Mr. Chairman and members of the Subcommittee, thank you for this opportunity to appear before you again. At the Subcommittee's previous hearings, I first reported to you on our safety program at the Federal Railroad Administration emphasizing zero tolerance for any safety hazard, and second, on our regulation and oversight of safety "hardware," such as track, signals, and equipment. Today, I will concentrate on the important issue of human factors in rail safety, which we believe equates directly to assuring a positive safety culture. The Administration's safety bill, the Federal Railroad Safety Authorization Act of 1998, focuses squarely on the core human factor safety issues: assuring effective workplace communication of important safety information, eliminating harassment and intimidation, and combating fatigue. Passage of this bill, which is appended to my testimony, is an essential element of our shared goal of zero incidents, zero injuries, and zero deaths in the railroad industry, and I ask that a copy of this legislation be submitted for the record.

In my prior testimony, I emphasized that at no time in history has so much concentrated change affected rail transportation in our country. Spurred by increases in international trade, rail intermodal traffic has increased more than 40 percent since 1990-up 7 percent in 1997 alone. This means more fast trains competing for space on increasingly congested railroads. In some ways the railroad industry is becoming an industry of extremes, as recent mergers have produced mega­railroads while at the same time shortline and regional railroads have proliferated. This enormous restructuring, focused on competitive gains, clearly has raised issues of safe operation. Simultaneously, as rail traffic has expanded significantly, increasing more than 30 percent in revenue­ton­miles since 1990, railroad employment has fallen to the lowest number in this century, about half the number in 1980. Not surprisingly, operations on these huge systems have dramatically increased fatigue in employees and supervisors, fostered inadequate communications, and created other human factor safety hazards.

In fact, accidents caused by human factors account for about one­third of the train accidents and many personal injuries. These hazards include not only fatigue and the broad, overlapping category of safety culture, but also but also inadequate training, ambiguous or conflicting rules, impairing substances, technology that is not designed to work in the same manner that human beings typically think and work, and other causes. Human factors caused 31.5 percent of reported train accidents in 1991, 34.1 percent in 1992, 31.1 percent in 1993, 34.1 percent in 1994, 36.0 percent in 1995, 30.3 percent in 1996, and, according to preliminary figures, 33.0 percent in 1997. (A statistical chart appended to my testimony provides the raw numbers on which these percentages are based.)

To address this critical safety threat, FRA has employed a multifaceted approach. In my testimony today, I will first outline how we have used the Safety Assurance and Compliance Program, or SACP, to create partnerships among rail labor, management, and FRA to address the challenge of human factors, look for the root causes of safety hazards, and identify solutions across whole railroads. This technique, because it includes safety culture, enables us to concentrate on specific operational or even institutional circumstances that lead to human lapses and thus safety issues. As my previous testimony outlined, the program has produced significant safety gains as measured by our result­oriented data. FRA continues to work with all parties to urge railroads to address safety culture issues, assuring that the words "safety first" are not just slogans but actually the motivation behind every act and decision.

Second, I will describe how the Administration's rail safety reauthorization bill addresses the core human factors safety challenges. Among the most important provisions of the bill is a section that proposes Congressional findings supporting the SACP and the other central component of FRA's reinvented safety program, the Railroad Safety Advisory Committee (RSAC), both of which contribute to a positive safety culture in the railroad industry by building trust and cooperation among rail labor, rail management, and FRA to achieve safety goals. Other key elements of the bill go to fostering a positive safety culture by deterring harassment and intimidation of employees for safety­related activities. The bill attacks perhaps the most pervasive safety issue in the railroad industry-fatigue that hampers the alertness of operating employees. The legislation offers railroad management and labor incentives to come to agreement on ways to reduce on­the­job fatigue and fatigue­caused accidents through comprehensive fatigue mitigation plans. Voluntary cooperative efforts being piloted on at least three major railroads offer great promise, and our proposal is designed to encourage and expand on those efforts.

Last, my testimony will describe our efforts to address a series of other human factor issues, including alcohol and drug testing and locomotive engineer certification. Safety hazards will continue to escalate as railroad operations grow ever more complex, and I will highlight how FRA has focused on emerging safety hazards and dissemination of "best safety practices" that go beyond our existing regulations through issuance of safety advisories.

ASSURING A POSITIVE SAFETY CULTURE THROUGH THE SACP

SACP Success on Class I Railroads

As I have discussed in detail in my prior testimony, FRA's SACP program addresses the root causes of safety hazards through an innovative safety partnership. This systemic approach is especially suited to address operational human factors safety issues, and I would like to describe for the Subcommittee how we have effectively enhanced safety through the SACP.

FRA's SACP initiative on the Burlington Northern Santa Fe (BNSF) provides a very clear example of fostering true safety cultural change. On February 1, 1996, a BNSF train derailed on the mountainous Cajon Subdivision in California, fatally injuring the conductor and brakeman and seriously injuring the engineer. FRA's preliminary investigation indicated an overspeed derailment that could have been avoided, if the train crew had had a way to make an emergency application of the train brakes from the rear of the train. A two­way end­of­train device is capable of making such an emergency application, if it is activated. In the wake of a similar accident in December 1994 on the same Subdivision, BNSF voluntarily committed to begin equipping its trains with the device. The train involved in the February 1996 accident was equipped with the device, but it was not activated. In response, FRA issued an emergency order calling for special procedures for certain BNSF trains to assure that the devices were effective. FRA simultaneously launched a SACP initiative with BNSF to identify the human factors that were the deeper causes of the derailment and to create a better safety culture on the railroad. This SACP process began with an intensive, week­long inspection of the Cajon Pass operations involving more than 60 FRA and State inspectors.

BNSF made a full commitment to the SACP process, because they realized that while senior management had issued directives intended to assure operation of two­way end­of­train devices on Cajon, middle management had focused first, in many instances, on "getting trains over the hill." This cultural reexamination through the SACP process resulted in a reengineering of the Cajon safety focus to address critical human factors that had been ignored. For example, as a result of this partnership effort, the railroad made improvements in a number of human factor areas:

Braking Procedures. The railroad implemented clearer procedures indicating when an engineer should initiate an emergency application of the train brakes, eliminating any pressure for a "macho" approach to "ride it out."

Compiling of Operating Rules. By gathering scattered operating rules into one book, the railroad made them more readily available and easier for train crews to follow.

Training of Locomotive Engineers. The railroad revised its training program to make sure that student engineers who would be operating on descending mountain grades received specialized training in the classroom and on the locomotive simulator.

