Part 225 Submittal Methods Session 1
General
Thank you for attending FRA's first Part 225 Technical Symposium, held virtually on July 17, 2024. If you were unable to attend, please feel free to watch the recording or review the Q&A below.
Session Recording
You can view the recording here: FRA's Part 225 Technical Symposium I.
Please note a password is required to view the recording. When prompted to “Enter the passcode to watch "FRA Part 225: Submittal Methods Technical Symposium", please type in: hm.Pk8K$ and select “Watch Recording.”
Q&A
To view the Q&A from the session, please expand the "Q&A" tab below.
The following questions were posed to FRA during the Part 225 Technical Symposium Session 1. The questions and answers from the session have been modified for clarity.
- Will the web portal contain the most accurate list of cities/towns in which the railroad has stations?
FRA will use the most accurate lists of cities and towns. FRA will look at standardizing forms to request information for cities, counties, and states in a more consistent manner and ensure that the entries are valid.
- What does the timeframe look like for implementing this change?
It will be based on several variables, so the timeframe is unknown. It will be based around the timeframe for the rule, which has not yet been finalized.
- I like the form consolidation idea. Will this result in less forms? Some of them are very redundant and I feel like they could be easily combined.
Yes, FRA is looking at form consolidation, and that would result in fewer forms.
- What is the average time delta for amendments?
Assuming this means the average time needed to amend and submit a report, that is unique to each reporting railroad and their reporting officer. That information is not captured by FRA.
- Are the forms going to change, as far as data entry?
Yes, they will likely change.
- Regarding the statement that Part 225 reporting changes will not affect requirements for other agencies: is this an opportunity for inter-agency safety data standardization, if utility and accessibility of data is a goal?
FRA is not currently considering inter-agency data standardization.
- Small railroads, especially the stand-alone operations, may not have higher-end software programs that Class I railroads have. Will your new processes accommodate us?
FRA will provide a web-based application to accommodate both small and large operators, at no charge.
- Will records be available to download in a report format?
The form PDFS will be available for download in the system and once released publicly. The dataset will also be available for download.
- Will FRA work with any currently known vendors that already assist with Part 225 submissions?
A contractor to developer the web-based application has not yet been determined. No further determinations regarding third-party vendors have been made. However, FRA has welcomed interested third-party vendors to participate in the technical symposium sessions.
- On the current forms used for reporting, there is a lot of manual input that relies on user guides. Will there (or is there potential) to implement drop-down options to make the forms easier to complete? Will there still be room for "other" explanations that can be described?
Yes, FRA will allow drop-down menus for selection and free-form data entry text input, where applicable.
- Is there any plan to revise accident cause codes?
That is out of scope for this meeting, as it relates to the regulation itself.
- Is FRA still requiring form submissions within 7 days?
Assuming this refers to Form 97, which must be filled out within 7 days of an accident/incident, this currently only applies to an internal form. Any changes to that timeframe are out of scope for this meeting, as they relate to the regulation itself.
- Will railroads be able to submit late and amended reports electronically vs. the current method, which involves emailing hard copy forms and manually-updated Form 55s with "Late Report" and "Amended Report" written in red ink at the top of the form?
Yes, everything will be submitted electronically, no paper involved. Any amendments would follow the same, new electronic process.
- This new, planned reporting system sounds like the existing AIRGNET system. How will the new system improve upon AIRGNET?
Will the web-based portal method be different from the current AIRGNET?
AIRGNET is installed locally on an individual's computer and has limits as to who can access and update the forms. For example, only one person can fill out a form at a time because it is installed locally. A web-based portal will allow multiple people within an organization to access and complete the forms simultaneously from their individual computers. Since AIRG is installed on an individual's PC, updates to the system must be manually downloaded. The web-based application will have updates automatically applied, so no updates will ever have to be downloaded.
- Are changes to the data captured in the current forms part of the scope of this effort, or are you just attempting to improve the collection of the current data?
FRA intends to capture and provide access to historical data. FRA is also attempting to improve the collection of the current data.
- Will the new system reduce the time needed to process and disseminate data on the FRA website?
