Verbatim feedback: Railway consultation - Safety Management Systems Regulations
The feedback received through the railway consultation has been reviewed and posted according to Technical Safety BC’s Content Submission Guidelines.
Also see Verbatim feedback: Railway consultation for:
Requiring all 12 components of the SMS Regulations
| Date | Respondent | Reasonableness |
|---|---|---|
| 10/10/2018 14:18 | Nutrien Ag Solutions | Somewhat unreasonable |
| 10/10/2018 22:18 | NELSON ELECTRIC TRAMWAY SOCIETY | Reasonable |
| 10/19/2018 | Teck Coal | Unsure |
| 11/5/2018 | Cando Rail Services Ltd | Unreasonable |
| 11/22/2018 | Anonymous (Industrial Railway) | Reasonable |
| 11/22/2018 | Anonymous (Heritage Railway) | Reasonable |
| 11/23/2018 | Kamloops Heritage Railway | Somewhat reasonable |
New requirements
| Date | Respondent | Reasonableness | Comments |
|---|---|---|---|
| 10/10/2018 14:18 | Nutrien Ag Solutions |
Accountable Executive: Neutral Reporting safety hazards: Reasonable Fatigue management: Neutral |
N/A |
| 10/10/2018 22:18 | NELSON ELECTRIC TRAMWAY SOCIETY |
Accountable Executive: Reasonable Reporting safety hazards: Reasonable Fatigue management: Neutral |
These are not new. We already have identified an executive who is accountable and we are on the lookout for hazards on a daily basis. Fatigue management is not an issue as our Operators only do a 3 hr shift. |
| 10/19/2018 | Teck Coal |
Accountable Executive: Neutral Reporting safety hazards: Reasonable Fatigue management: Reasonable |
This section is somewhat confusing as some of the 12 components are part of the SMS today. |
| 11/5/2018 | Cando Rail Services Ltd |
Accountable Executive: Reasonable Reporting safety hazards: Reasonable Fatigue management: Somewhat reasonable |
In 2015 the federal SMS regulations were put in place, with 3 specific parts to it. Part 1, Part 2 Div 1, Part 2 Div 2. They were set up in this fashion to recognize the various distinction between different types of train operations and took into account the size of the organization. Part 1 regulations are basically for the Main line, long haul, large railway companies. Part 2 Div 2 addressed those operations that may go on non-main track and the associated components of those regulations addressed the requirements of that kind of RR operation. BC Technical Safety should consider adopting the same type of regulations that Transport Canada has adopted. For a small industrial railway Part 1 is burdensome and unnecessary and would be better served falling under Part 2 Div 2. |
| 11/22/2018 | Anonymous (Industrial Railway) |
Accountable Executive: Reasonable Reporting safety hazards: Reasonable Fatigue management: Reasonable |
|
| 11/22/2018 | Anonymous (Heritage Railway) |
Accountable Executive: Reasonable Reporting safety hazards: Neutral Fatigue management: Reasonable |
|
| 11/23/2018 | Kamloops Heritage Railway |
Accountable Executive: Reasonable Reporting safety hazards: Reasonable Fatigue management: Neutral |
The SMS system allows for review of factors that will contribute to operating a safe rail operation. |
General Operating Instructions
| Date | Respondent | Agreement | Comments |
|---|---|---|---|
| 10/10/2018 14:18 | Nutrien Ag Solutions | Neither agree nor disagree | |
| 10/10/2018 22:18 | NELSON ELECTRIC TRAMWAY SOCIETY | Disagree | We already have an active SMS. Why do we need another level of bureaucracy.? A G,.O.I, is a waste of time and more paperwork to be done. We need less not more.. |
| 10/19/2018 | Teck Coal | Unsure | Again, somewhat confusing. Not all industrial railways perform rail operations that fall within the definition of rail operating instructions. Industrial railways typically maintain operations training manuals. |
| 11/5/2018 | Cando Rail Services Ltd | Agree | All railways should have a GOI so it shouldn't be an issue incorporating it into an SMS. It is already part of our SMS. |
| 11/22/2018 | Anonymous (Industrial Railway) | Agree | - |
| 11/22/2018 | Anonymous (Heritage Railway) | Agree | - |
| 11/23/2018 | Kamloops Heritage Railway | Neither agree nor disagree | Depending on size and complexity of the rail line, there are existing rules and procedures, which if followed, should govern the operations. |
Occurrence reporting guidelines
| Date | Respondent | Helpfulness | Comments |
|---|---|---|---|
| 10/10/2018 14:18 | Nutrien Ag Solutions | Somewhat helpful | |
| 10/10/2018 22:18 | NELSON ELECTRIC TRAMWAY SOCIETY | Unhelpful | We already conform to Reporting regulations with the use of Part A and Part B. |
| 10/19/2018 | Teck Coal | Neutral | |
| 11/5/2018 | Cando Rail Services Ltd | Neutral | While it may benefit some smaller RR's, others already have defined investigation protocols and would end up having to fill a number of documents out that essentially will mean the same thing. Burdensome. |
