Safety management system regulations

The Railway Safety Management System Regulations (SMS) are designed to ensure railway companies take responsibility for managing the safety of their operations. A new SMS Regulations was introduced by the federal government in 2015. Before applying the new SMS Regulations across the province, Technical Safety BC is developing amendments. To ensure the highest level of safety in BC, we are proposing that provincial railways incorporate all 12 SMS components within their safety management system. 


Accountable executive

1. Accountable Executive *new*

Every railway company must designate one person as accountable executive who has overall responsibility for the safety management system. The accountable executive may designate other employees who are in a management position as managers to implement certain SMS components. The managers must report to the accountable executive annually with regards to their SMS component. 

2. Safety Policy

Every railway company must have a written safety policy that is signed by the accountable executive. The safety policy must be communicated to the employees and reviewed annually.

General operating instructions

3. Ensuring compliance with regulations, rules and other instruments

Every railway company must have a list of instruments (regulations, rules, engineering standards, any exemptions, any notices of order) that are applicable to the railway’s operations. The railway company must update the list and verify compliance with the instruments. 

  • Proposed change
    Technical Safety BC proposes adding to that list that all railways are required to create and maintain a General Operating Instruction (GOI). 

4. Managing railway occurrences

Railway occurrences reporting guidelines

Railway occurrences must be reported to the company’s management, and the procedure for reporting must be communicated to the employees. Railway companies are required to review any occurrence.

  • Proposed change
    Technical Safety BC proposes adding that railways when reviewing any railway occurrence must comply with Technical Safety BC’s Railway Occurrence Reporting Guidelines. This amendment is for clarity purposes as it is already mandated that the guidelines should be in certified railway safety management systems under Technical Safety BC’s protocol agreement with the Ministry of Transportation and Infrastructure. 

5. Identifying safety concerns

Frequency of conducting safety analyses

Every railway company must, on a continual basis, conduct analyses of its operations to identify safety concerns. The analyses must be based on data such as occurrence and injury reports, inspection results, SMS monitoring and audit report.

  • Proposed change
    Technical Safety BC proposes adding a provision that requires each railway company to specify in their SMS the frequency of conducting these analyses.

6. Risk Assessment

Every railway company must conduct a risk assessment following the identification of a safety concern. Risk assessments are also required for any changes to the transportation of dangerous goods and for any proposed changes to railway operations that may affect public/personnel safety or property, or the environment. This includes a technology change, a change in railway work, a change in the number of employees or in their responsibilities or duties. A risk assessment must entail the level, likelihood and impact of the risk and, if necessary, the remedial action required. 

Annual proficiency testing

7. Implementation and evaluation of remedial actions 

Following the risk assessment, necessary remedial actions must be implemented and evaluated for their effectiveness in reducing or eliminating the risks. For risks that require remedial action, the railway company must consult with the employees or their representative or bargaining agents.

8. Targets and initiatives

Every railway company must, for each year, establish targets designed to improve the safety of its railway operations based on identified safety concerns, and develop initiatives to achieve each target. 

9. Reporting contraventions and safety hazards (Whistle-Blower Protection) *new*

Whistle-blower protection

Every railway company must have a procedure for employees to report, without fear of reprisal, any safety hazard or any contravention to a regulatory instrument. Railways must have a whistle-blower policy for protecting employees from reprisals. This must be developed in collaboration with the employees or their representative or bargaining agents, and communicated to all employees. 

10. Managing Knowledge (qualification, skills, knowledge)

Every railway company must list and ensure that every employee has the skills and qualifications required to work for the railway operations. Employees and other authorized persons whose activities affect the railway operations must have knowledge of applicable regulatory instruments and the railway’s internal procedures, standards, instructions, bulletins. 

  • Proposed change
    Technical Safety BC proposes adding that all railways must conduct annual proficiency testing (job observations) for employees in safety critical positions.
Scheduling with fatigue management

11. Scheduling (Fatigue Management) *new*

The principles of fatigue science include:

  • that human fatigue is governed by physiology;
  • that human alertness is affected by circadian rhythms;
  • that human performance degrades in relation to hours of wakefulness and accumulated sleep debt; and
  • that humans have baseline minimum physiological sleep needs.

Every railway company must apply these principles when scheduling the work of employees who work according to a schedule that: 

  • is not communicated to the employee at least 72 hours in advance;
  • requires the employee to work beyond his or her normal work schedule; or
  • requires the employee to work between midnight and 6am
  • How the fatigue science has been taken into account must be communicated to the affected employees.

Exception: This section does not apply when scheduling the work of employees during an emergency related to the safety of railway operations.

Annual SMS audits

12. Continual improvement

Every railway company must monitor the implementation of its SMS and inquire any identified deficiencies. An annual monitoring report is to be submitted to the accountable executive. A SMS audit must also be conducted every three years to evaluate the implementation of each SMS component and establish an action plan to address any identified deficiencies, signed by the accountable executive

  • Proposed change
    Technical Safety BC proposes to amend that railways conduct audits annually instead of “every three years.
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