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 training program had been in place for several years and had produced 13 apprentice classes. One reason is that the program had never been thoroughly evaluated. As a result, coordination difficulties, documentation needs, the reactions of apprentices to their training, and scheduling deficiencies were not identified and resolved. The Safety Board believes that Amtrak management needs to determine how training activities are integrated and coordinated in the program and to evaluate how these activities are contributing to or detracting from the program mission.

—The Safety Board is concerned that the 49 CFR Part 240 final rule may not provide sufficient guidance to the railroad industry for developing, operating, and evaluating engineer training programs. The rule identifies nominal activities for acceptable programs but does not specify which standards these activities must meet. The Safety Board takes particular notice of the exclusion of minimum training time requirements for activities such as physical characteristics qualification and learning operating skills. The Safety Board believes that after granting preliminary approval for a railroad's program, the FRA should base final approval on a thorough assessment of all training and evaluation activities.

The Safety Board also believes that the FRA should employ rigorous criteria in evaluating both new and existing programs in order to judge potential training effectiveness and to ensure an equitable approval process for all railroads. All railroads submitting requests for approval should include minimum completion targets for training activities based on actual program performance. Finally, the FRA should solicit comments from participants in the training programs for which approval is being sought and include such inputs in its evaluation process.

Because the rule is new, the Safety Board does not have enough information to evaluate the effectiveness of the FRA approval process. However, the Safety Board will monitor the FRA locomotive engineer certification program as it develops.

Locomotive Event Recorders
After reviewing the event recorder strip chart of the data from Amtrak train 66, Safety Board investigators determined that the locomotive crew had operated the train in excess of the authorized 100-mph speed on three occasions Amtrak train 66 operated at speeds up to 110 mph between Kingston and Providence and between South Attleboro and Route 128, and it operated at speeds up to 109 mph between Route 128 and the POD. The end-of-tape mark on the magnetic tape prevented strip chart output of data from Route 128, and Safety Board laboratory engineers had to recover that data by a manual data extraction process on the data pack.

Safety Board investigators could not determine how the end-of-tape mark was placed on the accident magnetic tape. Amtrak officials reported that the strip charts from their initial readout of the data pack showed no accident data. The Safety Board believes that if Amtrak's current postaccident event recorder procedures had been in effect at the time of the accident, this problem could have been prevented.