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The Interstate Commerce Commission has defined a train accident as one involving the operation of trains which results in damage to railroad property aggregating $750 or more, excluding the cost of clearing. This definition has been taken over by the Department of Transportation. The sole criterion is the monetary damage to railroad property.

For this reason, it does not logically follow that train accidents result in casualties. Some do-but the great majority do not result in death or injury to any person. Between 1961 and 1967, inclusive, train accidents never accounted for more than 5.9 percent of all railroad casualties, and in the last 3 of those years they were less than 4 percent (table B).

A substantial number of train accidents, year by year moreover, are grade crossing accidents, which are more an element of highway than of railroad safety.

Even if one were to assume that casualties in train accidents are significant as a measure of railroad safety, the Secretary and the Chairman of the Board have not presented the complete picture. Both of them stress the increase in the number of train accidents in recent years. Neither of them, however, has stated the fact that during this same period casualties resulting from train accidents have decreased from 1.220 in 1961 to 924 in 1967, or a positive improvement of 24.3 percent.

The $750 limit for reporting train accidents was set by the Interstate Commerce Commission effective January 1, 1957. There has been no subsequent adjustment since that date to take into account the increase in prices and wages. The railroads are reporting more accidents today in part because the cost minimum has not kept pace with the times.

The dollar measure of train accidents has been stressed by other witnesses; but I do not believe any witness has mentioned the fact that casualty reporting required of railroads also differs from that required of other industries, whether for train accidents or any other kind of accident.

Under rules promulgated by the Interstate Commerce Commission following enactment of the Accident Reports Act, which were in effect prior to 1961, a reportable fatality is one which results in death within 24 hours after the hour of the accident; and a reportable injury used to be one which resulted in incapacitation of the injured employee for more than 72 hours within the 10-day period-240 hours-immediately following the accident.

In revised reporting rules issued by the Commission, effective January 1, 1961, the definition of a reportable injury was changed to cover incapacitation of the injured employee for more than 24 hours within the 10 days-240 hours-immediately following the accident. The theory for shortening of the period for reportability from 72 hours to 24 hours presumably was that the railroads should be on the same basis as all other industries.

The railroads are governed by rigid Federal law in reporting casualties. Under Department of Transportation rules, an injured employee must be able to return to duty within 24 hours and to the same job he was performing at the time he was injured for the case not to be considered reportable.

Industry generally follows United States of America Standards Institute Standard Ž.16-1 which permits an injured employee to return to any regularly established job. This standard permits a machinist who is injured and cannot return to operating his machine to be placed on, for example, a job in the stockroom counting or issuing tools or materials.

However, a railroad section laborer who is injured laying rails must be able to perform all the duties of his job and cannot be used on a less strenuous, but regularly established, job such as sorting track bolts or providing flag protection.

Too, other industry is permitted to rely upon what the attending physician has to say about an injured employee's incapacity; but the railroads, while they may consider what the doctor says, must rely ultimately on the employee's statement as to his ability to work. A doctor may examine an allegedly injured railroad employee, find no evidence of any injury, and release the man for return to work, but if the man himself believes that he cannot work, the railroads must consider the case reportable.

Thus, it can be seen that the railroads still are not on the same reporting basis as industry generally. If they were, the statistical safety record would be correspondingly improved.

Those who have used air services have heard the oft-repeated admonition of the stewardess to remain seated and keep seatbelts fastened until the pilot has brought the engines to a stop. This warning serves a twofold purpose: first, the airline does not want its passengers to be hurt and, second, if an accident occurs to a passenger after the engines have been stopped, it is not considered reportable.

On the other hand, if a train has come to a complete stop and a passenger or crew member falls down the steps of a coach in detraining and is injured, the railroads are required to report such an occurrence as a "train service" accident. This is another area in which these two modes of transportation are not on the same basis.

The year 1960 was the last year that the railroads were accorded a 72-hour period for reporting employee injuries. During that year, there were reported to the Interstate Commerce Commission 13,245 employee injuries. In 1961, when the reporting period was shortened to 24 hours, there were reported 19,682 employee injuries, or a 48.6-percent increase. However, since 1961, there has been a marked decline in total railroad employee casualties. In 1961, deaths and injuries totaled 19,819, and in 1967 according to preliminary Federal Railroad Administration figures they totaled 17,466, an 11.9-percent decrease. Since 1961, total casualties to all classes of persons in all types of railroad accidents have also declined. In 1961 there were 29,245 such casualties and in 1967, according to preliminary figures, there were 26,652. This is a decline of 8.9-percent (table C).

