotive or, while the locomotive is stationary, be replaced in the cab by another member of the same crew.
        - The locomotive does NOT have to be coupled to the equipment, but has to be in the vicinity.

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Utility Employees(Conditions)
        - The utility employee must establish communication with the crew by contacting the designated crew member on arriving at the train and before commencing any duties with the crew.
        - The railroad operating rules must define a specific designated crew member as a point of contact.

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Utility Employees(Conditions)
        - Before commencing duties, DCM provides notice & identity of UE.
        - Once crewmembers acknowledge this notice, the DCM advises UE he/she is authorized to work as part of crew.
        - Communication must be maintained (each member understands duties).

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UE is performing one or more of the following functions:

Set or release hand brakes

Couple or uncouple air hoses & other  connections

Prepare cars for coupling

Set wheel blocks or wheel chains

Conduct air brake tests (including cutting air brake components in or out & positioning retaining valves)

Inspect, test, install, remove or replace a rear end marking device or EOT

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Utility Employees

	These six functions are also limited to train and yard crews unless blue signal protection is provided.  There’s a seventh function for crew members inspecting their assigned locomotives.

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When UE has ceased all work in connection with the train:
        - UE notifies DCM.
        - DCM provides notice to each crew member that UE is being released.
        - Each crew member acknowledges the notice.
        - DCM notifies UE he is released from the train or yard crew.

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Communications Between UE and DCM
        - Direct verbal contact,
        - Radio (per Part 220), or
        - Oral telecommunication of equivalent integrity.

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Utility Employees
        - No more than three utility employees may be attached to one train or yard crew at any given time.
        - Any railroad employee who is NOT assigned to a train or yard crew, or authorized to work with a crew under the five conditions, is a worker requiring blue signal protection.

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Learning Objectives

	Let’s review the learning objectives that were stated at the beginning of this module:
        - Recall the definitions necessary to apply blue signal regulations
        - Explain the scope of the blue signal regulations (218.21)
        - Apply the utility employee regulations (218.22)
        - Define blue signal display (218.23)
        - Illustrate the blue signal protection requirements for workers under all conditions specified in 218.25 through 218.30
        - Influence compliance with the requirements in his/her district.

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