BMWED Comment Letter

Brotherhood of Maintenance of Way Employes Division
of the International Brotherhood of Teamsters

July 7, 2009
(Electronic Submission)

Mr. Robert Brogan
Office of Safety, Planning and Evaluation
RRS-21
Federal Railroad Administration
1200 New Jersey Ave., SE., Mail Stop 17
Washington, DC 20590

Re:

Proposed Agency Information Collection Activities; Docket No. FRA-2009-0001-N-16

Dear Mr. Brogan:
The Brotherhood of Maintenance of Way Employes Division (BMWED), a labor organization
representing 36,000 railroad workers who build, maintain, repair, and inspect tracks, bridges, and related
railroad infrastructure throughout North America, submit the following comments in support of the
proposed new information collection activity in Docket No. FRA-2009-0001-N-16.
The BMWED National headquarters is located at 20300 Civic Center Drive, Suite 320, Southfield,
MI 48076-4169. The BMWE Department of Safety is located at 25 Louisiana Ave, NW, 7th Floor,
Washington, DC 20001, phone 202-508-6449, fax 202-508-6450.
COMMENTS
The purpose of the proposed “Track Transportation [track inspection] Time Study, OMB Control
Number: 2130-NEW, Docket No. FRA-2009-0001-N-16” is to address four issues raised in the Rail
Safety Improvement Act (RSIA): (1) Determine whether the required intervals of track inspections for
each class of track should be amended; (2) Determine whether track remedial action requirements should
be amended; (3) Determine whether different track inspection and repair priorities or methods should be
required; and (4) Determine whether the speed at which railroad track inspection vehicles operate and the
scope of the territory they generally cover allow for proper inspection of the track and whether such speed
and appropriate scope should be regulated by the Secretary.
In response to the Proposed Agency Information Collection Activities; Comment Request published
in the Federal Register on July 6, 2009, (Volume 74, Number 127, pages 32029-32030) BMWED supports
the proposed study and related information collection activities. As such, BMWED respectfully requests
OMB approval.
BMWED offers the following comments in support:

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The proposed collection of information is necessary for the Department to fulfill its
Congressional mandate under the RSIA to conduct a track inspection time study. This
information is necessary to evaluate the conditions under which visual track inspections are
conducted and to develop a report to the Congress responsive to Section 403 of the RSIA.

•

The collected information will have practical utility to the Secretary of Transportation and the
Federal Railroad Administration (FRA) in their analysis of track inspection issues within the
industry.

•

The Department’s estimates of burden hours and costs are reasonable.

•

The methodology proposed for this information collection activity is suitable and appropriate for
the study and the respondent population and will facilitate the collection of data with high utility.

•

The proposed information collection activity has been designed to be minimally burdensome on
respondents and the proposed information collection activity is of limited duration.

Visual track inspections conducted under 49 CFR Parts 213.233, 213.235 and 213.365 play a vital
and integral role in maintaining track structural integrity and the safety of railroad operations. BMWED
believes that the “Track Transportation [track inspection] Time Study, OMB Control Number: 2130NEW, Docket No. FRA-2009-0001-N-16” is necessary to allow the Secretary to fulfilling the
Congressional mandate of Section 403 of the RSIA to: (1) determine whether the required intervals of
track inspections for each class of track should be amended; (2) determine whether track remedial action
requirements should be amended; (3) determine whether different track inspection and repair priorities or
methods should be required; and (4) determine whether the speed at which railroad track inspection
vehicles operate and the scope of the territory they generally cover allow for proper inspection of the
track and whether such speed and appropriate scope should be regulated by the Secretary.
The BMWED appreciates the opportunity to present these comments in support of “Track
Transportation [track inspection] Time Study, OMB Control Number: 2130-NEW, Docket No. FRA2009-0001-N-16.”

Respectfully,

President

cc:

Mr. Perry Geller
Mr. Rick Inclima

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