Mentors for Locomotive Engineers. BNSF started a mentoring program in which new engineers were given opportunities to talk to, and work with, veteran engineers who shared their experience on how to handle mountain territory.

Redeploying Experienced Mechanical Employees. BNSF engaged in a partnership with labor to assure equitable distribution of the most experienced carmen and other inspectors at the Barstow inspection point across all shifts, including weekends and the third shift from midnight to 8:00 a.m.

The improvements were especially significant because all increased safety beyond existing regulations and all involved human factors. These are just a few of the more than 50 operational changes BNSF made, in partnership with labor and FRA, as a result of the SACP process. Nearly all of the steps implemented address human factors issues in one way or another.

The SACP process at Cajon was so successful that BNSF took immediate steps to implement this safety partnership system wide. Although seven years is the generally accepted time period to change the culture of a large organization, the Cajon tragedy motivated labor, FRA, and BNSF to try to make it happen sooner. BNSF has begun to change its corporate culture. BNSF's new booklet entitled "Vision & Values" outlines its corporate vision; corporate style; shared values; commitment to community; and ideals of liberty, equality, and efficiency. An example of this changing culture is the recent agreement in which BNSF joined with the Brotherhood of Maintenance of Way Employes (BMWE) regarding who should select employees to participate in the railroad's safety process, e.g., its safety committees and safety audits. Historically, railroad management's position was that the matter was a safety issue and that safety issues were not negotiable. Early in the SACP process, the railroad's unwillingness to negotiate on this question was identified as a major obstacle to cultural change. Through the improved communications of SACP, the parties came to an understanding that the issue was not safety, but whether the railroad or the labor organization should select employees for participation in the safety process. This issue was resolved with the signing of a safety participation agreement between the BNSF and the BMWE, and the offer by the BNSF to engage in negotiations with any and all labor organization that felt the need for formal participation agreements.

BNSF's leadership in changing its corporate culture can be further illustrated by numerous accomplishments, including Chairman Krebs' series of system­wide "Town Hall Meetings" with employees; the chartering of a permanent labor­management task force to address systemic problems and culture issues; a jointly drafted Safety Action Plan; an Employee Empowerment policy jointly developed with rail labor organizations; a strong anti­fear and intimidation process; and the railroad industry's most progressive fatigue countermeasures program. FRA's SACP work on BNSF has resulted in increases in safety that can be quantified, as well as testified to, by management and labor alike.

As I described in detail in my previous testimony, we have initiated significant SACP programs on other major Class I railroads, including CSX Transportation and Union Pacific. FRA also focused extensively on identifying potential human factors safety hazards as part of the Safety Implementation Plan development in connection with the proposed acquisition of Conrail. Many of the new initiatives on these and the other Class I mega­railroads address systemic human factor safety issues and tie directly to the establishment of a positive safety culture.

SACP Success on Regional Railroads

The SACP process works not only for mega­railroads but for regional railroads. For example, after a series of train accidents in 1996, FRA formed a partnership with the Wisconsin Central (WC) aimed at reducing its accident rate. The resulting compliance agreement has led to the development of a variety of initiatives that have reduced the number of accidents caused by human factors and contributed to a substantial improvement in safety culture. For example, WC has implemented:

Revised Efficiency Testing. WC has created comprehensive efficiency testing programs designed to allow managers to focus tests and inspections on areas that involve human factor accidents and employee injuries. Test results are incorporated into a new computer database that permits sorting of results by system or division, by individual tested, by supervisor, or by particular location.

Training Initiatives for New Employees. Designed to reduce error by inexperienced employees, these initiatives include identification of clearance points, use of arm bands to identify new employees, and Overlap Safety Meetings.

Other Training Initiatives. WC has instituted new and comprehensive safety programs for maintenance­of­way, operating, and mechanical forces. These training programs target specific safety concerns that FRA and WC had jointly identified.

The value of these initiatives and WC's commitment to the partnership with FRA and an improved safety culture are already apparent. All train crews interviewed by FRA said that the training they received enabled them to set "bad order" cars out of the train. Everyone talking to FRA indicated that they were allowed to perform required inspections, and no one reported being told to run defective cars in a train. As a result, WC's human factor accidents have decreased as dramatically indicated in a three­month comparison (January 1 to

March 31): in 1996, there were seven such accidents reported to the FRA; in 1997, six; and in 1998, four.

BNSF and Wisconsin Central are but two examples of how SACP works to improve a railroad's safety culture. The difficulty of changing a safety culture that has been in existence for well over 100 years cannot be underestimated. Significant safety improvements across the industry in almost every category we measure are a testimony to the effectiveness of FRA's SACP process nationwide in addressing critical human factors safety issues. FRA's experiences with SACP initiatives on the BNSF, like those on the Union Pacific and CSX Transportation, have taught us that we must become involved not only with mega­railroads but with mega­issues, such as hiring and training, effective communications, corporate safety culture, and fatigue.

LEGISLATIVE PROPOSALS TO REINFORCE SAFETY CULTURE INITIATIVES

Congressional Findings Supporting SACP and RSAC

As part of FRA's broad initiative to decrease human factor and other accidents by improving the safety culture of the railroad industry, section 2 of the bill would state findings of the Congress showing support for SACP and RSAC as key elements of FRA's overall safety program. Adoption of these findings will help to institutionalize the reinvented rail safety program and assure the continued transformation of the Federal railroad safety program into one that emphasizes partnerships and results. As I have detailed in my previous testimony to this Subcommittee, these collaborative efforts, which are based on the government reinvention initiatives of the National Performance Review, have accelerated improvements in safety and in the industry's safety culture.

Eliminating Harassment and Intimidation to Increase Safety

Our bill also contains provisions to protect safety whistle­blowers on railroads that have less than a positive safety culture. We have received a large number of complaints from employees of instances in which they have conscientiously attempted to comply with FRA safety rules but gotten a wide range of negative responses from supervisors: from mixed messages about safety and efficiency and winking assurances that the employee should cut corners on rules compliance to move trains, to outright harassment and intimidation for these safety­related activities. For example, these allegations include:

Complaints from mechanical department personnel about being harassed for not authorizing the use of defective equipment;

Complaints from employees who are retaliated against for reporting, or attempting to report, on­the­job injuries; and

Complaints from employees about supervisors interfering with their medical treatment for on­the­job injuries in order to avoid making the injury reportable to FRA.

