Subject: "Oversight of the Amtrak Accident in Philadelphia."; Testimony by Dennis Pierce, National President, BLET
Post date: Jun 23, 2015 3:09:59 AM
I wanted to share with you BLET President Dennis Pierce's powerful testimony before the T&I Committee regarding the Amtrak Accident in Philadelphia last month. Brother Pierce makes strong arguments concerning the failure to implement Positive Train Control (PTC), to demand two person crews, engineer fatigue and the lack of adequate funding from Congress for Amtrak.
Congressional Documents and Publications
June 2, 2015
House Transportation and Infrastructure Committee Hearing;
"Oversight of the Amtrak Accident in Philadelphia.";
Testimony by Dennis Pierce, National President, Brotherhood of Locomotive
Engineers and Trainmen
Good morning, Chairman Shuster, Ranking Member DeFazio, and Members of the
Committee. My name is Dennis Pierce and I am the National President of the
Brotherhood of Locomotive Engineers and Trainmen, or BLET, which has nearly
39,000 active members; I also am the President of the 70,000-member Rail
Conference of the International Brotherhood of Teamsters. My testimony today
will encompass the views and concerns of both groups.
I would like to begin by offering my most sincere condolences to the victims of
the tragic Amtrak 188 accident and to their families. One of the most difficult
parts of my job is when I have to convey the BLET's sorrow to the families of
members killed in the line of duty. I have had to do that eleven times -- to the
families of Glenn Steele, Chance Gober, Dan Hall, John Hall, Todd Burckhard, J.
G. Hadden, Chris Carter, Tom Anderson, Tom Kenny, Stanley Watts and Darrell
Amerson -- since I became BLET National President on July 1, 2010, and
unfortu-nately I fear that I will have to do it many more times during my
What is even more difficult to accept is when proven safety technology exists
that could have prevented even one of those deaths. In fact, of the eleven names
I just mentioned, five of those deaths could have been prevented by Positive
Train Control alone. Further, for the period from 2005 through 2013, the NTSB
completed 16 investigations of railroad accidents that could have been prevented
or mitigated with Positive Train Control (PTC). These 16 accidents claimed 52
lives and injured 942 others; the damages totaled hundreds of millions of
dollars. These figures exclude the PTC-preventable accidents that NTSB did not
investigate. So believe me when I say that I share the frustration of those
whose lives have been forever changed by the Amtrak 188 tragedy.
As background information, the BLET's Safety Task Force is a party to the
ongoing National Transportation Safety Board investigation of Amtrak 188. An
investigative team from the Brotherhood of Maintenance of Way Employes Division
of the Teamsters Rail Conference also is assisting in the investigation. Both
Organizations are governed by the NTSB's confidentiality rules and, therefore,
and have been asked not disclose any investigative information that may have
come to our attention unless it has been publicly released by the NTSB.
In this regard, the NTSB has publicly commented on two points. One is that
excess train speed at the Frankford Junction curve contributed to Amtrak 188
leaving the tracks. The other is that this accident would not have occurred if
PTC, as an overlay on top of the existing signal system, had been operational.
Beyond that, I can tell you that the Amtrak 188 tragedy places a number of core
elements of fed-eral oversight of the nation's railroads front and center. One
is the statutory mandate that PTC be implemented by year's end. Another is the
safety redundancy afforded by maintaining two-person crews in locomotive cabs. A
third is the vexing issue of crew fatigue. Fourth, I want to briefly address
inward-facing cameras as I am certain that subject will come up during this
hear-ing. And, finally, I want to comment on the nation's expectations for
But before I turn to those issues, I'd like to spend a few moments giving you --
and all those watching -- the unique perspective shared by locomotive engineers
and, indeed, all railroad op-erating employees. It is important that you spend a
few minutes in our shoes, because what non-railroaders see as solutions to
problems often bring with them adverse unintended consequences that we can
identify in advance.
About one in ten thousand Americans is a working locomotive engineer today. We
comprise one of the most highly skilled, highly trained and highly regulated and
federally licensed professions in the nation's workforce. Our work is very
dangerous, with the potential for catastrophe -- for ourselves, our co-workers,
the traveling public and the communities through which we work -- always lurking
in the background, as May 12th starkly reminds us.
Just as in nearly every other workplace over the past couple of decades,
technology has revolu-tionized the workplace of locomotive engineers in freight
and passenger service. In fact, the ef-ficiency and the productivity of today's
locomotive engineer are at levels that couldn't be imagined 50 years ago.
