Memorandum submitted to CRS

To

       Sri S K MITTAL,

       THE COMMISSIONER OF RAILWAY SAFETY,

       SOUTHERN CIRCLE,

       NO.7   SESHADRI ROAD,

       BANGALORE- 9

Respected Sir,

                   In view of the 16591 Humpi Express accident on 22-05-2012 at Penukonda, the South, South Western and Guntakal division of South Central Railway AILRSA decided to stage a CRS office march from Bangalore City railway station, to highlight the reasons for human failure and resultant accidents in Indian Railways. This association finds following reasons that has to be addressed in war footing.

1. CONTINUOUS NIGHT DUTIES

      It is evident from the last one week working particulars of the loco pilots of 16591, that he was booked to work 6 night trains continuously from 14-05-2012 to 19-05-2012 and on 20-05-2012 he got a night rest and on 21-05-2012 he worked Humpi express and met with an accident. It appears that even though he got a night rest before working this train he could not control his sleep due to the reason of micro sleep which lasts from 30 to 60 seconds beyond the control and knowledge of an individual due to accumulated sleep deprivation. One can find accumulated sleep deprivation of 6 nights in this particular case which defeats the existing 6 nights continuous duty rule of HOER. The RDSO findings indicate that mid night -early morning time zone produce greatest stress on loco pilots as their mental alertness shown slackening. Working on second night has been found to dampen further the mental alertness making loco pilots vulnerable to operational lapses, and thereby recommended two consecutive night duties in place of 6. The railways are refused to implement this safety findings and implementing three to four continuous night duties in mail crew link and goods crew are forced to work 6 continuous night duties as they have no goods crew links. Recently there was a recommendation for air pilots that if their nine hour duty happens to be in a full night stretch, it has to be reduced to seven hours. Railway management should take lessons from the above and CRS should insist the railway management to implement two continuous night duty in place of six.

2. WORKING HOURS OF LOCO RUNNING STAFF

      

       The existing railway rule in HOER insists 13 hours duty at a stretch as an upper limit per day, even though weekly hours are 48. The ILO convention allows only 9 hours upper limit per day (+ 1 hour extra in case of emergency). The parliamentary standing committee on safety in 2004 recommended 8 hours duty, but railways refused to accept it. The long duty hours develop fatigue in crews; this can lead to operational lapses and sleep. Goods crews are still made to work more than 13 hours at a stretch to bring their trains to destination unsafely. No employee in a government sector is working for more than 8 hours by law. Recently RLC Chennai classified loco pilots passenger and express as INTENSIVE by a job analysis and railway refused to implement it. However railways have gone for an appeal to CLC/New Delhi for buying time and after CLC direction at least the CRS should insist on intensive classification to loco running staff, and now 10 hours in goods and 8 hours in passenger/ express. CRS should note that the railways are forcing to work 13 hours at a stretch under threat of DAR action. Even an unskilled daily wage earner is not made to work more than 9 hours in an unorganized sector. Even the ‘prevention of cruelty to animals’ rules 2001’ limits their walking per day to 8 hours with drinking/feeding every 2/4 hours.

3. WEEKLY REST

       Only four 30 hour and five 22 hours rest are allowed by railway rule under HOER, which is a manipulation of the ambiguous language of HOER. Hubli bench of Karnataka has recently allowed 30+16 hours PR , and railway are so far not given appeal on that and so the matter being undisputed is liable to be implemented. All other railway employees get 12 national holidays and 52 Sundays as guaranteed weekly rest but loco running staff does not get any NH and the meager weekly rest of 30 hours against 40 hours of others is not guaranteed. So all the personal work has to be done by availing leave, or between short spells in between duties, which creates mental agony, losing concentration in running duties. In the present crew link four 30 hours PR are not allowed and mostly 22 hours PR are preferred, which make the life of loco pilots / assistant loco pilots still worse. So this association requests the CRS to insist railways to implement 46 hours PR in the crew links.

      

4. OUT STATION DETENTION AND ABSENCE FROM HEAD QUARTERS

       The existing rule under HOER insists 72/96 hours away from headquarters under normal/emergency conditions. The goods crew are badly affected by this rule and they are put at out station to 72/96 hours and on reaching headquarters they are given 12 hours rest if they happens to arrive as passenger by some trains and this causes much constraints and hardships to running staff to look after their family and results in mental agony loosing concentration on job. Recently the railway board had issued a circular proposing that as far as possible out station detention will be limited to 36 hours and this should be insisted by CRS to railways to follow in letter and spirit

      

5. ERGONOMICS OF LOCOMOTIVE

       The heavy noise, dust pollution, excess heat and diesel smell in the diesel locomotive are contributing to early fatigue of the crew. The noise level in a diesel locomotive is 100 decibels which is 25 decibels more than maximum allowed limit of 75 decibels by the Industrial pollution control board. Even though the railway has a research organization like RDSO, it has miserably failed to propose a permanent location for short/ long hood horns which can reduce noise pollution in driving cab. Presently the horns are fitted in such a way that the sound rebounds with the coaches and never reaches the 10^th coach out of the 23 coaches and so the proposal of AILRSA to fit the horns above respectively head light should be insisted by CRS to RDSO and loco sheds. The heat, diesel smell, noise from the engine room comes to the driving cab as the doors in driving cab are not designed sound proof. To overcome this problem the locomotive cab has to be air-conditioned so that fatigue will not attack the operators and they can concentrate on their duties properly and ensure safety of trains.

