U.S. Department of 

Transportation 

Federal Railroad 

Administration

Emergency Escape Breathing Apparatus 

Office of Research 

and Development 

Washington, DC 20590 

DOT/FRA/ORD-09/11 Final Report

May 2009 
NOTICE 

This document is disseminated under the sponsorship of the Department 

of Transportation in the interest of information exchange. The United 

States Government assumes no liability for its contents or use thereof. 

NOTICE 

The United States Government does not endorse products or 

manufacturers. Trade or manufacturers’ names appear herein solely 

because they are considered essential to the objective of this report. 

 
i 

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1. AGENCY USE ONLY (Leave blank) 2. REPORT DATE 3. REPORT TYPE AND DATES COVERED

May 2009 

4. TITLE AND SUBTITLE 5. FUNDING NUMBERS 

Emergency Escape Breathing Apparatus DTFR53-07-Q-00036 

6. AUTHOR(S)

Paul Chambers (TPI), Doug Kimbel (TPI), Alan Misiaszek (FRA) 

7. PERFORMING ORGANIZATION NAME(S) AND ADDRESS(ES) 8. PERFORMING ORGANIZATION 

Technical Products, Inc. REPORT NUMBER

50 Pratt’s Junction Rd. 

Sterling, MA 01564

9. SPONSORING/MONITORING AGENCY NAME(S) AND ADDRESS(ES) 10. SPONSORING/MONITORING 

 AGENCY REPORT NUMBER U.S. Department of Transportation 

Federal Railroad Administration 

ORD/FRA/DOT-09/11 Office of Research and Development 

Washington, DC 20590

11. SUPPLEMENTARY NOTES 

COTR: 

12a. DISTRIBUTION/AVAILABILITY STATEMENT 12b. DISTRIBUTION CODE

This document is available to the public through the National Technical Information Service, Springfield, VA 22161. 

13. ABSTRACT (Maximum 200 words)

Through sponsorship by the Federal Railroad Administration and in cooperation with the railroad industry and railroad labor 

organizations. Technical Products, Inc. (TPI) has developed information and recommendations relative to the use of emergency 

escape breathing apparatus (EEBA) by train crews who may have exposure to hazardous materials and would pose an inhalation 

hazard in the event of unintentional use. The research included defining the scope of the triggering criteria—the presence on 

trains of hazardous material that would pose an inhalation hazard in the event of unintentional release, the state of EEBA 

technology, the methods by which EEBAs might be provided to crews, the incidence rate of accidents with fatalities and serious 

injuries attributable to the inhalation of released hazardous material, and the economic issues involved with the provision of these 

devices to all train crew members. 

14. SUBJECT TERMS 15. NUMBER OF PAGES

Emergency escape breathing apparatus, hazardous materials, inhalation hazard, inhalation 41 

toxicity, simple asphyxiants, acutely toxic, flammable liquid, employee health and safety, public 16. PRICE CODE

health and safety, chlorine, immediately dangerous to life or health, respirator, self-contained 

breathing apparatus, air-purifying respirator, filtered self-rescuer, powered air-purifying 

respirator, breathing time, rebreather

17. SECURITY CLASSIFICATION 18. SECURITY CLASSIFICATION 19. SECURITY CLASSIFICATION 20. LIMITATION OF ABSTRACT

 OF REPORT OF THIS PAGE OF ABSTRACT

Unclassified Unclassified Unclassified 

NSN 7540-01-280-5500 Standard Form 298 (Rev. 2-89) 

Prescribed by ANSI Std. 239-18 

298-102 
ii 

METRIC/ENGLISH CONVERSION FACTORS 

ENGLISH TO METRIC METRIC TO ENGLISH

LENGTH (APPROXIMATE) LENGTH (APPROXIMATE) 

1 inch (in) = 2.5 centimeters (cm) 1 millimeter (mm) = 0.04 inch (in) 

1 foot (ft) = 30 centimeters (cm) 1 centimeter (cm) = 0.4 inch (in) 

1 yard (yd) = 0.9 meter (m) 1 meter (m) = 3.3 feet (ft) 

1 mile (mi) = 1.6 kilometers (km) 1 meter (m) = 1.1 yards (yd) 

 1 kilometer (km) = 0.6 mile (mi)

AREA (APPROXIMATE) AREA (APPROXIMATE) 

1 square inch (sq in, in2

) = 6.5 square centimeters (cm2) 1 square centimeter (cm2) = 0.16 square inch (sq in, in2) 

1 square foot (sq ft, ft2

) = 0.09 square meter (m2) 1 square meter (m2) = 1.2 square yards (sq yd, yd2) 

1 square yard (sq yd, yd2

) = 0.8 square meter (m2) 1 square kilometer (km2) = 0.4 square mile (sq mi, mi2) 

1 square mile (sq mi, mi2

) = 2.6 square kilometers (km2) 10,000 square meters (m2) = 1 hectare (ha) = 2.5 acres 

1 acre = 0.4 hectare (he) = 4,000 square meters (m2

) 

MASS - WEIGHT (APPROXIMATE) MASS - WEIGHT (APPROXIMATE) 

1 ounce (oz) = 28 grams (gm) 1 gram (gm) = 0.036 ounce (oz) 

1 pound (lb) = 0.45 kilogram (kg) 1 kilogram (kg) = 2.2 pounds (lb) 

1 short ton = 2,000 pounds = 0.9 tonne (t) 1 tonne (t) = 1,000 kilograms (kg) 

(lb) = 1.1 short tons

VOLUME (APPROXIMATE) VOLUME (APPROXIMATE) 

1 teaspoon (tsp) = 5 milliliters (ml) 1 milliliter (ml) = 0.03 fluid ounce (fl oz) 

1 tablespoon (tbsp) = 15 milliliters (ml) 1 liter (l) = 2.1 pints (pt) 

1 fluid ounce (fl oz) = 30 milliliters (ml) 1 liter (l) = 1.06 quarts (qt) 

1 cup (c) = 0.24 liter (l) 1 liter (l) = 0.26 gallon (gal) 

1 pint (pt) = 0.47 liter (l) 

 1 quart (qt) = 0.96 liter (l) 

1 gallon (gal) = 3.8 liters (l) 

1 cubic foot (cu ft, ft3

) = 0.03 cubic meter (m3) 1 cubic meter (m3) = 36 cubic feet (cu ft, ft3) 

1 cubic yard (cu yd, yd3

) = 0.76 cubic meter (m3) 1 cubic meter (m3) = 1.3 cubic yards (cu yd, yd3)

TEMPERATURE (EXACT) TEMPERATURE (EXACT) 

[(x-32)(5/9)] °F = y °C [(9/5) y + 32] °C = x °F

QUICK INCH - CENTIMETER LENGTH CONVERSION

0 1 2 34 5

Inches

Centimeters 0 1 2 6 3 4 5 7 8 9 10 11 12

QUICK FAHRENHEIT - CELSIUS TEMPERATURE CONVERSION

°F -40° -22° -4° 14° 32° 50° 68° 86° 104° 122° 140° 158° 176° 194° 212°

 °C -40° -30° -20° -10° 0° 10° 20° 30° 40° 50° 60° 70° 80° 90° 100°

 For more exact and or other conversion factors, see NIST Miscellaneous Publication 286, Units of Weights and 

Measures. Price $2.50 SD Catalog No. C13 10286 Updated 6/17/98

13
iii 

CONTENTS 

EXECUTIVE SUMMARY .............................................................................................................1 

Summary..............................................................................................................................5 

Introduction......................................................................................................................................6 

Task 1 7 

1.1 

1.2 

Triggering Criteria - General .......................................................................7 

Data and Analysis ........................................................................................8 

1.2.1 HazMat Types, Originations and Routes.........................................8 

1.2.2 Accident Data...................................................................................12 

1.3 

1.4 

Task 2 17 

Triggering Criteria Discussion...................................................................16 

Triggering Criteria Conclusion..................................................................17 

2.1 

2.2 

2.3 

EEBA Technology - General.....................................................................17 

Classes of Respirators................................................................................18 

EEBA Selection for T&E Crew.................................................................19 

2.4 

2.5 

2.6 

Escape SCBA.............................................................................................20 

EEBA Breathing Duration .........................................................................24 

EEBA Conclusions ....................................................................................24 

2.7 EEBA Recommendation............................................................................25 

Task 3 25 

3.1 

3.2 

3.3 

3.4 

3.5 

Task 4 30 

Device Deployment-General .....................................................................25 

EEBA Deployment Survey........................................................................26 

EEBA Survey Results................................................................................27 

EEBA Deployment Discussions ................................................................27 

EEBA Deployment Conclusions................................................................29 

4.1 Accident Rates – General...........................................................................30 

4.2 

4.3 

4.4 

Historical Analysis.....................................................................................30 

Casualty Data.............................................................................................31 

HazMat Incidents.......................................................................................32 

4.5 Accident Data Conclusions........................................................................33 

Task 5 33 

5.1 EEBA Economics – General......................................................................33 

5.2 

5.3 

Life Cycle Costs.........................................................................................34 

Stakeholder’s Positions..............................................................................36 

5.4 Economics Conclusions.............................................................................36 

References..........................................................................................................................37 
iv 

Illustrations 

Figure 1 - Filtering Face Piece with Hood.....................................................................................19 

Figure 2 - Filtering Self-Rescuer with full face mask ...................................................................19 

Figure 3 - Powered Air Purifying Respirator (PAPR)...................................................................19 

Figure 4 - Open Loop Self Contained Breathing Apparatus (OL-SCBA).....................................19 

Figure 5 - Closed Loop Self Contained Breathing Apparatus (CL-SCBA)...................................19 

Figure 6 - 60-min Closed Loop Air Supplying Rebreather Devices .............................................23 

Figure 7 - Open Loop Air Supplying Breathing Devices ..............................................................23 

Tables 

Table 1. Historical Ranking of Aggregated Hazardous Materials Commodities by Originations 

............................................................................................................................................10 

Table 2. Hazardous Material Shipment Characteristics by Mode of Transportation ...................11 

Table 3. HazMat Classifications as a Percent of Total Tank Car Originations 

in the U.S., Canada and Mexico* ......................................................................................11 

Table 4. HazMat Classifications as a Percent of Total Tank Car Originations 

in the U.S., Canada and Mexico* .....................................................................................12 

Table 5. Ten 10-Year Accident/Incident Overview by Railroad...................................................13 

Table 6. Accidents Involving a HazMat Release...........................................................................14 

Table 7. Train Accidents, All U.S. Freight Railroads: 1997-2006 ................................................15 

Table 8. Train Accident Rates, All U.S. Freight Railroads: 1997-2006.......................................16 

Table 9. Non-Passenger T&E Employees - on duty (A) casualties...............................................31 

Table 10. 4.05 - Casualties By State, Railroad or Type................................................................32 

Table 11. Estimated Cost for Deploying EEBA in Various Modes .............................................35 
1 

EXECUTIVE SUMMARY 

On January 6, 2005, a Norfolk Southern Railway Company freight train (train 192), while 

traveling through Graniteville, SC, encountered an improperly lined switch that diverted the train 

from the main line onto an industry track, where it struck an unoccupied, parked train (P22). The 

collision derailed both locomotives and 16 of the 42 freight cars of the train 192, as well as the 

locomotive and 1 of the 2 cars of train P22. Among the derailed cars from train 192 were three 

tank cars containing chlorine, one of which was breached, releasing chlorine gas. The train 

engineer and eight other people died as a result of chlorine gas inhalation. [1,2] 

In its report on the Graniteville accident, the National Transportation Safety Board (NTSB) cited 

an accident that occurred in Macdona, TX, in June 2004, where one of the crew members of the 

train involved in that accident succumbed due to chlorine gas inhalation following a catastrophic 

release of a similar nature. These two fatalities of operating crew members in similar 

circumstances led to a recommendation in Railroad Accident Report NTSB/RAR-05/04 R-05-17

that reads, 

“Determine the most effective methods of providing emergency escape breathing apparatus 

for all crew members on freight trains carrying hazardous materials that would pose an 

inhalation hazard in the event of unintentional release, and then require railroads to provide 

these breathing apparatus to their crew members along with appropriate training.” 

This recommendation led the Federal Railroad Administration (FRA) to commission this study 

and report. 

The NTSB recommendation encompasses a wide range of issues that FRA needed assistance in 

evaluating. Accordingly, this report addresses the following tasks: 

1. Define the scope of the triggering criteria, “freight trains carrying hazardous materials 

that would pose an inhalation hazard in the event of unintentional release.” 

Freight railroads transport a variety of hazardous materials across the country, through rural 

areas and populated cities alike, and it is difficult to predict in advance which hazardous 

materials (HazMat) will be transported, where they will be transported, when they will be 

transported, and what other HazMat may share the same train. This means that, in effect, almost 

any freight train and Train and Engine (T&E) crew could be involved in a HazMat incident if 

that train is involved in an accident. 

On the basis of these factors, as well as analysis of HazMat accident data in the body of this 

report, we suggest that FRA specify as “triggering criteria” the deployment of emergency escape 

breathing apparatus (EEBA) on a train consist that includes one or more HazMat tank car(s) 

whose cargo poses an inhalation, poisonous or oxygen deficiency threat, or cars containing other 

bulk HazMat cargo (i.e., 50-gallon drums) totaling a quantity similar to a tank car. 

 

2. Define the state of EEBA technology to protect crew members from “hazardous 

materials that would pose an inhalation hazard.” 
2 

Because catastrophic railroad HazMat incidents have the potential to release concentrations that 

are immediately dangerous to life or health (IDLH) and/or displace oxygen, only “air-supplying” 

self-contained breathing apparatus (SCBA) equipment should be considered for adequate crew 

protection. Air-purifying respirators like filtered self-rescuers (known as FSR) or, powered airpurifying respirators (known as PAPR) must be ruled out due to the potential presence of IDLH 

HazMat concentrations in the area around the train following a catastrophic accident such as 

those that occurred in Graniteville or Macdona. The FRA EEBA should possess a capacity of 

not less than 30 minutes of breathing time, with a suggestion that devices with 60 minutes be 

considered. 

3. For each device recommended, define the different methods by which the devices 

might be provided to employees by their railroad employers.

Different methods by which EEBAs might be provided to employees were researched. Railroads 

and union representatives provided input on this matter via completion of a targeted 

questionnaire. 

Like other safety equipment, we considered the EEBA could be provided to the crews in a 

number of ways. Factors that influence the decision on how to deploy the device include the 

configuration of the selected EEBA and whether it can, or should be, hand-carried or must be 

mounted on the equipment. Also considered is the configuration of the EEBA and whether it is a 

generic one-size-fits-all or a customized-to-user type with mask size or of a type to accommodate 

facial hair, etc. 

Regarding assignment, we defer to the responses provided from rail industry experts. 

Unanimously, each railroad that responded to the questionnaire preferred that in the event 

EEBAs were mandated, they should be assigned to each T&E employee. The railroads prefer 

the responsibility for care and maintenance of EEBAs be assigned to T&E employees. 

Railroads’ opinions are largely predicated on prior experience with regulated equipment that 

disappears because of loss, pilfering, or damage. Additionally, their logic is that if personally 

assigned, EEBAs will be better cared for. Better care results in lower replacement costs if the 

EEBA can be deployed until its end-of-service life or when mandatory replacement is required. 

In contrast, union responses recommended that supply, maintenance, and inspection be 

accomplished by the railroad carrier. 

4. Quantify the incidence rate of accidents with fatalities and serious injuries attributable 

to the inhalation of released hazardous material. 

Research into triggering criteria revealed dramatic improvements in rail operations’ safety 

performance. Overall accidents and casualty rates have declined significantly from the 1970s 

into the 1980s and again from the 1980s through the 1990s, with the past decade experiencing a 

leveling off of safety performance. 

As shown in a May 2005 presentation by Robert Fronczak, P.E., Assistant VP, Environmental 

and HazMat for the Association of American Railroads (AAR), railroad incidents have been 
3 

reduced significantly over the past two decades [3]. By any other industrial or business sector, 

the statistical improvements realized by the rail industry would be considered outstanding. 

Railroads have exhibited exceptional safety performance in many areas, including: 

• Lower injury rates compared to other major industry groups. 

• Lower injury rates compared to other transportation modes. 

• Lower injury rates compared to most major European railroads. 

• Declines in HazMat incident release rates (down 71 percent since 1980 and 56 

percent since 1990). 

• Declines in HazMat accident rates (down 90 percent since 1980 and 49 percent since 

1990). 