We think that anti­safety pressure, harassment, and intimidation appear all too frequently in the industry. Our mail and our discussions with employees support this assessment, and so does research by the Department's Volpe National Transportation Systems Center. In 1996, a Volpe Center researcher held a focus group to discuss the general issue of compliance with company operating rules. Many company operating rules mirror FRA safety regulations, so violation of the company rule is violation of an FRA safety rule. Twelve operating rules officers participated, representing Class I, II, and III railroads. In addition, individual structured interviews were held before and after the focus group. Focus group participants generally reported that senior management tends to emphasize productivity over safety, suggesting that some railroads may have created an organizational culture that unintentionally encourages operating rules violations. Follow­up interviews with a number of industry representatives supported this view.

We have heard from upper managers on many railroads that a poor safety culture does not make for good business. Recently, two mid­level managers on a Class I railroad threatened to resign in protest of a pattern of harassment by a higher level manager, who reportedly discriminated against them for conscientiously working to comply with the FRA equipment safety regulations. Later, the upper manager departed the company, the two middle managers were implored to stay, and one of the two middle managers was promoted. It is impossible to exaggerate the importance of these events. They indicate monumental change in the corporate safety culture and great courage on the part of the head of the company. Top management of that company recognized the need for the free flow of communication. Those employees working for managers who are not so enlightened need the protection of our bill.

Section 401 of our bill calls for speedy and effective employee remedies for an expanded series of safety activities. Currently, certain protections are available under 49 U.S.C. 20109, which is administered under the Railway Labor Act,2 if an employee is discriminated against or discharged for filing complaints of rail safety violations or testifying in a rail safety proceeding. Section 401 would expand the list of protected activities. The bill would extend coverage to the acts of reporting injuries, cooperating in an FRA or NTSB investigation, or refusing to authorize use of unsafe equipment. Moreover, the bill would improve the existing Railway Labor Act remedy for such discharge or discrimination. First, it would provide for reinstatement and compensatory damages and for punitive damages to deter such conduct. It would remove the present $20,000 cap on liability for damages for conduct not affecting pay. The possibility of a large award of punitive damages from the "public law board" on the property or the National Railroad Adjustment Board could effectively deter anti­safety harassment in the industry. Even so, high damage awards do little good if they are long delayed. The bill would also expedite resolution of claim under Railway Labor Act procedures if claim involves conduct affecting pay, reducing the time for resolution from 180 days to 60 days.

Section 402 of the bill would close gaps in the criminal law pertaining to interference with FRA or National Transportation Safety Board investigations of major derailments, collisions, or other accidents. The provision would establishing a criminal prohibition on interfering with or hampering such investigations in certain ways, for example, by intimidating or bribing witnesses. Existing criminal laws against witness tampering, codified at 18 U.S.C. 1512, apply to tampering that occurs in the context of an "official proceeding" that has been commenced or will be commenced. Our research indicates that this term is generally construed to mean a criminal or quasi­criminal proceeding. Since railroad accidents do not always involve violations of criminal law or even violations of civil law, witness tampering in the context of an FRA or NTSB investigation of such an accident may not be within the scope of those prohibitions. Section 402 is designed to reach such interference.

Both sections 401 and 402 are comparable to existing provisions applicable to other industries. For example, section 11(c) of the Occupational Safety and Health Act (29 U.S.C. 660(c)) provides protection, similar to that proposed in section 401, for employees3 who are discharged or discriminated against because they have complained about an unsafe working condition within the jurisdiction of the Occupational Safety and Health Administration. In addition, bills have been introduced in both the House and Senate (H.R. 915 and S. 100) to extend whistleblower protection to employees in the airline industry who have complained about a violation of Federal Aviation Administration regulations. Criminal prohibitions that would be established by section 402 of our bill with respect to investigation of railroad accidents are similar to existing criminal prohibitions with respect to investigation of other transportation accidents. For example, 49 U.S.C. 1155 contains a criminal prohibition against knowingly and without authority removing or concealing a part of a civil aircraft involved in an accident.

Fatigue in the Railroad Industry

In the same way that our bill's provisions to deter harassment and intimidation reinforce a positive safety culture, other provisions of our bill reinforce a positive safety culture by combating fatigue.

The Federal Hours of Service Laws

The Federal hours of service laws govern the on­duty and off­duty periods of railroad operating employees. These laws were enacted in 1907, over 90 years ago. 4 Congress last adopted major amendments to them in 1969 and revised the maximum on­duty period for train service employees from 16 hours to 12 hours. The hours of service laws limit the work hours of railroad employees who are engaged in duties so related to the safe operation of trains that physical and mental fatigue causing diminished job performance endangers themselves, their coworkers, and the public. Covered employees fall into three categories: those involved in train and engine service (e.g., train crews); those involved in giving mandatory orders directing train movements (e.g., operators and dispatchers); and those in signal service (e.g., installers, maintainers, and repairers). As the Supreme Court explained in a 1917 case, the hours of service laws were passed because

of the many casualties in railroad transportation which resulted from requiring the discharge of arduous duties by tired and exhausted men whose power of service and energy had been so weakened by overwork as to render them inattentive to duty or incapable of discharging the responsibilities of their positions.5

The Supreme Court was describing a category of human factor accidents marked by lack of alertness or slow response time, and not only those caused by the extreme fatigue that manifests itself in the unconsciousness of sleep. Unfortunately, modern experience has shown that the basic protection of these laws must be supplemented by a broader, more comprehensive approach to fatigue mitigation.

Human Factor Accidents

Railroad employees want to work safely and efficiently. They know that their own lives, as well as the lives of others, depend on consistent compliance with operating rules, signal indications, and other safety requirements; but these safety and performance requirements are often compromised by employees' inability to obtain adequate rest in existing railroad operations. Available information suggests that these employees face real challenges in managing their work and rest due to the demands of railroad operations and the rigidity of some existing work rules.

As previously mentioned, about one­third of the train accidents and many personal injuries occur due to human factors. In 1996, for example, 784 of the 2,584 accidents (30 percent) were caused by human factors. While only three of these were reported as directly related to an employee being asleep, even when an employee is apparently awake and alert at the time of an accident (and excess service is not an issue), cumulative fatigue is often a contributing cause to an employee's poor judgment. Since an accident investigation cannot always determine why a fully trained employee made a fatal mistake, the accident data probably understates the magnitude of the fatigue problem.

To illustrate the seriousness of the fatigue problem in the railroad industry, consider this transcript of a recorded telephone conversation between a locomotive engineer on a Class I railroad and a crew caller. The call for her to report to duty came in the early morning hours, about one o'clock, last summer.

