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Railway Mail Service under date of February 2, 1920, and that changes be accomplished on or before June 30, 1923. The order, however, did not include new cars built (or rebuilt) upon the plans and specifications of 1912-1914, so long as such cars filled the requirements of the service.

On September 20, 1922, you were advised that for certain reasons it had been determined to postpone the enforcement of the above-mentioned order for a reasonable time, dependent primarily upon the physical condition of the cars and the specific requirements of the service. However, certain requirements were insisted upon and you were urged to carry out other suggestions for the betterment of the service.

In view of the fact that it has been nearly six years since the issuance of circular letter R. A. 503 and four and a half years since the enforcement of said circular was postponed for a reasonable time, it is thought ample time has now been allowed; therefore, it has been decided that railroad companies should standardize, if deemed advisable and necessary by the Railway Mail Service, all nonstandard cars as they pass through the shops.

All full R. P. O. and mail apartment cars constructed hereafter shall be equipped with electric fans, as provided for in section 2, page 15, of the specifications for the construction of steel full and apartment railway post office cars, revised to December 24, 1925.

Full R. P. O. and mail apartment cars now in service or under construction shall be equipped with electric fans where deemed essential by the Railway Mail Service.

Wooden mail apartment cars to be operated as trailers to self-propelled cars must at least be Plan No. 1 and standard in interior arrangement, equipped with electric lights and heated by hot-water system.

In self-propelled cars the partition between engine room and mail apartment must be insulated with a sound-deadening material; the doors in this partition to be so insulated and made to fit tightly when closed.

W. IRVING. GLOVER, Second Assistant Postmaster General.

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Subject: Mail cars-Construction and operation.
All railroad companies:

Circular letter of May 23, 1927, has been modified in part as follows: The Postmaster General has agreed to give the railroad companies not more than two and a half years from September 1, 1927, to comply with the Postmaster General's Order No. 5438 of May 13, 1927, provided that each railroad company affected advise me in writing of their willingness to comply with same, and show their good faith by immediately arranging to take care of the situation within the two and one-half year period; that is, at least provide a proportionate number of cars each year that is necessary to meet the conditions set forth.

In order for railroad companies to take advantage of the two and one-half-year extension of time as specified in the above paragraph, it will be necessary for each railroad company to advise me in writing prior to January 1, 1928, just what arrangements have been made to meet the situation and how many mail apartment cars have been purchased or contracted for since August 15, 1927.

Regarding the standardization of old equipment, the first paragraph on page 3 of my circular letter of May 23, 1927, is modified to read as follows:

"In view of the fact that it has been nearly six years since the issuance of circular letter R. A. 503 and four and a half years since the enforcement of said circular was postponed for a reasonable time, it is thought ample time has now been allowed; accordingly it has been decided that railroad companies should standardize railway post-office cars as and when deemed advisable and necessary by the Railway Mail Service in order to supply adequate distributing and storage facilities in such cars for the particular trains in which they are operated or to provide cars of similar type for certain trains."

The two and one-half year extension of time does not apply to the above paragraph.

It should be further understood that wooden mail apartment cars to be operated as trailers to self-propelled cars are to comply with circular letter of May 23, 1927, except that the interior arrangement may not need to be changed if the

present arrangement and type of fixtures meet the needs of the service. However, mail apartment cars with side letter case, paper boxes on partition and old circular racks are not satisfactory and should be remodeled and equipped with modern fixtures.

The second and third paragraphs on page 3 of circular letter of May 23, 1927, relative to electric fans have not been modified; therefore, all new full R. P. O. and mail apartment cars shall be equipped with fans before they are placed in mail service.

All electric lighted full R. P. O. and mail apartment cars now in service shall be equipped with electric fans by May 1, 1928, and cars not equipped with electricity by May 1, 1929, where deemed essential by the Railway Mail Service. The safety ceiling fan has been in service in some mail cars for about a year, and reports from clerks performing service in these cars state that they are satisfactory and give much needed relief during the hot weather. Therefore, it will be satisfactory to install this type of fan in any car. As other types of fan are approved, railroad companies will be advised.

W. IRVING GLOVER,

Second Assistant Postmaster General.

STEEL-UNDERFRAME CARS

The present law permits the use of what is known as steel-underframe cars and many hold that such cars are of equal strength to the steel car, but such contentions are not proven by experience. These cars are of the same approximate strength as the steel car as far as the underframe is concerned, but the danger in those cars lies above the floor. In case of wrecks the superstructure of these cars is crushed or sheared off by the over-riding floors of adjoining cars. These cars were built in the early steel car period, and are not comparable with the steel equipment now in use. They will not withstand the shock of the heavy steel train.

