Tuesday, December 13, 2011



To

Dr. Anil Kakodkar
Hon’ble Chairman,
High Level Safety Review Committee

Respected Sir,
SUB: SUBMISSION OF MEMORANDUM ON SAFETY SYSTEM AND PROTOCOL IN INDIAN RAILWAYS.

All India Loco Running Staff Association represents Loco Pilots (Mail & Exp), Loco Pilots (Passenger), Loco Pilots (Goods) , Loco Pilot (shunting) and Asst. Loco Pilot of Indian Railways. The long cherished demand of this Association is that the existing system and procedure followed in Indian Railways shall be probed by the independent high level committee with experts has come true. This Association welcomes the committee and submits this memorandum although this category of Loco Pilots are familiar and end user of the various system in motive power , signaling , OHE, Track, bridges, but don’t have much technical expertise in these system to prove our point. This vital category of Loco Pilots who play a pivotal role in safe train working, the inputs from this category of field level will be useful to formulate the systems and procedure by this committee.
In majority of collision between trains, the Signal Passing at Danger (SPAD) finds a major factor in which Loco Pilots are involved in one way or other. With the limited resources and limitation in knowledge, this Association submits the following points for your kind perusal.

I) SIGNALLING SYSTEM
A) Signalling system is fool proof but not fail safe
The present signaling system is fool proof system but not fail safe system. Any interference in the system makes the system favorable to the train operation which often ends up in eventuality. The figurative statement of Railways proves that any unauthorised interference or otherwise make the system vulnerable and prone to accident. Hence the signaling system has to be made fail safe even in the case of any system failure or interference in the system. The main aim should be to make the system without possibility of human interference.
B) Recording of events in signalling system
At present there is no direct evidence available with regards to signal aspects and many Accident enquiries relied on circumstantial and/or indirect evidences only to arrive at the conclusion whether the signal behaved properly or misbehaved. This very essential point of evidence in the absence of any recording device (direct evidence) to record the aspect of signal and other events pertaining to the signalling system evades to find out the bottom of the truth and the real cause of accident and to improve the system effectiveness, recording system is necessary.
The present data logger system to record the events in the signaling system is having many infirmities like
1. Not recording the signal aspects as Yellow, Green, Red in station limits
2. Signaling equipments room (Relay Room) where unauthorized interference is possible is not digitally locked with data logger
3. Data logger are not provided for signals out side the station limits
4. Loco Pilots are also not imparted with adequate knowledge about data logger to decipher the details from the system.
   Hence more effective recording system has to be put in place.

C) Display the Signal aspects in the Driving Cab
At present Loco Pilots are sighting many number of fixed signals from the cab. This is having the problem to identify and possibility of mistaking of signals. This is further compounded in multiple line section where signals of adjacent lines are in close proximity which are also seen by the Loco Pilot. In long hood driving of diesel locomotive signal visibility is poor to the engine crew. Turn table system to make short hood driving is done away with. Hence it is necessary to device a system so as to display the aspect of the signal well in advance in the cab itself to avoid any lapse on the part of Loco Pilot in identifying the correct signal.
In spite of technologies introduced in Railways like  Auxiliary Warning System, Train Protection Warning System, Anti Collision Device, Vigilance Control Device etc to reduce the human dependence but still collisions are taking place on account of Signal Passing At Danger (SPAD) due to many constraints and limitations in the above technologies.
 Signals are sentinels and very importantly safety is attached to signals. Any signals passing at danger (SPAD) may prove fatal and thereby great importance is attached in this aspect. Hence signal aspect be displayed in the driving cab with recording arrangement.
The trains are expected to run at same speed both in day and night even when night visibility is restricted. The aid of Head Light in visibility is also restricted to 150-250 metres. Further visibility of 200-300 metres in normal weather especially during night gets reduced to almost 10-20 metres even zero metres due to fog, which is the main reason behind trains running behind schedule and sometimes it leads to accident too. The speed should be further reduced depending upon the density of the fog. Currently, there are no devices / instruments which could help Loco Pilots to sight the signals during fog. Night visibility to be improved so as to stop the train within emergency braking distance (EBD) arrived for various trains which ranges from 400-900 metres. In Airlines zero visibility instrumentation systems are used for landing/ taking off of aircraft. The same advent of this advance technology may be made available in Indian Railway to improve safety.
 If a Loco Pilot could be alerted about the signal in his cabin with the help of technology like Global Positioning, it may help in safe running of trains on time.
D) Uniformity and Standardisation of signals
At present signaling arrangement are arranged in the maintenance point of view. Hence visibility, location of signal etc has to be interlinked with braking distance, speed, load etc. This aspect to be scientifically analysed and remedial measures are to be prescribed in the view point of end user (Loco Pilot), and also more number of types of signaling should be avoided and it is necessary for uniformity and standardization in respect to signals to avoid confusion in the minds of Loco Pilots who work in different Zonal Railways.
E) More number of signals – Stress on loco pilots.
  Indian Railway widely adopting the policy of enhancing the line capacity by the way of increasing the number of signals by introducing Automatic Block System, Intermediate Block Signals / Block Post, modified Semi-Automatic Signals in the section. In any transport system when more no of signals are introduced the average speed drops, therefore highways / expressways are being laid without or with minimum signals and crossings. Contrary to the above concept Railway is trying to achieve more number of trains with maximum speed in the available infrastructure is taxing the Loco Pilot and certainly stressful. The aspect of Human endurance of Loco Pilot under these circumstances to be considered and relief shall be given by limiting the duty hours and any other possible assistance.
F)  Utilization of over-aged assets
Further at present many Panel / Route Rely Interlocking (RRI) for the operation of signals & points are over-aged and due to which signals fail and many Commissioner of Railways Safety enquiry reports reveal the true fact about Signal failures. Such over-aged assets are to be replaced and monitoring the same by third party arrangement is also necessary.