Engineer: "I haven't had any sleep. I'm just going to have to lay off. I haven't had a chance to get any sleep."

Crew caller: "So you're telling me that you would probably work unsafe."

Engineer: "You can lay me off 'personal.' I am tired and 'account fatigue.' However you want to call that."

The crew caller said he could not allow her to lay off on that basis.

Engineer: "We are not robots, though . . . ."

Crew caller: "I totally agree with you. They are working us 16 hours down here. We're getting . . . we're getting six hours of sleep and coming right back and working 16 more because we're short­handed, too, and I . . . I agree with you . . . ."

Although the crew caller expressed some sympathy for her situation, he told her that she would be subject to discipline if she did not accept the call. In the end, she accepted the call and went on duty as a locomotive engineer, even though she was exhausted. She told the crew caller, "Okay. If the railroad is willing to take the risk of employees that are fatigued, then that's just the way it's going to have to be."

This same incident could have happened on any number of railroads in this country, and

the solution is not easy. Allowing that engineer not to report would have probably meant that another engineer who had even less expectation of being called would be called to report in her place. The point is, however, that this is the sort of risk that railroads take, and that the country takes, by not taking stronger action to abate fatigue in the railroad industry.

Research on Fatigue and Alertness

FRA and NTSB accident investigations, FRA SACP efforts, and research studies by Department of Transportation agencies, including FRA, working together as one DOT, and by other institutions have suggested the need to address irregular work cycles, with particular attention to promoting the alertness of crew members assigned to rapidly advancing shifts. Train and engine crews in road service are sometimes required to report for successive duty periods with as little as two hours' notice and only eight hours off between shifts, setting up a work/rest cycle of less than 24 hours. FRA and other research has determined that work/rest cycles shorter than 24 hours may lead to increased risk of incidents and injury. Moreover, because information regarding scheduling of trains is not readily available or is unreliable, or because employees in line to take earlier assignments report sick or are otherwise unavailable, an employee can be called to work suddenly without having adequate sleep. Cumulative fatigue, or sleep deficit, may also be a problem, particularly where assignments are scheduled to maximize crew availability within the laws (which permit returning to work with eight hours rest after a duty tour of eleven hours and fifty­nine minutes). FRA has also noted work patterns on some railroads that may require or permit employees to work long hours on many days successively without a day off, often leading to cumulative fatigue regardless of the work/rest cycle. In addition, FRA researchers point out that age affects one's ability to adjust to an unpredictable work schedule. It is well known that, compared to younger employees, people over 40 years of age have greater difficulty adjusting to irregular work hours. A large percentage of locomotive engineers are more than 40 years old and therefore having a harder time coping with the erratic hours often associated with being on call.

I would like to summarize the results of two related examples of FRA's studies to help determine the nature of performance decreases that operating employees may experience. In the first study,6 FRA observed the performance of locomotive engineers on the Research and Locomotive Evaluator Simulator (RALES) facility at the Illinois Institute of Technology Research Institute. The RALES simulator was developed through FRA research and has served as the model for simulators used in the railroad industry worldwide to train locomotive engineers and assist in qualifying them. This study investigated how work schedules affect engineers' train handling performance and vigilance. Certified locomotive engineers performed normal job duties while operating a highly realistic locomotive simulator on two different work schedules. The work schedules were designed to conform with the Federal hours of service laws, to cause shifts to begin earlier each day at different rates, and to produce different levels of sleep deprivation. In the group whose shifts started four hours earlier each day, engineers got an average of 4.6 hours of sleep. In the group whose shifts began only two hours earlier each day, engineers got an average of 6.1 hours of sleep. In both groups, as time went on across successive work periods, there were increased failures to sound the train horn at grade crossings, response times to the audible warning on the alerter, and fuel use.

The next phase of this work will include evaluation of napping strategies (similar to those being tested in international aviation and on railroads, e.g., BNSF's voluntary fatigue countermeasures program) and research into automated vigilance monitoring. In addition, other mitigation strategies designed to help engineers deal with shift work problems will be studied.

Second, FRA, with the participation of the Brotherhood of Locomotive Engineers and major railroads, conducted a limited study of actual work patterns among engineers. We gathered "activity diaries" from 200 locomotive engineers employed by six railroads. The diaries consisted of self­reporting with respect to quantity and quality of sleep, estimates of alertness at various times while on duty, time on duty, commuting time, and the accuracy of information provided to crews about job­start times. The conclusions resulting from this effort included the following:

On average, engineers participating received almost the same amount of sleep as the general population, which was seven and one­half hours. However, for jobs starting between 10:00 p.m. and 4:00 a.m., sleep averaged less than six hours. This means that the engineers who had had less rest than normal began shifts during a period when lack of alertness would be expected.

Engineers felt they were less alert during the early morning hours, and these periods extended longer than would be expected for scheduled shift work.

Engineers reported that the most important change that could improve their alertness was more accurate information about the time of the next job start (permitting better planning of rest).

FRA continues to analyze diaries gathered from a separate sample of engineers­­those participating in the study of work, stress, and fatigue using the RALES simulator-to determine whether actual measures of performance on the simulator can be predicted using software designed to evaluate alertness based on work and rest cycles and biological rhythms. A brief summary of FRA's fatigue­related research and development is appended to my testimony.

Notwithstanding FRA's research effort on fatigue and unscheduled shift work, FRA lacks the regulatory authority provided to the Federal Aviation Administration and Federal Highway Administration to address hours of duty of safety­sensitive employees. As I have noted, while Congress last enacted major amendments to the Federal hours of service laws in 1969, since that time, railroad operations have changed materially. Human factors research into shift work, fatigue, and the body clock has produced a significant body of information that can help guide development of improved crew management practices.

Fatigue Initiatives under the Safety Assurance and Compliance Program

Anticipating the need to address identified issues of fatigue and lack of alertness by employees working long or irregular hours, in 1991 we requested complete regulatory authority over the area of hours of service, and in 1994 we requested a more limited authority to approve pilot projects, including waivers of the statute, proposed jointly by rail labor and management. Neither approach yielded a productive outcome.

Nevertheless, during the past few years, railroads have launched a number of fatigue initiatives not requiring waiver of the hours of service laws. Under SACP, FRA has aggressively enlisted the cooperation of rail labor and management to identify and correct the root causes of systemic railroad safety problems, including fatigue.