This, in my opinion, is more meaningful than any statistics about numbers of "train accidents."

Under existing reporting rules, casualties to railroad employees are divided into three categories. The first is "train accidents" which I have already described.

The second category is "train service" accidents, which encompasses any casualty which occurs in an accident arising in connection with the operation or movement of trains or cars and which does not damage

railroad property to the extent of $750. I have already given an example of certain types of accidents in this category that railroads must report, but airlines do not. Similar limitations apply to truck carriers under DOT safety jurisdiction.

The third category is "nontrain" accidents, which covers men in railroad repair shops, trackmen, signalmen, bridge, and building men. It also covers employees such as salesmen on duty but not on railroad property. Here again the railroads must report numerous accidents. that airlines and trucks do not. A good example in accidents in repair shops.

As compared with these other industries, therefore, the railroads. must report a much wider variety of accidents, many of which do not arise directly from the performance of transportation services. We have no objection to this method of reporting except when the resulting statistics are misused.

One form of misuse is to compare total reported accidents or casualties in railroading with total reported accidents or casualties of truck lines or airlines. Since the reporting bases differ the results are not comparable.

Total casualties in "train accidents" have been declining since the end of 1962. In fact, comparing 1967 with 1963, there has been a 46.7 reduction (table D).

Mr. O'Connell's letter does not mention this.

In casualties to employees on duty attributable to "train-service" accidents, the majority of which occur in yards and terminals, there has been a 3-percent reduction, comparing 1966 with 1961. The reduction in "non-train" accident casualties to employees on duty (using the same base years, 1966 and 1961) was 14.5 percent (table D).

And, as previously mentioned, the reduction in all types of casualties suffered by employees on duty, comparing 1967 with 1961, was 11.9 percent (table C).

I have used 1966 rather than 1967 in certain of the comparisons I have just made because the earlier year is the only one for which all the necessary cause separations have been made.

In 1961, all industries reporting their casualties to the National Safety Council had a composite casualty ratio of 5.99 per million manhours worked. For the year 1966, that ratio had gone up to 6.91 disabling injuries per million man-hours worked. Using the same statistical source for the 2 years-1961 and 966-it is interesting to note that practically every industry group had an increase in its casualty ratio. For example: Communications went from .93 to 1.26; cement from 2.91 to 4.10; shipbuilding from 3.97 to 6.14; pulp and paper from 7.39 to 8.08; iron and steel products from 7.77 to 10.48; meat packing from 14.06 to 21.00; air transport from 14.94 to 19.50.

Based solely on man-hours worked, the casualty ratio for all class I railroads in 1961 was 11.98, and in 1967, 12.01-an increase of only three one-hundredths of a point (table E).

However, man-hours alone are not a realistic yardstick for measuring performance. Primarily railroads are haulers of freight. They sell ton-miles. Shippers are not interested in whether it takes one man or a thousand men to move a carload of freight from one point to another. Shippers are interested in freight being moved expeditiously and economically.

The railroads, on the other hand, must be concerned with their ability to move the freight traffic they obtain with the smallest possible expenditure of man-hours. Technological improvements in recent years have expanded this ability. As a result, railroads are today able to move the same amount of freight with the use of fewer man-hours than was possible only a few years ago.

A better way to equate railroad safety, therefore, is to compare casualties to billion gross tons handled. In 1961 there were 12.32 casualties to employees per billion gross ton-miles. In 1967 casualties to employees per billion gross ton-miles had dropped to 8.94 (table E). Another method of measurement is casualties per million trainmiles. In 1961 that figure was 12.35. At the end of 1966 it had declined to 11.93 (table F).

I have attached tables to my statement which amplify certain of the comments made in the statement of Mr. Menk (tables G and H and chart H).

In one of the statements filed by Chesser in the course of these hearings he criticized the railroads for using the ton-mile measure to show the frequency of employee casualties. He calls it "a completely unreliable index."

