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Safety Recommendation R-14-020
Synopsis: This report discusses the 2012 accident in which a Consolidated Rail Corporation (Conrail) train derailed while traveling over a moveable bridge in Paulsboro, New Jersey. Three tank cars containing vinyl chloride came to rest in Mantua Creek, of which one was breached and released about 20,000 gallons of vinyl chloride. On that day, 28 residents sought medical attention for possible exposure, and the train crew and many emergency responders were also exposed. Damage estimates were $451,000 for equipment and about $30 million for emergency response and remediation. This report addresses safety issues: training and qualification of train crews for moveable bridge inspection; Conrail safety management; timeliness of hazardous materials communications to first responders; failure of the incident commanders to follow established hazardous materials response protocols; firefighter training and qualifications; inadequacies of emergency planning, emergency preparedness, and public awareness for hazardous materials transported by train; and rail corridor risk management analysis. Safety recommendations to: Conrail, US Department of Transportation, Federal Railroad Administration, Pipeline and Hazardous Materials Safety Administration, Association of American Railroads, American Short Line and Regional Railroad Association, International Association of Fire Chiefs, National Volunteer Fire Council, four New Jersey state agencies, with three reiterated.
Recommendation: TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Collaborate with the Federal Railroad Administration and the American Short Line and Regional Railroad Association to develop a risk assessment tool that addresses the known limitations and shortcomings of the Rail Corridor Risk Management System software tool.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Acceptable Action
Mode: Railroad
Location: Paulsboro, NJ, United States
Is Reiterated: No
Is Hazmat: No
Accident #: DCA-13-MR-002
Accident Reports:
Report #: RAR-14-01
Accident Date: 11/30/2012
Issue Date: 8/22/2014
Date Closed: 4/7/2017
Addressee(s) and Addressee Status: PHMSA (Closed - Acceptable Action)

Safety Recommendation History
From: NTSB
Date: 4/7/2017
Response: We are pleased that you have collaborated with the FRA and the ASLRRA, as well as with the Association of American Railroads (AAR), to provide assessment methods to reduce or eliminate hazards on a rail corridor. We note that the FRA has audited Class 1 railroads, AAR has a rail corridor risk management system program, and PHMSA has conducted joint sessions with each entity to ensure that railroads other than Class 1, such as regional and short line railroads, have developed their own programs to analyze safety and security risks along routes. Accordingly, Safety Recommendations R-14-20 and -21 are classified CLOSED--ACCEPTABLE ACTION.

Date: 3/16/2016
Response: -From Marie Therese Dominguez, Administrator: The PHMSA concurs. As noted in a November 11, 2014letter from FRA Administrator Joseph C. Szabo, FRA has funded the development and beta testing of the Hazmat Transportation Risk Analytical Model (H-TRAM) web-based software tool. This tool is for short line and regional railroads to perform safety and security risk analyses in accordance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), specifically,§ 172.820. The tool uses railroad operating information and route attributes to assess the 27 key risk factors list in Part 172, Appendix A-Rail Risk Analysis Factors, with particular emphasis on population density. The FRA funded an independent verification and validation of the tool and findings of this study (primarily "ease of use" issues and process documentation) are being addressed. Currently, H-TRAM is used by 14 railroad companies. The FRA has requested funding to continue the project. Furthermore, PHMSA and FRA met recently with the Association of American Railroads (AAR) for a demonstration on the use of the Rail Corridor Risk Management System (RCRMS) software tool for when a railroad only has one route. Similar to H-TRAM, RCRMS provides calculated risk scores based on the 27 key risk factors for each route input into the system. Various visualization tools and reports are available for analysts to use to assess individual routes. Additionally, a railroad can look at the risk profile of a single route and can change a factor like track class or operating speed to reduce the risk associated with the given route. Therefore, PHMSA believes that RCRMS can still be a useful risk assessment tool for short line and regional railroads that only have one route available to assess. The PHMSA recommends that NTSB reach out to AAR for a similar demonstration on the capabilities of RCRMS in reconsideration of its view that the tool has "limitations and shortcomings." Regarding the recommendation to conduct audits of short line and regional railroads, FRA has an established program to audit compliance with§ 172.820 visiting most, if not all, of the Class I railroads as well as a select number of short line and regional railroads annually. The audits reflected carriers are operating in compliance with the regulations. Specifically, regional and short line railroads that do not use RCRMS or H-TRAM have developed their own methodology to analyze the safety and security risks along required routes. Furthermore, FRA has collaborated with the American Short Line and Regional Railroad Association (ASLRRA) and presented at the March 2015 ASLRRA conference in Orlando, Florida to promote the importance of performing a complete and thorough route analysis. The FRA, jointly with Countermeasure Assessment & Security Experts (CASE), the developers of H-TRAM, provided an overview of the use of H-TRAM as well as detailing FRA's expectations during audits. They also highlighted the ongoing system improvements and the creation of a web-based training program for railroads. We note that FRA also met with short line conglomerates (Genesee and Wyoming; WATCO; and Omni-Trax) to discuss various hazardous materials regulatory compliance matters with their subsidiary railroads during the same month. The FRA, as the rail modal arm of DOT, and primarily acting in an enforcement capacity for the transportation of hazardous materials by rail, has taken the lead on actions to address these recommendations. The FRA has the expertise and oversight to complete the actions stated above (i.e., final roll out ofthe H-TRAM software tool and continuation of audits of short line and regional railroads) for Safety Recommendations R-14-20 and R-14-21. Therefore, we plan no further action beyond providing support and assistance to FRA on these actions as necessary. Moreover, given that NTSB has issued the exact same recommendations under Safety Recommendations R-14-16 and R-14-17 to FRA, we see no safety reason for the duplication of safety recommendations issued to FRA and PHMSA, as Safety Recommendations R -14-16 and R -14-17 require the same collaboration among the relevant parties as Safety Recommendations R-14-20 and R-14-21.

From: NTSB
Date: 2/24/2015
Response: We are encouraged that you, the FRA, and the American Short Line and Regional Railroad Association (ASLRRA) have initiated efforts to address this issue, particularly the FRA and the ASLRRA’s collaboration to develop and implement a Hazmat Transportation Analytical Risk Model specifically for short line railroads subject to section 172.820 to use in collecting data and analyzing route risks. Pending completion of the recommended action, Safety Recommendation R-14-20 is classified OPEN—ACCEPTABLE RESPONSE.

Date: 11/24/2014
Response: -From Timothy Butters, Acting Administrator: The Federal Railroad Administration (FRA) has been collaborating with the American Short Line and Regional Railroad Association (ASLRRA) to develop and implement a Hazmat Transportation Analytical Risk Model (H-TRAM) designed specifically for use by short line railroads subject to § 172.820 data collection and route risk analysis requirements. H-TRAM is an industry affirmed viable work-in-progress with potential to greatly increase the ability of regional and short line railroads to meet route risk analysis requirements. However, significant work remains to be done to ensure the effective implementation of the model for use as a short line hazmat risk analysis reduction tool. Industry feedback highlighted areas that could be improved including the need for: (1) accurate and descriptive information regarding railroad operating characteristics to be included in the analytical rating criteria; (2) further delineation and expansion on numerical risk categories; and automating the data input and collection process and optimizing the availability of real-time access to the statistical data output. It should be noted that this project is not simply a furtherance or adaptation of the current Rail Corridor Risk Management System (RCRMS) software tool. Instead, the end product of this project is a risk assessment methodology built by and for the short line and (regional) industry and its operating railroads. PHMSA will lend support to the FRA and the ASLRRA in whatever manner necessary to address improvements to H-TRAM.