Page:Derailment of Amtrak Passenger Train 188 Philadelphia, Pennsylvania May 12, 2015.djvu/28

NTSB "would also establish minimum requirements for the roles and responsibilities of the second train crewmember on a moving train, and promote safe and effective teamwork."

The engineer on train 188 was alone in the control cab, as is customary for most Amtrak operations on the Northeast Corridor, and therefore he was solely responsible for ensuring compliance with signals and speed restrictions. The Brotherhood of Locomotive Engineers and Trainmen (BLET) has advocated for a two-person crew requirement and asserts that a second qualified employee in the cab would have prevented this accident, but they do not explain the basis for this assertion. (See BLET Revised Final Submission in the public docket for this accident.)

Increased crew size is one of the options for enforcing speed limits at specific locations in the Fixing America's Surface Transportation (FAST) Act (Public Law 114-94, December 4, 2015). Section 11406 of the FAST Act requires railroads providing intercity rail passenger transportation or commuter rail passenger transportation to develop action plans for warning and enforcing speed limits at locations not governed by PTC where there is a speed reduction of more than 20 mph approaching a curve, bridge, or tunnel. Appropriate actions listed in the act include the following:

"* modification to ATC systems or other signal systems
 * increased crew size
 * installation of signage notifying crews of the maximum authorized speed
 * installation of alerters
 * increased crew communication
 * other practices"

The NTSB agrees that relying on a single person to make correct decisions can result in a single point failure. This single-point failure will be substantially addressed by full PTC implementation since that system will provide an independent automated means of compliance with speed and signal restrictions in case of human error. In areas where PTC is not implemented, other ways of addressing this single point failure may be necessary. It is unclear if a two-person crew would satisfactorily address this issue because there is insufficient data to demonstrate that accidents are avoided by having a second qualified person in the cab. In fact, the NTSB has investigated numerous accidents in which both qualified individuals in a two-person crew made mistakes and failed to avoid an accident. (See appendix C.)

The NTSB attempted to use the FRA accident database, which comes from accident reports submitted by railroads, to determine whether trains with one-person crews have a higher rate of accidents than trains with multi-person crews; however, investigators found the data were not useful in making such a comparison. The FRA acknowledged in its recent NPRM that it "cannot provide reliable or conclusive statistical data to suggest whether one-person crew operations are generally safer or less safe than multiple-person crew operations." The 18