II) ROLLING STOCK
A) Cab Ergonomics-Standardisation of Loco Equipment-Crew Friendly Cab
The driving cab environment should be more crew friendly in order to discharge the duties of Loco Pilot which is directly connected with the safe operation of trains. At present different loco sheds providing equipments at different places for same type of locos and locations are different for different type of locos too. Loco Pilots are finding it difficult in driving the loco due to non standardisation. For safe and comfort driving equipments such as speedometer, brake handles (A9, SA9), horns, Flasher Light / Head Light switches, wipers, indication lamps, instrument lighting and valves and cut out cocks etc., are to be standardised. Earlier it was recommended by various committees.
  B) Road Worthiness Certification Of Wagons / Coaches by Loco Pilots
  The prescribed rules for giving the road worthiness certification for wagons and coaches (fit certificate) are issued by the competent person who is well qualified and trained personnel of Railways such as Junior Engineer / Section Engineer / Rolling stock (Train Examiner) before permitting the train operations as per General / Subsidiary rules. But in the recent years in the name of economy the duties of Train Examiner are thrusted upon the Loco Pilots to examine the wagons / coaches and to issue fit certificate by amending the General Rules 4.31. Such a change in protocol will affect the safety because,
v                       Train Examiner educational qualification is Diploma / Degree in Engineering or the departmental candidates after having adequate experience / training also inducted to this category. But the qualification of Loco Pilot is 10th STD + ITI.
v                       Train examiners are given with more than a year exclusive training in wagons / coaches (theoretical/practical) but Loco Pilots are given mere 4 days training in wagon / coaches just to familiarise only.
v                       Mere operational and trouble shooting capabilities cannot be taken as Loco Pilot is well qualified person to issue fit certificate for road worthiness of wagons / coaches for which he is not qualified and it is beyond his competence.
v                       Even for the locomotives where Loco Pilot is having regular examination in day to day working, Loco Pilots are not authorized to issue fit certificate for road worthiness of locomotives.
Hence this type of procedure shall be done away with, in the interest of safety and qualified / competent Train Examiner only be authorized to issue fit certificate.
C) Brake Power and Braking Distance.
Brake power of trains and braking distance are the two paramount factors which entail safety due to increase in load and speed. These two factors are having a significant role to play in safe train operation. The standard and scientific operating procedures are to be evolved so as to equip the Loco Pilot of his train brake power and braking distance to keep the train under his control and safe stoppage at the desired place which is absent today.
So it is requested to evolve scientific methods and gadgets to judge the Brake Power based on velocity (Speed), mass (Load) and Track gradients and the distance at which a train can bring to a stop by the Loco Pilot.

