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The ICG did not comply with Illinois Commerce Commission Order No. 196, since no operating rule or bulletin order was in force requiring implementation. Compliance with the intent of the order might have prevented this accident, although the order, as written, contains some of the same weaknesses as the ICG operating rules. For instance, it is questionable whether the station overrun at 27th Street would have been interpreted as an "unscheduled stop” or an "unusual slowdown." However, immediate radio communication between the two trains would have been an effective accident deterrent.
Systems Failure
In order for this accident to have occurred, a number of things, involving crewmembers, management, operating rules, train equipment, and environmental factors, had to go wrong. Since these factors are interrelated, the accident indicates a system breakdown.
For example, as train 416 was backing toward the station platform, the conductor had to stand in the center vestibule of the rear car in order to operate the intercom. Although Rule 915 does not state where on the rear car a trainman should be located during a back-up movement, it seems obvious that he should have a view to the rear.
Even if the conductor could have seen to the rear of the train from the center vestibule, the location of the various Controls would have interfered to some degree with his carrying out his function. The conductor door control and intercom were located across the vestibule from the emergency brake valve. If people were standing in the aisle, the conductor would have some difficulty in stopping the train.
Because the ends of the Highliner cars were painted black, they were difficult to distinguish from the station platform and other appurtenances at 27th Street under the overcast sky on the morning of the accident. The end marker lights on train 416 were very small. If train safety depends on the ability of an engineer or conductor to "stop short of train," then the markings of the car ends were incompatible with safety.
Although there is no prescribed sight distance for a train approaching a signal, the visibility of Signal 5-3.10 was a factor in this accident. Because the authority conveyed by a signal is not applicable until the signal is passed, the signal theoretically does not need to be visible until a train is directly upon it. However, since a signal is supposed to convey information to employees operating trains, a man-made obstruction such as the walkway at 27th Street is inconsistent with the purpose of the signal.