On the Union Pacific (UP), a SACP effort found that a root cause of the fatigue problem on the UP was inadequate staffing levels and poor crew utilization. FRA found that additional train and engine service crews were needed to fill vacancies caused by attrition, and to meet the demands for increased service. One factor contributing to the crew shortage stemmed from the difficulty in anticipating when vacancies would occur. During the first half of 1997, UP experienced extremely low rates of retirement and attrition among train and engine service personnel, while the second half of the year saw a sharp increase in retirements. Another factor contributing to UP's crew shortage was an increase in train traffic brought about by an increase in business.

The unpredictability of job vacancies was compounded by the long development time that was necessary to properly train and qualify train and engine service personnel. UP provides a minimum of six months training to become a locomotive engineer, and additional time is required for engineers to become qualified on the territories in which they operate. Longer training and qualification periods were often necessary to operate freight trains in highly demanding service over mountain grade territory.

UP's crew shortage problem has been exacerbated by the fact that the railroad industry is currently experiencing a growth in employment for the first time since deregulation of the industry in 1980. For much of the past 15 years, as railroads have downsized, a pool of qualified employees was often readily available to fill vacancies on short notice; however, this situation no longer exists. Recently, railroads nationwide have been expanding the ranks of train and engine service personnel; consequently, an available pool of qualified trainmen no longer exists.

UP is engaged in a hiring effort to augment staffing in key crafts. UP began an aggressive hiring program among train and engine service personnel, transportation and crew managers, and Train Dispatchers to address critical shortages of safety­sensitive personnel in the operating and transportation departments. Since September 1, 1997, UP has hired 500 train and engine service personnel and 33 dispatchers. Furthermore, UP has projected attrition levels among train crews through the year 2015 in order to anticipate future hiring and training needs.

The SACP Working Group is studying the causes of fatigue­related problems and recommending solutions to fatigue­related issues, including napping, lodging, uninterrupted rest periods, education, improved crew utilization, and scheduling. Employee education and awareness efforts are beginning. In the fall of last year, the UP agreed to provide UP train crews the right to guaranteed time off after working a predetermined number of days; UP is the first major carrier to make such a system­wide commitment to address crew fatigue.

BNSF, working with the SACP Task Force, has developed the most advanced "Fatigue Countermeasures Program" in the railroad industry. For example, to deal with acute fatigue during the workday, the carrier has instituted a policy on napping that permits train crewmembers to take naps while on the job if certain rules are met. One train crewmember at a time is allowed to take a nap; there must be negotiation between the employees in the locomotive cab on who will take the nap; and the employee in charge of the locomotive controls is prohibited from taking a nap unless the train is stopped to meet or pass a train, waiting for track work, or other similar conditions. BNSF has also provided ten hours rest in situations when the statute calls for only eight hours. Finally, BNSF has established pilot programs in which employees' off­duty time is not constantly subject to interruption by a duty call, where the employee has certain assigned days off, and where duty calls may occur only during certain "calling windows."

As these approaches succeed, employees will be empowered to take responsibility for their own fitness for duty and have better tools to meet their safety responsibilities. Other Class I railroads, including CSX, have similarly focused on fatigue issues on their systems.

North American Rail Alertness Partnership

FRA's work on fatigue through SACP efforts, and our continued research into fatigue and fatigue countermeasures, have stimulated a broad assault on fatigue and its effects, especially by evaluating the effectiveness of various scheduling and strategic napping policy changes. As a result, we joined with passenger and freight railroads and major rail unions to establish a North American Rail Alertness Partnership (NARAP). Through NARAP, FRA is disseminating information and promoting innovative approaches that permit employees to schedule their rest, take time when they need it to deal with cumulative fatigue, deal with acute fatigue, and prepare themselves to address the requirement for alertness when the body clock is in conflict with the railroad's need to move freight. NARAP also serves as a mechanism for FRA to obtain valuable insight on specific fatigue­related problems in the variety of operational settings and work groups. While no single approach may work everywhere, neither should we miss the opportunity to transplant approaches that will work elsewhere on the National rail system.

NARAP has documented 23 specific projects that are now underway on railroads as FRA continues to evaluate the implementation of various fatigue countermeasures such as napping strategies, mandatory days off, designated calling windows, and other innovative approaches. Other strategies are continuing to be evaluated, and the willingness of employees and railroads to try new approaches has never been higher. Throughout the rest of 1998, FRA will place a major emphasis on the success of NARAP and SACP action plan items concerning employee fatigue.

Proposed Legislative Requirements

While FRA will continue to promote the joint initiative of NARAP and the independent efforts of the leading carriers, we believe that legislative action to assure comprehensive action is necessary. In the broadest terms, the provision calls for each major railroad and affected employee groups to jointly submit to FRA for approval a fatigue management plan systematically addressing the fatigue countermeasures the railroad intends to take to deal with its specific operating circumstances and to deal with a series of specific issues. If full consensus cannot be reached, the railroad must file a plan, but employees are encouraged to submit comments on the plan. The plan is due within one year of enactment. During the first two years after enactment, compliance with a plan not involving a statutory waiver would be voluntary. Plans involving a waiver would be mandatory immediately. After two years, compliance with the plans would become mandatory, and FRA would be authorized to issue regulations requiring additional railroads to submit plans.

This provision builds on the industry's existing cooperative efforts that I have described earlier, which FRA has tried to foster through SACP initiatives and most recently the North American Rail Alertness Partnership. Like those efforts, the provision asks each railroad and affected employee groups to tailor an approach to their specific circumstances. FRA recognizes that there is no silver bullet to remedy the fatigue problem. The bill's provision is flexible and results­oriented, both in specifying the general subjects to be addressed but not demanding that they be addressed in only one way, and in giving railroads two years to fine­tune their programs before they become mandatory. The provision uses a systems safety approach, requiring that the problem of fatigue be addressed as a whole and in the context of the railroad's general operations rather than piecemeal. Transportation safety experts uniformly acknowledge the desirability of taking a systems approach to safety. Finally, the provision also gives railroad management and labor incentives, first, to come to agreement on ways to reduce fatigue on the job and fatigue­caused accidents by authorizing waiver of the statutory provisions upon joint petition by labor and management, and, second, to move employees from an irregular, "on­call" system to a scheduled system by requiring fewer subjects to be addressed in the plan for scheduled employees than for on­call employees.

Each fatigue management plan would have to address specific, enumerated issues. These include such important matters as:

o basic education and training on physiological and psychological factors that affect fatigue, to give employees the scientific tools to manage their fatigue knowledgeably;

o identification and treatment of sleep disorders, which are very common;

o an analysis demonstrating that staffing levels and workloads were considered when the plan was formulated, so that staffing deficits and work overloads such as those mentioned in connection with the SACP initiative on UP can be avoided; and

o alertness strategies, such as policies on napping, which BNSF pioneered and which were discussed earlier.