• Declines in accidents with a HazMat release (down 76 percent since 1980 and 17 

percent since 1990).

Furthermore, the U.S. Department of Transportation (DOT) quoted the FRA representatives in a 

2004 overview as saying that accidents declined nearly 70 percent since the late 1970s, and over 

the previous 3 years the Nation has had the lowest number of rail-related deaths and employee 

fatalities on record. Despite more than 2 million movements of HazMat cars, 2003 marked the 

lowest number of train accidents involving a HazMat release in the previous 5 years. 

To the best of our knowledge and research, during the past 20 years, only two incidents of T&E 

crew members killed by inhalation of an acute toxic gas occurred, which resulted from a 

collision and breached tank car. These were the individuals who died as a result of the 

Graniteville and Macdona incidents. The NTSB lists both of these casualties as “killed by 

inhalation.” For some perspective of the relative risk, the casualty rate for these two deaths can 

be expressed in three ways: 

• One Fatality per 367 million train miles (Annual rate based on 10-year period 

average 1997- 2006 statistics found in Table 5). 

• One Fatality per 5.7 million shipments of the Top 125 HazMat (1997-2006) [4]. 

• One Fatality per 1.1 million shipments of chlorine.

This last statistic is based on testimony by former FRA Administrator Joseph Boardman: 

“Considering just chlorine, for example, since 1965 (the earliest data available) there have 

been at least 2.2 million tank car shipments of chlorine–only 788 of which were involved in 

accidents (0.036 percent of all the shipments). Of those accidents, there were 11 instances 

of a catastrophic loss (i.e., a loss of all, or nearly all) of the chlorine lading 0.0005 percent of 

all the shipments). Of the 11 catastrophic losses, four resulted in fatalities (0.00018 percent 

of all the shipments).” [5] 

Of those four accidents, two resulted in fatalities involving crew members, including those in 

Macdona in June 2004, and Graniteville in January 2005. Thus, for chlorine alone, the risk of a 

crew member fatality due to inhalation is one per 1.1 million shipments. 

5. For the recommended devices from Task 2, define the economic issues involved in the 

provision of these devices to all crew members. 
4 

The economics of implementing the EEBA program across the rail industry are subject to the 

regulatory position taken by the FRA in terms of: 

• Technology deployed (e.g., a 60-minute closed loop escape self-rescuer costs $750 

whereas a 60-minute open loop SCBA costs $3,000—a 4-fold increase in cost. 

• Deployment mode (e.g., issuing each T&E member their personal system versus 

equipping the locomotive of a HazMat consist can affect the total number of systems 

deployed by a factor of 2–3. 

• Required recertification/training, etc. (e.g., some EEBAs may require training every 

month while others may require training every 6 months. This can affect cost by a 

factor of 2–3.

We considered the implementation costs associated with EEBAs. Regardless of the basis of 

issue and level of technical sophistication, the EEBA will be a very significant investment by the 

railroads. Also, like all technically sophisticated safety equipment, the EEBA will require 

significant on-going expenditures for maintenance, inspection, repair and replacement. In 

addition, on-going administrative costs exist for crew training and record keeping of the training, 

device issue and return, and device maintenance conducted. Finally, depending on the nature of 

the technology involved—some of the possible devices contain chemicals (i.e., catalysts, 

absorbents)—some disposal costs could be associated with the chemical end of life. 

The numerical estimates for T&E employees and locomotives were derived from a cost/benefit 

analysis supplied by the AAR with adjustments made to scrap figures (i.e., shelf life) and 

training time based on the equipment manufacturer’s recommendations. Cost estimates 

compared the assignment of EEBAs to the locomotive and assignment to T&E employees. For 

locomotive assignment, estimates were based on issuance of three EEBAs per locomotive to 

provide for two T&E employees plus an additional person. The cost estimated compares open 

loop SCBA respirators (using Grade D compressed air) to closed loop SCBA respirators (using 

compressed oxygen). A net present value (NPV) over 15 years was used in the equation for 

equipment, training, maintenance, replacement (due to damage, pilfering, or loss), and tracking 

(for issuance, maintenance, service life, etc.). 

The resultant 15-year NPV estimates are as follows. 

SCBA Type Open Loop Closed Loop 

Assignment Locomotive Employee Locomotive Employee 

Total Capital Cost $79,760,000 $67,200,000 $67,080,000 $83,330,000 (NPV) 

Summary 

The technology exists to provide train crews with effective EEBA to protect themselves in the 

event of a catastrophic HazMat release. Implementation of a regulation to mandate EEBA on 

HazMat train consists has significant economic implications for the operating companies. 

Accident data shows this scenario to be possible, but extremely unlikely. 
5 

The responsibility to make the decision on implementing the NTSB recommendation 

R-05-17 to address this possibility lies with DOT/FRA. 
6 

Introduction 

This report is intended to support the Federal Railroad Administration (FRA) decisionmaking in 

response to a National Transportation Safety Board (NTSB) recommendation for a proposed 

regulation requiring railroads to provide emergency escape breathing apparatus (EEBA) to 

railroad operating employees for use during railroad incidents involving the release of hazardous 

materials. The report does this by compiling factual information and performing technical, risk 

and economic analyses surrounding the proposed regulation. 

The research used a variety of historical and public data sources covering the rail transportation 

of dangerous goods/HazMat, and incident rates, and casualties for both railroad and non-railroad 

industries. Other sources of information reviewed included safety regulations from FRA, the 

U.S. Department of Transportation (DOT) and the National Institute for Occupational Safety and 

Health (NIOSH) as well as recommendations of the National Transportation Safety Board 

(NTSB). Data was also retrieved from non-government entities including the American 

Association of Railroads (AAR), railroads, union representatives, and rail, civilian, and research 

organizations. 

Historical data was analyzed over various periods of time, some as far back as 20 years to 

determine the actual frequency of rail-based HazMat incidents and, more specifically, of train 

crew injuries and fatalities caused by the release of HazMat into the environment (as opposed to 

injury from the mechanics of the crash, derailment, fire, incident). What was uncovered turned 

out to be an incongruous set of circumstances, whereby the two deaths attributable to HazMat 

incidents in the past 20 years occurred during a recent period when safety performance rates 

were most improved. 

The other aspects of the research involved defining the economic and logistical scope of 

deploying EEBAs to train and engine (T&E) crews by considering the following: 

1.The state of EEBA technologies currently available to protect crew members from 

HazMat that would pose an inhalation hazard. 

2.The different methods by which the devices might be provided to T&E employees. 

Ascertaining the different methods by which the devices might be provided would be driven 

by several issues, including current industry practices regarding the placement of other types 

of emergency equipment on locomotives, as well as the need to ensure that all crew 

members are provided the devices. 

3.The economic issues involved in the provision of these devices to all T&E crew members. 

Direct feedback canvassed from rail industry professionals on the implementation of EEBAs was 

used in our analysis. This report is presented on a task-by-task basis as defined in the statement 

of work incorporated into the contract authorizing this effort. The tasks are discussed 

individually (although naturally some cross-referencing occurs) and then the research and 

analyses conducted are concluded with a summary of our findings and recommendations. 
7 

Task 1: Define the scope of the triggering criteria, “freight trains carrying hazardous 

materials that would pose an inhalation hazard in the event of unintentional release.” 

1.1 Triggering Criteria–General 

Freight railroads transport a variety of hazardous materials across the country, through rural 

areas and populated cities alike, and it is difficult to predict in advance which HazMat will be 

transported, where they will be transported, when they will be transported, and what other 

HazMat may share the same train. This means that, in effect, almost any freight train and T&E 

crew could be involved in a HazMat incident if that train is involved in an accident. 

During 2000 to 2005, an average of 1.2 million tank car loads of hazardous materials were 

shipped. Seventy-three percent of these shipments were of the top 25 hazardous commodities 

shipped by rail. Of the top 25 hazardous commodities, 14 have specific known levels and types 

of inhalation toxicity, ranging from simple asphyxiants such as liquefied petroleum gas and 

carbon dioxide, to acutely toxic gases such as ammonia and chlorine. The balance of the 

commodities are identified by such names as FAK (Freight–All Kinds) hazardous material, 

elevated temperature liquid NOS (not otherwise specified), flammable liquid NOS, some of 

which may also pose inhalation hazards. 

The question is: At what point does the transport of these materials justify the mandate to require 

that EEBA be provided to the train crew? 

The criteria that delineate when the requirement for EEBA should be applied will include (but 

not be limited to) the following considerations: 

•At what volume/weight does any specific cargo (e.g., LPG) pose a HazMat threat 

•What effect does the configuration of the train and the relative location of HazMat-carrying 

cars have on the overall scenario? For example, two cars of LPG adjacent to each other may 

be a different hazard level than two cars of LPG separated by 10 “benign” cars. 

•What is the relative hazard level under differing operating conditions of speed, traffic, 

likelihood of proximity to other moving trains, etc. (e.g., shunting in a freight yard versus 

local transit versus long haul)?

The problem is more complicated due to the varying nature of the cargo. For example, should 

the criteria be based on volume/weight by class of freight or be applied at the individual 

substance level? Does a train with (270) 50-gallon drums of a HazMat spread throughout the 

train represent the same risk as a single 13,500-gallon tank car? 

 

The decision to implement a regulation requiring the provision of EEBA equipment involves 

significant capital and operating cost and so must be balanced against the frequency of 

occurrence and incident cost of HazMat release. The real crux of this decision becomes one of 

cost/benefit analysis with “cost” and “benefit” being defined in the broadest senses to include 

capital and operating costs when nothing happens, financial cost when a HazMat release occurs 

resulting in injury or death, employee health and safety, public health and safety, legal liability, 

societal cost and benefit, and more. 
8 

On the basis of these criteria and conditions, FRA wants a recommended set of criteria to be 

applied against the specific train consist and cargo set to generate a go/no-go decision point for 

the mandatory use of EEBA. 

1.2 Data and Analysis 

This task addresses the question of when the crew or train should carry an EEBA from a purely 

technical perspective. The economics of implementing a mandatory EEBA regulation is ignored 

in this analysis but is addressed in Task 5. 

The question of when the crew/train should carry EEBA is a function of the following factors:

• The amount of HazMat being carried, 

• Its toxicity (manner in which it causes harm), 

• Its physical properties (solid, liquid, vapor, gas—which will determine if it will be in 

the atmosphere following release in sufficient quantities to cause harm) 

• The likelihood of a release, and 

• The potential for damage/injury/loss of public life occasioned by the HazMat release 

rendering an unprotected crew ineffective.

In an effort to answer these questions, data was acquired from several rail industry and 

government sources. This data was analyzed with regard to operating logistics of HazMat 

transported by rail as well as incident and casualty figures relative to HazMat tank car 

originations and accidents. 

1.2.1 HazMat Types, Originations and Routes 

A document published by the Centers for Disease Control (CDC) titled, Public Health 

Consequences from Hazardous Substances Acutely Released During Rail Transit [6] released 

January 28, 2005, states the following: 

“Approximately 800,000 shipments of hazardous substances travel daily throughout the 

United States by ground, rail, air, water, and pipeline; approximately 4,300 shipments of 

hazardous materials travel each day by rail, including chemical and petroleum products. 

Although nearly all of these materials safely reach their destinations, many are explosive, 

flammable, toxic, and corrosive and can be extremely dangerous when improperly released. 

These materials frequently are transported over, through, and under areas that are densely 

populated or populated by schools, hospitals, or nursing homes, where the consequences of 

an acute release could result in environmental damage, severe injury, or death.” 

 ... 

“Findings from the HSEES (Hazardous Substances Emergency Events Surveillance) system 

suggest that rail events constitute only 2 percent of total hazardous-substance releases. 

Furthermore, most rail events involved small-scale releases (75 percent of events involved 

<70 gallons). However, large-scale, acute releases during rail transit can occur (10 percent 

of events involved >2,200 gallons) and can cause substantial injury and death, as 
9 

demonstrated by case reports.” 

The 2004 Macdona, TX and 2005 Graniteville, SC accidents released 9,400 and 9,218 gallons of 

liquid chlorine, respectively [1,2]. These are the only two identified large-scale release incidents 

(>2,200 gallons) that resulted in T&E crew killed by inhalation of an acute toxic gas stemming 

from a collision and breached tank car. Of all aggregated HazMat commodity origins over the 

10-year period 1997 through 2006, chlorine has ranked 12th or lower (see Table 1). According 

to the Acting NTSB Chairman Mark Rosenker in a 2005 NTSB Safety Recommendation [7], 

“The Macdona and Graniteville accidents, both of which have occurred since the Minot 

report was issued, resulted in the puncturing of two chlorine tank cars and the death of 12 

people from chlorine inhalation. When a liquefied gas such as chlorine, which is poisonous 

by inhalation, is released, large clouds at lethal concentrations can be generated within 

minutes.” 

This statement has theoretically been proven true per a 2005 document entitled, “Detailed 

Numerical Simulation of Graniteville Train Collision.” [8] 
10 

Table 1. Historical Ranking of Aggregated Hazardous Materials Commodities by Originations 

All Car Types, U.S. and Canada, 1997–2001

Source: Association of American Railroads, Bureau of Explosives 

 Annual Reports of Hazardous Materials Transported by Rail 

RANK 

COMMODITY (DOT PROPER SHIPPING 

NAME) 2006* 2005* 2004 2003 2002 2001 2000 1999 1998 1997 

LIQUIFIED PETROLEUM GASES (LPG) 1 1 2 2 2 2 2 2 2 2 

ALCOHOL/ALCOHOLS, N.O.S. 2 6 6 9 10 11 12 13 15 15 

FAK-HAZMAT 3 2 1 1 1 1 1 1 1 1 

ELEVATED TEMPERATURE LIQUID 4 3 3 3 3 3 4 4 4 4 

SODIUM HYDROXIDE SOLUTION 5 4 4 4 4 4 3 3 3 3 

SULFURIC ACID 6 5 5 6 5 5 6 5 5 5 

DIESEL FUEL 7 8 8 5 6 8 21 18 24 25 

SULFUR, MOLTEN 8 7 7 7 7 6 7 6 6 6 

AMMONIA, ANHYDROUS 9 10 9 8 8 7 8 7 7 7 

GASOLINE 10 11 10 10 9 9 10 10 8 13 

FLAMMABLE LIQUIDS, N.O.S. 11 9 19 23 24 -- -- -- -- -- 

CHLORINE 12 12 11 11 11 10 9 8 9 8 

FUEL OIL (HAZARD CLASS 3) 13 13 14 20 21 12 5 9 11 10 

PHOSPHORIC ACID 14 14 13 13 14 16 14 12 13 14 

ENVIRONMENTALLY HAZARDOUS 

SUBSTANCE, LIQUID, N.O.S. 15 16 15 14 15 13 -- -- -- -- 

VINYL CHLORIDE STABILIZED 16 15 12 12 12 15 11 -- 12 12 

METHANOL 17 17 16 15 13 14 13 11 14 11 

HYDROCHLORIC ACID 18 19 18 16 18 18 15 14 20 19 

CARBON DIOXIDE 19 20 20 17 19 20 19 16 17 18 

ENVIRONMENTALLY HAZARDOUS 

SUBSTANCE, SOLID, N.O.S. 20 18 17 14 15 13 17 -- 22 21 

PROPANE 21 -- -- -- -- -- -- -- -- -- 

STYRENE MONOMER, INHIBITED 22 22 21 19 20 21 18 15 19 16 

BUTANE 23 -- -- -- -- -- -- -- -- -- 

AMMONIUM NITRATE FERTILIZERS 24 21 22 18 17 17 16 17 16 17 

PETROLEUM DISTILLATES, N.O.S. 25 24 25 -- -- -- -- -- -- -- 

SODIUM CHLORATE -- 25 23 21 23 22 20 19 23 22 

PROPYLENE -- 23 24 22 22 23 22 -- -- -- 

BUTADIENES, INHIBITED -- -- -- -- -- -- 24 22 25 23 

* Include U.S., Canada & Mexico 
11 

According to DOT’s 2002 Commodity Flow Survey in Table 2, total HazMat shipments in tons 

have risen by nearly 7 percent from 1997 to 2002. However, the rate of ton–miles has declined 

by 8.3 percent and the average miles per shipment also declined by 17 percent over the same 

period of time. More recent data was not available at the time of this report. 

