Following the third anniversary of the catastrophic derailment that leveled East Palestine, Ohio, the Association of American Railroads (AAR) published a page outlining “freight rail safety actions” taken since the incident. At first glance, it reads like a comprehensive reform agenda.
But rail safety is not judged by bullet points. It is judged by outcomes, transparency, and enforceability.
Here is what readers should keep in mind:
- “Historic Low Rates” Do Not Equal Fewer Incidents
AAR emphasizes that accident rates per million train miles are near their lowest recorded levels.
Rates matter. But so do total incidents.
The Federal Railroad Administration (FRA) provides public datasets showing both accident rates and total derailments, injuries, and hazardous materials releases. Reviewing only rates without examining raw totals can obscure the real-world frequency of serious events.
If the denominator changes, the rate changes. Communities experience actual derailments and releases, not normalized statistics.
- The 170°F Threshold Claim Is More Complex Than It Appears
AAR highlights lowering the hot bearing detector threshold from 200°F to 170°F.
The underlying rule language is more nuanced. AAR’s Field Manual of Interchange Rules, Rule 36, historically referenced:
- 200°F measured directly on a bearing cup with a handheld device, and
- 170°F above ambient temperature for wayside detector criteria, along with additional confirmation requirements.
Source: AAR Field Manual of Interchange Rules, Rule 36 (Roller Bearings), entered into the NTSB docket
Why this matters: the public framing suggests a simple, dramatic tightening. In reality, bearing detection effectiveness also depends on detector spacing, response procedures, and interpretation of alerts.
The National Transportation Safety Board (NTSB) found that detector performance, spacing, and operating procedures were key factors in the East Palestine derailment.
Source: NTSB Board Meeting Summary, East Palestine, Ohio
Adjusting a threshold number is not the same as resolving systemic detection and response issues.
- Announced Actions Are Not the Same as Demonstrated Results
AAR’s page lists revised standards, updated practices, and new initiatives.
What it does not provide is evidence that these changes have measurably reduced high-consequence derailments or hazardous material releases.
The NTSB emphasized that further evaluation and research are needed to determine whether certain industry changes will materially improve safety outcomes.
Source: NTSB Board Meeting Summary, East Palestine, Ohio
Communities deserve data showing results, not simply descriptions of activity.
- Real-Time Train Consist Information Did Not Arise Voluntarily
AAR highlights improved real-time train consist information for first responders.
The NTSB identified delays in transmitting accurate consist information as a safety issue in East Palestine.
Source: NTSB Investigation Report, East Palestine, Ohio
Further, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a Notice of Enforcement Discretion related to real-time train consist information implementation, reflecting regulatory pressure and compliance challenges.
Source: PHMSA Notice of Enforcement Discretion
Presenting these developments solely as proactive industry leadership omits the investigative findings and regulatory oversight that prompted them.
- Voluntary Industry Standards Are Not Federal Regulations
Many changes cited involve AAR interchange rules and internal standards.
Voluntary standards can play a role in safety. However, they are not equivalent to federally enforceable regulations subject to inspection, auditing, public reporting, and penalties for noncompliance.
This distinction is critical, particularly as policy debates continue over inspection frequency, reporting transparency, and oversight requirements.
Without enforceable rules and transparent data, the public must rely on industry assurances.
The Bottom Line
AAR’s page is incomplete.
- It emphasizes rates over raw totals.
- It highlights actions without proving outcomes.
- It simplifies complex technical changes.
- It presents voluntary standards alongside regulatory reforms without clearly distinguishing between them.
After a disaster like East Palestine, the standard should not be messaging. It should be measurable safety improvement, transparent reporting, and independent oversight.
Reading the headline is not enough. Communities must read between the lines.
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