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For example, the frequency rate during the second half of the year 1964, when 35.1 percent of all freight and yard operations were conducted without firemen was at substantially the same level as during the same period of the preceding year, and was somewhat under the second half of 1961. There were 6.55 casualties per billion gross ton-miles during the second half of 1961 ; 6.40 during the last half of 1963; and 6.41 during the same months of 1964.

Casualty frequencies during the third quarter of 1964, when 34.0 percent of the service was operated without firemen, were lower than during the same quarter of the year 1961. The casualty rate during the fourth quarter of 1964 was lower than during the fourth quarter of each of the years 1961 and 1963. Although the proportion of the service operated without firemen increased from 34.0 percent during the third quarter of 1964 to 36.2 percent during the fourth quarter of the same year, the casualty rate declined from 6.51 to 6.32. With the exception of the second quarter, all of the 1964 frequency rates show little or no change or declines at the percentage of the service operated without firemen has increased.

As of the present time, figures are not available to permit the calculation of frequency rates for 1965, but the preliminary data now available indicate a continuation of the results reflected on Table D-1, and a probable decline in casualty frequencies in 1965. TABLE D-1.-CASUALTY RATES PER BILLION GROSS TON-MILES IN TRAIN OPERATION TO TRAIN AND ENGINE

SERVICE EMPLOYEES, U.S. RAILROADS

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1 Accident data for all railroads; gross ton-mile data for class I line-haul railroads. Source: ICC Statements M-400 and OS reports.

E. TRAIN ACCIDENTS AND TRAIN ACCIDENT FREQUENCIES As described in Part A, the number of train accidents reported to the ICC are affected by changes in the levels of costs. Because of higher wage rates and increases in the costs of materials and equipment many accidents which were formerly unreportable, because damage involved was less than $750, are now reportable train accidents. As discussed in Part B, the effect of the redistribution of operations among the several classes of employees no doubt has contributed to the increase in train accident frequencies. Nothwithstanding these factors, the increases in train accident frequencies from 1963 to 1964 were less than the increases from 1962 to 1963. (As shown on Table E-1 for the calendar years 1961 to 1965, and on Table E-2 for eight-month periods, May to December, for the same years.)

Preliminary data for the year 1965 on Tables E-1 and E-2 indicate little or no change in the rate of increase in frequency of train accidents in 1965 over 1964, and a considerable reduction in the rate of increase for the period May to December 1964 to 1965 compared with increases between 1962 and 1963 and between 1963 and 1964. The 1965 preliminary train accident figures shown on all of the tables in this series are subject to upward adjustment because of late reporting or corrections. In 1964 the difference between the preliminary and final train accident totals amounted to 3.3 percent. A change of this size in the 1963 preliminary figures would result in a slightly higher rate of increase between 1964 and 1965 than between 1963 and 1964, but the rate of increase in the eight-month period May to December 1961 to 1965 would still be substantially lower than for the comparable period of 1963 to 1964.

Although since 1961 there has been an upward trend in the frequency of train accidents, there appears to be no relationship between these increases and the amount of service that has been operated without firemen since the Award of Arbitration Board 282 became effective. This is evident from an examination of the data appearing on the following tables.

The data appearing on Table E-3 was derived from figures reported on ICC Statements M-400 for the years 1964, 1963, and 1962. Comparable data for the year 1965 is not yet available. The study covers 76 Class I Line-Haul Railroads, representing a substantial majority of all of the Class I Railroads parties to the Arbitration Award. These 76 carriers were grouped into two categories, those that conducted 35 percent or more of their freight and yard service without firemen during the last six months of the year 1964, and those that conducted less than 35 percent of their freight and yard service without firemen during the same period. There were 33 carriers in the first group and 43 carriers in the second group. The operations of each of the two groups produced approximately the same locomotive and motor train-miles.

The first group of 33 carriers conducted 49.1 percent of their operations without firemen during the last six months of the year 1964. The second group of 43 carriers conducted only 25 percent of their operations without firemen during that period.

The data show that prior to the effective date of the Arbitration Award the 33 carriers in the first group experienced greater increases in their train accident rates than the 13 carriers in the second group. However, following the effective date of the Award of the 33 carriers, which conducted nearly 50 percent of their freight and yard operations without firemen, had lesser increases in their train accident rates than the 13 carriers which conducted only 25 percent of their train operations without firemen. The significance of the comparisons on Table E-3 is that they show no relationship between the extent of operations without firemen and changes in train accident frequency rates. This lack of relationship is further illustrated by the quarterly frequency rates shown on the following table.

