Do you have that recurring dream, that one where FRA decides to audit your Operational Testing Program and all you have to show the inspectors are...blank pieces of paper, empty data fields in your electronic records of the program, missing documentation establishing the proficiency of your testing officers?
Once a week? Twice a week? Every night? Put down the Ambien. Step back from the window ledge. Joe (not Sam) Pasanello and Dave (not that Dave; this Dave) Schanoes are coming-- or can be contacted, contracted and otherwise enticed to arrive on your property and help end your sleepless nights, your cold sweats, your terror when the caller ID on your phone displays that phone number beginning with (202), your vertigo when you hear the numbers 217.9, 217.11 or when you think you hear someone at the next table say something that sounds like "subpart F"!
We have, we can, and we will, review your Operational Testing Program for compliance with 49 CFR parts 217.9, 217.11, subpart F 218, and the additional mandatory tests. We have, can and will, where necessary rewrite sections of your existing plan to make it compliant. We can and will rewrite the plan in its entirety if conditions so warrant.
We have, can, and will develop a plan for conducting certain tests at frequencies that both satisfy FRA directives and will build you a better, safer railroad.
We have, can, and will identify other tests that can be used to provide a "snapshot" of the operating proficiency and the overall safety of your train operations.
We have, can, and will develop the criteria for qualifying your testing officers, for developing the training modules for you officers, including classroon and field sections, tests for proficiency, and the training course syllabus.
We have, can, and will develop scenarios or templates for "structured" or "set-up" tests, including tests that require coordination between your field officers and your operations control centers.
We can't do everything, of course. We can't conduct the testing for you. We don't want to, and you don't want us to. We don't write the computer code for electronically recording the data from your program. But.....we are responsible to nobody but you in developing a complete program that meets FRA's requirements and improves the expertise of your line officers and your operating employees, which, after all, is the point of the regulations.
and sleep better. Count on it.
May 21, 2014
"Giving you more of what you're funking for..."
-George Clinton and the Parliament-Funkadelics, "One Nation Under A Groove."