If all of the railroad's covered service employees are on a regular schedule, no more specific topics need to be addressed. However, if some of the railroad's covered service employees are in unscheduled service, additional issues would have to be addressed, such as enhancing the predictability of work schedules by lengthening the notice provided for reporting to duty. FRA's fatigue research has stressed the overriding importance of notice of start time.

Highlights on Necessary Hours­of­Service Safety Amendments

The bill would also make some specific substantive changes in the hours of service statute to take effect immediately. For example, one set of these technical amendments would ensure that the current statutory restrictions cover all persons, not simply railroad employees, who maintain railroad signal systems for a railroad. This group of provisions would eliminate the unsafe and unfair current situation of having people working side by side doing the same work, some of whom are covered by the hours of service laws and some of whom are not. In some instances, railroad signals are installed, repaired, and maintained not only by railroad employees but by contractors and subcontractors to railroads. We must remember that an exhausted contractor employee doing railroad signal work could cause a major accident by something as simple as installing a relay backwards. This set of amendments would also clarify the existing coverage of persons who engage in dispatching or train service as contractors.

Other proposed amendments to the hours of service laws would regulate hours of employees who work for more than one railroad or contractor to a railroad. This assures that employees with multiple railroad jobs are treated the same as employees who work for only one railroad. FRA is aware of a number of employees who perform signal work for more than one railroad. Often they work on critical grade crossing signals. Almost every year, fatalities caused by grade crossing accidents make up half or almost half of all railroad­related fatalities. A serious safety hazard could result if a dually employed person performing the signal maintenance is not given the same minimal protections of the hours of service laws as an employee who works for only one railroad.

Finally, the bill would make a signal employee's last hour returning from a trouble call not off­duty time but "limbo time." (Limbo time is not counted as either time on duty or time off duty.) There is no safety rationale for giving a signal maintainer less time available for rest than other covered employees receive.

In summary, the fatigue management plans provision and the hours of service technical amendments together offer a comprehensive approach to the problem of fatigue in the railroad industry. The NTSB has long recognized this problem. We believe that this approach will build on industry initiatives against fatigue and reinforce a positive safety culture, just as other parts of the bill reinforce a positive safety culture by preventing harassment and intimidation.

OTHER HIGHLIGHTS OF THE BILL

The Department's four­year authorizing legislation includes a number of other provisions that would advance railroad safety.

To promote passenger safety, section 502 would clarify the Secretary's authority to assure that, when making grants or loans either to commuter railroads or for their benefit, safety issues are addressed from the beginning.

To reduce the paperwork burden on the industry, section 107 would encourage agency waivers and rulemaking to allow hours of service records to be made, maintained, and submitted electronically, and section 301 would eliminate the notarization requirement for accident reports and allow the Secretary to set the interval for filing, but not less than quarterly.

To facilitate the operation of high­speed trains, section 302 would direct the Secretary, in consultation with the Environmental Protection Agency, to issue regulations regarding the noise related to those operations. The EPA has set standards for railroads, and there has been little or no problem with compliance for traditional freight and passenger rail equipment. Current EPA standards do not, however, address the unique noise characteristics of railroad equipment operations in the 150 mph to 200 mph range. The provision would permit FRA to update these standards.

To provide for more efficient inspection practices, sections 201 and 202 would allow FRA railroad safety inspectors to monitor railroad radio communications outside the presence of railroad personnel for railroad safety purposes.

To protect the environment, section 501 would expand FRA's existing emergency order authority to address emergency situations involving a hazard of significant harm to the environment.

To further grade crossing safety, section 504 would redirect Federal "1­800" pilot programs for encouraging emergency notification of grade crossing problems from a State­by­State approach to a railroad­by­railroad approach.

OTHER FRA INITIATIVES TO ASSURE A POSITIVE HUMAN­FACTORS FOCUS AND SAFETY CULTURE

Recognizing that human factor issues such as training, human attentiveness, and fatigue play into nearly every aspect of railroad operations, FRA has initiated a series of actions intended to address these core safety concerns. FRA has widely disseminated important safety information through safety advisories published in the Federal Register. FRA also has focused specifically on alcohol and drug testing, locomotive engineer certification, railroad operating rules compliance, and other evolving safety issues.

Alcohol and Drug Program

FRA has successfully attacked drug and alcohol abuse in the railroad industry and, in fact, has led the way by becoming, over a decade ago, the first civilian agency to adopt stringent testing regulations applicable to a regulated industry. The Supreme Court decision upholding FRA's original program became a landmark case that paved the way for testing safety­sensitive employees in all modes of transportation. Subsequently, both random drug testing and random alcohol testing requirements have been added to the regulations. FRA continues to operate the only comprehensive post­accident toxicology program applicable both to surviving and deceased safety­sensitive employees.

The results of FRA's post­accident toxicological testing program confirm the progress that has been made in reducing alcohol and drug use since the regulations were implemented in 1986. For FRA post­accident toxicological testing, positive test results have dramatically declined since this type of testing began. In 1987 there was an employee positive rate of 5.5 percent, and in 1997 the rate had dropped to 1.2 percent. For post­accident toxicological testing, there were 42 employees who produced a positive specimen in 1987, compared to three employees who produced a positive specimen in 1997. The positive rate for FRA random testing during the first year of the implementation of the program in 1990 was approximately 2 percent to 3 percent. In 1997 the random­testing positive rate was approximately 1 percent.

These dramatic declines in the random­testing rate have facilitated a performance­oriented approach determined by the previous year's overall violation rate for the railroad industry. This approach has allowed FRA to lower the minimum random­testing rate to 25 percent for both 1997 and 1997.

To ensure enforcement of this regulation, FRA relies upon regular inspections of railroad companies and properties, special assessments, and investigation of complaints. FRA believes that education is a primary adjunct to successful program implementation. During 1997, all Federal and State operating practices inspectors received week­long comprehensive training in the applicable regulations, which included a highly successful industry day for our labor and management partners. An extensive reference guide including sections on control of alcohol and drug use was developed and issued to the operating practices work force.

Locomotive Engineer Qualifications Program

FRA's program of certifying locomotive engineers, in which FRA reviews and approves each railroad's qualification standards, has significantly enhanced railroad safety. All engineers must be given prescribed training, testing, and evaluation before receiving certification, and they must be reevaluated every three years. Incidents of unsafe train handling result in mandatory periods of certification revocation.