       Due to non standardization of location of A9, SA9, throttle handles, speedometers and various gauges along with the side of driving, the reflex action developed over so many years is lost. The RDSO should note that in India there are cars worth 2 lakhs to 80 lakhs being manufactured and many of their origins are from Europe and America with left hand driving but due to the fear of loosing market in India cars are manufacturing with right had drive and standard locations of clutch, brake, accelerator, gauge and speedometer uniformly to maintain the reflexes of the operator. But the railway management are foolishingly experimenting with left hand drive, bonnet type locos, bus type locos, speedometers away from the direction of look out, brake application and throttle application in opposite direction in WDP4/WDG 4, comparing to other conventional locos, destroying all the reflexes attained by the operator. In right hand drive in long hood direction loco pilot will sight the signals in a particular point but in left hand long hood that sighting point is changing and immediate reaction is delayed in case of emergencies at higher speeds. The hectometers are kept in middle of the double lines owing to right hand driving but due to left hand driving loco pilot has to frequently depend on assistant loco pilot to know the KM position and railway should put KM posts in left, middle and right in double line section due to non-uniformity in direction of driving side. All the above aspects are only a matter of common sense and it appears that RDSO has no application of mind in safety related matters of design of locomotives and this has to be corrected by the intervention of CRS.

 6. LONGHOOD WORKING

       Visibility of track and signals ahead is the biggest casualty in long hood working and some signals can be seen only for a moment and in higher speeds due to long hood leading if missed will land in an accident. The long hood length of WDP 4 and WDG 4 is increased by 5 meters than the conventional locomotives reducing the visibility. The visibility of WDP 4/WDG 4 is further obstructed by radiator fans and battery box and so it is proposed to run in short hood only as once proposed by SIKRI committee, by turning at triangular sections at junction stations or reviving the old steam turning tables or run WDG4 as multiple units in short hood leading in goods trains. The improper working and non working of wipers are a problem for visibility in rainy season that has to be improved at least by learning and copying from a nano car or autorikshas where wipers are working better than a locomotive worth 10-12 cores.

7. ASSESMENT OF SANCTIONED STRENGTH AND FILLING UP OF VACANCIES

      The present sanctioned strength of loco running staff is far below than the required strength due to dilution in existing formula of engine hours for goods crew and tight crew links of passenger and mail trains without following four 30 hours PR. Dr. Anil Kakodkar safety committee has recommended resuming from leave/ sick at 08:00 hrs, but many divisions still resorting 00:00 hrs position. Holiday specials are running for 8 months in a year but there is no sanctioned strength earmarked in goods crew for that. 30 % leave reserve is now manipulated with 10 % out of it as trainee reserve for refresher courses. Now the refresher courses are in two tractions, diesel and electric; requiring more days and also initial training for new locomotives being introduced like WAG 9 and WDP 4 and many more to come in future. Out of the 11 days CL and 30 days LAP for each loco running staff, one could avail only 11 days CL and 10 days LAP in a year to maximum. Assessment of sanctioned strength should be inclusive of four 46 hrs PR and two continuous night duty consecutively. Presently willfully as a matter of economy 20% vacancies are maintained and so CRS is required to intervene and insist the Railway Board to maintain Zero level vacancies. Due to the huge vacancy position the meager weekly rest and leave is denied causing accidents

8. OTHER DUTIES THRUST UP ON LOCO RUNNING STAFF

                   GR: 3.78 is diluted by a CSO order that any competent railway servant nominated by railway shall pilot a loco pilot with a train in to a section where crew has no LRS. GDR check to certify the formation is fit to run manipulating GR: 4.31 and running IMS trains is a safety hazard.  Manipulating SR: 4.34(iii) by COM to thrust innumerable coupling/uncoupling on the assistant loco pilots are creating mental agony and distraction from safe running of trains.  There is no meals break to loco running staff and forced to consume food while driving trains at 110 kmph which is also a safety hazard. Totally we can see that most of the rules are accident prone and therefore correct it in view of ensuring safety.

9. RUNNING ROOMS

.       In running room, cubicles are to be introduced to avoid disturbance of sleep when other crew are getting ready for duty and putting lights etc. At places where the room temperature is more than 30 degree Celsius air-conditioners are to be provided to get sound sleep before working trains.

10. EXTENDED CREW LINKS

       Although there is a crew beat of 430 kms in MAS-BZA section, 390 kms in MAS-ED section, 350 kms in MAS-SBC section,310 kms in ED-ERS section, 320 km in SBC-GTL is not feasible for a extended run as it is a single line unlike others are double line. SBC-GTL section working involves lot of crossings increasingly fatigue and working hours due to late running of trains. So till SBC-GTL section becoming double line crew changing should be introduced at Dharmavaram for all trains to ensure safety. The many direction working will reduce the acquaintance of the crew as he will cover that section only once in 20 to 30 days due to various reasons. Crew links should be prepared in such a way that once in 10 days the crew is working in each direction to ensure safety even though the road learning rule is valid for 3 months as per SR: 3.78.

       From the above mentioned facts we hope that your good self will be convinced that HUMAN FAILURE is caused due to inhumane rules and inhuman attitude of railways. From last two recent accidents like Penukonda and Saithya, six continuous night duty rule are found to be exact cause. Sainthiya loco pilot was working the fifth continuous night duty when met with accident. From the way of running trains at present by railway, it appears that railways are expecting safety by luck and chance and not by correct rules. Lastly this association requests you, who is the custodian and guardian of safety to insist railway management to comply with the ten points cited above.

       Thanking you.

                                                                                                                    

Yours sincerely

 GEOMY GEORGE,   C.SUNISH      GN SHAW

      .                                                                                                          GS/AILRSA/SR       GS/AILRSA/SWR     Jt GS /AILRSA/SCR  

Banglore,

07-06-2012.                                                                                                                                                                                   

                                                                                                                  

                

Copy to: 1) CCRS/Luknow                                                                      

             2) Director of safety/Railway Board

            3) Director /RDSO/Lucknow 

             4) Sri. Basudeb Acharia, MP