III) OVER HEAD EQUIPMENT (OHE)
Location of Neutral Section in close proximity with Stop Signals.
As per instruction contains in para.10206 of chapter II Volume I of AC Traction Manual that special care is to be taken in fixing the location of neutral sections, on level tangent track far away from signals, level crossing gates etc to ensure that the train coast through the neutral section at a sufficiently high speed to obviate all possibility of its stopping and getting struck within the neutral section. This is also to ease the stress and strain on the part of the Driver when approaching the Neutral section close to signals, gates, and turn outs. Invariably all over Indian Railways neutral sections are located contravening the provisions of AC Traction Manual and the reasons are best known to the Railway Authorities. Drivers working electrical Loco haul trains are put too much stress and strains while negotiating these neutral sections because of their vulnerable locations.

IV) TRACK
While laying Double / Multiple line of tracks adequate distance to be maintained between adjacent two lines to avoid collision when derailed trains of one track obstructs the adjacent line. Laying of tracks in close proximity though having the limitations of land availability is not conducive to safety.

V) HUMAN RESOURCE DEVELOPMENT
A) Mode of Selection and Entry Qualification of Loco Pilots
Initial mode of selection of Loco Pilots is Asst Loco Pilot. Asst Loco Pilots are selected through direct recruitment from open market and through departmental selection. The entry qualification of Asst Loco Pilots is 10th STD + ITI qualification. Asst Loco Pilots are initially imparted with training on Technical and transportation rules (General and Subsidiary Rule). The station masters whose entry grade qualification is Graduate are also imparted with training of same Transportation Rules (GRS) and etc. As such the qualification for Asst Loco Pilots, who are future Loco Pilots shall not be less than graduates to posses the same knowledge of station master as both have to play a vital role in safe Train operation based on Transportation Rules (GRS).          
More over the Railway is introducing most sophisticated locomotives, modern technologies are being introduced in signal, over head equipments (OHE), tracks, wagon / coaches and advanced / modern safety gadgets to cope up with above situation the present qualification of  10th STD + ITI for Assistant Loco Pilot is inadequate and higher qualification of Graduation with Engineering for Asst Loco Pilot is the need of the hour.
B) Training for Loco Pilots.
Training is important for the safe and efficient train operations. The training period is being constantly reduced. During 1990 Asst Loco Pilots were given with 52 weeks training for imparting three types of locomotives and Transportation Rules (GRS). Subsequently during 1998 the training was reduced to 38 weeks to train Asst Loco Pilots in four types of locomotives including Transportation rules (GRS). From 2009 onwards this training period was further reduced to 17 weeks to train up 11 types of locomotives apart from Transportation Rules (GRS).
Though there is a substantial increase in syllabus as compared above the training period is reduced sighting the reasons as advanced teaching tools are introduced for imparting training.  It is submitted here that, the advanced teaching tool may help for better understanding but there is no reduction of effort required to be put forth by the trainee to cope up with the syllabus that too with lesser educational qualification.
This will result pushing / rushing in Initial / Promotional / Refresher course training, hence training period should be suitably enhanced.
C) Highest Medical Standard for Loco Pilots.
Highest Medical standard AYE ONE is prescribed from Asst Loco Pilot to Loco Pilot Mail, until his retirement. High medical standard cannot be maintained up to the age of 60 yrs. This is also accepted by Railways. Hence like Air Pilots, Loco Pilots in their advancement of age preferably after the age of 50yrs are to be given with non-driving duties with out loss of emoluments like Loco / Driving / Training inspectors, Crew / Power controllers, Crew booking duties, Instructors in Training centers etc. At present Loco Pilots of younger age are manning these non-driving duties. A method should be evolved so as to avoid possible vulnerable operational lapses due to advancement of age.
D) Provision of Asst Loco Pilots in EMU / MEMU / DEMU
In single man operation in Electrical Multiple Unit (EMU) / Mainline EMU /Diesel EMU there is no Asst Loco Pilot but only Motorman is manning the suburban trains. This single man operation in such saturated system is more stressful and there is no assistance to the Motor man with respect to signals, train operation, trouble shooting techniques etc. The provision of Dead man handle (DMH) is not a substitute for Asst Loco Pilot and this device intervenes only when the Motor man is incapacitated physically and falls away from DMH. Despite the provision of the DMH accidents like collisions, SPADs are happening and the collision occurred recently near Arakkonam of Southern Railway is a glaring example. There are also instances and possibilities of driving a train by a Motorman in subconscious state for which there is no alternative mechanism to avoid any eventuality. Hence it is reiterated that Asst loco Pilots are to be provided invariably in all EMU / MEMU / DEMU.
E) Fatigue Management.
In many Foreign Railways, Transportation System developed separate national commission to study fatigue management, microsleep phenomena, sleep debt, sleep deprivation etc on Rail Road drivers and recommended various measures to combat fatigue encountered due to longer hours, irregular pattern of working, night duties etc. Such a scientific approach is all the more necessary in the modern scientific era to decide working hours of train drivers based on sound level, vibration, temperature, electromagnetic induction which is having a direct bearing in the safe train operation. Presently we feel in diesel/ electric locomotives the permissible levels of above parameters are on a higher level, which increases stress and strain.
Apart from the above inadequately maintained and designed driving cab with louder noise, uncomfortable seating arrangement and mainly absence of facility to attend nature call, long hood working in Diesel locomotive which prevents continuous visibility (especially on WDP4 ), Dead man handle pressure on Motor man in EMU / MEMU / DEMU increases stress and strain.
In the present arrangement in Railways, fatigue level measuring system is not prevailed but Loco Pilots are complaining about these aspects to various committees and commissions. Hence it is necessary to evolve a system to gauge the fatigue level scientifically, and also to mitigate the fatigue caused by the above narrated facts shall be scientifically analyzed and improvement to be made on these aspects.
Further an aspect which is of great importance in ensuring a driver’s well being and alertness on duty is the condition of Running Room.  Though various high power committees had stressed on this matter, the improvement in Running Room has been inadequate.
F) Improvement in service condition.
At present in case of SPAD deterrent punishments are given to Loco Pilots like Removal, Dismissal, etc. This factually gives negative feed back that accidents which cannot be hided, only have been reported. Thus the real causes of accidents are not coming out and SPAD’s are continuing. The views of Railway Safety Review Committee headed by Justice H.R.Khanna shall be considered and the service condition of Loco pilots shall be suitably modified.