Table 2. Hazardous Material Shipment Characteristics by Mode of Transportation 

For the United States: 2002 and 1997 

Mode of 

Tons Ton-Miles Average Miles Per Shipment 

2002 1997 

Transportation (thousands (thousands % 2002 1997 % % 

) ) Change (millions) (millions) Change 2002 1997 Change 

Rail 109,369 102,508 6.7 72,087 78,619 -8.3 695 837 -17 

 

Source: United States: 2002, Hazardous Materials, 2002 Economic Census, 

Transportation, 2002 Commodity Flow Survey 

Examination of AAR data for the 5-year period 2002 through 2006 shows 68 percent of HazMat 

tank car origins were of the top 25 hazardous commodities shipped by rail and 90 percent of 

HazMat tank car origins were of the top 125 hazardous commodities shipped by rail (see Tables 

3 and 4). 

Table 3. HazMat Classifications as a Percent of Total Tank Car Originations in the U.S., 

Canada, and Mexico* 

Source: Association of American Railroads, Bureau of Explosives 

 Annual Report of Hazardous Materials Transported by Rail 

 % to Top 25 HazMat Tank Car Origins 

Hazard Class Hazard Title 2002* 2003* 2004* 2005 2006 

2.1 Flammable Gas 23.24% 18.55% 21.03% 20.70% 19.68% 

2.2 Non-Flammable Gas 8.31% 7.61% 8.51% 8.02% 7.58% 

2.3 Poison Gas 4.61% 3.83% 4.42% 4.04% 3.96% 

3 Flammable Liquid 19.52% 18.65% 23.32% 26.05% 29.06% 

CL Combustible Liquid 1.70% 14.80% 2.28% 2.66% 2.86% 

4.1 Flammable Solid 2.92% 2.95% 2.70% 2.41% 2.39% 

5.1 Oxidizing Material 0.00% 0.00% 0.00% 0.00% 0.00% 

6.1 Poisonous Material 1.43% 1.23% 1.43% 1.28% 1.30% 

8 Corrosive 23.65% 20.16% 22.39% 22.64% 21.84% 

9 Miscellaneous 14.63% 12.22% 13.91% 12.21% 11.34% 

Totals 100.00% 100.00% 100.00% 100.00% 100.00% 

% Top 25 HazMat Origins to Total HazMat 

Tank Car Originations: 65% 75% 66% 69% 67% 

* Figures for Mexico not available for 2002–2004 
12 

Table 4. HazMat Classifications as a Percent of Total Tank Car Originations in the U.S., 

Canada, and Mexico* 

Source: Association of American Railroads, Bureau of Explosives 

 Annual Report of Hazardous Materials Transported by Rail 

 % to Top 125 HazMat Tank Car Origins 

Hazard Class Hazard Title 2002* 2003* 2004* 2005 2006 

2.1 Flammable Gas 19.89% 18.86% 18.30% 18.07% 17.92% 

2.2 Non-Flammable Gas 6.13% 6.42% 6.31% 6.01% 5.63% 

2.3 Poison Gas 4.41% 4.22% 4.24% 3.87% 3.74% 

3 Flammable Liquid 25.57% 26.53% 27.33% 28.58% 31.19% 

CL Combustible Liquid 3.64% 3.82% 4.05% 4.14% 3.97% 

4.1 Flammable Solid 2.22% 2.56% 1.97% 1.77% 1.78% 

5.1 Oxidizing Material 0.93% 1.08% 1.06% 1.20% 1.27% 

6.1 Poisonous Material 1.57% 1.73% 1.73% 1.56% 1.50% 

8 Corrosive 22.00% 21.85% 21.73% 21.98% 21.04% 

9 Miscellaneous 13.63% 12.93% 13.28% 12.82% 11.95% 

Totals 100.00% 100.00% 100.00% 100.00% 100.00% 

% Top 125 HazMat Origins to Total 90% 90% 90% HazMat Tank Car Originations: 93% 91% 

* Figures for Mexico not available for 2002–2004 

At the request of the AAR, numerical values for each hazard class in Tables 3 and 4, as well as 

total origins, are classified due to security concerns. 

Consideration was also given to HazMat tank car originations by railroad type. Without 

jeopardizing the AAR’s classified HazMat numbers, we can first consider that over the 5-year 

period 2002 through 2006, Class I railroads comprised 87 percent of all freight car originations 

[9]. The balance of originations was on regional and local lines. When comparing HazMat tank 

car origins globally to the total number of freight car origins, we find that 2.7 percent of HazMat 

tank cars were of the Top 25 origins and 3.4 percent of HazMat tank cars were of the Top 125 

origins. When we look at these percentages for Class I railroads only, we find the 5-year average 

of top 25 HazMat tank car origins to be 3.10 percent of all Class I freight car origins. For the top 

125 HazMat tank car origins, the average is 3.95 percent of all Class I freight car origins. 

1.2.2 Accident Data 

According to FRA data, rail accident rates have decreased significantly over time: 

• The 10-year average from 1978 through 1988 saw the accident rate plunge by 69.9 

percent, a factor of 3 from 14.8 to 4.6 accidents per million train miles. 

• The 10-year average from 1987 through 1996 saw the accident rate decrease to 4.2 

accidents per million train miles. 

• The 10-year average from 1997 to 2006 shown in Table 5 saw the accident rate 

involving all railroads decrease further to 3.9 accidents per million train miles (2,911 

accidents over 734,655,521 mainline miles) of which:
13 

• 1.47 accidents per million train miles occurred on the mainline track (950 

accidents over 648,218,079 mainline miles). 

• 18.35 accidents per million train miles occurred on yard track (1,568 accidents 

over 85,437,442 mainline miles).

Of the 29,110 train accidents involving all classes of railroads, 72 percent were the result of 

derailments and 7 percent were due to collisions. 

Table 5. 10-Year Accident/Incident Overview by Railroad 

ALL RAILROADS—SUMMARY BY CALENDAR YEAR, (January–December ) 

Source: FRA Office of Safety Analysis Web Site, http://safetydata.fra.dot.gov/officeofsafety/ 

Category 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 10-yr. 

avg 

TRAIN 

ACCIDENTS 2,397 2,575 2,768 2,983 3,023 2,738 3,017 3,380 3,261 2,968 2,911 

Train 

accidents per 

million train 

miles 

3.5 3.8 3.9 4.1 4.2 3.8 4.1 4.4 4.1 3.7 3.96 

Train 

accidents on 867 934 858 976 1,025 886 964 1,019 1,003 963 949.5 

main line 

Rate–permillion train 1.5 1.6 1.4 1.5 1.6 1.4 1.5 1.5 1.4 1.3 1.47 

miles 1/ 

Accidents on 

yard track 1,223 1,306 1,531 1,6197 1,569 1,478 1,667 1,921 1,808 1,555 1567.7 

Rate-permillion yard 

switching 

train miles 

14.4 15.6 17.5 18.2 18.3 18.2 20.4 22.9 20.5 17.5 18.35 

Collisions 202 168 205 238 220 192 198 237 273 201 213.4 

Derailments 1,741 1,757 1,961 2,112 2,234 1,989 2,131 2,430 2,301 2,179 2083.5 

Total train 

miles (1,000) 676,716 682,894 712,452 722,876 711,549 728,674 743,330 770,152 788,807 809,099 734,655 

Yard 

switching 84,873 83,692 87,458 88,919 85,747 81,002 81,630 83,934 88,084 89,031 85,437 

miles (1,000) 

Data was further analyzed based on track type and Railroad type to determine any trends in the 

occurrence of HazMat incidents over the 10-year period from 1997 through 2006. The criteria 

used in Table 6 include collisions, derailments and highway-rail accidents that resulted in a 

HazMat release. 
14 

Table 6. Accidents Involving a HazMat Release * 

10-year Total 1997–2006 

Source: Department of Transportation 

All Railroads Class I Railroads 

Track Type Track Type 

Yard Mainline Yard Mainline 

No. of Accidents Involving HazMat Cars Releasing 100 198 88 162 

No. of Cars Carrying HazMat 31,884 32,957 28,369 29,168 

No. of HazMat Cars Damaged 4,747 3,816 4,018 3,151 

No. of HazMat Cars Releasing 130 394 100 323 

*Table 6 demonstrates that accidents involving a HazMat release occur nearly twice as much on mainline track 

versus yard track. The total number of cars carrying HazMat in those accidents is nearly equal yet the number of 

cars damaged is lower on mainline track accidents. Of particular note is that the total number of cars releasing 

HazMat is three times greater on mainline track. Lastly, Class I railroads comprise the majority (84 percent) of 

accidents involving a HazMat release. 

AAR maintains data relative to the transportation of HazMat and sorts the data of released 

HazMat into several categories. One category that is heavily tracked concerns tank car nonaccident releases (NARs). In consideration of this effort to analyze the need for providing 

emergency escape breathing apparatus for all crew members on freight trains carrying HazMat, 

instances of NARs have been excluded due to the relatively low release volumes stemming from 

sources such as plumbing fittings, valves lines, and vents. Instead, data pertaining to train 

accidents involving HazMat is given precedence considering the comparative and potential 

catastrophic effects resulting from damaged or breached tank cars. 

Analyzing the 29,110 accidents between 1997 and 2006, the average number of accidents 

involving HazMat tank cars shown in Table 7 is as follows: 

• 725 or 25 percent, of the total accidents involved a HazMat tank car. 

• Of those 725 accidents involving a HazMat tank car, 359 accidents resulted in one or 

more tank cars being derailed or sustaining damage. 

• Of the 359 accidents with derailed or damaged HazMat tank cars, an average of 33 

accidents resulted in a HazMat release. 

• These 33 accidents resulted in 57 tank cars releasing HazMat. 
15 

Table 7. Train Accidents, All U.S. Freight Railroads: 1997–2006 

Source: FRA Office of Safety Analysis Web Site, http://safetydata.fra.dot.gov/officeofsafety/ 

Year 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 Total Avg. 

Total Accidents (including 

grade crossing ) 2,397 2,575 2,768 2,983 3,023 2,738 3,017 3,380 3,261 2,968 29,110 2,911 

with Hazardous Material 

Cars in the consist: 520 598 690 725 768 714 752 843 839 796 7,245 725 

in which a Hazmat Car was 

Damaged or Derailed: 278 305 356 374 389 385 382 388 359 378 3,594 359 

in which a Hazmat Car 

Released Product: 31 42 42 35 32 31 27 29 36 27 332 33 

Number of cars releasing 

Hazmat: 38 67 76 75 57 56 38 47 49 68 571 57 

It is difficult to derive firm conclusions as to the efficacy of efforts to reduce HazMat incidents 

from the historical values observed over this 10-year period. Table 8 details the incidence rate 

values for each of the data categories in Table 7. The data suggests that as total train accidents 

rise and fall year to year, the accompanying incidence rates (e.g., the number of HazMat cars in 

the consist, number of HazMat cars damaged/derailed, etc.) don’t always follow the same riseand-fall trend. However, 131 million more train miles were traveled in 2006 versus in 1997, yet 

the rate-per-million train miles in which HazMat cars released product remained steady at a rate 

of 0.05. In fact, when analyzing the number of HazMat cars releasing per million train miles 

traveled, the data does not demonstrate any substantial difference in the rate over this 10-year 

period. 

Comparing the rate-per-million train miles in 1997 versus 2006, the number of accidents in 

which HazMat cars released product decreased by 40 percent. However, the number of cars 

releasing HazMat was 33 percent higher, again making it difficult to derive firm conclusions as 

to the efficacy of efforts to reduce HazMat incidents from the historical data observed over this 

10-year period. 
16 

Table 8. Train Accident Rates, All U.S. Freight Railroads: 1997–2006 

Source: FRA Office of Safety Analysis Web Site, http://safetydata.fra.dot.gov 

Year 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 Avg. 

TOTAL TRAIN MILES (million): 676.7 682.9 712.5 722.9 711.5 728.7 743.3 770.2 788.8 809.1 734.7 

Accidents per Million Train Miles 

Total Accidents (including grade 

crossing ) 3.54 3.77 3.88 4.13 4.25 3.76 4.06 4.39 4.13 3.67 3.96 

with Hazardous Material Cars in 

consist: 

the 

0.77 0.88 0.97 1 1.08 0.98 1.01 1.09 1.06 0.98 0.98 

in which a Hazmat Car was Damaged 

or Derailed: 0.41 0.45 0.5 0.52 0.55 0.53 0.51 0.5 0.46 0.47 0.49 

in which a Hazmat Car Released 

Product: 0.05 0.06 0.06 0.05 0.04 0.04 0.04 0.04 0.05 0.03 0.05 

Number of cars releasing Hazmat: 0.06 0.1 0.11 0.1 0.08 0.08 0.05 0.06 0.06 0.08 0.08 

1.3 Triggering Criteria Discussion 

Historical operational data clearly demonstrates that railroad safety performance has improved 

immensely over the past 20 years, especially with regard to the transportation of HazMat. 

According to an article entitled “Industrial Chemicals as Weapons: Chlorine” [10] by Benjamin 

H. Brodsky, “Of the approximately 12 million tons of chlorine produced annually in the United 

States, almost 3 million tons are shipped by rail, usually in 90-ton pressurized tank cars. Rail 

shipment of HazMat is very reliable; 99.997 percent of the 1.8 million annual HazMat shipments 

in the United States arrive without incident.” 

Many industry experts predict supplementary enhancements in tank car design as well as 

strategic placement of tank cars in train consists will further effectuate safety performance. FRA 

is currently overseeing several ongoing car placement programs to reduce accidents. 

With this in mind and in consideration of the data offered in this section, it appears that the real 

likelihood of a HazMat release on a large scale would come from a train hauling a HazMat tank 

car. Realistically, it seems that a reasonable answer to the question, “When should the 

crew/train carry EEBA?” would be: “When the train includes a tank car of HazMat or an 

equivalent volume.” 
17 

1.4 Triggering Criteria Conclusion 

Although catastrophic HazMat-related rail accidents involving large volumes of explosive, 

flammable, toxic, and corrosive materials being released are very rare, they are most commonly 

associated with those in which tank cars are damaged from collisions and derailments. 

Derailments make up the majority of all accidents, and whereas collisions make up a minor 

portion of overall accidents, these possess greater potential for a catastrophic HazMat release. 

In addition to car placement and car marshalling studies, several reports exist on the risk 

assessment of hazardous material transport via rail. One of those reports, A National Risk 

Assessment for Selected Hazardous Materials Transportation [11] concisely summarizes our 

assessment of its research that “the overall societal risk due to hazardous materials transportation 

is low. However, the potential exists for very serious accidents with many injuries and fatalities, 

although the probability of such events is very low.” 

Regarding HazMat type and volume, there is not sufficient history to label triggering criteria 

according to these attributes. In addition to the Macdona and Graniteville accidents, two other 

recent and notable “near misses” occurred including the 2002 Minot, ND accident in which five 

tank cars derailed and released 146,700 gal of anhydrous ammonia, and the 2003 Tamaroa, IL 

accident in which several derailed cars released methanol, phosphoric acid, hydrochloric acid, 

formaldehyde, and vinyl chloride. The Minot and Tamaroa accidents did not result in the death 

of any T&E crew. However, of these four cited accidents, all but one of the materials released 

(formaldehyde) are listed in the top 25 HazMat category for 2006. 

The review of available data confirms that the scope of the triggering criteria should be any train 

consist that includes one or more HazMat tank cars containing volume and contents that pose a 

risk of injury or death by inhalation due to properties that make the material toxic by inhalation 

or would displace sufficient atmosphere to cause suffocation, or other bulk HazMat cargo (i.e., 

50-gallon drums) totaling a similar quantity. 

Task 2: Define the state of emergency escape breathing apparatus (EEBA) technology to 

protect crew members from “hazardous materials that would pose an inhalation hazard.”

2.1 EEBA Technology—General 

The optimal EEBA will be defined by how and where it will be used. By this we mean: 

• How will it be employed? 

 By professional HazMat personnel who undergo refresher training each month. 

 By the occasional SCBA users who recertifies once annually. 

 By persons who will probably only use such a device once in their lives and who, 

realistically, are not highly trained—such would be the case with an FRA application. 

• What is it protecting against? 

 Toxic chemicals (chlorine, etc.), 

 Dangerous particulates (e.g., lead), and 

 Lack of oxygen (as a result of a fire). 
18 

 

• How is it deployed? 

 As a “pool” item, 

 Generically configured but permanently allocated to an individual, and 

 Custom fitted and permanently allocated to an individual.