It is possible that FRA will be able to publish data sooner. This was brought up as a goal from the railroad associations during initial meetings in 2022.
- Is the API currently available to integrate with?
No, it has not yet been developed, but stay tuned for future developments.
- Will the web-based application accommodate the Macintosh OS and Safari?
FRA only supports and is able to test any system in Google Chrome and Microsoft Edge. If a railroad can successfully use Macintosh and Safari to submit data, there should not be any problem, but FRA does not have access to Macintosh and Safari and thus cannot test if functionality works using the OS and browser. It would also be unable to troubleshoot any issues identified in the Macintosh OS or Safari.
- With updating the regulation, is FRA going to have virtual or in-person training? And, if so, will there be several opportunities to attend?
FRA will offer virtual training sessions. FRA does not hold in-person training sessions unless asked to present at an event.
- I am currently looking to extract the data out of AIRGNET and am doing it manually. Will there be a way to extract railroad data to for analysis?
Yes, FRA plans to collect and provide access to historical, revised data.
- With a change in submission to an online portal, will there still be someone auditing month-to-month submissions for inconsistencies or deviations in data?
Yes.
- For Part 225, on-site audits, will we still be required to produce paper copies of our forms for review by the auditors or will FRA access the data themselves?
Assuming the data is contained in the new web-based application, FRA prefers electronic copies of forms. However, the preference for paper or electronic copies is at the discretion of the auditor.
- Will the new system allow for a trackable trail of changes for potential auditing purposes?
Yes, several railroads have asked for this functionality and FRA intends to implement it.
- If we are a small railroad and just plan to use the web portal to submit data, is it necessary for us to attend the additional symposiums?
No, not unless you are interested in providing input into the development of the web-based application. Attendance at the symposiums is completely optional.
- Many railroads are currently updating their own systems. When will they know what kind of electronic system FRA is going to use, so that railroads have time to make sure their system is compatible with FRA's new system?
All information will be shared during the symposiums and all documentation will be shared with Part 225 respondents as soon as it becomes available. More information will become available when the Notice of Proposed Rulemaking is published.
- Would Forms 78 or 150 be able to be emailed instead of a self-addressed stamped envelope?
FRA will be looking at the submission method for all forms. FRA will look at how to best have the forms submitted in a way that is not overly burdensome.
- Currently we file through e-file with the FRA contractor. I understand that we will most likely continue to file our alternative forms through e-file. Will this continue to be through the contractor or will it be a direct file to FRA?
FRA anticipates that all data will be sent directly to the FRA.
- Will there be ways to submit feedback once the portal is implemented? For example, I have noticed data entry errors and have no way to inform a federal employee.
That information will be very helpful to share with the FRA. FRA will also hold a user acceptance testing period for the new system to invite railroads to test before implementation.
You can also contact the Help Desk at RSISHelpDesk@dot.gov at any time for AIRG.
- Will future Part 225 audits be performed strictly online, or should we expect a visit from a designated FRA officer?
Part 225 audits will continue to be performed both virtually and in-person.
- Will there be a mobile version of the software?
That is something that can be considered, but the primary focus is on a web-based application accessible from a PC.
- Will there be aid for very small railroads with poor computers/poor internet access? Can you provide minimum computer/connection standards to reliably run the program?
FRA will be unable to provide aid for respondents with poor computers/poor internet access. However, FRA can provide recommended connection and computer standards for the system in our documentation.
- Will multiple people within an agency be able to log in to view what was submitted?
Yes. All verified users within an organization will be able to log-in and view their organization's submissions.
- Forms 78 and 150 are not submitted directly to FRA. They are sent to employees and/or grade crossing users, with the option to complete and submit. Right now, railroads are required to hand deliver or physically mail a self-addressed stamped envelope for them to return the form, if they choose. Emailing the form directly would be easier. In addition, they would be able to complete it on their end. Would it be possible to create a portal specifically for the employee/user to submit the completed forms?
FRA will take this under consideration.
- Will the new system be able to spot check errors, for example, incorrect numbers for latitude/longitude, injury codes, etc.?
