Brian Brendal - Comments

Regarding questions posed by the FRA on page 2210 Federal Register / Vol. 76, No. 8 / Wednesday, January 12, 2011 / Proposed Rules. I think instead of "providing keys" directly for first responders, if somehow the Fire Department could be provided with keys via a "Rapid-Entry Box" system, like fire departments across the country already utilize to get into buildings, it would work out better than having keys floating around fire stations. "Rapid-entry" systems provide a common-keyed lock-box on the outside of a structure, which the FD has a single key for; a version of that system could also be used for a vehicle like a locomotive. Fire Departments could pry or batter a locked door open, but that takes some time depending upon familiarity with the lock and how substantial the lock is. Also, this ruins the door completely. So the answer to "unduly delayed(?)" is "possibly". Regarding "will door locks *prohibit*emergency responder access?" With 34 years of experience of emergency responses to vehicle crashes of all types, I doubt FD would be "prohibited" from entering the locomotive cab if the crew is incapacitated. We will get in. Regarding "how can the doors be secured...to allow access by emergency responders?" If a small break-out panel or window is provided near a dead-bolt type lock, it can be broken out and the lock then actuated by a person reaching through the opening and working the mechanism. Working the lock from the "locked" side is standard Fire Department forceable entry practice. The location and extent of this 'break out panel' can be made known to first responders thorough informative bulletins and drill sessions with the railroads Brian C. Brendel, Battalion Fire Chief Fairfax County Fire & Rescue Department Battalion 5 C-Shift Rail Advisory Committee Chair 7936 Telegraph Road, Alexandria, VA 22315 (Battalion HQ)703-719-9298 (c)571-221-1305