VI) NEED FOR THIRD PARTY AUDIT
Various aspects were discussed in the above subject of Human Resources Development. The present monitoring arrangement in Indian Railways has not met with expected standard. An attempt is also being made to relieve the role of Commissioner of Railway Safety in Indian Railway as proposed in the draft rules by the General Rules Review Committee. Hence to oversee the safety performance of Indian Railways an effective third party safety audit is necessary.
It is pertinent to quote here the observation of Railway Safety Review Committee headed by Justice H.R.Khanna which is in para 4.3.1 of Part-II,
 “The present practice on IR is to interpret every accident as being attributable to some individual – the “who went wrong “ syndrome rather than the more pertinent “ what went wrong” approach.”
This kind of approach does not solve human failure on accidents. It is to be added that filling up of vacancies in safety categories more importantly in Loco Pilot category is having a direct bearing on safety.
Also, the usage of over aged assets like signaling gears, tracks, bridges etc. are continued to be in kept usage beyond its lifetime in the name of economy which will affect the safety performance of Indian Railways. The Internal Safety Audit System does not prove its efficiency and it is our firm view that the External Safety Audit System will find a solution to eradicate the occurrence of major chunk of human failure in accidents.
Further as discussing in para 5.6.1 of Railway Safety Review Committee headed by Justice H.R.Khanna, in foreign countries like USA, an independent agency called NTSB arrangements in vogue in improving safety in different transportation moods. Similar effort may be adapted to effectively deal with Safety related issues in Indian Railways.
These include non filling up of vacancies too. But these will have to be monitored by exclusives authority.

CONCLUSION:
We hope the Honorable committee will consider our views from our submission in the representation for improving safety in Railways. It is also prayed for a personal hearing to present our views in person at your convenience.

Yours sincerely

Date:08.12.11 :                                                                                                                                                                                                                                M.N. Prasad, 
Place :  New Delhi                                                                   Secretary General
                                                                                                      AILRSA 

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