We completed a technical review of the different types of EEBA necessary to address the 

different HazMat carried by the railroads, including their varying modes of toxicity and physical 

state (compressed gases: ammonia, carbon dioxide, chlorine, and vaporizing liquids: solvents, 

LPG). 

2.2 Classes of Respirators 

An EEBA falls under a broad category of “respirators.” To define EEBA technologies best suited 

to protect crew members from HazMat exposure, it is prudent to define the types of respirators 

available and how they work. Respirators fall into two categories: 

Air-Purifying: Remove specific air contaminants by passing ambient air through 

an air-purifying element, such as an air-purifying filter, cartridge, 

or canister. 

Atmosphere-Supplying: Supply breathing air from a source independent of the ambient 

atmosphere and includes airline supplied-air respirators (SARs) 

and self-contained breathing apparatus (SCBA) units. 

Examples of air-purifying and atmosphere-supplying respirators are shown in Figures 1–5. 

 

 
19 

Figure 3 - Powered Air 

Purifying Respirator (PAPR) 

Figure 2 - Filtering Self-Rescuer with 

Figure 1 full face mask - Filtering Face 

Piece with Hood 

Figure 4 - Open Loop Self 

Contained Breathing Apparatus Figure 5 - Closed Loop Self 

Contained Breathing Apparatus 

Illustrations of possible Emergency Escape Breathing Apparatus range from simple mask 

mounted filters to sophisticated closed loop re-breather devices. 

2.3 EEBA Selection for T&E Crew 

NIOSH is the Federal agency within the CDC that works with government and industry partners 

to develop respirator standards. Respirator equipment approvals are done in accordance with the 

NIOSH regulations codified at Title 42 Code of Federal Regulations (CFR) Part 84 [12]. NIOSH 

also develops information on safe levels of exposure to toxic materials and harmful physical 

agents and issues recommendations for respirator use. 

The Occupational Safety and Health Administration (OSHA) is the agency within the U.S. 

Department of Labor responsible for developing and enforcing workplace safety and health 

regulations. OSHA regulates the use of respiratory protection, including emergency escape 

devices, in the regulation codified at 29 CFR 1910.134 [13]. 

In considering the possible types of EEBAs that may be used by T&E crews, the requirements of 

both of the Federal agencies must be considered to ensure that whatever devices are 
20 

recommended are consistent with them. 

NIOSH has developed a comprehensive selection process for respirators. For more information, 

visit http://www.cdc.gov/niosh/docs/2005-100/#foreword. Two major factors that must be 

considered in that selection process are to determine if the respirator is intended for use in an 

oxygen-deficient atmosphere, i.e., less than 19.5 percent oxygen, (O2) and to determine if the 

respirator intended for entry into or escape from unknown or IDLH atmospheres (e.g., an 

emergency situation). 

Based on the findings in the 2005 report entitled, “Detailed Numerical Simulation of Graniteville 

Train Collision” [5], the concentration of the toxic chlorine cloud over derailment site area of the 

Graniteville incident was estimated at 2,000 parts per million (ppm). OSHA classifies chlorine 

as having an IDLH level of 10 ppm. Roughly estimating the distance between the final resting 

spot of the ninth (chlorine) tank car relative to the train crew, as well as the wind speed and size 

of breach, it is likely the chlorine plume traveled to the T&E crew within 2 minutes. According 

to the coroner’s report on the eight civilian fatalities in that incident, the primary cause of death 

was asphyxia, or lack of oxygen. The engineer’s primary cause of death was listed as lactic 

acidosis. The secondary cause of all deaths in the Graniteville incident was attributable to 

exposure to chlorine gas. In this example, both NIOSH selection criteria existed; lack of oxygen 

and toxic gas concentration exceeding IDLH levels. 

Because catastrophic railroad HazMat incidents have the potential to release IDLH 

concentrations and/or displace oxygen very quickly without the crew’s knowledge, the crew may 

need to respond to any incident (meaning collision or derailment) by donning their EEBA—

even before investigating the accident. Considering the variables associated with rail 

transportation of HazMat and the potential hazards that exist, the NIOSH selection criteria 

identify an escape-type self-contained breathing apparatus (SCBA) as the device needed for this 

application. 

2.4 Escape SCBA 

Escape devices have a single function: to allow a person working in a normally safe environment 

sufficient time to escape from suddenly occurring respiratory hazards. Given this function, 

selection does not rely on assigned protection factors. Instead, these respirators are selected 

based on a consideration of the time needed to escape and the likelihood of IDLH or oxygen 

deficiency conditions. 

Escape SCBA devices are commonly used with full-face pieces or hoods and, depending on the 

supply of air, are usually rated as 3 to 60 minute units. Available types of atmosphere-supplying 

SCBA are:

• Open Loop SCBA–typically classified as positive pressure, open loop systems whereby 

the user receives (inhales) clean air with 21 percent oxygen (O2) from a compressed air 

cylinder worn with a harness on the back. The user’s exhaled breath contains significant 

amounts (15 percent) of unused oxygen that is vented to atmosphere. Because much of 

the user’s exhaled breath vents to atmosphere, the size of open loop systems are larger 

than closed loop systems. Open loop SCBA systems employ the use of full face masks, 
21 

half-face masks or hoods and typically require an airtight seal against the head, face or 

aural/nasal area. 

 Rebreathers–can be positive pressure or negative pressure systems. Classified as 

closed loop O2 systems, rebreathers perform as its name implies; the user re-breathes 

his exhaled oxygen. A scrubber removes the user’s CO2 and a small compressed 100 

percent O2 bottle makes up metabolized O2. Because the user is re-breathing his 

exhaled air containing 15 percent oxygen, a rebreather has four times the efficiency 

compared to an open loop system, which is why they either last much longer than open 

loop systems (if size were comparable) or they can provide the same breathing duration 

as an open loop system but in a smaller package. Rebreathers use full-face masks, halfface masks, hoods or bite-down mouth pieces. Negative pressure rebreathers do not 

require a tight seal. 

Compressed air via airline—user is tethered to compressed air source (“shop” air) and 

employs the use of full-face masks, half-face masks, or hoods (not appropriate for this 

application). 

An example of a common open loop positive pressure SCBA system is that which is used by first 

responders (such as firefighters) for entering an emergency event. These devices are heavy and 

cumbersome as they incorporate a large compressed air cylinder mounted to a harness and the 

use of a full-face piece. Logistically and economically, the incorporation of a full-face piece is a 

difficult undertaking because it requires an airtight seal around the users face. An airtight seal 

means that each user must be personally fitted for the device. It also means that the user must be 

cleanly shaven, which is difficult to enforce. 

A useful alternative to full-face masks are hoods as seen in Figure 1. These universal fitting 

devices can be used with open-loop SCBA, do not require fitting to the user, operate regardless 

of the facial features or hair, and also offer the significant benefit of allowing the wearer to 

communicate while using the SCBA. 

Emergency entry devices can include additional technologies such as electronics for 

communications, tracking user location, alarm signals (i.e., for low air), and heads-up displays, 

none of which are required for escape situations. 

An example of an escape closed loop system is the self-contained self rescuer devices commonly 

used in the mining industry and military/naval sectors. These basic rebreather devices utilize a 

bite-down mouth piece to avoid the problems of face seals and facial hair, and are designed as 

one-use escape devices. Whereas the cost for an open-loop SCBA emergency entry device is as 

much as $3,000, an escape SCBA typically costs less than $750. 
22 

The advantages and disadvantages of these two types of SCBA respirator are summarized below: 

• Open loop escape respirators 

Advantages Disadvantages 

√ Portable √ Heavier than closed loop 

√ Easy to use √ Larger than closed loop 

√ Incorporates use of a hood versus a √ Shorter breathing duration than 

face piece (no fitting required) closed loop (typically offered in 5, 

√ Hood best for communicating 10 and 15 minute breathing 

√ Uses Grade D air; more available duration) 

than oxygen for recharging √ Compressed air cylinders need to 

be hydro-tested every 5 years, 

adding a maintenance cost 

• Closed loop escape respirators 

Advantages Disadvantages 

√ Portable √ Incorporates use of a bite-down 

√ Easy to use mouthpiece 

√ Light weight √ Not ideal for communicating 

√ Small package unless a bone conduction 

 √ Variable and longer breathing microphone is added to the 

durations (commonly 15, 30, 60, 120 mouthpiece for simple 

minutes) communication 

√ Low maintenance √ Disposal cost for unused CO2

√ Long shelf life (10 or 15 years) scrubber material

Examples of a suitable closed loop escape rebreather EEBA is any of the 60-minute devices such 

as those shown in Figure 6. Manufacturer brochures for these devices are provided in Appendix 

A. The listed devices are approved by NIOSH with an average retail price of approximately 

$650: 

• Ocenco EBA6.5; NIOSH certified as a 60-minute compressed oxygen rebreather. 

Dimensions are 8.5 in x 11.8 in x 4.5 in and weight is 8.0 lbs. 

• Draeger Oxy K Plus S; NIOSH certified as a 60-minute compressed oxygen rebreather. 

 Dimensions are 7.8 in x 10.0 in x 4.0 in and weight is 6.6 lbs. 

• CSE SR-100; NIOSH certified as a 60-minute oxygen generating (KO2) rebreather. 

Dimensions are 7.75 in x 4.0 in x 5.5 in and weight is 5.7 lbs. 
23 

Ocenco EBA 6.5 Drager Oxy K Plus S CSE SR-100

 Figure 7. - Open Loop Air Supplying Breathing Devices 

Scott ‘ELSA’ Drager QuickAIR

 Figure 6. - 60-min Closed placeLoop Air Supplying Rebreather 

Other candidate respirators are those that are open loop, compressed air systems, many of which 

come with “smoke” hoods for a universal fit (Figure 7). Manufacturer brochures for these 

devices are provided in Appendix B. The following devices are approved by NIOSH and 

average approximately $550 retail price: 

• Scott Health and Safety “ELSA”; NIOSH certified as a 15-minute compressed air 

rebreather. Weight is 9.5 lbs. 

• Draeger QuickAIR; NIOSH certified as a 10-minute compressed air re-breather featuring 

a hood. Weight is 10.0 lbs. 

Potential eye irritation must be considered and the requisite protection provided. Many of the 

HazMats of concern (e.g., chlorine) are eye irritants. This consideration is important for 

determining the face piece type on an EEBA. Many T&E crew wear prescription glasses so it 

will likely be necessary to accommodate them when selecting the specific make/model of EEBA. 
24 

Devices equipped with a full-face piece or hood should be selected rather than a device equipped 

with a half mask or mouthpiece with separate goggles. Another factor to consider is the 

presence of facial hair. If an EEBA relies on a good seal around the face to maintain its 

protection level, then its use by bearded or heavily mustached individuals is problematic. 

Similarly, use of full-face masks requires that the wearer be correctly sized to the device. Putting 

an XL mask on a small face results in leaks and critically reduced protection. 

2.5 EEBA Breathing Duration 

Considering how quickly a HazMat plume can travel, it is vital that the crew has adequate 

breathing time available to allow them to move a significant distance from the site while 

protected from the atmosphere around them. If the incident is the result of a collision, as was the 

case in the Macdona and Graniteville incidents, one should also consider situations where 

additional time may be needed to assist/extricate fellow crewmembers who may be hurt or 

trapped. If it takes 10 minutes to assist a fellow crewmember and they’re each wearing a 15-

minute open loop respirator, they are left with just 5 minutes to egress from the plume that is 

already likely upon them—quite possibly not enough time. Allowing for the “Murphy’s Law” 

effects of accidents happening at night, in tight terrain, resulting in crew injury, with a fastmoving plume, it would seem reasonable to expect that the minimum acceptable breathing 

capacity of the EEBA should be 30–60 min, explained by the following time-line: 

• Event happens: Non-incapacitated crew immediately don EEBA, 

• Event + 5 min: Crew working to release/aid injured member, 

• Event + 10 min: All crew exit locomotive, assess situation and begin movement away 

from train, 

• Event + 30 min: Crew (including injured) move 800 m away to seek help, and 

• Event + 60 min: Crew maintaining protective posture until responding HazMat teams 

give all-clear. 

2.6 EEBA Conclusions 

Because catastrophic railroad HazMat incidents have the potential to release IDLH 

concentrations and/or displace oxygen, only air-supplying SCBA equipment should be 

considered for adequate crew protection. Air-purifying respirators like filtered self-rescuers 

(FSR), powered air-purifying respirators (PAPR) are ruled out due to the potential for rapid 

IDLH concentrations of HazMat around the train consist and the unknown nature of the hazard 

and potential for a low-oxygen environment. 

The FRA EEBA should have an inherent capacity of not less than 30 minutes with a life of 60 

minutes being suggested. The EEBA must incorporate eye protection from irritant gases. The 

EEBA must maintain an acceptable protection level regardless of user size and the presence of 

facial hair. 
25 

2.7 EEBA Recommendation 

Based on the above discussions, the EEBA should be configured in one of two ways: 

• A 30- to 60-minute open loop air-supplying SCBA device with smoke hood or face mask. 

• A 30- to 60-minute closed loop air-supplying rebreather device equipped with 

goggles/smoke hood. 

Task 3: For each device recommended, the contractor will define the different methods by 

which the devices might be provided to employees by their railroad employers. Include an 

analysis of the pros and cons for each method defined including costs and practical 

considerations. Ascertaining the different methods, by which the devices might be 

provided, would be driven by several issues including current industry practices regarding 

the placement of other types of emergency equipment on locomotives, as well as the need to 

ensure that “all crewmembers” are provided the devices. 

3.1 Device Deployment—General 

Like other safety equipment, the EEBA could be provided to the crews by the railroads in several 

ways, for example: 

• It could be treated as a uniform item and permanently issued to the crew. 

• It could be issued and recovered at the start/end of each shift as part of the clock in/out 

process: 

 As a dedicated personnel item permanently allocated to an individual. 

 As a pool item issued randomly. 

• It could be mounted in the locomotive and other crew duty areas of each train: 

• Permanently. 

 As a train containing HazMat tank cars is made up. 

Four aspects of EEBA that influence the decision on how to deploy the device are: 

• The configuration and form factor of the selected EEBA and if it can, or should be, handcarried or must be mounted on the equipment. 

• The configuration of the EEBA and whether it is a generic one-size-fits-all or customized to 

a user with mask size or type to cater to facial hair, etc. 

• The capital and operational costs for inspection, maintenance, and replacement will 

determine whether the item is issued as personnel equipment on a permanent basis or 

whether it is issued from a pool only for HazMat train crews. 

• Railroad’s experience with other (technical or safety) regulated devices relative to theft, loss, 

damage, etc. 

Like all safety or operational equipment, some responsibility is placed on both the railroad 

operating company and the crew members to ensure that the equipment is available, in place, 

trained on, and used correctly. Therefore, all parties involved have a real interest in deriving the 

optimum strategy for its employment. Considering all of the aspects above and primarily the 
26 

complex and significant logistics imposed on the operating company for assigning a regulated 

safety device, such as a respirator, the user companies were polled as to what their preferred 

deployment methodology would be. 

3.2 EEBA Deployment Survey 

A survey questionnaire was developed and sent to multiple Class 1 railroads and labor 

organizations representing crew members with the intention to have them define their preferred 

deployment methodology for the EEBA. Regardless of how this technology is deployed and 

managed, it will come with large capital and operating costs, so the operational and support 

mechanisms for these devices are very important. Based on this logic, the hope was that the 

railroads and labor would select a means of EEBA deployment that would meet their needs. 

The questionnaire was sent to the following railroads: 

• Union Pacific Railroad (UP) 

• Norfolk Southern Railway 

• CSX Transportation 

• BNSF Railroad 

• Canadian National Railway 

• Canadian Pacific Railway 

The questionnaire was also sent to the following rail labor organization: 

• BLET (Brotherhood of Locomotive Engineers and Trainmen) 

Detailed responses received to that survey are attached to this report as Appendix C and are 

summarized. 

3.3 EEBA Survey Results 

Unanimously, each railroad preferred that in the event EEBAs were mandated, they should be 

assigned to each T&E employee. One Railroad included T&E and yard employees. The 

railroads prefer the responsibility for care and maintenance of EEBAs be assigned to T&E 

employees. Union responses recommended that supply, maintenance, and inspection be carried 

out by the “carrier.” 

The railroads’ opinions are largely predicated on prior experience with regulated equipment that 

disappears, due to loss, pilfering, or damage. Additionally, their logic is that if personally 

assigned, EEBAs will then be better cared for. Better care results in lower replacement costs if 

the EEBA can be deployed until its end-of-service life or when mandatory replacement is 

required. 

