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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 hidden. They are set forth for all to read in the 80th Annual Report of the ICC, at pages 64–65. Here is what the Commission says at that place:

In the 30 years of administering safety regulations for interstate buses and trucks, the Commission has required the reporting of accidents only by common and contract carriers. It has been estimated that private carriers and for-hire carriers of so-called exempt commodities number six times as many as authorized carriers. Yet, the total number of vehicles operated by nonlicensed carriers is approximately equal to the number of vehicles operated by authorized carriers.

Because we have no accident reports from private carriers of property and very few reports from carriers of exempt commodities, our knowledge of accident trends necessarily is limited to data gained from reports filed by common and contract carriers subject to the Commission's economic regulation.

It is therefore evident that Mr. Homer has made a direct comparison of the railroad industry statistics (including many deaths occurring at grade crossings, which are basically problems of highway safety) with statistics of two other transportation industries which are (1) partial, and (2) reported on a narrower basis.

He uses this comparison to suggest that because these other industries are subject to broad safety regulation, the railroad industry should be regulated similarly. His comparison and his suggested conclusion are both false.

On the L. & N. we have had for many years printed safety rules which are guidelines for employees in safely performing their work. Each officer and supervisor has an accident prevention manual which spells out his duties and responsibilities.

New safety posters are displayed each month, and more often if the occasion demands. In each shop and in each gang safety meetings are held prior to the beginning of work. Men in train and engine service are furnished an illustrated booklet giving specific safety tips and suggestions on their particular work. Each month all supervisors receive new material for suggested safety talks with their men.

A continuing educational program in traffic safety is carried on for all employees who drive company-owned motor vehicles in their work. Each month each employee driver receives a new booklet on traffic safety tips. Periodically inspections are made of all properties for housekeeping and fire-safety hazards.

Inspections regularly are made of yards and terminals to see that conditions are safe for men to work. Employees from different crafts are appointed as safety committeemen. In that capacity they talk with all employees about safe work practices and look for and report housekeeping and fire hazards.

Monthly trophies are awarded for the department of each operating division having the best employee safety performance.

At the end of each year the three divisions having the best safety record receive plaques as a permanent recognition of safety attainment.

On the night of Tuesday, May 21, 1968, more than 500 employees (and their wives and children) of our Knoxville and Atlanta division were honored for their outstanding safety performance in 1967. The affair started with dinner, then there was a program of entertainment, following which our vice president-operations presented to the employees the railroad's first-place safety plaque.

My experience has convinced me that programs of this kind have a definite beneficial effect and that they must be continued and even in

tensified. That is because they deal with the element of human attitudes. It is intangible, but it is nevertheless the most important part of safety. A man with the proper attitude toward his safety and that of his associates is bound to be a good worker and a safe worker. Government regulation cannot take the place of that attitude or create it. Thank you, sir.

(Tables A through H, and chart H referred to in Mr. Daulton's statement, follow :) TABLE A.-TOTAL TRAIN ACCIDENTS AND TRAIN ACCIDENTS RESULTING IN CASUALTIES, RAILWAYS OF ALL

CLASSES, 1961-67

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1 Preliminary.
Source: Reports of the Department of Transportation and Interstate Commerce Commission.

TABLE B.-TOTAL CASUALTIES IN RAILROAD ACCIDENTS, RAILWAYS OF ALL CLASSES, 1961-67

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27, 118 29, 245
26,880 28, 986

11.0
27, 456 29, 596

2 1.6 27,614 30, 037

13.2 25, 789 28, 188

11.0
25, 552 28, 236 211.9
24, 194 26, 652

18.4
Total casualties in train accidents
1,062 1,220
1.394
1,595

: 27.2
1,581
1,732

124.9
1, 028
1,219

2 26.5
864

1,055 900 1,114

1 12.0 754

924

1961. 1962. 1963. 1964 1965. 1966. 19673

158 201 151 191 191 214 170

131.3 2 13.4 135.0 115.0

24.2 1 16.2

2 30.7

2 8.6 1 29.6 1 13.5

25.6 117.1

1 20.6

1 Decrease.
? Increase.
3 Preliminary.

Note: Casualties in train accidents were 4.2, 5.5, 5.9, 4.1, 3.7, 3.9, and 3.5 percent of total casualties in the years 1961-67, respectively.

Source: Reports of Department of Transportation and Interstate Commerce Commission.

95–388—68—13

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