FRA is considering using existing latitude/longitude coordinates of grade crossings as a validation. AIRG currently has validation to ensure correct data is entered. When physical copies of forms are mailed or emailed, the data is manually entered by FRA, so it is hard to catch all invalid data. All validations for the new application will be automated.
- Are we still going to receive a scanned report after an audit? Or will this change?
Changes to the audit are not anticipated at this time but are
The following ideas were posed to FRA during the Part 225 Technical Symposium Session 1. The ideas from the session have been modified for clarity.
- Some states require railroads to send monthly FRA reports to the state, in addition to the FRA. It would be helpful if the new web-based application can easily send reports to the state.
- The new web-based application should contain a drop-down menu of valid state, county and city names, as well as station names, if possible.
- Consolidate forms to reduce redundancy.
- The new web-based application documentation should contain a flow chart to help the respondent determine which form to use and if an accident/incident is reportable or accountable.
- Provide a downloadable report for records in the new web-based application.
- Provide drop-down menus for data entry in the new web-based application.
- Revise accident cause codes.
- Consider changing the Form 97 requirement of 7 days to increase the timeframe.
- Consolidate form 97 and 54 and 98 and 55a.
- No longer require all railroads to file Human Factor Forms. Only the consist should file the form.
- Create a flexible Q&A for Part 225 respondents that is updated over time as new questions are received.
- Provide a way for railroads to export their submitted data from the new web-based application for analysis.
- Provide an audit trail of data changes and make the changes accessible to the railroad(s).
- Provide an easy way for respondents to report validation or system issues.
- Make a mobile version of the new web-based application.
- Enable the new web-based application to allow multiple users at an agency to log in and manage the forms.
- For Forms 78 and 150, which are not submitted directly to FRA, develop an electronic way (1) for railroads to send the forms to the employee/highway user and (2) for the employee/highway user to submit the form. Currently, railroads are required to hand deliver or mail the forms, along with a Self-Addressed Stamped Envelope.
- Provide the ability to save a form that is a work-in-progress.
- Develop cross-form validation to identify inconsistencies and errors (e.g. if a respondent submits two Form 55a forms, an error should flag if "one" 55a form is selected while filling out the Form 55 form).
- Provide ability to suggest changes (add/edit) to lookup data (e.g. City/Town). It would be reviewed by an administrator for approval before modifying the production data.
- Automate all validations, removing any manual review and correction process.
- Add railbike to Rail Equipment Involved and/or Type of Equipment Involved fields.
- Provide pre-filled fields when starting a new form (railroad name, call letter, date).
- The validation for Visibility on Form 54 and 57 should be more flexibile, allowing for a respondent to select "Dark" after 10 PM, as it can be light in Alaska at night.
- Create a function that poses questions about the accident/incident to help the respondent determine which form(s) need to be filled out and/or submitted.
- Allow forms to pre-fill fields based on a railroad's operations. For example, a freight railroad would not be required to input "N/A" for passenger miles or passengers carried or N/A would automatically be filled in.
- Display a drop-down list of values that contain both the code and the associated text. Enable the PDF to display the text descriptions in addition to the code (Form 55a).
- Allow user to collect latitude and longitude, city, county and state from a map pinpoint.
- Ensure most current OMB dates are on the form.
- Ensure data can be exported for analysis.
- Allow users to select a pinpoint on a map for a more precise measurement of latitude and longitude.
- Provide a feature that clearly explains/defines the data entry point (e.g. you hover the mouse over a section and a text box will pop-up explaining the function).
- Enable the new web-based application to sum the employee hours in the annual Form 56, based on content in monthly Form 55s.
- Enable the web-based portal to contain a compliance aid component or wizard to determine which forms need to be filled out.
- Provide railroads with the ability to have multiple user types with different roles for their agency. For example, allow a primary reporting officer with read/write access to designate secondary reporting officers that may only have read access.
- Provide railroads with the ability to designate a third-party company to report on their behalf.
- Determine why types of of data analysis are performed and what tools are needed in order to perform or enable that analysis within the web-based portal.
- Provide functionality for holding companies to be able to manage multiple railroads with one set of login credentials.