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Kevin Russell is an electrical engineer and licensed professional engineer with two decades of experience in the amusement industry, including five years at Arrow, and ten years at Paramount Parks. He no longer works directly for the ride industry.
I read with interest Kathy’s editorial about the CPSC amendment. I am not a proponent of the CPSC, as I feel they are the wrong tool for the job. I think there has been much written on that subject and I won’t add to that here. However, I have been involved with various state and local authorities over the years, between my years on the manufacturers' side and, later, on the park side. While there are some very good state ride programs, I haven’t encountered any that hit on all cylinders. For example:
- Many state inspection programs look to the manufacturer as the ultimate authority. The state either feels it does not have the expertise to question the manufacturer, or does not want to take the liability. Jurisdictions that I know of that do not treat the manufacturer as the ultimate authority include California, Michigan, Clark County (Nevada) and New Jersey. Ohio is particularly careful about avoiding liability since the prosecution of two of their inspectors.
- Many states are not staying current with the ASTM standards. Last time I talked to inspectors from North Carolina and California, their states had not adopted F2291, despite that standard being at least 3 years old. California is not enforcing the current version of any of the ASTM standards, as their law was written based on the version of the standards in force at the time the law was written.
- Only a few of the states are active in the ASTM organization. New Jersey is extremely active, as is Clark County, Nevada. A handful of other state and local authorities are involved. In 5 years, I never saw a rep from Florida, Texas or California. They may have been there, but they must have hid in the corner.
- Some states are requiring changes, even if the manufacturer opposes them, while other states will not accept a change that is not approved by the original manufacturer. I believe that is a classic definition of a “catch-22”.
I could go on and on, but I think it is more productive to talk about what a good program should be:
- A good program should be actively involved in the Amusement Standards organization ASTM. Not only is this an opportunity to influence the standards, this is an opportunity to communicate with the engineers, manufacturers and end users. Dialogue in this environment can increase the inspectors' understanding of the industry.
- A good program should have an active training program for its inspectors, whether it is NAARSO, or some other program. Rides are constantly becoming more complicated, and require a breadth of knowledge. Unless the inspector is only exposed to one class of rides (portables for instance) they need more than just on-the-job training.
- A good program should also look at rides holistically. You can’t just look at the ride; you need to look at operator and maintenance training, record keeping, fencing, egress, sight lines, etc.
- A good program should have a “first article” review when a new type of ride appears. This review should include looking at all of the assumptions that the manufacturer put into the design, and verifying that adequate care went into the design. If the authority doesn’t have the capabilities to do this type of review, an approved third party could do it.
- A good program should do at least one annual inspection and at least one surprise inspection each year. The surprise inspection should include observation of operation, and a check on operations and maintenance training. On traveling rides, these levels should be stepped up. I don’t have an opinion on what that level should be, but I am sure a reasonable level can be established.
- A good program should have plans in place for an incident investigation. There should be staff trained in various failure analyses, or third parties pre-arranged that are qualified in areas such as fatigue analysis, controls, hydraulics, etc.
- A good program should have a process in place to deal with ride modifications performed by someone other than the manufacturer. Some manufacturers no longer exist. But no licensed professional engineer is going to take responsibility for the entire ride just because they engineered a replacement for an obsolete part. Some kind of reasonable standard needs to be established for this. Also, there have been occasions where existing manufacturers have refused to come back to work on older rides, because it adds to their liability with very little economic benefit. Again, some reasonable mechanism has to exist to deal with this situation. It doesn’t make sense to let liability concerns limit our ability to improve the safety of a ride.
- A good program can use third party inspectors, but there must be a system to make sure there are no conflicts of interest, and that the third party inspectors are performing their duties as representatives of the state or local authority.
- A good program should have a method of identifying a ride, even when it changes hands. There should also be access to manufacturers' bulletins and a mechanism to track the bulletin and the ride.
I am sure that if I kept working at it, I could come up with additional planks. Maybe I can convince Kathy to open a page up for the “model inspection program”, and I can take suggestions from Saferparks readers to incorporate into the page. In any case, while I know of programs that meet each of these criteria, I don’t know of any program that meets all of them. If the industry truly wants to avoid any kind of federal intervention, then perhaps we need to fill in the holes in some of the state and local programs.
Saferparks' Response:
Ask and ye shall receive. I've added a new blog feature entitled "Building Better Ride Safety Regs" to be moderated by Kevin. He'll keep a working redline of a model inspection program, developed through collaborative discussion and debate. All serious input is welcome.
Kevin and I agree on most of his points. State and local programs do need attention, and most of the issues he raises must be dealt with locally. I'm curious, though, to see how his state/local program will deal with ever-sticky issues of interstate ride tracking and cases where a manufacturer opposes safety improvements deemed necessary by public safety officials..
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Kevin Russell worked for ride manufacturer, Arrow, developing control systems for rides such as Steel Phantom at Kennywood, Viper at Magic Mountain, and Drachen Fire at Busch Williamsburg. He spent ten years at Paramount Parks (now owned by Cedar Fair) as corporate controls engineer, working on projects such as Son of Beast and the Borg relocation, and upgrading the company's standards for ride systems. An active member of the ASTM F-24 industry standards committee, he worked on the controls section of F2291 and served as the first chairman of the F24:80 subcommittee for world harmonization. He left Paramount in 2007.