The steel underframe car built in accordance with present specifications is a better car and it will be contended by some that they are as good as the allsteel car. That is doubtful in the case of a wreck and then, when new cars are built now they are built of all-steel, so the present specifications do not eliminate those cars built years ago. They are a menace to the lives of railway postal clerks. Only within the past few months we have an illustration of what happens in those steel-underframe cars. A clerk was killed in the State of Minnesota last November while on duty in a steel-underframe car. This was a head-end collision between a heavy transcontinental passenger train and a double-headed freight. Result, mail car demolished, one clerk killed, one injured, passengers safe. (Photo of wreck shown committee.)

Some railroad companies refuse to withdraw unsafe equipment because it is held that steel-underframe cars comply with the law. A recent wreck on the Frisco Railway between Memphis and Birmingham resulted in three clerks being disabled for life, yet this company refuses to withdraw a similar car from service on that line because it is rated as a steel-underframe car. The Post Office Department seems to be powerless and only requests that it be done. The railroad declines to do it. Clerks continue to run in death traps. There is never a wreck in which steel-underframe cars are involved which does not disprove the contentions that they are as good as steel cars.

It should not be necessary to call attention to the fact that wooden mail cars are still in use. The cars that are admitted to be all wood have been relegated to side lines, it is true, but we have that alleged "reinforced wooden car" even on main lines. Railroad companies even go to the extreme of camouflaging the car by riveting to the outside of the car steel sheathing, giving it the appearance of a steel car. By placing some steel in the floor and bolting steel plates to the end posts of the car we have a "reinforced wooden car," which is used in heavy trains. The department laid down such specifications in 1912 or 1913, and permitted those old wooden cars to be rebuilt even though the law called for replacement with all-steel equipment. What happens in case of a wreck is shown in photos of wrecks in which wooden cars are involved. By wooden cars I mean those cars which are primarily of wooden construction, even though reinforced with steel.

There is another condition arising by the use of wooden cars in which the Government is financially interested. The protection of the mails as well as

the lives of the clerks is important.

Large amounts of money are being transported daily in these mail cars. The Federal reserve banks ship large amounts, and while we can not state positively just what these amounts are, there is no doubt that shipments running into the millions of dollars are carried in some of these mail cars. In the case of a wreck with a fire following losses occur. Then, again, these cars are not equipped for the protection of the mails in case of robbery. Just a year or so ago a mail train was held up in northern Illinois on the trunk line between Chicago and St. Paul. The registered mail on that trip carried between two and three million dollars. Even although a few of the clerks are armed, such does not protect the mails, for in such cases a gas bomb is hurled through the car window with the results that the clerks can give no further protection to this valuable mail. The windows of these mail cars are only protected by ordinary glass, while it should be of the strongest reinforced glass possible, so as to protect the mails against such action in case of attempted robbery.

When the present steel car laws were passed the railroads only received car rental for those mail cars of 40 or more feet in length, and the law was so worded as to include only those cars for which the railroads received rental in addition to the transportation charges based upon the tonnage of the mail. Mail apartments of less than 40 feet in length were furnished by the railroads without receiving any car rental for the use of the mail apartment. This was presumably for the reason that the railroad used part of the car for railroad business. Under the law apartment cars, unless used in conjunction with steel equipment, did not need to be of steel construction.

After the change in basis of compensating railroads for the transportation of the mails, which occurred in 1916, all mail cars were put upon a rental basis with payment for each mile the car was hauled while in service. Without any change in the law as to the construction of the car the department very properly assumed that as all mail cars were upon a rental basis that the same regulations should apply to all. This was an improvement, and many of the worst cars were retired from the heavy trains, but unless the railroad company was willing to withdraw the old steel-underframe car such could not be forced, and it continued to be used with the heavy steel equipment. The law permits and some railroads take advantage of that provision of law, well knowing what happens to the steel-underframe car in case of a wreck.

For the operation of these mail cars the railroads receive an aggregate annual income from the Government of more than $50,000,000. Payment is made upon a mileage basis at the following rates per mile for each mile the mail car is hauled.

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In addition to above income must be added the payment for storage mails carried in baggage cars which amounts, at present, to another $50,000,000 annually.

The usual plea of the railroads, in the past, has been inability to finance the construction of new steel railway post office cars but that alibi now would not be substantiated by reports as to the ability of railroads to finance the purchase of equipment, for the orders for new equipment are very heavy at present. Recent announcements have been made that the Southern Railway has just contracted for $12,000,000 worth of rolling stock. This railroad has been about the most negligent in the matter of postal car equipment, yet in this contract of $12,000,000 of equipment the postal equipment to be purchased is less than 2 per cent of the contract. With the postal equipment much below standard on this system it is evident that proper consideration is not being given to the Government business handled by this railroad. Some other roads are in the same category. The photographs of actual wrecks submitted to your committee, visualize what actually occurs in case of a wreck involving all of the different types of cars.