Based on conversations with the railroad companies, EEBAs assigned to locomotives instead of 

individual employees would require three such devices to be within the crew cab. Three devices 

would cover the engineer, conductor and an additional person such as a supervisor, trainee, 
27 

inspector, etc., who might be in the locomotive cab. If three EEBAs were assigned to each 

freight service or yard locomotive, then that number would constitute a lesser number than if 

assigned to each T&E employee and hence, a lower capital equipment cost. Nevertheless, each 

railroad respondent to the questionnaire preferred EEBA assignment to the employee, predicting 

overall and long-term cost savings by reducing replacement costs. 

One railroad assigned an estimated dollar value to the implementation of EEBAs, and a member 

of the AAR provided a cost-benefit analysis based on the assumption that these devices were to 

be mandated. This information is discussed under Task 5. 

3.4 EEBA Deployment Discussions 

The previous section summarizes the position of the operating companies and labor unions on 

the deployment of the EEBA. Notwithstanding these positions, which are flavored by the nature 

of the respondents, advantages and disadvantages exist to any deployment scheme. 

As stated, three methodologies exist to deploy the EEBA across the train/crew fleet. This section 

discusses each of these options and summarizes the advantages and disadvantages of each. 
28 

• The EEBA could be treated as a uniform item and permanently issued to the crew members. 

 Pros. 

 Device will be with user at all times. 

 Company is relieved of most of the responsibilities for device management. 

 Individual is responsible for the state of their own equipment. 

 Could be a customized device. 

 Cons. 

 Monitoring of device status (good/damaged/leaking) is more difficult. 

 Difficulty of ensuring device is with user at all times. 

• The EEBA could be permanently assigned to an individual as a dedicated personnel item, 

and would be issued and recovered at the start/end of each shift as part of the clock in/out 

process. 

 Pros. 

 Supports centralized inspection and maintenance. 

 Keeps device with user at all times. 

 Could be a customized device. 

 Cons. 

 Increases size of EEBA fleet since all T&E personnel require stocked devices. 

• The EEBA could be a pool item issued randomly and recovered at the start/end of each shift 

as part of the clock in/out process. 

 Pros. 

 Supports centralized inspection and maintenance. 

 Minimizes number of devices required. 

 Keeps device with user at all times. 

 Cons. 

 Loss of ownership (and therefore interest in long-term serviceability) of device. 

 Can only be a generic one-size-fits-all device. 

 Management burden increases for tracking/recovery. 

• The EEBA could be permanently mounted in the locomotive cab.

 Pros. 

 Ensures HazMat consists are always equipped. 

 Supports centralized inspection and maintenance. 

 
29 

 Cons. 

 Increases size of EEBA fleet since non-HazMat consists still carry devices. 

 Increases management burden for tracking/recovery. 

 Increases management burden for item inspection and maintenance. 

 Provides EEBA for worst case crewing (including possible mandatory 

supernumerary personnel. 

 Can only be a generic one-size-fits-all device. 

 

• The EEBA could be mounted in the locomotive and other crew-duty areas of each train as a 

train containing HazMat tank cars is made up. 

 Pros. 

 Minimizes number of devices required. 

 Ensures HazMat consist is appropriately equipped. 

 Caters to differing crew sizes most efficiently. 

 Cons. 

 Increases management burden for initial issue to consist. 

 Increases management burden for tracking/recovery. 

 Increases management burden for item inspection and maintenance. 

 Can only be a generic one-size-fits-all device. 

 

3.5 EEBA Deployment Conclusions 

Railroad respondents preferred that in the event EEBAs were mandated, they should be assigned 

to each T&E employee. With the exception of the union responses, the railroads prefer the 

responsibility for care and maintenance of EEBAs be assigned to T&E employees. Union 

responses recommended that supply, maintenance, and inspection be carried out by the railroad 

carrier. 
30 

Task 4: The contractor will quantify the incidence rate of accidents with fatalities and 

serious injuries attributable to the inhalation of released hazardous material (HazMat). 

4.1 Accident Rates – General 

The FRA has done a preliminary review of accident data and related employee casualty data for 

the purpose of a quantitative risk assessment involving hazardous materials released by 

accidents. This preliminary review has identified two fatalities of this nature during the last 20 

years. During this same period, the HazMat shipments cited in Task 1 were made. This 

preliminary review suggests a low risk of the type of incident that occurred at Macdona or 

Graniteville happening with any frequency. 

4.2 Historical Analysis 

Historical accident and incident data from up to 20 years ago was analyzed to determine the 

actual frequency of rail-related HazMat incidents and, more specifically, of train crew injuries 

and fatalities caused by the release of HazMat into the environment (as opposed to injury from 

the mechanics of the crash, derailment, fire, incident). 

According to data published in a September 2005 presentation by Robert Fronczak, P.E., 

Assistant VP, Environmental and HazMat for AAR [3], railroad incidents have been reduced 

significantly over the past two decades. By any other industrial or business sector, the statistical 

improvements realized by the rail industry would be considered astounding. 

Railroads have exhibited exceptional safety performance in many areas including: 

• Lower injury rates compared to other major industry groups. 

• Lower injury rates compared to other transportation modes. 

• Lower injury rates compared to most major European railroads. 

• Declines in HazMat incident release rates (down 71 percent since 1980 and 56 percent since 

1990). 

• Declines in HazMat accident rates (down 90 percent since 1980 and 49 percent since 1990). 

• Declines in accidents with a HazMat release (down 76 percent since 1980 and 17 percent 

since 1990). 

Furthermore, DOT stated in a 2004 Overview [14] that “accidents declined nearly 70 percent 

since the late 1970s, and over the previous three years the Nation has had the lowest number of 

rail-related deaths and employee fatalities on record. Despite more than 2 million movements of 

HazMat cars, 2003 marked the lowest number of train accidents involving a HazMat release in 

the previous five years.” 

Although overall accident rates have declined significantly from the 1970s into the 1980s and 

again from the 1980s through the 1990s the past decade has experienced a leveling off of safety 

performance. The accident rate, as of 2006, remains at 3.95 accidents per million train-miles. 
31 

4.3 Casualty Data 

In keeping with the FRA statement of work, casualty data was examined for non-passenger train 

and engine personnel only. 

Casualty data for on-duty T&E employees was analyzed for the 10-year period from 1997–2006. 

Over this period, there were of 25,941 non-passenger T&E on-duty casualties. Thirty-eight were 

fatalities and 25,909 were injuries. Within this data set, three specific types of casualty data 

were examined: those resulting from collisions, derailments, and inhalation. 

Table 9. Non-Passenger T&E Employees–OnDuty (A) Casualties 

Source: Federal Railroad Administration Safety Database–4.02 Casualty Data Reports 

Reporting 

Year 

Overall 

Casualties 

Collision 

Casualties 

Collision 

Fatalities 

Derailment 

Casualties 

Derailment 

Fatalities 

Inhalation 

Casualties 

Inhalation 

Fatalities 

1997 2834 96 8 38 0 58 0 

1998 3004 86 1 37 0 86 0 

1999 3211 76 7 54 1 73 0 

2000 3169 82 2 44 0 63 0 

2001 2872 86 4 50 0 68 0 

2002 2405 84 2 46 1 50 0 

2003 2281 75 2 44 1 63 0 

2004 2211 73 5 55 0 70 1 

2005 2102 84 0 27 0 69 1 

2006 1852 60 1 28 0 64 0 

10 year 

Avg 2594.1 80.2 3.2 42.3 0.3 66.4 0.2 

Table 9 is intended to demonstrate the difference between total T&E casualties (an average of 

2,594 over 10 years) to those T&E casualties resulting from collisions, derailments, and 

inhalation. The balance of injuries is attributable to other causes (e.g., slip and fall, etc). Injury 

type “inhalation” was chosen as a data point because these casualties represent the only two T&E 

deaths resulting from a HazMat release. Injury types “derails” and “collisions” were chosen as a 

data point because these casualties represent the most likely events leading to a HazMat release 

with T&E personnel present. These events also have the most potential for damage/injury/loss 

of public life occasioned by a HazMat release rendering an unprotected crew ineffective. 

The 10-year average of 193 T&E casualties (injured and killed) due to inhalation, collision, and 

derailment represents 7.4 percent of the average number of 2,594 T&E on-duty casualties during 

the same period. 

Table 9 suggests that collisions prove to be the most life threatening, whereby 84 percent (32 out 

of 38) of T&E casualties involved in a collision resulted in death compared to 7 percent (3 out of 

38) involved in a derailment. Only 5 percent (2 out 38) of T&E casualties died from inhalation, 

those being in the 2004 Macdona and 2005 Graniteville accidents. 

The two on-duty T&E deaths resulting from a collision and subsequent inhalation of HazMat 
32 

compared to average annual train miles in the period 1997–2006 of 734.6 million can be 

expressed as a rate of one death per 367 million train miles. 

Note that Table 9 has been modified to show two total deaths from inhalation whereas the reports 

from the FRA Safety Database lists only one fatality over this 10-year span—the death from 

Graniteville. The Macdona death in 2004 was listed as being killed by collision when in fact the 

cause of death was inhalation (see Table 10). Once a record is entered into the FRA database it 

is not changed so as to guard the integrity of the data. This sometimes results in the cause of 

death to ultimately be recorded incorrectly. 

Table 10. 4.05 - Casualties by State, Railroad, or Type 

Selections: 

Railroad All Railroads 

State All States County - All Counties 

Region All Regions 

 All Job Types / On or Near Track / Fatalities Only 

 Type of Person RR Emp on duty 

 Report Sort Sequence - Date 

 

RR Year Month Day TA Incident 

Number 

Type 

Person Condition Event St County Age

UP 2004 June 28 1 0604SA011 RR Emp 

on duty Fatality Collision - between on track equipment TX BEXAR 23

NS 2005 January 6 1 19414 RR Emp 

on duty Fatality Exposure to fumes - inhalation SC AIKEN 28 

 TA=Type Accident/Incident: 1 = Train Accident (form 54), 2 = Highway-rail (from 57), 3 = Other (form 55a) 

4.4 HazMat Incidents 

Incident data relative to trains carrying HazMat materials are covered in Task 1 for triggering 

criteria. It is worthy to restate the findings from the Hazardous Substances Emergency Events 

Surveillance (HSEES) System, which reports that rail events constitute only 2 percent of total 

hazardous-substance releases. Furthermore, most rail events involved small-scale releases (75 

percent of events involved <70 gallons). However, large-scale, acute releases during rail transit 

can occur (10 percent of events involved >2,200 gallons) and cause substantial injury and death, 

as demonstrated by case reports. The Macdona and Graniteville accidents released 9,400 and 

9,218 gallons of liquid chlorine respectively. 

4.5 Accident Data Conclusions 

In the period from 1997 to 2006, total T&E on-duty casualty rates have declined steadily, 

particularly from its high point in 2000 when 3,893 casualties were reported. In 2006, significant 

improvement to casualty statistics was demonstrated with 2,473 reported casualties (Appendix 

D). However, when referencing those casualties attributed to inhalation, collision, and 

derailment, the data does not illustrate an appreciable reduction over time in casualty 
33 

performance. Although 2006 alone demonstrated improvement, the balance of the period 

showed variation in casualty performance. 

Of all the historical data reviewed only two fatalities among on-duty T&E crew could be 

identified that were related to the release of a hazardous material associated with a railroad 

accident. These were the individual T&E crew member fatalities involved in Macdona in 2004 

and Graniteville in 2005, both of which were from acute inhalation of chlorine from a breached 

tank car that occurred as a result of a collision. The casualty rate for these two deaths can be 

expressed according to 2006 statistics as follows: 

• One death per 367 million train miles (1997-2006). 

• One death per 5.7 million shipments of the top 125 HazMat (1997-2006). 

Because no other casualties of similar circumstances could be identified, at least for the past 20 

years, drawing conclusions is impractical from the aforementioned rates that indicate positive or 

negative trends for this kind of fatality. 

Task 5: For the recommended devices from Task 2, the contractor will define the economic 

issues involved in the provision of these devices to all crew members 

5.1 EEBA Economics–General 

Any regulation mandating the use of EEBAs will require significant initial and on-going costs 

for the railroads. Similar to all technical, and specifically safety equipment, the EEBA will 

require significant ongoing expenditure in terms of maintenance, inspection, crew training, 

repair, and replacement. As a safety item it will also impose a significant administrative burden 

to track its issue, use and maintenance, and the users will need to have their initial and refresher 

training logged. Finally, depending on the nature of the technology involved and the chemicals 

it contains (catalysts, absorbents, etc.) some disposal costs could exist associated with its end of 

life. 
34 

5.2 Life Cycle Costs 

We considered attributes associated with some respirator models that could affect the cost model 

to the railroads, such as if the units require periodic refurbishment or recharge and whether that 

action can only be completed at the manufacturers plant, as opposed to a rail depot in which case 

ongoing maintenance costs could be significantly different to other in-house maintained options. 

The volume estimates for T&E employees and locomotives were derived from the AAR’s 

Cost/Benefit Analysis (Appendix E). Exceptions to scrap figures (i.e., shelf life) and training 

time noted in the AAR report are adjusted based on the equipment manufacturer’s 

recommendations. 

In general, respondents to the questionnaire led this author to the conclusion that their 

understanding of available respirator technologies was somewhat lacking, at least as it pertains to 

the type of HazMat threat in question. Therefore, the respondents’ recommendations for the 

same were in large part not considered. The responses relative to the type of device, how long it 

should protect the user and the cost of the device were quite varied. The only respondent that 

could lend any credence in these matters was from UP. This respondent had a level of practical 

respirator knowledge due to the ongoing Respiratory Protective Equipment program for T&E 

crew operating in Colorado’s Moffat Tunnel. 

In consideration of the economics involved in the deployment of an EEBA program for the 

railroad, the cost schedule in Table 11 captures the following elements: 

• Net Present Value (NPV) over 15 years for equipment, training, maintenance, replacement 

(due to damage, pilfering or loss), and tracking (for issuance, maintenance, service life, etc.). 

• Compares open loop SCBA (using Grade D compressed air) to closed loop SCBA (using 

compressed oxygen) 

• Compares Assignment to Locomotive and assignment to T&E employees. Pooling devices 

at yards were not considered due to respondents’ desire to have the EEBAs personally 

assigned and the associated concern about logistics, pilfering, and loss. 

• For locomotive assignment, estimates are based on issuance of three EEBAs per locomotive 

to cover two T&E employees plus an additional person (e.g., supervisor, trainer, other 

personnel). 

• Assumes the Railroads would be granted approximately five years to fully outfit their labor 

force with the devices 

• Maintenance cost for open loop devices includes labor plus $25 per unit for 5-year hydro 

testing on cylinders. 

• Scrap levels (replacement age) were not considered for open loop devices because they 

possess an indefinite shelf life. 

• Scrap levels (replacement age) for closed loop devices reflect a common shelf life of 10 

years. 
35 

Table 11. Estimated Cost for Deploying EEBA in Various Modes 

SCBA Type Open Loop Closed Loop 

Assignment Locomotive Employee Locomotive Employee

No. Units 45,000 68,307 45,000 68,307 

Cost per Unit $550 $550 $650 $650 

Capital Cost (NPV) $60,890,000 $46,300,000 $52,440,000 $66,340,000 

Training and Maintenance (NPV) $18,870,000 $20,900,000 $14,640,000 $16,990,000 

Total Capital Cost (NPV) $79,760,000 $67,200,000 $67,080,000 $83,330,000 

Replacement Age N/A N/A 10 Years 10 Years 

The following cost schedules are provided in Appendix F as supporting documentation to the 

cost estimates: 

• Cost Schedule–Positive Pressure, Open Loop SCBA with Hood, Grade D Pressurized Air 

Supply, Assigned to Employee. 

• Cost Schedule–Positive Pressure, Open Loop SCBA with Hood, Grade D Pressurized Air 

Supply, Assigned to Locomotive. 

• Cost Schedule–For Positive Pressure, Closed Loop SCBA with Mouthpiece, Oxygen 

Pressurized Air Supply, Assigned to Employee. 

• Cost Schedule–For Positive Pressure, Closed Loop SCBA with Mouthpiece, Oxygen 

Pressurized Air Supply, Assigned to Locomotive. 