Train accident frequency rates for each of the four quarters, as well as the annual rates, for the years 1961 through 1965 are shown on Table E-4.

Accident and casualty frequencies during the first quarter of each calendar year are largely determined by weather conditions, and such data are of limited usefulness in evaluating the effect of other factors. By way of illustration, as shown by the United States Weather Bureau data presented by the carriers in September of 1965 before the Committee on Commerce, United States Senate, weather conditions during the first three months of the year 1964 were relatively and unusually dry and mild. Operating conditions were good throughout the country, and accident and casualty frequencies were abnormally low. Weather conditions were more adverse during the first quarter of 1965, operating conditions were severe in certain parts of the country, and the train accident frequency rate increased by 23.3 percent.

However, in each of the second, third, and fourth quarters of 1965 the increase in train accident frequency rates was less than in the corresponding quarters of 1.964 or 1963, although the percent of freight and yard operations without firemen in each of the quarters in 1965 was considerably greater than in the corresponding quarters of 1964, and firemen were employed on practically all freight and yard locomotives in 1963.

The fact that there is no relationship between the extent of operations without firemen and increases in train accident frequencies is further illustrated by an examination of the figures for the third quarter. By the third quarter of 1964, 34 percent of the firemen in freight and yard operations had been eliminated. The percentage increase in the train accident frequency rate was 7.1 percent over the third quarter of the year 1963. In the third quarter of 1963 (prior to the effective date of the Arbitration Award) the percentage increase in train accident frequency over the corresponding quarter of 1962 was 15.5 percent. The same type disparity prevails in the second and fourth quarter rates, with the sole exception of the increase in second quarter of 1964 over the corresponding quarter of 1963.

As previously indicated, the 1965 train accident data and frequency rates are preliminary, and are subject to some upward adjustment. An adjustment of 3.3 percent (the size of the 1964 adjustment) would of course increase the 1963 frequency rates, but not sufficiently to affect the conclusion that there is no relationship between train accident frequency rates and the volume of freight and yard operations operated without firemen.

TABLE E-I.-TRAIN ACCIDENTS AND TRAIN ACCIDENT FREQUENCIES, U.S. RAILROADS, YEARS 1961-65

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TABLE E-2.-TRAIN ACCIDENTS AND TRAIN ACCIDENT FREQUENCIES, U.S. RAILROADS, MAY TO DECEMBER

INCLUSIVE, 1961-65

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TABLE E-3.-TRAIN ACCIDENT RATES (PER MILLION LOCOMOTIVE AND MOTOR TRAIN-MILES), CLASS I LINE

HAUL RAILROADS

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1 Carriers operating 35 percent or more of their freight and yard service without firemen, July-December 1964
2 Carriers operating less than 35 percent of their freight and yard service without firemen, July-December 1964.
Sources: ICC Statements M--400; ICC Operating Statistics and Annual Transport Statistics.

TABLE E-4.-TRAIN ACCIDENTS PER BILLION GROSS TON-MILES, U.S, RAILROADS

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1 Accident data for all railroads; gross ton-mile data for class I line-haul railroads. 1965 accident data and frequency rates are preliminary,

2 Preliminary.
Source: ICC Statements M-400 and M-450 and OS reports.

INTERSTATE COMMERCE COMMISSION,

Washington, D.O., March 14, 1966. Hon. HARLEY O. STAGGERS, Chairman, Committee on Interstate and Foreign Commerce, House of Representatives, Washington, D.O.

DEAR CONGRESSMAN STAGGERS : This is in reply to your letter of March 8, 1966, concerning the increase in defective locomotives found by our Inspectors and an increase in accidents in Fiscal Year 1965.

During Fiscal Year 1965, our District Inspectors inspected a total of 76,044 locomotive units of which 9,391, or 12.3%, were found to have defects which were in violation of the Commission's regulations as compared to 11.1% found defective in Fiscal Year 1964.

Of the total number of locomotive units inspected in Fiscal Year 1965, 616 units, 67 units more than in Fiscal Year 1964, were found to have defects which warranted their being ordered out of service.

In Fiscal Year 1965, 87 accidents were caused by the existence of defects on locomotives which were in operation as compared to 76 accidents in Fiscal Year 1964. We believe that the following factors are involved in this undesirable trend:

The average age of the Nation's locomotive fleet is increasing and approximately 85% of the locomotive units currently in service were built prior to 1958. It may reasonably be expected that increased maintenance is necessitated by the increased age.