Of course, we do not use that measure exclusively. I have already given in this statement and the attachments the frequency ratios measured by both man-hours and train-miles, and I am not ashamed of them. I have shown, for example, that the railroad employee casualty ratio measured by man-hours-which Mr. Chesser suggests is the only valid measure-has increased by ony an extremely small percentage since 1961, and a percentage far smaller than that experienced by numerous other industries.

Whatever one may think of Mr. Chesser's views in this respect, some of the ratios used by his associates among the labor proponents of this bill as set out in Mr. Homer's "Supply Memorandum" are not only unreliable but wholly unrealistic, leading as they do to distorted conclusions.

Table 16 of Mr. Homer's memorandum, for example, is headed "Train Accidents Caused by Roadway Defects" and he measures the frequency of these train accidents by millions of locomotive and motor train-miles.

Such a measure might be acceptable for train accidents caused by interlocking and block signal systems, but very few accidents result from that cause. Indeed, according to Mr. Homer's figures, over the 6-year period 1961-66 an average of less than three such accidents occurred in each year.

On the same table, however, Mr. Homer also shows the frequency of train accidents caused by all other way and structure defects and uses the same measure of locomotive miles. This is absurd because the matters involved are rails, bridges, roadbed, ballast, ties, fasteners, and the like, all subject to the wear and tear of traffic.

The volume of traffic to which these structures are subjected is, therefore, the critical measure of their exposure to the chance of accident and the volume of traffic can be measured only by gross ton miles moving over the structures, not locomotive miles. It is obvious that a train consisting of a locomotive and 5,000 trailing gross tons exerts greater stress and wear and tear on the track structure than a locomotive with 1,000 trailing gross tons.

On table 18 of Mr. Homer's memorandum he again uses million locomotive and motor train miles to measure the ratio of train accidents caused by defects in equipment.

A train of 100 cars creates an exposure to the danger of train accidents by reason of car defects or failures that is 10 times greater, potentially, than does a train having only 10 cars in it, but if each of these trains travels the same distance each will have produced an identical number of locomotive miles.

Surely when the question is one of defects in equipment, the measure of the incidence of such defects causing accidents must be the miles that equipment covers, not merely the miles covered by locomotives, which constitute but one element of equipment-and a numerically small element at that-when compared with the number of cars.

Exactly the same is true of Mr. Homer's table 21, which relates to collisions as measured by the same factor. Collisions take place in yards even without the agency of a locomotive. In fact, a large percentage of collisions do occur in yards. Very few of them are the horrible head-on meetings of fast-moving road trains that the word "collision" might bring to the mind of someone not familiar with the industry, yet Mr. Homer measures this area of train accidents by locomotive and motor train miles, including all the millions of miles covered by road locomotives.

The same distorting error is repeated in Mr. Homer's tables 20, 25, 27, and 28.

If the railroad industry had attempted to measure casualties or accidents by locomotive miles I would expect to receive severe criticism from Mr. Chesser and his associates.

I should also mention another respect in which Mr. Homer's figures are misleading and place railroads in a bad light without justification. At page 2 of Mr. Homer's memorandum he compares fatalities on railroads with those of air carriers and those on motor carriers which he says were subject to ICC authority.

He then goes on to assert that railroad accidents killed many more persons in the same period than were killed by these other modes of transportation.

I have already indicated that accident reporting requirements as among these three modes of transportation differ so greatly that the results are not comparable. Mr. Homer's comparison is therefore improper.

I must assume that Mr. Homer was unaware of these reporting differences; for I cannot imagine that he would have made the unfair and inflammatory comparison he does on his page 2 if he had known about it.

Unfortunately these errors are not the only ones that infect the conclusions Mr. Homer draws on the second page of his memorandum. At that place he says that 9,236 deaths occurred in accidents involving "motor carriers subject to ICC authority." The committee is left to draw the conclusion that this means carriers subject to the ICC's safety authority, but it does not; the reference is solely to carriers under the ICC's economic authority.

These figures, as set forth by Mr. Homer, would appear to include the entire trucking industry, but according to the estimate of the ICC itself they cover only a fraction of the industry. The facts are not hid

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