The difference between the values for an open loop device assigned to a locomotive versus 

employee is largely predicated on the assumption that there would be a 20 percent 

pilfering/damage loss as compared to just 5 percent loss if assigned to the employee. The 

assumption is that if the EEBA is assigned to the employee, then it will be better taken care of 

and less susceptible to loss, pilfering, or damage. Estimates for open loop devices also include a 

maintenance fee that accounts for periodic hydrostatic testing of the compressed air cylinder. 

Closed loop devices assume the same percentages for pilfering/damage loss as open loop devices 

(i.e., 20 percent if locomotive assigned vs. 5 percent employee assigned). Although there is no 

maintenance cost associated with closed loop devices, there is a shelf life of 10 years. The 

difference between the values for a closed loop device assigned to a locomotive versus employee 

is largely predicated on the raw difference between the number of units assigned to locomotives 

versus employees (approximately 23,000 units). 
36 

5.3 Stakeholder’s Positions 

While all respondents to the questionnaire agree that training in the use of EEBAs should be 

managed by the Railroad, the responses relative to inspection and maintenance vary. Some 

believe the responsibility for inspection and maintenance belongs with the employee where some 

believe it is the responsibility of the railroad. Most railroads believe the responsibility for 

inspection and maintenance falls on the employee whereas one railroad would accept that 

responsibility and farm those services out to contract engineering firms. That same company 

expressed concern about the manpower availability of such firms to handle the magnitude of an 

EEBA program, further suggesting a high tech, expensive transponder system would needed to 

facilitate the check-in/check-out process of bar coded EEBAs. 

5.4 Economics Conclusions 

The implementation of EEBAs would pose a significant financial burden on the railroads 

regardless of the method of assignment (i.e., locomotive or employee) or the type of EEBA (i.e., 

closed or open loop escape rebreather). 

Based on the raw financial figures, the least expensive option suggests closed loop devices 

assigned to the locomotive are the best choice. However, the railroads’ desire to have EEBAs 

personally assigned to the employee suggests open loop devices are the best choice. 
37 

References 

1. National Transportation Safety Board. Railroad Accident Report NTSB/RAR-06/03. 

Collision of Union Pacific Railroad Train MHOTU-23 with BNSF Railroad Company Train 

MEAP-TUL-126-D With Subsequent Derailment and Hazardous Materials Release, 

Macdona, Texas. June 28, 2004. 

2. National Transportation Safety Board. Railroad Accident Report NTSB/RAR-05/04. 

Collision of Norfolk Southern Freight Train 192 with Standing Norfolk Southern Local 

Train P22 with Subsequent Hazardous Materials Release at Graniteville, South Carolina. 

January 6, 2005. 

3. Robert Fronczak, U.S. Railroad Safety Statistics and Trends, Association of American 

Railroads. May, 2005. 

4. Annual Report of Hazardous Materials Transported by Rail, Calendar Year 2006, 

Association of American Railroads, Bureau of Explosives, Report BOE 06-1, October 2007 

5.Testimony of Joseph H. Boardman, Administrator, Federal Railroad Administration, U.S. 

Department of Transportation, before the Committee on Commerce, Science, and 

Transportation, United States Senate. January 18, 2007. 

6. Centers for Disease Control. Public Health Consequences from Hazardous Substances 

Acutely Released During Rail Transit; Morbidity and Mortality Weekly Report, January 28, 

2005; 3:7. 

7. National Transportation Safety Board. Safety Recommendation R-05-14–17. December 

12, 2005. 

8. Buckley, R.L. Detailed Numerical Simulation of the Graniteville Train Collision. 

Savannah River National Laboratory, Report WSRC-MS-2005-00635 October 2005. 

9. Association of American Railroads. Railroad 10-Year Trends 1997-2006. 

10. Brodsky, B.H. The James Martin Center for Nonproliferation Studies; Industrial 

Chemicals as Weapons: Chlorine. July 31, 2007. 

11. Brown D.F., Dunn W.E., and Policastro A.J. A National Risk Assessment for Selected 

Hazardous Materials in Transportation. U.S. Department of Energy. December 2000. 

12. National Institute for Occupational Safety and Health (NIOSH) 42 CFR 84; Approval 

of Respiratory Devices. Available at 

http://www.access.gpo.gov/nara/cfr/waisidx_04/42cfr84_04.html 

13. Occupational Safety and Health Administration (OSHA) 29 CFR 1910.134; Personal 

Protective Equipment. Available at 

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=

12716

14. United States Department of Transportation, 2004 Overview. Available at 

http://www.dot.gov/bib2004/overview.html
 A-1

Appendix A

• Ocenco EBA6.5; NIOSH certified as a 60-minute compressed oxygen rebreather. 

Dimensions are 8.5” x 11.8” x 4.5” and weight is 8.0 lbs. 
 A-2
 A-3

• Draeger Oxy K Plus S; NIOSH certified as a 60-minute compressed oxygen rebreather. 

Dimensions are 7.8” x 10.0” x 4.0“ and weight is 6.6 lbs. 
 A-4
 A-5

• CSE SR-100; NIOSH certified as a 60-minute oxygen generating (KO2) rebreather. 

Dimensions are 7.75 ̋ x 4.0 ̋ x 5.5 ̋ and weight is 5.7 lbs. 
 A-6
 B-1

Appendix B 

• Scott Health and Safety ”ELSA”; NIOSH certified as a 15-minute compressed air 

rebreather. Weight is 9.5 lbs. 
 B-2

• Draeger QuickAIR; NIOSH certified as a 10-minute compressed air rebreather featuring 

a hood. Weight is 10.0 lbs. 
 B-3
 C-1 

Appendix C 

EEBA Deployment Survey 

Template Questionnaire regarding Emergency Escape Breathing Devices (EEBD) 

and their possible use in the Railroad Community 

1. Emergency Protocol 

1.1. If you don’t believe EEBD’s are a necessary safety device for train crews, please explain 

the protocols a train crew should undertake (if any) when there is an unintentional 

release of hazardous and/or toxic material on their consist. 

2. Equipment 

2.1. If EEBD’s were mandated, what type of device would you recommend for your train 

crew? Choose those that apply: 

• Air Purifying – These contain an air-purifying filter, cartridge, or canister that removes 

specific air contaminants by passing ambient air through the air-purifying element. These do 

not supply oxygen and must only be used when there is sufficient oxygen to sustain life and 

the air contaminant level is below the concentration limits of the device. Common choices 

are as follows: 

o Particulate respirators use a mechanical filter to remove particulate matter such as 

dusts. 

o Gas and vapor respirators (or chemical cartridge respirators) use chemicals such as 

activated charcoal to remove specific gases and vapors from the air. These are 

effective for concentrations of no more than ten times the TLV of the contaminant, if 

the contaminant has warning properties (odor or irritation) below the TLV. 

o Combination respirators have filters for both particulates and vapors. 

o Powered air-purifying respirators (PAPR) use a blower to force the ambient air 

through air-purifying elements to the inlet covering. 

• Compressed Air-Supplying ‘Self-Contained Breathing Apparatus’ (SCBA) – This is 

much like the apparatus a SCUBA diver or fire fighter might use. Air (or oxygen) is supplied 

from a compressed cylinder, usually through a full-face mask, which is worn on the back. 

This gives greater movement than an air-line respirator, but the air supply is limited. Two 

common choices are as follows:

o Open loop system – unused exhaled O2 is lost to atmosphere, hence larger cylinders 

to provide adequate breathing time. Typical breathing duration is 30 minutes.

o Closed loop system – captures and reuses exhaled O2. Scrubber removes CO2 and 

small makeup O2 bottle provides additional O2. Typical breathing duration is a 

minimum of 1 hour.

• Filtering Face piece (dust mask) – the filter is an integral part of the face piece

• Bite Valve with Nose Clamp – breathing through bite valve with nostrils pinched off

• Half Mask – respirator covering the mouth and nose. Requires optimum fit. Facial hair is 

not recommended.

• Full Face piece – respirator designed to seal around the entire face. Must be sized and fitted 

per user, particularly with a closed loop system.

• Negative Pressure Respirator – wearer draws air through filter or cartridge by breathing
 C-2

2.2. If you believe EEBD’s should be air-supplying versus air-purifying, should the supplied 

gas be compressed ‘clean’ air (ie: grade D) or compressed oxygen? (Note: open loop 

compressed air systems typically have sizeable cylinders to provide adequate breathing 

duration whereas closed loop compressed O2 systems have much smaller cylinders, yet 

provide substantially longer breathing duration). 

2.3. If EEBD’s were mandated, how much breathing time should the device provide? Please 

provide reasoning, taking into consideration the time it may take for the train crew to 

extricate themselves from their immediate surroundings which may be encompassed 

with a toxic cloud. 

2.4. If EEBD’s were mandated, what do you think would constitute a reasonable shelf life of 

the device before mandatory replacement? 

3. Assignment 

3.1. If EEBD’s were mandated, should the devices be assigned to the locomotive or should 

they be assigned to each appropriate employee? 

3.2. If EEBD’s were mandated and assigned to employees, which employees would receive 

the devices (ie: T&E, other)? 

3.3. How many employees would that constitute? 

3.4. How many locomotives are in your fleet: 

• Freight service = 

• Yard/switchers = 

3.5. If EEBD’s were mandated, would they need to accompany personnel on every type of 

locomotive? 

4. Economics 

4.1. If EEBD’s were mandated, what do you believe is a practical price to pay per device? 

4.2. If EEBD’s were mandated, there is certainly going to exist a need for training, 

maintenance, inspection and tracking. Based on the type of device you recommend, how 

would you handle each of these (ie: internally or externally), how often, and what do you 

estimate are the associated costs for the same? 

• Training: (address if training might be one-on-one or in a group, and how often 

training should take place) 

• Maintenance: (address who would be responsible for maintenance and how often it 

should take place, ie: preventative maint.) 

• Inspection; (address who would be responsible for inspection and how often it should 

take place) 

• Tracking: (address who would be responsible for tracking and how often it should 

take place. Please compare a tracking program for EEBD’s to other similar devices 

that need to be present on the consist, such as fire extinguishers. How are those 

tracked?) 

5. Professional Opinion 

5.1. What is your professional opinion about the need or use of these devices for train crews? 

Please elaborate on your answer. 
 C-3

5.2. Do you believe the number of incidents in the form of collisions, derailments or near 

misses with consists carrying Hazmat freight, compared to the number of deaths and 

injuries resulting from the same, warrants the need for EEBD’s for train crews? 
 C-4

Questionnaire regarding Emergency Escape Breathing Devices (EEBD) and their 

possible use in the Railroad Community 

B. Blissett (BLET) Response 

1. Emergency Protocol 

1.1. Do you believe EEBD’s are a necessary safety device for train crews? If not, please explain the 

protocols a train crew should undertake (if any) when there is an unintentional release of 

hazardous and/or toxic material on their consist. 

YES 

2. Equipment 

2.1. If EEBD’s were mandated, what type of device would you recommend for the train crew? 

Choose those that apply: 

• Air Purifying – These contain an air-purifying filter, cartridge, or canister that removes 

specific air contaminants by passing ambient air through the air-purifying element. These do 

not supply oxygen and must only be used when there is sufficient oxygen to sustain life and 

the air contaminant level is below the concentration limits of the device. Common choices 

are as follows: 

o Particulate respirators use a mechanical filter to remove particulate matter such as 

dusts. 

o Gas and vapor respirators (or chemical cartridge respirators) use chemicals such as 

activated charcoal to remove specific gases and vapors from the air. These are 

effective for concentrations of no more than ten times the TLV of the contaminant, if 

the contaminant has warning properties (odor or irritation) below the TLV. 

o Combination respirators have filters for both particulates and vapors. 

o Powered air-purifying respirators (PAPR) use a blower to force the ambient air 

through air-purifying elements to the inlet covering. 

• Compressed Air-Supplying ‘Self-Contained Breathing Apparatus’ (SCBA) – This is 

much like the apparatus a SCUBA diver or fire fighter might use. Air (or oxygen) is supplied 

from a compressed cylinder, usually through a full-face mask, which is worn on the back. 

This gives greater movement than an air-line respirator, but the air supply is limited. Two 

common choices are as follows: 

o Open loop system – unused exhaled O2 is lost to atmosphere, hence larger cylinders 

to provide adequate breathing time. Typical breathing duration is 30 minutes. 

o Closed loop system – captures and reuses exhaled O2. Scrubber removes CO2 and 

small makeup O2 bottle provides additional O2. Typical breathing duration is a 

minimum of 1 hour. 

• Filtering Face piece (dust mask) – the filter is an integral part of the face piece 

• Bite Valve with Nose Clamp – breathing through bite valve with nostrils pinched off 

• Half Mask – respirator covering the mouth and nose. Requires optimum fit. Facial hair is 

not recommended. 

• Full Face piece – respirator designed to seal around the entire face. Must be sized and fitted 

per user, particularly with a closed loop system. 

• Negative Pressure Respirator – wearer draws air through filter or cartridge by breathing 

2.2. If you believe EEBD’s should be air-supplying versus air-purifying, should the supplied gas be 

compressed ‘clean’ air (ie: grade D) or compressed oxygen? (Note: open loop compressed air 

systems typically have sizeable cylinders to provide adequate breathing duration whereas closed 
 C-5

loop compressed O2 systems have much smaller cylinders, yet provide substantially longer 

breathing duration). 

2.3. If EEBD’s were mandated, how much breathing time should the device provide? Please provide 

reasoning, taking into consideration the time it may take for the train crew to extricate 

themselves from their immediate surroundings which may be encompassed with a toxic cloud. 

2.4. If EEBD’s were mandated, what do you think would constitute a reasonable shelf life of the 

device before mandatory replacement? 

3. Assignment 

3.1. If EEBD’s were mandated, should the devices be assigned to the locomotive or should they be 

assigned to each appropriate employee? 

Locomotives and yard offices where crews report and take their lunch time. Crews 

already carry a lot of gear both company mandated and personal supplies, because of the 

extended stays away from home. 

3.2. If EEBD’s were mandated and assigned to employees, which employees would receive the 

devices (ie: T&E, other)? 

Engineers, Conductors and Brakeman is assigned to the crew. 

3.3. If EEBD’s were mandated, would they need to accompany personnel on every type of 

locomotive? 

YES 

4. Economics 

4.1. If EEBD’s were mandated, what do you believe is a practical price to pay per device and who 

should pay for that device? 

I have no idea how much they would cost. I should think about $250.00 and they 

should be supplied and maintained by the Carrier. 

4.2. If EEBD’s were mandated, there is certainly going to exist a need for training, maintenance, 

inspection and tracking. Based on the type of device you recommend, how would you expect the 

operating company to handle each of these (ie: internally or externally), how often, and what do 

you estimate are the associated costs for the same? 

• Training: (address if training might be one-on-one or in a group, and how often training 

should take place) 

Training could take place in a group and could be peer based. 

• Maintenance: (address who would be responsible for maintenance and how often it should 

take place, ie: preventative maintenance program.) 

The carrier should be responsible for all maintenance and it should take place per 

manufactures recommendations. 

• Inspection; (address who would be responsible for inspection and how often it should take 

place) 

The carrier should be responsible for inspection and it should take place per 

manufactures recommendations. 
 C-6

• Tracking: (address who would be responsible for tracking and how often it should take place. 

Please compare a tracking program for EEBD’s to other similar devices that need to be 

present on the consist, such as fire extinguishers. How are those tracked?) 

I believe that they should have a life of at least 90 days as all locomotives have to be 

inspected on this time line. 

4.3. Has your organization performed any cost/benefit analysis on this matter? If so, please describe 

and/or supply the analysis. 

NO 

5. Professional Opinion 

5.1. What is your professional opinion about the need or use of these devices for train crews? Please 

elaborate on your answer. 

Railroads are carrying more and more hazardous shipments. There have been a 

significant number of accidents and hazardous material releases. There have been 

large haz mat spills of Anhydrous Ammonia and Chlorine and with shipments on 

the rise there are bound to be more. The only way a train crew can survive a haz 

mat release is to have a EBB. 

5.2. Do you believe the number of incidents in the form of collisions, derailments or near misses with 

consists carrying Hazmat freight, compared to the number of deaths and injuries resulting from 

the same, warrants the need for EEBD’s for train crews? 

YES 

5.3. Can you personally cite instances in the past several years where having an EEBD available 

would have proved beneficial to the train crew? 

