Railway consultation: Feedback summary

Canadian Rail Operating Rules, Track Safety Rules, Safety Management System Regulations

From October 9 to November 23, 2018, Technical Safety BC consulted with the railway industry on various aspects of the Canadian Rail Operating Rules, Track Safety Rules, and Safety Management Systems. In total, seven railway clients and stakeholders responded to the consultation through the online feedback form.

The respondents represented:

Feedback on the Canadian Rail Operating Rules

*4 respondent said this question was not applicable
**1 respondent said this question was not applicable

Securing unattended equipment

• Should be a primary safety concern
• Rule is now clearer and easy to follow
• Confirmed compliance
• Engine does not have handbrakes

Locking unattended engines

• Confirmed compliance (3)
• Good safety practice

General feedback on the CROR

• Following the rules will improve safety

Feedback on the Track Safety Rules

Remedial action requirements for rail defects

• Confirmed compliance
• Repairs affecting safe train movement must be done

Certification and training of track supervisors and track inspectors

• Confirmed compliance (2)
• Minimum one year experience in track inspection is difficult to comply for industrial railways

Feedback on the Safety Management System Regulations

New requirements (naming an accountable executive, reporting safety hazards, applying fatigue management principles)

• Requirements already exist in SMS or operations (2)
• Consider only applying certain components to various types or sizes of railways operations
• SMS program leads to safe operations

Requiring a GOI in list of instruments to follow

• GOI adds unnecessary bureaucracy and does not add value
• Industrial railways typically maintain operations training manuals. Some do not perform operations that fall within the definition of rail operating instructions.
• Many railways should have a GOI, depending on size and complexity of rail operations
• All railways should have a GOI

Following Technical Safety BC’s railway occurrence reporting guidelines

• Confirmed compliance / Already or will comply with occurrence reporting guidelines (2)
• This would cause duplication of work as many operations have existing investigation protocols
• Provide all operations with updated and consistent reporting forms

Frequency of conducting safety concern analyses

• Can be part of annual SMS audit
• Be more definitive about specific times
• More proactive approach: Define circumstances where when analysis is required
• Need to ensure that all operations have consistent procedures for conducting safety analyses

Annual proficiency testing (job observation)

• Confirmed compliance (3)
• Unsure where proposed amendment is
• Important that proficiency testing be done well to improve safety culture in organization
• Need to provide consistent basic format for proficiency reviews

Annual audits

• Confirmed compliance (2)
• Uncertain whether audit means reviewing the SMS document or an audit of whether the operation complies to the processes in SMS
• Was not aware of requirement to audit every three years
• Size of the operation and number of incidents should dictate frequency
• Suggestion: Review how SMS is actually functioning at a particular location
• Depends on traffic volumes

Specific components

General feedback on SMS Regulations

• Make requirements simpler to follow
• Frequency of audits and what the audits contain is confusing
• Confirmed compliance