Summer 2000
Volume 107 - No. 2
Summer 2000
Volume 107 - No. 2
BLE Focus
The Issues: Cab Working Conditions
In the Report to Congress on Locomotive Crashworthiness and Cab Working Conditions, FRA noted the following:
"The research and analysis done in response to the Act supports further work in concert with the industry parties to address temperature extremes in the locomotive cab and toilet areas. Literature on human performance suggests that more strictly controlling cab temperature would provide greater confidence in the capacity of crew members to perform their duties safely and efficiently."
The Report cited several potential health and safety benefits from addressing locomotive cab conditions, including:
The BLE has been working through the RSAC process to implement a high temperature standard for locomotive cabs through the Temperature Task Force of the Cab Working Conditions (CWC) RSAC. The CWC also has been working on revising the noise standards for locomotive cabs, to make them equivalent to the standards applicable to workers whose safety is protected by the Occupational Safety and Health Act (OSHA).
Other topics that are a part of the crashworthiness/cab conditions report - which also will be addressed in the RSAC process in the future - include ergonomics, air quality and vibration.
Cab Working Conditions: Toilets
A major issue assigned to the Cab Working Conditions group, and one
that is nearing a deadline for completion, is a regulation governing sanitary
toilet facilities. While there is general agreement that toilet facilities
must be self-contained septic devices, rather than the dry hopper option
preferred by some railroads, consensus has not yet been reached on several
key issues.
These include: when the determination as to fitness is to be made; what constitutes an unsanitary condition; whether unsanitary conditions caused by mechanical defects and those arising from lack of proper maintenance are to be treated differently; and what restrictions will be placed on the use of a locomotive with a non-complying toilet facility.
What's in store?
The BLE believes that FRA must adopt a clearly defined standard, in order to protect this most basic matter of human dignity. Furthermore, the standard that eventually is established must be enforceable if our members are to realize their right to safe and sanitary toilet conditions. Part of that enforcement process may mean the development of a manual and/or video by FRA and perhaps through the RSAC process, which will provide for easy identification of non-complying facilities.
Cab Working Conditions: Temperature
In a speech given to BLE members attending the International Western Convention in June 2000, FRA Administrator Jolene Molitoris promised to help improve the lifestyle of BLE members by aggressively moving foward on the issue of high temperatures in locomotive cabs. Molitoris stated:
"Before my tenure as FRA Administrator ends, I am committed to
issuing a Notice of Proposed Rulemaking on Locomotive Cab Working Conditions.
The RSAC working group on Locomotive Cab Working Conditions has done good
work on sanitation issues and noise exposure. But the issue of temperature
is far from being resolved. And a recent letter from President Dubroski
notified me that his negotiations with AAR had discontinued and asked that
FRA move forward with a rule as soon as possible. I will provide the RSAC
one more opportunity to resolve this issue because I believe a consensus
agreement will best serve us all. But if RSAC cannot reach resolution timely,
I will move forward with the notice to assure a notice of proposed rulemaking
before year's end.
"I have a very personal recollection of what it's like to ride in the Tucson heat without air conditioning. And I was there on a 'cool' day; it was only about 100 degrees. President Dubroski and I will be going on another ride very soon to raise public awareness and to pique the conscience of all in our industry, including those in the corporate offices, about what it's like to spend hours in a locomotive without air conditioning when the temperature is 110 degrees or more."
Title 49 of the Code of Federal Regulations (CFR), at Section 229.119, specifies that the temperature in a locomotive cab may not be less than 50 degrees Fahrenheit, but there is no uppermost temperature specified in the rule. The lack of a maximum temperature standard results in dreadful working conditions during the summer months and in places that are excruciatingly warm year round.
Recently, BLE member Jeff Sellers of Division 566 (Sanderson, Texas) reported that temperatures in the area of south San Antonio were reaching as high as 125 degrees in his cab. FRA has documented temperatures of 131 degrees. While he has never personally suffered from heat exhaustion, he takes preventive measures to minimize the possibility that he will suffer from heat-related health problems.
"We wear light colored clothing and pour ice water over our heads to keep cool" said Sellers, "but it is still miserable."
FRA Administrator Molitoris agreed.
"There is no other transportation industry subjecting its employees to such conditions," she said. "It is time, and way overtime, for such practice to stop in the railroad industry."
Many locomotive cabs provide the perfect breeding ground for heat exhaustion. Early symptoms of heat exhaustion include dizziness and fatigue, which obviously are dangerous when operating a locomotive.
Later symptoms are even more problematic, with the major ones being poor decision making, vision problems and irrational behavior. These health risks, along with the threat to safety that they pose, explain why getting air conditioning systems installed in locomotive cabs is a top BLE priority.
What's In Store?
Many in the industry realize the importance of the problem of heat exhaustion,
and are formulating a solution. The trip that President Dubroski and FRA
Administrator Molitoris will make in August will dramatize the working conditions
under which BLE members toil.
© 2000 Brotherhood of Locomotive Engineers