The Safety Appliance Act (SAA)
The Railroad Safety Appliance Act (“SSA”) was passed by Congress on March 2, 1893 in response to the large number of injuries and deaths attributed an unregulated railroad industry. Prior to the enactment of the SSA, most rail cars were not equipped with mechanisms to make them safe and many of the practices and procedures used by train service employees were unsafe. The initial Safety Appliance Act required the use of power brakes on all trains engaged in interstate commerce. It also required that all railcars be equipped with automatic couplers, draw bars and handholds. In 1903, Congress passed the second Safety Appliance Act that extended the requirements of the first Act beyond railcars to any equipment engaged in interstate commerce. The third passage of the Act occurred in 1910 requiring that all vehicles be equipped with hand brakes, sill steps, and where appropriate, running boards, ladders and roof handholds. The third enactment also required that the Interstate Commerce Commission (ICC) designate the number, dimensions, locations, and manner of application of the various safety appliances identified in the Act. The Act can be found here.
Like the Locomotive Inspection Act (see here) the SAA places an absolute duty on a railroad to comply with safety standards set-forth in the Act. Under the SSA, it is unlawful for a railroad to operate a railcar on its rail lines unless it complies with the requirements of the Act. A railroad’s violation of the Act results in strict liability. What that means is that there is no consideration regarding whether the Railroad was negligent with respect to whether it caused a Railroader’s injuries. Negligence was recently discussed in this blog here. The issue of negligence is not relevant to the claim that the Railroad violated the SAA, since the SAA imposes an absolute duty on the Railroad for injuries cause in whole or part by violations of the Act. In addition to the absolute duty placed on the Railroad, there is no consideration whether the injured Railroader was negligent or whether his or her negligence played any part in causing his or her injuries. In other words, if a jury determines the Railroad violated the LIA, it cannot consider whether the injured Railroader was contributorily negligent. (See here.)
By Matt Darby