Part III: The 'pretzel logic' of remote control
Carriers, AAR, UTU employ twisted logic to justify implementation, continued use of RCL
(This is the third in a three-part series of articles in which the BLET takes a look at recent actions of the Federal Railroad Administration, the United Transportation Union, and the Association of American Railroads to further expand the use of Remote Control Locomotives in the railroad industry. Part I was published in the October issue of the Locomotive Engineeers & Trainmen News while Part II was published in the November issue.
(A complete copy of this series is available on the BLET website at the following link: http://www.ble-t.org/pr/pdf/pretzel.pdf . In Part III, we conclude by posing numerous questions that remain unanswered by the FRA, UTU and AAR.)
This recent turn of events raises a series of questions that the RCL troika must address.
To FRA: In discussing the "unique operating characteristics presented by RCLs," why does your letter fail to include the hazards arising from the autonomous and authoritarian actions of the RCL's Onboard Control Computer, as explained in the Gamst/Gavalla Report?
Why have you continued to refuse to initiate a rulemaking for processor-based RCL operations, based on the rationale used to determine that rulemaking was appropriate and necessary for processor-based Positive Train Control operations?
Since you were "surprised to learn that railroads had some RCL operations on main tracks" because guidelines instead of regulations were issued, and accepted data provided by the railroads that you had previously identified as flawed, why do you now believe that the industry will be any more forthcoming in addressing your concerns, particularly when railroads seek "credit" for RCOs operating on main track in satisfying the 120-hour operating recommendation?
Doesn't the fact that you deemed "most" main track RCO operations as adequate avoid consideration and potential mitigation of rare-event, high-risk accidents that could have catastrophic results?
One reason you conclude that conventional operations on main tracks are safer than RCL operations is that "engineers have the ability to immediately respond to these situations with considerably more controls than those afforded to RCOs." Why did this aspect of your discussion exclude factors such as longer on-the-job experience, more experience in train handling under varying operational conditions and, above all, the kinesthetic feedback (that "seat-of-the-pants feeling") a conventional engineer receives from his/her locomotive and train consist.
To AAR: If the "rail industry is committed to the safe implementation of this important technology," why does it wait to be pushed by the FRA for implementation of RCL safety not extant on the railroads? Why haven't the Class I railroads provided FRA with data delineating labor hours and employee headcounts for switching operations, as requested in Recommendation C.4 of FRA's RCL guidelines?
To UTU: You echo FRA's findings and proposals concerning RCO on main track, why have you not accepted the findings of the Gamst/Gavalla Report, covering mainly yard and industrial switching operations within yard limits - showing that the majority of hazards occur in such locations - in which so many UTU members participated?
Privately, some have attempted to dismiss the Gamst/Gavalla Report as a bought-and-paid-for "opinion piece."
This conveniently overlooks the fact that Dr. Gamst has contracted to perform research for FRA, AAR, and UTU in the past. Moreover, the implication that Mr. Gavalla, a former senior FRA safety official, is turning tricks is despicable. Instead of utilizing "focus groups" - as FRA has done in the past when conducting research - the Report was the product of a vastly broader, more comprehensive and longer term ethnographic study than ever has been undertaken by its critics, and was conducted by independent professionals with impeccable credentials.
Publicly, of course, FRA, AAR, and UTU have chosen to ignore the Report. They have no choice but to do so, because they cannot refute the supporting narratives, conceptualizations, and methodologies employed by the authors. FRA, AAR, and UTU while choosing to ignore the Report are missing opportunities to improve safety. Predictable accidents that occur which are the result of RCL hazards identified in the Report, such as the amputation earlier this week, will cause many to ask if ignoring the Report's findings and recommendations is better than addressing them openly.
BLET National President Don M. Hahs had this to say about this latest turn of events: "I will not comment, for the present, on the legal and collective bargaining implications of FRA's letter, and the reaction of AAR and UTU. However, everyone should be mindful that scores of municipalities have joined us to voice their concern about remote control, the State of California has requested a RCL rulemaking, and the State of Washington has not closed the door with respect to its own rulemaking. We will not be deterred from keeping this issue on the front burner, because the safety of all railroad workers and the communities through which our nation's railroads operate demand no less."
© 2005 Brotherhood of Locomotive Engineers and Trainmen