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Making cab video compliant

For cab image recording systems

Inward and outward facing cameras in transit cabs are no longer optional, and neither is protecting what they record. This page sets out the requirement, what a compliant protected video memory actually has to do, and how a crash hardened memory module fits an existing image recording system.

CHM86 marketing sheet

CHM86 marketing sheet

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CHM26 brochure

CHM26 brochure

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CHM8X brochure

CHM8X brochure

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Where the requirement comes from

The FAST Act directed the Secretary of Transportation to require inward and outward facing image recording devices on passenger trains, and FRA implemented that in a final rule published in October 2023, amending 49 CFR Parts 217, 218, 229 and 299. The fleet deadline is 12 October 2027: by that date every lead locomotive in commuter and intercity passenger service must carry a compliant image recording system, and any system installed since 12 October 2024 has had to comply already. On the transit side, FTA Safety Bulletin 20-2 and APTA RT-OP-RP-024-19 apply the same thinking to rail transit operating compartments, both tracing back to NTSB recommendation R-17-13. In Canada the equivalent requirement is already in force: the Locomotive Voice and Video Recorder Regulations, SOR/2020-178, have applied since September 2022.

  • 229.136(a)(1) — passenger railroads must install a cab-mounted image recording system in every lead cab used in commuter or intercity passenger service.
  • 229.136(a)(4) — the image recording system must record at least the most recent 12 hours of operation. This is where the 12-hour figure comes from, and it is a requirement rather than a recommendation.
  • 229.136(a)(5) — those recordings must be held on a memory module meeting the certified crashworthy ERMM requirements of Appendix D, or on an alternative remote storage system approved by FRA as giving at least equivalent protection.
    Appendix D to Part 229 — for certification purposes an image or audio recording device memory module is itself considered an ERMM. Same crush, fire, immersion and shock criteria.
  • 229.136(e)(2) — at each annual test the operator must take sample downloads from the image recording system's crashworthy memory module to confirm correct operation.
  • Canada, SOR/2020-178 — the Locomotive Voice and Video Recorder Regulations require 48 hours of voice and video data on at least one crash-protected memory module meeting IEEE Std 1482.1-2013, with older data permanently erased. Voice recording is mandatory, the minimum inward frame rate is 15 fps against 5 fps under the FRA rule, and the regulations cover freight as well as passenger operations. In force since September 2022.
  • APTA RT-OP-RP-024-19 — minimum requirements for selection, installation, operation, maintenance and data management in transit operating compartments, with 48 hours of retention.

What a compliant protected video memory has to do

Surviving the crash is one requirement out of six. A module that survives but drops frames, fills up, corrupts the open file on power loss, or cannot prove it is healthy has not done the job. These are the properties to write into a specification, independent of supplier.

Receive

A communications interface that can absorb every camera channel in the cab at once — Ethernet, or serial capable of 30 MB/s and above — with the installation kept to as few cables as possible.

Sustain

Sustained continuous write, indefinitely — in the order of 10 MB/s and above for a multi-camera cab. The CHM86 is validated at 11 MB/s, about 90 Mbit/s. The recording never stops, for the service life of the vehicle.

Sequence

Overwrite-only file management, driven by the recording application: files are deleted only to make room for new recording, and strictly oldest first. The module does not silently discard data on its own, and it permits no other deletion pattern.

Hold

Power-loss integrity, so that an interruption still leaves a readable file. Loss of vehicle power is exactly the condition an accident produces.

Scale

Capacity measured in days of continuous recording rather than hours. The floor is 12 hours under the FRA rule, 48 hours under APTA RT-OP-RP-024-19 in the United States, and 48 hours under the Canadian regulation — and operators regularly specify more.

Report

Storage health, wear and power-on hours available on demand through APIs callable over the network connection, together with subsystem self-tests, which is what makes the annual §229.136(e)(2) check straightforward without pulling the unit.

What this does to the storage design

Constraint

Why it changes

Capacity

Two cameras at typical surveillance bitrates generate roughly 3.4 GB per hour. Retention requirements are measured in days.

Sustained write rate

Video is a continuous 24/7 write load. The memory has to absorb aggregate camera bandwidth without dropping segments.

Endurance

Continuous rolling recording rewrites the storage repeatedly for the service life of the vehicle. Endurance has to be designed for, not assumed.

Power interruption

The file open at the moment of the event is the file that matters. Energy storage on board the unit closes it cleanly.

Thermal margin under fire

Heat sensitivity rises with capacity, so the fire test has to be passed at the largest capacity offered.

Terms used in the rule

  • ERMM — crashworthy event recorder memory module.
  • Image recording system — the cameras and the components that convert images into data stored on a memory module.
  • Certified DOT Crashworthy — the marking a manufacturer applies to certify against Appendix D.
  • Fire and crash protected memory — the plain-language name for the same device: storage that survives the fire and the impact that destroy the recorder around it.

Endurance and reliability: the two numbers to ask for

Continuous video is the hardest duty a storage device can be given. A module recording several cameras around the clock rewrites its entire capacity every few days, for the service life of the vehicle, and it does so at temperature, inside a sealed enclosure that cannot be cooled by a fan. Two figures describe whether it will last, and they measure different things.

Nominal TBW — how much writing the memory can take

Terabytes written is the endurance rating of the flash itself: the total volume that can be written before the memory is considered worn out. It is the figure that matters for rolling video, because a rolling recorder never stops writing. Divide the nominal TBW by the volume written per day and the answer is the expected service life. Two cameras writing about 3.4 GB an hour amount to roughly 30 TB a year, so a fifteen-year installation on that duty needs an endurance rating of several hundred terabytes — and proportionally more as cameras and bitrates rise. Ask any supplier for the number, and ask which capacity it applies to — ratings vary by orders of magnitude.

MTBF — how reliable the electronics are

Mean time between failures describes the unit as a whole rather than the memory, and it is a calculated figure, so the calculation method matters. The CHM86 is rated at 500,000 hours to SN 29500, a recognised standard for electronic reliability prediction.

Why a specification should ask for both

MTBF tells you how often the unit fails. TBW tells you when the memory reaches the end of its designed life even though nothing has failed. A specification that asks only for MTBF can be satisfied by a module that wears out after three years of continuous video.

All CHM Modules are Manufactured in the USA - FTA Buy America compliant

How it fits an image recording system

The CHM86 and CHM26 present themselves to the recorder as network storage over Ethernet, using SMB or NFS. The image recording system keeps its own cameras, encoder settings and management software; only the storage target changes.

One thing the recording application must do

Protected memory does not manage retention on the operator’s behalf. The recording application monitors free space and deletes the oldest files first, at a rate at least matching the write rate, so that space is always available for the next segment. It is a small addition to the recorder’s storage handler, it is specified in the installation handbook, and it is the one integration detail worth confirming before a retrofit is quoted.


Frequently asked

See the CHM86