To assure the continued effectiveness of these requirements, FRA tasked the Railroad Safety Advisory Committee with updating the regulations. The RSAC working group has nearly finished its proposal and will include new testing requirements in light of recent experience. For example, FRA's current requirements for locomotive engineer visual acuity and color perception are equivalent to those imposed by the Federal Highway Administration on motor carriers and similar to Federal Aviation Administration standards. A key element being considered for the new certification program is a revised visual testing regime addressing issues raised by the fatal collision in February 1996 at Secaucus, NJ, in which the engineer's color blindness is believed to have resulted in his running a red signal. To assure the highest level of safety pending issuance of the new rule, we also intend to issue a safety advisory in the near future relaying pertinent information on this issue to the medical community and the railroad industry.

Railroad Operating Rules Compliance

FRA's railroad operating rules regulations (49 CFR Part 217) govern oversight of the railroad industry's operating rules and practices with respect to trains and other rolling equipment. Each railroad is required to instruct its employees in operating practices. Additionally, each railroad is required to conduct operational tests and inspections of its employees to determine the extent of compliance with its code of operating rules, timetables, and timetable special instructions, in accordance with a written program which is retained at its system headquarters and the division headquarters for the railroad division where the tests are conducted. FRA operating practices inspectors monitor the railroad's efforts by inspecting pertinent records and by accompanying railroad managers when efficiency tests are conducted. These efforts form a basis to assess impartially the railroad's efforts to develop and maintain a suitable safety program, rather than to criticize the railroad's managers for deficiencies in the program or single out employees for disciplinary action. Where appropriate, recommendations for operating rules changes or revisions are addressed through the SACP process or other suitable avenues. FRA believes that its operating practices regulatory oversight effectively addresses critical human factor safety concerns in the context of railroad operations.

Safety Advisories

As FRA has sought to disseminate important information on critical safety concerns, we have issued a number of safety advisories. By publishing them in the Federal Register, these notices have reached a wide audience. This is particularly important in the human factors context where issues of training are important to ensure continual safety focus. For example, FRA alerted railroads to locomotives designed with an emergency fuel cut­off switch that was located near the engineer's knee and therefore easy to activate unintentionally. Such a fuel cut­off switch contributed to an accident involving a runaway UP freight train at Hayden, California, on

January 12, 1997. We have also issued safety advisories on possible gaps in train control systems, train handling procedures, equipment securement procedures, and procedures for reducing the risk of damage to tracks and bridges from flash floods. FRA will continue to issue safety advisories where appropriate in order to assure the widest possible awareness of critical best safety practices.

Addressing Evolving Safety Hazards

The causes of railroad accidents vary from year to year; hazards are shifting and complex, requiring a prompt and flexible response. In 1997, 12 employees were killed in yard and switching incidents. This is the single highest category for on-duty railroad employee fatalities. FRA has formed a task force to explore the causes of these fatalities to train and engine crews during switching operations. The task force consists of representatives from the Office of Safety, rail labor, and rail management, including the Association of American Railroads, and The American Short Line and Regional Railroad Association. The goal of the task force is to identify best practices that will reduce and prevent incidents as well as to implement corrective measures through the SACP process. The group will seek to find remedies to the conditions and behaviors that have made this a problem that has not been addressed with complete success since the inception of the industry. FRA will remain vigilant to emerging patterns of safety hazards and take prompt responsive action to address them.

CLOSING

In closing, advancing these human factor and other safety initiatives throughout an industry of 265,000 employees and 220,000 miles of track, more than a million cars and locomotives, and thousands of facilities is a daunting but absolutely essential task. The safety of every employee demands it. The economy demands it. The country's 21st century transportation future demands it.

As I have pointed out, several elements of the Administration's rail safety reauthorization bill are based on the many lessons of the past two years that I have reviewed today. We believe that enactment of the Federal Railroad Safety Authorization Act of 1998 is critical to maintaining the continuous safety improvement that we have achieved to date. The legislation will allow FRA to fulfill its safety mission by focusing its limited resources in large part on safety culture and fatigue issues and on existing regulatory mandates, which will be discussed at the next scheduled hearing. Mr. Chairman, I appreciate this opportunity to testify, I look forward to your help and support as we move forward with our rail safety agenda, and I again offer our assistance as the Subcommittee considers important rail safety legislation.

Number Caused

by Human Total Percent Caused

Year Factor(s) Number by Human Factor(s)

1991 887 2814 31.5

1992 864 2531 34.1

1993 865 2785 31.1

1994 911 2669 34.1

1995 944 2619 36.0

1996 783 2584 30.3

1997 834* 2526* 33.0*

____________

* Figures for 1997 are preliminary.

BACKGROUND

Approximately one­third of all railroad accidents are caused by human error. The Federal Railroad Human Factors Research Program has focused on identifying the root causes for human error affecting safety in the railroad industry. The goal of this research program is to reduce the frequency and severity of accidents attributable to human error. Technologies, practices, and procedures evolved from research and development (R&D) on the effects of stress and fatigue are expected to provide one of the means for reaching this goal while improving railroad operating efficiency and environmental quality. The Federal Railroad Administration (FRA) is working in conjunction with the other modal administrations to address stress and fatigue issues.

Workload, Stress, and Fatigue

A primary purpose of this technical activity is to determine whether work schedules that are commonly encountered in railroad operations produce sufficient fatigue (lack of alertness) and stress in locomotive engineers, dispatchers, and other railroad personnel to compromise the safety and efficiency of their work performance. A related question concerns the amelioration of such fatigue and stress by adjustments in work schedules, crew calling procedures, hours of service requirements, work environment, etc. Currently, there are sub­activity areas addressing this topic in enginemen, high­speed operations, yard and terminal operations, and dispatchers.

Locomotive Engineer Stress and Fatigue

The Enginemen Stress and Fatigue Phase II project was initiated in April 1992. The central question in this study is whether the hours of service laws and work schedule produce sufficient fatigue and stress in locomotive engineers to compromise the safety of their work performance. Fifty­five experienced, certified locomotive engineers were used as test subjects. Each subject was observed during a one­week period on the Research and Locomotive Evaluator/Simulator (RALES) facility at the Illinois Institute of Technology Research Institute (IITRI). The current law governing hours of service for locomotive engineers allows work schedules that have backwards­rotating shift­start times. Locomotive engineers who work under such schedules can accumulate a progressive sleep debt over a period of days. The locomotive engineers in this study, while working on such schedules, reported progressive decrease in subjective alertness across the duration of the study. Several aspects of job performance, including safety­sensitive tasks, degraded during the same time period. The final report on this work has just been published.

