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to you fully on the subject. There is really no necessity for haste, as the Commission has fixed March 1, 1904, as the limit of time within which railroads may comply with the requirement for grab irons upon locomotives.

In your report you seem to indicate that the conclusions there stated are based largely upon views expressed by a representative of the Interstate Commerce Commission. If the Commission or its representative is to bear any portion of the responsibility, I beg that you will set forth in the report what the views of this representative are and the reasons why he has taken the position indicated.

Personally, I do not think it requisite that the front ends of locomotives shall be equipped with handholds separate from a proper uncoupling lever; but I do believe that locomotives should be equipped with an uncoupling lever, running from one side to the other of the front end of a locomotive, made of iron at least 1 inch in thickness, well bolted, and with a 24-inch clearance (as outlined in your proposed report), so that under all circumstances the employee will be able to use such uncoupling lever as a grab iron. It is my belief that this would satisfy the requirements of the law for a handhold or grab iron on the front end of locomotives, and that a grab iron on the side of a locomotive near the front end is unnecessary.

Although not required by the statute, it is noted with satisfaction that your proposed report recommends the addition of a foothold or step on the pilot, to be used by the employee in connection with the grab iron.

It should be borne in mind that the law requires handholds on the fronts and sides of locomotives unless this Commission relieves the carrier from such requirement. Notwithstanding the position taken by some railway managers that handholds on the front ends of locomotives are unnecessary and are an element of danger, the Commission is not likely, in view of the contrary belief held by representatives of practically all railroad employees who are at risk, to relieve the carriers from this obligation. It appears, moreover, that a large number of railroad companies had equipped their locomotives with front end handholds before the law requiring such handholds was passed, and it is believed that the opinion of the mechanical men employed on the roads of those companies should also have consideration. The ideal condition would be that the employee should on all occasions be afforded facilities which would obviate the necessity of placing himself in front of the locomotive or at other unnecessary risk. As you are aware, and as was brought out at our meeting, such ideal condition frequently does not exist in actual practice; the trainman is often compelled by the exigencies of his employment to expose himself in this

manner.

As long as the service subjects men to such risks, everything in the way of equipment which their practical experience demonstrates will safeguard their lives and limbs in the performance of their duties should be cheerfully provided.

It is believed that the use of a solid or rigid coupler which does not open is bad practice, and as it is understood that this is the unanimous opinion of the committee it should be noted in your report.

It was also the unanimous opinion of the committee, I believe, that road engines should not be used in yard service unless such changes are made as will fit them for that work. Following that view, is it not proper that the report should recommend the removal of pilots on road engines engaged in yard service; that footboards and long uncoupling levers on the front ends of locomotives and rear ends of the tenders should be applied; and that the driving-wheel brake should be in good condition?

If the foregoing suggestions are adopted, the Commission will undoubtedly concur in your report. As the report will probably be adopted as the recommended practice, and as such continue in force for a considerable period of time, there should be, I think, a complete understanding as to its provisions, and it should fully cover the matters necessarily involved in practical operation.

Sincerely, yours,

EDW. A. MOSELEY, Secretary.

NEW YORK CENTRAL AND HUDSON RIVER R. R. Co.,
West Albany, October 19, 1903.

Mr. EDWARD A. MOSELEY,
Secretary Insterstate Commerce Commission, Washington, D. C.

DEAR SIR: I have your letter of October 16 in regard to the report of the committee of the American Railway Master Mechanics' Association on "The location of grab irons on the front ends of locomotives." As chairman of the Master Mechanics' committee, I am obliged to you for your time and attention.

I agree with you that everything in the way of safeguards to reduce to a minimum

the risks of trainmen in the performance of their duties should be provided, and believe most railroads will willingly and cheerfully do this, regardless of cost. If I correctly understand the case, the matter of the cost of applying grab irons to the front ends of locomotives is not the main consideration in the minds of many operating and motive power department officials, who consider their application at this point an invitation to employees to assume unnecessary risks by riding on the pilot. In regard to the use of the solid or rigid coupler on the pilot: You are right in stating that our committee does not consider these as complying with the law, but it seems best not to include this in the report on "The location of grab irons on the front ends of locomotives," for which our committee was appointed.

You are correct in saying that our committee was of the unanimous opinion that when it is necessary to use road engines for yard service the pilots should invariably be removed and standard footboards and proper handholds applied, both to the front end of the engine and the rear of the tender, and that the driver brakes should be in good condition. We are, however, of the opinion that this would be out of place in our report, as it is not covered by the subject we were appointed to investigate.

Yours, truly,

C. H. QUEREAU, Superintendent of Shops.

RAILWAY ACCIDENTS.

LAW REQUIRING MONTHLY REPORTS OF ACCIDENTS.

[PUBLIC-No. 171.]

AN ACT requiring common carriers engaged in interstate commerce to make full reports of all accidents to the Interstate Commerce Commission.

Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, It shall be the duty of the general manager, superintendent, or other proper officer of every common carrier engaged in interstate commerce by railroad to make to the Interstate Commerce Commission, at its office in Washington, District of Columbia, a monthly report, under oath, of all collisions of trains or where any train or part of a train accidentally leaves the track, and of all accidents which may occur to its passengers or employees while in the service of such common carrier and actually on duty, which report shall state the nature and causes thereof, and the circumstances connected therewith.

SEC. 2. That any common carrier failing to make such report within thirty days after the end of any month shall be deemed guilty of a misdemeanor and, upon conviction thereof by a court of competent jurisdiction, shall be punished by a fine of not more than one hundred dollars for each and every offense and for every day during which it shall fail to make such report after the time herein specified for making the same.

SEC. 3. That neither said report nor any part thereof shall be admitted as evidence or used for any purpose against such railroad so making such report in any suit or action for damages growing out of any matter mentioned in said report.

SEC. 4. That the Interstate Commerce Commission is authorized to prescribe for such common carriers a method and form for making the reports in the foregoing section provided.

Approved, March 3, 1901.

TABLES COMPILED FROM ACCIDENT RECORDS FOR THE YEAR ENDING JUNE 30, 1903.

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TABLE A.-SUMMARY OF CASUALTIES TO PERSONS-Continued.

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TABLE B.-COMPARATIVE STATEMENT, YEARS 1903, 1902, 1901, 1893.

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Killed. Injured. Killed. Injured. Killed. Injured. Killed. Injured.

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a In 1902 and 1903 this item includes fixed obstructions at the side of the track as well as overhead. The diminution in the number of employees killed and injured by miscellaneous causes in 1902 and injured in 1903, as compared with 1901, is due, partly or wholly, to the inclusion in 1901 of employees in shops and on boats, wharves, and other places remote from the railroad, which are not included in the accident bulletins.

TABLE C.-COLLISIONS AND DERAILMENTS; DAMAGE TO CARS, ENGINES, AND ROADWAY.

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TABLE D.-CAUSES OF ACCIDENTS TO EMPLOYEES IN COUPLING AND UNCOUPLING CARS.

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TABLE E.-CAUSES OF ACCIDENTS TO EMPLOYEES CLASSIFIED (C6 AND C7) AS FALLING FROM AND GETTING ON OR OFF CARS AND ENGINES.

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