There was a Anhydrous Ammonia release in Minot, ND on January 18, 2002 and a Chlorine release 

in Graniteville, SC on January 6, 2005. 
 C-7

Questionnaire regarding Emergency Escape Breathing Devices (EEBD) and their 

possible use in the Railroad Community 

BNSF Response 

1. Emergency Protocol 

1.1. If you don’t believe EEBD’s are a necessary safety device for train crews, please explain 

the protocols a train crew should undertake (if any) when there is an unintentional 

release of hazardous and/or toxic material on their consist. 

2. Equipment 

2.1. If EEBD’s were mandated, what type of device would you recommend for your train 

crew? Choose those that apply: 

• Air Purifying – These contain an air-purifying filter, cartridge, or canister that removes 

specific air contaminants by passing ambient air through the air-purifying element. These do 

not supply oxygen and must only be used when there is sufficient oxygen to sustain life and 

the air contaminant level is below the concentration limits of the device. Common choices 

are as follows: 

o Particulate respirators use a mechanical filter to remove particulate matter such as 

dusts. 

o Gas and vapor respirators (or chemical cartridge respirators) use chemicals such as 

activated charcoal to remove specific gases and vapors from the air. These are 

effective for concentrations of no more than ten times the TLV of the contaminant, if 

the contaminant has warning properties (odor or irritation) below the TLV. 

o Combination respirators have filters for both particulates and vapors. 

o Powered air-purifying respirators (PAPR) use a blower to force the ambient air 

through air-purifying elements to the inlet covering. 

• Compressed Air-Supplying ‘Self-Contained Breathing Apparatus’ (SCBA) – This is 

much like the apparatus a SCUBA diver or fire fighter might use. Air (or oxygen) is supplied 

from a compressed cylinder, usually through a full-face mask, which is worn on the back. 

This gives greater movement than an air-line respirator, but the air supply is limited. Two 

common choices are as follows:

o Open loop system – unused exhaled O2 is lost to atmosphere, hence larger cylinders 

to provide adequate breathing time. Typical breathing duration is 30 minutes.

o Closed loop system – captures and reuses exhaled O2. Scrubber removes CO2 and 

small makeup O2 bottle provides additional O2. Typical breathing duration is a 

minimum of 1 hour.

• Filtering Face piece (dust mask) – the filter is an integral part of the face piece

• Bite Valve with Nose Clamp – breathing through bite valve with nostrils pinched off

• Half Mask – respirator covering the mouth and nose. Requires optimum fit. Facial hair is 

not recommended.

• Full Face piece – respirator designed to seal around the entire face. Must be sized and fitted 

per user, particularly with a closed loop system.

• Negative Pressure Respirator – wearer draws air through filter or cartridge by breathing

2.2. If you believe EEBD’s should be air-supplying versus air-purifying, should the supplied 

gas be compressed ‘clean’ air (ie: grade D) or compressed oxygen? (Note: open loop 

compressed air systems are typically have sizeable cylinders to provide adequate 
 C-8

breathing duration whereas closed loop compressed O2 systems have much smaller 

cylinders, yet provide substantially longer breathing duration). 

2.3. If EEBD’s were mandated, how much breathing time should the device provide? Please 

provide reasoning, taking into consideration the time it may take for the train crew to 

extricate themselves from their immediate surroundings which may be encompassed 

with a toxic cloud. 

2.4. If EEBD’s were mandated, what do you think would constitute a reasonable shelf life of 

the device before mandatory replacement? 

3. Assignment 

3.1. If EEBD’s were mandated, should the devices be assigned to the locomotive or should 

they be assigned to each appropriate employee? 

3.2. If EEBD’s were mandated and assigned to employees, which employees would receive 

the devices (ie: T&E, other)? 

3.3. How many employees would that constitute? 

3.4. How many locomotives are in your fleet: 

• Freight service = 

• Yard/switchers = 

3.5. If EEBD’s were mandated, would they need to accompany personnel on every type of 

locomotive? 

4. Economics 

4.1. If EEBD’s were mandated, what do you believe is a practical price to pay per device? 

4.2. If EEBD’s were mandated, there is certainly going to exist a need for training, 

maintenance, inspection and tracking. Based on the type of device you recommend, how 

would you handle each of these (ie: internally or externally), how often, and what do you 

estimate are the associated costs for the same? 

• Training: (address if training might be one-on-one or in a group, and how often 

training should take place) 

• Maintenance: (address who would be responsible for maintenance and how often it 

should take place, ie: preventative maint.) 

• Inspection; (address who would be responsible for inspection and how often it should 

take place) 

• Tracking: (address who would be responsible for tracking and how often it should 

take place. Please compare a tracking program for EEBD’s to other similar devices 

that need to be present on the consist, such as fire extinguishers. How are those 

tracked?) 

5. Professional Opinion 

5.1. What is your professional opinion about the need or use of these devices for train crews? 

Please elaborate on your answer. 

Do you believe the number of incidents in the form of collisions, derailments or near misses with 

consists carrying Hazmat freight, compared to the number of deaths and injuries resulting from 

the same, warrants the need for EEBD’s for train crews? 
 C-9

Questionnaire regarding Emergency Escape Breathing Devices (EEBD) and their possible 

use in the Railroad Community 

Response by Gregory Oblom, CSX RR 

1. Emergency Protocol 

1.1. If you don’t believe EEBD’s are a necessary safety device for train crews, please explain the 

protocols a train crew should undertake (if any) when there is an unintentional release of 

hazardous and/or toxic material on their consist. 

I don’t believe EEBD’s are necessary. If the train crew were to use simple logic or common 

sense in the event of an unintentional release of hazardous material, they should either decide to 

shelter in place or evacuate the area as quickly as possible. 

2. Equipment 

2.1. If EEBD’s were mandated, what type of device would you recommend for your train crew? 

Choose those that apply: A device similar to Draeger’s QuickAir system. 

• Air Purifying – These contain an air-purifying filter, cartridge, or canister that removes 

specific air contaminants by passing ambient air through the air-purifying element. These do 

not supply oxygen and must only be used when there is sufficient oxygen to sustain life and 

the air contaminant level is below the concentration limits of the device. Common choices 

are as follows: 

o Particulate respirators use a mechanical filter to remove particulate matter such as 

dusts. 

o Gas and vapor respirators (or chemical cartridge respirators) use chemicals such as 

activated charcoal to remove specific gases and vapors from the air. These are 

effective for concentrations of no more than ten times the TLV of the contaminant, if 

the contaminant has warning properties (odor or irritation) below the TLV. 

o Combination respirators have filters for both particulates and vapors. 

o Powered air-purifying respirators (PAPR) use a blower to force the ambient air 

through air-purifying elements to the inlet covering. 

• Compressed Air-Supplying ‘Self-Contained Breathing Apparatus’ (SCBA) – This is 

much like the apparatus a SCUBA diver or fire fighter might use. Air (or oxygen) is supplied 

from a compressed cylinder, usually through a full-face mask, which is worn on the back. 

This gives greater movement than an air-line respirator, but the air supply is limited. Two 

common choices are as follows: 

o Open loop system – unused exhaled O2 is lost to atmosphere, hence larger cylinders 

to provide adequate breathing time. Typical breathing duration is 30 minutes. 

o Closed loop system – captures and reuses exhaled O2. Scrubber removes CO2 and 

small makeup O2 bottle provides additional O2. Typical breathing duration is a 

minimum of 1 hour. 

• Filtering Face piece (dust mask) – the filter is an integral part of the face piece 

• Bite Valve with Nose Clamp – breathing through bite valve with nostrils pinched off 

• Half Mask – respirator covering the mouth and nose. Requires optimum fit. Facial hair is 

not recommended. 

• Full Face piece – respirator designed to seal around the entire face. Must be sized and fitted 

per user, particularly with a closed loop system. 

• Hood – covers entire head 

• Negative Pressure Respirator – wearer draws air through filter or cartridge by breathing 

2.2. If you believe EEBD’s should be air-supplying versus air-purifying, should the supplied gas be 

compressed ‘clean’ air (ie: grade D) or compressed oxygen? (Note: open loop compressed air 
 C-10

systems typically have sizeable cylinders to provide adequate breathing duration whereas closed 

loop compressed O2 systems have much smaller cylinders, yet provide substantially longer 

breathing duration). 

Compressed clean air. 

2.3. If EEBD’s were mandated, how much breathing time should the device provide? Please provide 

reasoning, taking into consideration the time it may take for the train crew to extricate 

themselves from their immediate surroundings which may be encompassed with a toxic cloud. 

10 minutes 

2.4. If EEBD’s were mandated, what do you think would constitute a reasonable shelf life of the 

device before mandatory replacement? 

3. Assignment 

3.1. If EEBD’s were mandated, should the devices be assigned to the locomotive or should they be 

assigned to each appropriate employee? 

Our experience with on-board accountability of anything that isn't bolted down is that they tend to 

disappear or be tampered with. Our experience has lead us to a system whereby each employee is 

typically issued the "device" and held accountable for it care and safekeeping. 

Case in point, when it was required that we provide train crew members with emergency response 

information (the DOT emergency response guidebook) we initially placed them in holders in the 

locomotive cab. After about a year of constant replacing -- and crews refusing to depart because 

there was no book -- we found it easier and more cost effective to issue to each T&E employee 

and state via the rules that they must have a copy in their possession while on duty. 

3.2. If EEBD’s were mandated and assigned to employees, which employees would receive the 

devices (ie: T&E, other)? T&E only 

3.3. How many employees would that constitute? 16,000 

3.4. How many locomotives are in your fleet: 

• Total = 3,800 

• Freight service = 

• Yard/switchers = 

3.5. If EEBD’s were mandated, would they need to accompany personnel on every type of 

locomotive? 

4. Economics 

4.1. If EEBD’s were mandated, what do you believe is a practical price to pay per device? $435.00 

(ref. Draeger QuickAir device) 

4.2. If EEBD’s were mandated, there is certainly going to exist a need for training, maintenance, 

inspection and tracking. Based on the type of device you recommend, how would you handle 

each of these (ie: internally or externally), how often, and what do you estimate are the 

associated costs for the same? 

• Training: (address if training might be one-on-one or in a group, and how often training 

should take place) 
 C-11

• Maintenance: (address who would be responsible for maintenance and how often it should 

take place, ie: preventative maint.) 

• Inspection; (address who would be responsible for inspection and how often it should take 

place) 

• Tracking: (address who would be responsible for tracking and how often it should take place. 

Please compare a tracking program for EEBD’s to other similar devices that need to be 

present on the consist, such as fire extinguishers. How are those tracked?) 

5. Professional Opinion 

5.1. What is your professional opinion about the need or use of these devices for train crews? Please 

elaborate on your answer. 

Largely unnecessary. If the train crew were to use simple logic or common sense in the event of 

an unintentional release of hazardous material, they should either decide to shelter in place or 

evacuate the area as quickly as possible. 

Do you believe the number of incidents in the form of collisions, derailments or near misses with 

consists carrying Hazmat freight, compared to the number of deaths and injuries resulting from 

the same, warrants the need for EEBD’s for train crews? 
 C-12

Questionnaire regarding Emergency Escape Breathing Devices (EEBD) and their possible 

use in the Railroad Community 

Response by Lyndle Burton, Canadian National RR 

1. Emergency Protocol 

1.1. If you don’t believe EEBD’s are a necessary safety device for train crews, please explain the 

protocols a train crew should undertake (if any) when there is an unintentional release of 

hazardous and/or toxic material on their consist. 

Train crew needs to either disconnect engine or walk/run upwind of the gas cloud. 

2. Equipment 

2.1. If EEBD’s were mandated, what type of device would you recommend for your train crew? 

Choose those that apply: 

• Air Purifying – These contain an air-purifying filter, cartridge, or canister that removes 

specific air contaminants by passing ambient air through the air-purifying element. These do 

not supply oxygen and must only be used when there is sufficient oxygen to sustain life and 

the air contaminant level is below the concentration limits of the device. Common choices 

are as follows: 

o Particulate respirators use a mechanical filter to remove particulate matter such as 

dusts. 

o Gas and vapor respirators (or chemical cartridge respirators) use chemicals such as 

activated charcoal to remove specific gases and vapors from the air. These are 

effective for concentrations of no more than ten times the TLV of the contaminant, if 

the contaminant has warning properties (odor or irritation) below the TLV. 

o Combination respirators have filters for both particulates and vapors. 

o Powered air-purifying respirators (PAPR) use a blower to force the ambient air 

through air-purifying elements to the inlet covering. 

• Compressed Air-Supplying ‘Self-Contained Breathing Apparatus’ (SCBA) – This is 

much like the apparatus a SCUBA diver or fire fighter might use. Air (or oxygen) is supplied 

from a compressed cylinder, usually through a full-face mask, which is worn on the back. 

This gives greater movement than an air-line respirator, but the air supply is limited. Two 

common choices are as follows: 

o Open loop system – unused exhaled O2 is lost to atmosphere, hence larger cylinders 

to provide adequate breathing time. Typical breathing duration is 30 minutes. 

o Closed loop system – captures and reuses exhaled O2. Scrubber removes CO2 and 

small makeup O2 bottle provides additional O2. Typical breathing duration is a 

minimum of 1 hour. 

• Filtering Face piece (dust mask) – the filter is an integral part of the face piece 

• Bite Valve with Nose Clamp – breathing through bite valve with nostrils pinched off 

• Half Mask – respirator covering the mouth and nose. Requires optimum fit. Facial hair is 

not recommended. 

• Full Face piece – respirator designed to seal around the entire face. Must be sized and fitted 

per user, particularly with a closed loop system. 

• Hood – covers entire head 

• Negative Pressure Respirator – wearer draws air through filter or cartridge by breathing 

2.2. If you believe EEBD’s should be air-supplying versus air-purifying, should the supplied gas be 

compressed ‘clean’ air (ie: grade D) or compressed oxygen? (Note: open loop compressed air 

systems typically have sizeable cylinders to provide adequate breathing duration whereas closed 

loop compressed O2 systems have much smaller cylinders, yet provide substantially longer 
 C-13

breathing duration). Supplied compressed ‘clean’ air because it’s logistically easier to fill with 

air (ie: finding a local dive shop to do refills) 

2.3. If EEBD’s were mandated, how much breathing time should the device provide? Please provide 

reasoning, taking into consideration the time it may take for the train crew to extricate 

themselves from their immediate surroundings which may be encompassed with a toxic cloud. 

30 minutes 

2.4. If EEBD’s were mandated, what do you think would constitute a reasonable shelf life of the 

device before mandatory replacement? 

3. Assignment 

3.1. If EEBD’s were mandated, should the devices be assigned to the locomotive or should they be 

assigned to each appropriate employee? Employee assigned 

3.2. If EEBD’s were mandated and assigned to employees, which employees would receive the 

devices (ie: T&E, other)? T&E 

3.3. How many employees would that constitute? 3,800 

3.4. How many locomotives are in your fleet: 

• Total = 

• Freight service = 

• Yard/switchers = 

3.5. If EEBD’s were mandated, would they need to accompany personnel on every type of 

locomotive? 

4. Economics 

4.1. If EEBD’s were mandated, what do you believe is a practical price to pay per device? $1,500.00 

USD 

4.2. If EEBD’s were mandated, there is certainly going to exist a need for training, maintenance, 

inspection and tracking. Based on the type of device you recommend, how would you handle 

each of these (ie: internally or externally), how often, and what do you estimate are the 

associated costs for the same? 

• Training: (address if training might be one-on-one or in a group, and how often training 

should take place) Assume 1 hour face-to-face training per employee (direct time/wages not 

included) plus the expense of the trainer. 

• Maintenance: (address who would be responsible for maintenance and how often it should 

take place, ie: preventative maint.) 

• Inspection; (address who would be responsible for inspection and how often it should take 

place) Each employee would check their device at the beginning and end of each run. The 

FRA will also spot inspect. 

• Tracking: (address who would be responsible for tracking and how often it should take place. 

Please compare a tracking program for EEBD’s to other similar devices that need to be 

present on the consist, such as fire extinguishers. How are those tracked?) It’s likely that 

Dangerous Goods Reps from our Hazmat Dept, not IH Dept would track the devices. 

Generally speaking, this would be an extremely demanding logistical problem for CN. 

5. Professional Opinion 

5.1. What is your professional opinion about the need or use of these devices for train crews? Please 

elaborate on your answer. EEBD’s are routinely used in mines. But mines are a captured entity 

whereas our RR has over 7K miles of track, so tracking & maintenance would be difficult, if not 

impossible and expensive to the company. 