Evaluation of Mitigation Strategies began in FY 1997. This activity consists of multiple projects designed to identify and test the intrusion of stress and fatigue on locomotive engineers' performance. The first two projects will be to look at (i) the use of planned, on­duty napping and (ii) vigilance monitoring. The use of napping to mitigate fatigue has become a focus of interest in the railroad industry and in other industries, notably aviation and trucking. The purpose of this project will be to examine and evaluate napping strategies that are compatible with railroad operations. The project will support decision­making in the Office of Safety regarding the necessity of changes in the hours of service laws, other rail safety laws, or FRA regulations. The project will be conducted at IITRI on the RALES. In the second project, existing vigilance­monitoring devices, and those known to be in advanced stages of development, will be evaluated to determine their usefulness in the railroad operating environment. This evaluation will be followed either by testing the most promising devices or attempting to develop a new device based on technology employed in various research activities for data acquisition. In addition to napping strategies and vigilance monitoring, changes in work environment, and scheduling and crew calling practices are other strategies that are likely to be evaluated.

Locomotive Engineer Work/Rest Cycles

This project began in 1998 to extend the analysis of locomotive engineer diary data that was previously collected by the Volpe National Transportation Systems Center in 1996 for FRA. On­call railroad employees are often forced into work/rest cycles either shorter than, or longer than, a typical 24­hour day. Numerous laboratory studies have shown that forced rest/activity cycles outside the body's normal range of entrainment can lead to circadian rhythm desynchronization, chronic fatigue, and impaired performance. A recent study by the FRA demonstrated that work/rest cycles shorter than 24 hours do indeed impair locomotive engineer performance in a locomotive simulator. No studies prior to the FRA simulator study have established the effects of work/rest cycles shorter than 24 hours in on­call railroad operations. Data from this study corroborate these findings and extend them to suggest how often, and under what circumstances, shorter­than­24­hour work/rest cycles occur in on­call railroad operations. Diary data from 198 locomotive engineers working on several railroads were analyzed. Across on­call assignments, locomotive engineers, on average, worked a shorter­than­24­hour work/rest cycle about one­third of the time (about 40 percent of the time for extraboard engineers). When engineers completed a shorter­than­24­hour work/rest cycle, they had significantly more sleep and subsequent alertness problems than when they completed a longer­than­24­hour work/rest cycle even though engineers were provided the statutorily required minimum of eight hours' rest (or more). Information suggests that shorter­than­24­hour work/rest cycles in on­call operations may put employees at greater risk for fatigue­related incidents, and that the federal requirement for a minimum eight hours of rest may not be enough.

High­Speed Train Operations

The Information-Mediated Fatigue and Stress in Railroad Operations Project began in 1996. It is intended to examine the workload, stress, and fatigue issue within the special context of high­speed operations to determine if there is a synergism of speed, sleep loss, and work/rest cycles in producing operator fatigue. High­speed operations increase the flow of information that is used by locomotive engineers to control the train. While train speeds increase, the ability of human beings to process information remains constant. As a result, human operators experience increased mental workload, and consequent stress and fatigue, in a high­speed operating environment. When the effects of speed, per se, on workload, stress, and fatigue have been determined, the project will examine speed effects in combination with circadian rhythms, sleep loss, and work/rest schedules.

Yard and Terminal Safety

As part of an effort to make a preliminary determination of the root causes of yard and terminal accidents, Phase I of the Yard and Terminal Safety Project examined the time of day at which accidents occurred. It was found that accidents peaked during the early morning (2:00 a.m. to 4:00 a.m.) and late afternoon (6:00 p.m.). This result is consistent with circadian patterns of fatigue observed in other industries and suggests that work/rest cycles and work schedules may be causal factors in many yard and terminal accidents. Phase II of this project began in March 1998 and will extend the observations of Phase I. Specifically, Phase II will further document the relationship of time of day to worker injuries and will compare key work/rest variables for injured and uninjured employees.

Dispatcher Workload, Stress, and Fatigue

There are three projects under this sub­activity which are intended to occur sequentially, dependent upon the success of the preceding phase. Phases I and II began in FY 1996.

The Dispatcher Workload, Stress & Fatigue, Phases I, II & III Projects will develop objective and reliable evaluations of train/railroad dispatcher's workloads, occupational stress, and fatigue. A 1987 survey of train dispatching offices and practices found that dispatchers were subjected to work overloads and heavy safety responsibilities. It was also found that there were some locations and instances where personnel were required or permitted to work on their assigned rest days. Together, these findings lead to concern about the effects of workload, stress, and fatigue on performance and safety. Phase I, completed in October 1997, identified candidate measures of workload, stress, and fatigue which are objective, well­defined, and suitable for use in the dispatcher's workplace (unthreatening, and as least intrusive or time­consuming as possible). Phase II, currently underway, will evaluate the candidate measures to identify and document those most suited for FRA use. Phase III will use the chosen measures in a full study of dispatcher workload, stress, and fatigue. It is anticipated that Phase III would be initiated in late FY 1998 or early FY 1999.

Future Technology

While the initial High­Speed Human Factors (HSHF) program addressed human­factor issues relating mostly to high­speed trains, the current program has grown considerably in scope and purpose since its inception. As emerging technologies continue to increase the complexity of all aspects of the railroad industry, broader human­factor concerns that impact both high­speed and slower speed operations need to be addressed. Operators, for example, must be able to quickly understand and respond to complex information in a dynamic environment. How that critical safety­related information is displayed and communicated, then, becomes increasingly important in one's ability to respond safely and efficiently to that information. Therefore, methods of communication, the presentation of information, and the design of various technological devices, should be evaluated for their impact on performance and decision­making before they are implemented.

Under this focus area, future and current work will focus on issues such as digital communications, locomotive display guidelines, and the impact of crew teaming (i.e., engineer, conductor, dispatcher, maintenance personnel, etc.) on critical decision­making. Methods are currently being developed to better categorize and understand the communication processes and cognitive representations used by operations experts in their jobs. With this information, software engineers can then design improved displays and sensory feedback systems that increase the saliency of key information to be used by these individuals in their critical decision­making processes. As new technological devices, visual displays, and other cognitive feedback systems are developed, specific features and design components will be tested for their capabilities of minimizing operator error.

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