During the last several years, there has been an appreciable increase in the number of miles operated daily by locomotives and they are now hauling more cars containing heavier loads and at higher speeds.

During the last several years, there has been a trend on the part of the carriers to centralize locomotive maintenance facilities. Consequently, there are now fewer facilities and fewer inspection and maintenance personnel than were available in the past.

We believe that on some railroads the quality of inspection and repair procedures used by carrier personnel has deteriorated. This belief is supported in part by the fact that the majority of locomotive units found defective and/or ordered out of service by our District Inspectors had previously been inspected by carrier personnel and were ready for service.

It is our further belief that accident potential, and consequently the number of accidents, increase as the operation of defective locomotives increase. If any further information is desired, we will be pleased to furnish it. Sincerely,

JOHN W. Bush,

Chairman.

ASSOCIATION OF AMERICAN RAILROADS,

Washington, D.C., March 28, 1966. Hon. HARLEY 0. STAGGERS, Chairman, Committee on Interstate and Foreign Commerce, House of Representatives, Washington, D.C.

DEAR CONGRESSMAN STAGGERS : Thank you for your letter of March 16 and the enclosed copy of a letter, dated March 14, addressed to you by Chairman Bush of the Interstate Commerce Commission. I appreciate the opportunity you have thus given us to comment upon it.

That letter is limited to the subject of locomotives and is largely a summary of portions of the 34th Annual Report of the Commission's Section of Locomotive Inspection for the fiscal year ended June 30, 1965 (but not published until March 7, 1966).

At the outset, I should inform you that the significance of certain facts stated in the letter and the validity of certain conclusions drawn from them have been directly challenged by this Association in litigation now pending before the Commission. This litigation, involving proposed amendments to the rules under which non-steam locomotives are inspected and known as Ex Parte 243, was begun in May 1964. Hearings were held before Commission Examiners during the period June 15 to December 15, 1965, and briefs to the Examiners were filed on March 15, 1966, the day before your letter was written.

Obviously it would be improper for me to comment here on the details of this litigation or the specific issues it involves while it remains undecided. It is appropriate, however, for me to respond to some of the statements in the letter, and I will do so partly on the basis of what we believe to be fully proved in the record of the case.

1. The letter cites an increase in defects found in locomotive units and an increase in units ordered out of service because of defects during the latest period as compared with the preceding period. It is demonstrable, however, that there is no necessary relation between defects found and casualties experienced. This is in part because many so-called “defects" have little or no relation to hazards, actual or potential.

2. The letter also cites an increase in the number of accidents in the latest period; but, it fails to mention that the number of casualties in this period is lower than in the preceding period and, in fact, is the lowest of the last three years.

3. As one of the causes of what is called "this undesirable trend"--though we cannot regard a trend toward fewer casualties as undesirable-the letter assigns the increasing average age of the locomotive fleet. But during the post-war period casualty rates have fallen as the average age of the fleet has risen. To ignore this fact--which is demonstrated by the Commission's own published figures—is to overlook the effectiveness of the railroads' extensive program of rebuilding and renovating older locomotives. Reference to original building dates does not take this program into account, though it is a matter of major significance as respects both the safety and the efficiency of the present fleet.

4. Also referred to are increases in average miles operated by locomotives with longer, heavier trains at higher speeds. The implication seems to be that older locomotives are being utilized to an extent that strains their capacity. The fact is, however, that these increases in the averages in recent years are attributable to the use of new and rebuilt locomotives, which are more powerful and efficient and are capable of providing this added service without strain or hazard. This capability, indeed, has been a major justification for the greater capital expanditure required to obtain the more modern units.

5. A slighting reference is made in the letter to railroad inspection facilities and practices, with the assertion that "a majority" of the units found defective and ordered out of service had "previously” been inspected by railroad employees. Each unit, however, must by law receive a general inspection by railroad employees at least once each day it is in service, to say nothing of various periodic inspections of particular appurtenances. Assuming that the approximately 30,000 non-steam units in the fleet are in service on an average of 350 days each in a year, it follows that well over 10 million general daily inspections are given them each year. The number of instances referred to is infinitesimal by comparison with this total. We believe our employees are entitled to be proud that only this tiny proportion of the inspections they have made has been asserted to be ineffective. In this connection, I should like to point out that there is no relationship between the inspections referred to and the presence or absence of a fireman, as necessary inspections are made by other railroad personnel.

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