| 11/22/2018 | Anonymous (Industrial Railway) | Helpful | - |
| 11/22/2018 | Anonymous (Heritage Railway) | Helpful | It would be useful if TSBC provide all operations with updated and consistent reporting forms |
| 11/23/2018 | Kamloops Heritage Railway | Neutral | Will report as per existing rules and regulations. |
Frequency of conducting safety concern analyses
| Date | Respondent | Agreement | Comments |
|---|---|---|---|
| 10/10/2018 14:18 | Nutrien Ag Solutions | Neither agree nor disagree | |
| 10/10/2018 22:18 | NELSON ELECTRIC TRAMWAY SOCIETY | Agree | What is it that Technical Safety wants? If they want a monthly report, a weekly report or a daily report - then just say so. |
| 10/19/2018 | Teck Coal | Neither agree nor disagree | This can be part of the annual SMS audit. |
| 11/5/2018 | Cando Rail Services Ltd | Somewhat disagree | Putting a numerical requirement on the frequency of conducting analyses is not the proper way to look at this particular requirement. A more pro-active way to look at it as a regulator is to define circumstances where conducting analyses of safety concerns would be required |
| 11/22/2018 | Anonymous (Industrial Railway) | Neither agree nor disagree | - |
| 11/22/2018 | Anonymous (Heritage Railway) | Agree | TSBC needs to ensure that all operations have consistent procedures for conducting safety analysis for their operations. |
| 11/23/2018 | Kamloops Heritage Railway | Somewhat agree | Operating personnel proficiency tests done annually. |
Annual proficiency testing (job observation)
| Date | Respondent | Agreement | Comments |
|---|---|---|---|
| 10/10/2018 14:18 | Nutrien Ag Solutions | Somewhat agree | |
| 10/10/2018 22:18 | NELSON ELECTRIC TRAMWAY SOCIETY | Agree | Where is the amendment. i t is already spelled out in our S.M.S. that this is done during each operating season. We operate only 5 months of the year and our proficiency testing is done at least 2 or 3 times on each operator.during each operation season. |
| 10/19/2018 | Teck Coal | Neither agree nor disagree | |
| 11/5/2018 | Cando Rail Services Ltd | Somewhat agree | While our organization already does this on a regular basis, it is important that proficiency testing be done well. If it is done to meet corporate or regulatory numerical requirements, it can very well lose the impact that it is being proposed for in the first place. Quality versus is the key point here. This is an opportunity for coaching and mentorship and should be treated in that fashion. If done well it will contribute to a better safety culture within the organization. If done poorly, it will negate an effective safety culture. |
| 11/22/2018 | Anonymous (Industrial Railway) | Somewhat agree | - |
| 11/22/2018 | Anonymous (Heritage Railway) | Agree | TSBC needs to provide consistent basic format for proficiency reviews. |
| 11/23/2018 | Kamloops Heritage Railway | Agree | [See previous comment] |
Annual audits
| Date | Respondent | Agreement | Comments |
|---|---|---|---|
| 10/10/2018 14:18 | Nutrien Ag Solutions | Neither agree nor disagree | |
| 10/10/2018 22:18 | NELSON ELECTRIC TRAMWAY SOCIETY | Unsure | We already do an audit each year. |
| 10/19/2018 | Teck Coal | Unsure | Does this audit refer to a review of the SMS document or overall adherence to the processes outlined in the SMS? I am surprised to read about an audit every 3 years. We have not been aware of this. |
| 11/5/2018 | Cando Rail Services Ltd | Somewhat agree | While it is important to ensure your SMS is functioning as intended, to a degree the size of the operation and number of incidents should dictate frequency. Our organization does annual regulatory audits of our SMS, but what is of more value is to review how the SMS is actually functioning at a particular location. Effecting change locally and through the SMS will enhance safety performance. |
| 11/22/2018 | Anonymous (Industrial Railway) | Agree | - |
| 11/22/2018 | Anonymous (Heritage Railway) | Somewhat agree | - |
| 11/23/2018 | Kamloops Heritage Railway | Somewhat agree | Depends on traffic volumes etc. |
Specific components
| Date | Respondent | Component | Comments |
|---|---|---|---|
| 10/10/2018 14:18 | Nutrien Ag Solutions | All components can be met
Safety policy |
N/A |
| 10/10/2018 22:18 | NELSON ELECTRIC TRAMWAY SOCIETY | All components can be met | N/A |
| 11/5/2018 | Cando Rail Services Ltd | All components can be met | N/A |
| 11/22/2018 | Anonymous (Heritage Railway) | All components can be met | N/A |
Other comments on the SMS Regulations
| Date | Respondent | Comments |
|---|---|---|
| 10/10/2018 22:18 | NELSON ELECTRIC TRAMWAY SOCIETY | Lets try to make it simpler to follow and not be caught up in jumbo jumbo. |
| 10/19/2018 | Teck Coal | Overall confusing about the frequency of audits and what the audits contain. |
| 11/23/2018 | Kamloops Heritage Railway | We submit an annual SMS. |