But the increased efficiency and productivity due in part to various
technologies are increasingly being offset by heightened safety risks:
* The use of "distributed power" or DP locomotives -- which are strategically
placed in the middle or at the rear of freight trains even though they are
controlled by the engineer on the lead locomotive -- allows railroads to run
much longer and heavier trains with one crew ... that's good in terms of
efficiency and productivity. However, the engineer must divide his attention in
order to monitor and control those sets of locomotives separately, including
constantly making separate mental calculations to operate each set of
locomo-tives ... and that increases risk.
* A large number of locomotives are equipped with "fuel saver" technology, which
opti-mizes fuel consumption through a series of computer calculations ... again,
good for effi-ciency and productivity. However, the system records all
locomotive activity and if the engineer substitutes his or her professional
judgment and experience for the computer al-gorithm, the engineer could suffer
employment sanctions ... again, there is increased risk because the system
punishes exercises of professional judgment and experience.
* Virtually every locomotive in America is equipped with an "event recorder"
that records dozens of locomotive activities ... which, once more, is good for
efficiency and produc-tivity. However, event recorder data is routinely
downloaded during a trip, and then ana-lyzed by a computer program that looks
for -- among things -- rapid manipulation of the throttle that increases fuel
usage or rapid braking that more quickly wears out brake shoes on locomotives
and cars. When an anomaly is discovered, the computer automatically notifies
someone in railroad management, which leads to a more in-depth investigation
and, all too often, causes the engineer to suffer employment sanctions even when
no ac-cident or incident results ... once more, risk is increased because the
system punishes ex-ercises of professional judgment and experience.
A typical workday for today's freight locomotive engineer consists of up to12
hours of monitor-ing and operating multiple train control systems, all the while
doing his or her best to avoid the pitfalls presented by fuel saver and event
recorder technologies, all of which distracts the engi-neer from focusing on the
external environment in which the train is operating. Similar distrac-tions
exist for passenger and commuter engineers, who have to account for every minute
of delay during their trip, even if the train's schedule allows that time to be
made up when the train ar-rives at its final destination.
Today's operating environment also increases risk because engineers are punished
for taking steps to avert a potential emergent situation. When I was a young
locomotive engineer, the "old timers" used to tell me, "If you think you need to
use your emergency brakes to avoid a problem and don't do it immediately, you're
already too late." Today, I am convinced that preventable train accidents and
incidents are occurring due to the fact that engineers have been trained under
threat of discipline to never apply the emergency brake. When they do, even if
it is to avoid an unsafe situation, engineers are routinely charged with a
violation of railroad policy. In other words, the foundation of today's
operation leads to accidents in situations where they wouldn't have happened in
The fact of the matter is that the level of vigilance required of a locomotive
engineer has reached the point of task overload in many parts of the industry.
And when too much is expected of any system -- whether man or machine -- some
type of breakdown is inevitable.
It's fashionable to look for a single cause of an accident, and when the cause
appears to be a hu-man error that usually seems to be the end of the inquiry.
It's been said that if people would just not make mistakes then everything would
work fine ... their otherwise faultless systems would run smoothly and without
Anyone who engages in root cause accident analysis will tell you this is an
oversimplification that punishes the person, in most cases an employee, and
camouflages underlying systemic prob-lems. If drivers obeyed every speed sign
and every traffic law and never made mistakes there would be no car collisions;
yet we mandate seatbelts and airbags because we know humans are not infallible.
Because weaknesses and shortcomings in equipment design and operational
prac-tices are generally found if a thorough root cause analysis of an accident
is performed, the ques-tion really must evolve into "which humans" made errors
that contributed to the accident in addition to the last human assumed to have
made an error.
So, for example, we know that Amtrak's Automatic Train Control (ATC) system was
active for westbound moves through Frankford Junction, but was not active for
eastbound moves, such as the move Amtrak 188 was making at the time of the
derailment. Amtrak has explained that the westbound speed reduction from 110 mph
to 50 mph entailed a higher risk than the eastbound speed reduction from 80 mph
to 50 mph, which made ATC activation for the westbound move a higher priority.
Was that decision a human error that contributed to the accident? Similarly, if
we eventually learn that, for some reason, the engineer of Amtrak 188 became
temporarily con-fused as to his location, it may be reasonable to conclude that
the simple use of speed signs in the approach to the curve, as a reminder, may
have prevented this accident. That would raise a ques-tion whether the decision
not to post such signs was a human error that contributed to the acci-dent.
It also may be true that Amtrak was forced to prioritize ATC installation the
way it did because the railroad did not have sufficient resources to implement