Note the condition of the cars and how well the all-steel car withstands the shock. Then note the steel underframe car, alleged to be as strong as the allsteel car. The actual event clearly disproves the allegation that the steel underframe car is equal to the steel car. Of course, no contention will be made that the wooden car or wooden reinforced car is safe though it has been contended that it is proper to operate same in certain kinds of trains. An examination of the photo of wrecks in which wooden cars have been involved is a convincing answer to any such contentions. No human being should be permitted to ride or work

in such type of cars.

It might be said that the employees could appeal to the safety division of the Interstate Commerce Commission and request an investigation as to the safety of any particular mail car. Such has been done but the investigation denied as evidenced by the following correspondence:

INTERSTATE COMMERCE COMMISSION,

RAILWAY MAIL ASSOCIATION,
Washington, September 18, 1920.

Washington, D. C.

GENTLEMEN: I am inclosing statement with reference to the condition of railway post office cars operated by the Southern Railway Co. This statement is presented in behalf of railway postal clerks who are required to work in such cars and it is contended by them that these cars do not comply with existing provisions of law governing the construction and operation of railway post office cars. These cars are not of steel construction and are being operated in trains of practically all steel equipment.

This matter has been presented to the proper officials of the Post Office Department and up to the present time no action has been taken to retire these cars from service. If railroad companies are permitted to operate cars of such construction then the so-called "steel car law" is of little effect. The employees who are required to perform service in these cars request that a rigid inspection be made of same, and a decision given by the Interstate Commerce Commission as to whether or not these cars comply with the provisions of the law. Respectfully,

W. M. COLLINS, Railway Mail Association.

POST OFFICE DEPARTMENT,

SECOND ASSISTANT POSTMASTER GENERAL,
Washington, September 25, 1920.

The INTERSTATE COMMERCE COMMISSION,

Bureau of Safety, Washington, D. C.

GENTLEMEN: Reference is made to your letter of the 23d instant (your file 105162) in which it is stated that your commission has been requested to make an inspection of Southern Railway postal cars Nos. 1 to 26 operated over various lines of that system, with respect to their safety and in which you ask the wishes of this office with regard to compliance with this request.

The cars mentioned are substantial steel underframe full R. P. O. cars built before the standard specifications of 1912 covering the construction of steel postal cars were issued, which specifications are applicable to the building of steel underframe cars so far as the underframe proper and the end construction are concerned. The end construction of these steel underframe cars, however, is not so strong as the end construction called for in the standard specifications, and this matter is now one of correspondence between the company and this office, the company having been advised that if these cars are continued in heavy assignments they must be strengthened. The company has stated recently that it is working out a program for the building of new steel postal car equipment, which will supplant these steel underframe cars operated in heavy assignments. With this statement of facts, it does not seem necessary at this time to do anything more than to see that the company takes proper action looking to a betterment of conditions as soon as practicable.

E. R. WHITE, Acting Second Assistant Postmaster.

Mr. W. M. COLLINS,

INTERSTATE COMMERCE COMMISSION,

BUREAU OF SAFETY, Washington, October 4, 1920.

Railway Mail Association, Washington, D. C. DEAR SIR: This will acknowledge receipt of your favor of the 18th instant, with inclosure of statement with reference to the condition of post-office cars operated by the Southern Railway, and requesting that inspection be made of the cars referred to in your communication.

Under date of September 23d, I took this matter up with the Post Office Department, and under date of the 25th ultimo, I received a reply from the department, a copy of which is inclosed.

Inasmuch as it is admitted that the cars in question do not meet in the service in which they are employed, and that the cars are to be supplanted as rapidly as new steel cars can be furnished for that purpose, an inspection by this commission as requested in your letter does not seem to be necessary.

Respectfully,

W. P. BORLAND,
Chief, Bureau of Safety.

Every reasonable effort has been made, on the part of the employees, to protect their lives. The railroads oppose any adjustment that requires expenditure for proper equipment until they are forced to do so. The present law does not force them beyond a certain point and that is as far as they will go. To secure proper protection for the lives of the clerks and for the safety of the mails, will require a specific act of Congress requiring that after a certain date no mail car, not of all steel construction, can be operated in any train. The railroads have now had 15 years, since the enactment of the first steel R. P. O. car law, to adjust their equipment in accordance with present-day standards. The time has now arrived when those railroads that have not recognized the fairness with which they have been accorded, be made to secure such equipment by an act of Congress so specific that no one may be in any doubt as to the letter of the law or the intent of Congress. We therefore appeal to your committee for prompt action on the pending bill in the name of humanity and justice to those who daily endanger their lives while in the performance of their duties as Government employees.

I ask permission to put into the record data covering railway post-office cars of each size and type of construction, a list of mail apartment cars, and the number of railway postal clerks killed and injured while on duty each year since 1905 and type of car in which such fatalities and injuries occurred, which figures have been furnished by the department as of 1926. (The data referred to is as follows:)

Railway post-office cars of each size and type of construction

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