Do you believe the number of incidents in the form of collisions, derailments or near misses with consists 

carrying Hazmat freight, compared to the number of deaths and injuries resulting from the same, warrants 

the need for EEBD’s for train crews? 
 C-14

Union Pacific Railroad (UPRR) Response 11-16-07 

Questionnaire regarding Emergency Escape Breathing Devices (EEBD) and 

their possible use in the Railroad Community 

1. Emergency Protocol 

1.1. If you don’t believe EEBD’s are a necessary safety device for train crews, please explain 

the protocols a train crew should undertake (if any) when there is an unintentional 

release of hazardous and/or toxic material on their consist. 

UPRR Response to Question 1: The UPRR Industrial Hygiene and Safety Engineering 

(IH&SE) staff has carefully reviewed the National Transportation Safety Board (NTSB) 

recommendations. A comprehensive risk assessment and feasibility study related to train 

crews, associated with an unintentional release of hazardous material, should be performed 

by a qualified, disinterested professional, before it is determined whether an Emergency 

Escape Breathing Apparatus (EEBA) or other escape device is necessary. This risk 

assessment should include quantification of exposure risk, a feasibility study, and a 

comparison of similar industries transporting hazardous chemicals. The UPRR IH staff 

has serious concerns regarding TPI, Inc. performing this risk assessment, since TPI 

supplies escape apparatus and naturally has a commercial interest in the outcome of this 

process. 

Current UPRR Policy, per Instructions for Handling Hazardous Materials in Form 8620, is 

that crew members will not be involved in hazardous material spill recovery, and should 

get out of harms way as quickly as possible. Our train crews receive regular training 

related to handling hazardous material shipments. 

2. Equipment 

2.1. If EEBD’s were mandated, what type of device would you recommend for your train 

crew? Choose those that apply: 

• Air Purifying – These contain an air-purifying filter, cartridge, or canister that removes 

specific air contaminants by passing ambient air through the air-purifying element. These do 

not supply oxygen and must only be used when there is sufficient oxygen to sustain life and 

the air contaminant level is below the concentration limits of the device. Common choices 

are as follows: 

o Particulate respirators use a mechanical filter to remove particulate matter such as 

dusts. 

o Gas and vapor respirators (or chemical cartridge respirators) use chemicals such as 

activated charcoal to remove specific gases and vapors from the air. These are 

effective for concentrations of no more than ten times the TLV of the contaminant, if 

the contaminant has warning properties (odor or irritation) below the TLV. 

o Combination respirators have filters for both particulates and vapors. 

o Powered air-purifying respirators (PAPR) use a blower to force the ambient air 

through air-purifying elements to the inlet covering. 

• Compressed Air-Supplying ‘Self-Contained Breathing Apparatus’ (SCBA) – This is 

much like the apparatus a SCUBA diver or fire fighter might use. Air (or oxygen) is supplied 

from a compressed cylinder, usually through a full-face mask, which is worn on the back. 
 C-15

This gives greater movement than an air-line respirator, but the air supply is limited. Two 

common choices are as follows:

o Open loop system – unused exhaled O2 is lost to atmosphere, hence larger cylinders 

to provide adequate breathing time. Typical breathing duration is 30 minutes.

o Closed loop system – captures and reuses exhaled O2. Scrubber removes CO2 and 

small makeup O2 bottle provides additional O2. Typical breathing duration is a 

minimum of 1 hour.

• Filtering Face piece (dust mask) – the filter is an integral part of the face piece

• Bite Valve with Nose Clamp – breathing through bite valve with nostrils pinched off

• Half Mask – respirator covering the mouth and nose. Requires optimum fit. Facial hair is 

not recommended.

• Full Face piece – respirator designed to seal around the entire face. Must be sized and fitted 

per user, particularly with a closed loop system.

• Negative Pressure Respirator – wearer draws air through filter or cartridge by breathing

UPRR Response to Question 2.1: To the best of my knowledge, the term “emergency 

escape breathing device” is not one recognized or used by the National Institute for 

Occupational Safety and Health. The term used by NIOSH when talking about such 

equipment is Self-Contained Breathing Apparatus (SCBA) – Escape Only, and it applies to 

a limited number of schedule 13F- respirators, all of which are designed for the express 

purpose of allowing employees to escape hazardous environments, including those that are 

immediately dangerous to life and health (IDLH). This is the list of 39 NIOSH-certified 

escape respirators with loose-fitting hoods that could potentially be appropriate for use by 

train engine and yard employees. 

Certified Equipment List Search 

CEL Results 

Selection Criteria 

Schedule(s) 

 13F - Self Contained Breathing Apparatus (SCBA) 

Face Piece Type(s) 

 Hood 

SCBA Use = Escape Only 

Do NOT Include Obsolete Respirators 

Schedule Approval # Manufacturer 

13F 0111 International Safety Instruments, Inc. ELSA 5 Hood 

13F 0145 International Safety Instruments, Inc. ELSA 10 Hood 

13F 0172 North Safety Products 845 Hood 

13F 0173 International Safety Instruments, Inc. ELSA 7XF Hood 

13F 0178 Respiratory Systems, Inc. Lifeair 10 Minute EEBA Hood 

13F 0179 Respiratory Systems, Inc. Lifeair 5 Minute EEBA Hood 

13F 0182 Dräger Safety, Inc. MAX Hood 

13F 0193 Respiratory Systems, Inc. Lifeair 5 minute High Flow EEBA Hood 

13F 0195 North Safety Products 850 Hood 

13F 0198 North Safety Products 855 Hood 
 C-16

13F 0200 Dräger Safety, Inc. ERMA Hood 

13F 0201 International Safety Instruments, Inc. ELSA 5XF Hood 

13F 0205 Airolife Safety, Inc. 550HF-7 Hood 

13F 0216 Mine Safety Appliances Company Custom Air V Hood 

13F 0217 Mine Safety Appliances Company Custom Air V Hood 

13F 0231 Survivair, Inc. EBA-5 Hood 

13F 0232 Survivair, Inc. EBA-10 Hood 

13F 0241 Respiratory Systems, Inc. Lifeair 7 minute High Flow EEBA Hood 

13F 0254 Mine Safety Appliances Company Custom Air V Hood 

13F 0255 Survivair, Inc. HF5 Hood 

13F 0291 International Safety Instruments, Inc. ELSA 6XF Hood 

13F 0347 Dräger Safety, Inc. Quick Air-5 Hood 

13F 0348 Dräger Safety, Inc. Quick Air-10 Hood 

13F 0349 Dräger Safety, Inc. Quick Air-H5 Hood 

13F 0395 Dräger Safety, Inc. QuickAir 5 Hood 

13F 0429 AVOX Systems Inc. 10 Min EEBD Hood 

13F 0438 Respiratory Systems, Inc. Lifeair 15 Hood 

13F 0445 Mine Safety Appliances Company Transair 5 Hood 

13F 0446 Mine Safety Appliances Company Transair 10 Hood 

13F 0470 International Safety Instruments, Inc. 5 minute EEBA Hood 

13F 0471 International Safety Instruments, Inc. 10 minute EEBA Hood 

13F 0484 Interspiro USA, Inc. Spiroscape HP 10 Minute Hood 

13F 0485 Interspiro USA, Inc. Spiroscape HP 15 minute Hood 

13F 0486 Scott Health & Safety Ltd Sabre ELSA 5 Hood 

13F 0487 Scott Health & Safety Ltd Sabre ELSA 10 Hood 

13F 0488 Scott Health & Safety Ltd Sabre ELSA 5HF Hood 

13F 0524 International Safety Instruments, Inc. CEEBA, 5 MINUTE Hood 

13F 0525 International Safety Instruments, Inc. CEEBA, 10 MINUTE Hood 

13F 0530 Scott Health & Safety Ltd ELSA 15 Hood 

Total records found: 39 

Records shown: 1 to 39 

Last Updated 10/12/2007 8:41:27 AM 

2.2. If you believe EEBD’s should be air-supplying versus air-purifying, should the supplied 

gas be compressed ‘clean’ air (ie: grade D) or compressed oxygen? (Note: open loop 

compressed air systems typically have sizeable cylinders to provide adequate breathing 

duration whereas closed loop compressed O2 systems have much smaller cylinders, yet 

provide substantially longer breathing duration). 

Response to Question 2.2: UPRR is limited to those devices certified by NIOSH per OSHA 

29CFR1910.134. To the best of my knowledge, a closed loop compressed oxygen system is 

not presently certified by NIOSH for industry use. 

2.3. If EEBD’s were mandated, how much breathing time should the device provide? Please 

provide reasoning, taking into consideration the time it may take for the train crew to 
 C-17

extricate themselves from their immediate surroundings which may be encompassed 

with a toxic cloud. 

Response to Question 2.3: To answer this question more scientifically, a disinterested, 

third-party professional should review the history of hazardous material accidents 

requiring crew evacuation to determine whether such devices would be, on balance, 

beneficial or harmful and, if beneficial, the appropriate requirement. 

2.4. If EEBD’s were mandated, what do you think would constitute a reasonable shelf life of 

the device before mandatory replacement? 

Response to Question 2.3: Shelf life should be consistent with the present requirements of 

OSHA 29CFR1910.134(g)(3), (h) and (i).

3. Assignment 

3.1. If EEBD’s were mandated, should the devices be assigned to the locomotive or should 

they be assigned to each appropriate employee? 

Response to Question 3.1: There are advantages and disadvantages to either choice. There 

are many parameters that need to be considered, such as EEBA size and weight, before a 

system design could be appropriately developed. Another option may be to contract an 

engineering firm to maintain, inspect and issue the equipment including employee training. 

The equipment would be checked-in and checked-out each work day by employees 

performing specific train operation duties. Again, a comprehensive risk assessment would 

be used to develop an appropriate system design. 

3.2. If EEBD’s were mandated and assigned to employees, which employees would receive 

the devices (ie: T&E, other)? 

Response to Question 3.2: All train, engine and yard (TE&Y) employees and other 

occupants whose duties require riding in locomotive cabs. 

3.3. How many employees would that constitute? 

Response to Question 3.3: This is difficult to estimate; however, there are approximately 

24,000 TE&Y employees. 

3.4. How many locomotives are in your fleet: 

• Freight service = Approximately 6500

• Yard/switchers = Approximately 2100 

3.5. If EEBD’s were mandated, would they need to accompany personnel on every type of 

locomotive? 
 C-18

Response to Question 3.5: We do not understand this question. 

4. Economics 

4.1. If EEBD’s were mandated, what do you believe is a practical price to pay per device? 

Response to Question 4.1: Current information is approximately $400 per 10-15 minute 

EEBA unit. 

4.2. If EEBD’s were mandated, there is certainly going to exist a need for training, 

maintenance, inspection and tracking. Based on the type of device you recommend, how 

would you handle each of these (ie: internally or externally), how often, and what do you 

estimate are the associated costs for the same? 

• Training: (address if training might be one-on-one or in a group, and how often 

training should take place) 

• Maintenance: (address who would be responsible for maintenance and how often it 

should take place, ie: preventative maint.) 

• Inspection; (address who would be responsible for inspection and how often it should 

take place) 

• Tracking: (address who would be responsible for tracking and how often it should 

take place. Please compare a tracking program for EEBD’s to other similar devices 

that need to be present on the consist, such as fire extinguishers. How are those 

tracked?) 

Response to Question 4.1: 

Training, maintenance, inspection, and tracking will certainly cause logistical challenges for 

approximately 24,000 UPRR TE&Y employees. Assuming EEBAs would be carried in each 

train crew grip, estimated costs would include the following: 

• $10,000,000 for EEBA purchase 

• $11,000,000 for transponder EEBA tracking systems * 

• $15,000,000 for maintenance, inspection, and tracking 

* This cost estimate includes a transponder based check-in/check-out system, which may be necessary to automate 

distribution at 430 crew change locations for a relatively heavy (greater than 4 pounds) “SCBA-escape only” system 

distribution. 

Training: Annual training including “hands-on” practice. Training should include a short 

lecture using Powerpoint or something similar in small groups of 5 to 10 employees maximum. 

Re-cert training after initial training recommended. 

Maintenance: UPRR IH&SE have successfully used consulting engineering firms for small 

pools of several hundred TE&Y traveling through tunnels, but the magnitude of this task would 
 C-19

max out the available manpower pool for one consultant firm very quickly. Numerous 

consulting firms would need to be involved, all with the same scope of work, equipment and 

following the same Federally required maintenance procedures. More than likely, multiple 

manufacturing firms would need to supply the EEBAs with the same specifications. Each 

manufacturer should be required to provide spare parts for a minimum of seven years after the 

last respirator of a given year group comes off their assembly line. 

Inspection: A consulting engineering firm. 

Tracking: Each EEBA should have an embedded bar-code or transponder assigned to the entire 

unit – hood, regulator, hose lines, tanks and cases. Replacement of any component would 

require the manufacturer to manage the replacement and update the bar-code/transponder for the 

entire unit. A very large number of EEBAs would be involved; as a result, automation 

technology would be necessary for proper EEBA tracking and maintenance. 

5. Professional Opinion 

5.1. What is your professional opinion about the need or use of these devices for train crews? 

Please elaborate on your answer. 

5.2. Do you believe the number of incidents in the form of collisions, derailments or near 

misses with consists carrying Hazmat freight, compared to the number of deaths and 

injuries resulting from the same, warrants the need for EEBD’s for train crews? 

Response to Question 5.1 and 5.2: 

We researched our records and identified one TE&Y conductor fatality related to a 

hazardous material release. Our major concern is that EEBAs may be counter productive 

for emergency escape, causing our TE&Y employees to spend extra time in a potentially 

hazardous area. In addition, the feasibility of complying with federal standards related to 

pressurized air tank maintenance and hands-on training for 24,000 employees 24/7 also 

raises concerns. EEBAs have limited usefulness when considering the multitude of 

chemical release scenarios. 

The railroad industry would be best served by a scientific approach. Specifically, the 

UPRR IH&SE staff recommend a disinterested, third party professional risk analysis, 

before discussing EEBA system design. 

5.3. Regarding the use of EEBD’s in the Moffat Tunnel: 

• How successful has the program been? 

• What lessons have been learned? 

• What would you do differently? 

• Can you incorporate any lessons learned from that program that would help in a 

system-wide EEBD approach? 

Response to Question 5.3: 

• How successful has the program been? 
 C-20

The Moffat Tunnel program includes 30-minute Self-Contained-Breathing-Apparatus 

(SCBA) systems specifically designed for tunnel emergencies. This system has been very 

successful during train stalls involving potentially high diesel emission exposure, not 

hazardous material release. 

• What would you do differently? 

We would do nothing differently. 

• Can you incorporate any lessons learned from that program that would help in a 

system-wide EEBD approach? 

Employee training, SCBA maintenance, and SCBA tracking is critical for a successful program. 

Training, including hands-on training, must be available at all times for efficient railroad 

operations. 
 D-1 

Appendix D 

Non-Passenger T&E Employees - on duty (A) casualties 

Source: Federal Railroad Administration Safety Database - 4.02 Casualty Data Reports 

Reporting Overall Collision Collision Derailment Derailment Inhalation Inhalation 

Year Casualties Casualties Fatalities Casualties Fatalities Casualties Fatalities 

 

1997 2834 96 8 38 0 58 0

1998 3004 86 1 37 0 86 0

1999 3211 76 7 54 1 73 0

2000 3169 82 2 44 0 63 0

2001 2872 86 4 50 0 68 0

2002 2405 84 2 46 1 50 0

2003 2281 75 2 44 1 63 0

2004 2211 73 5 55 0 70 1

2005 2102 84 0 27 0 69 1

2006 1852 60 1 28 0 64 0

10 year 

Avg 2594.1 80.2 3.2 42.3 0.3 66.4 0.2
E‐1

Appendix E 

AAR’s Cost/Benefit Analysis – Equipping T&E Employees 
E‐2

AAR’s Cost/Benefit Analysis – Equipping T&E Locomotives 
F-1

Appendix F 

Cost Schedule - Positive Pressure, Open Loop SCBA with Hood, Grade D Pressurized Air Supply, Assigned to 

Employee 

Cost Schedule - Positive Pressure, Open Loop SCBA with Hood, Grade D Pressurized Air Supply, Assigned to 

Locomotive
F-2

Cost Schedule - For Positive Pressure, Closed Loop SCBA with Mouthpiece, Oxygen Pressurized Air Supply, 

Assigned to Employee 

Cost Schedule - For Positive Pressure, Closed Loop SCBA with Mouthpiece, Oxygen Pressurized Air Supply, 

Assigned to Locomotive