BC Safety Authority held three Town Hall meetings for railway clients during the month of September. Representatives from Common Carrier, Industrial, Siding and Spur and Heritage railways were in attendance.
Monday September 14th New Westminster, British Columbia
Attendees: Canfor Pulp Taylor, Mitsui Homes Canada, Southern Railway BC, BCR Properties, BCIT Training Railway, Western Forest Products Woss, Canexus North Vancouver, Lehigh Cement Delta, Fraser Valley Heritage Railway, RTC Rail Solutions, Railtime Consultancy.
Tuesday September 15th Prince George, British Columbia
Attendees: Pinnacle Renewable Energy, Westfraser Lumber Quesnel, Chetwynd Mechanical Pulp, Cariboo Pulp & Paper Quesnel, Lafarge Fort St John, Dunkley Lumber, Quesnel River Pulp, Carrier Lumber Prince George, Prince George Pulp & Paper, RTC Rail Solutions, Universal Railway Operations.
Thursday September 17th Kamloops, British Columbia
Attendees: Sullivan Mine & Railway Historical Society, Tolko Armstrong Lumber, Kamloops Heritage Railway, Moly-Cop, HCA Mountain Minerals, Tolko Heffley Creek, RTC Rail Solutions, Universal Rail Systems.
The main points of discussion were as follows:
A Year in Review:
- Once again we did not have a fatality related to railway operations on a provincially regulated railway in the past year. There were fatalities on the commuter railways which are not attributed to the railways operations, these were suicides.
- BCSA continues to develop its “As Found Hazards" method of rating risk. Hazards found during assessments are rated according to risk on a scale of one through five, five being the highest risk. This rating is then applied to the non-compliances observed by safety officers. Therefore, each non-compliance can carry a different weight based on the hazard it represents. It is the weight of the non-compliances, rather than the number of non-compliances, that determine how client fees are annually assessed. This same process also applies to accidents. It is the severity of the accident, not necessarily the number of accidents, that affects a client's fees.
- BCSA intends to partner with BCIT in the new year to produce a series of railway safety videos which will be posted on BCSA's website. The first video will deal with safely securing railway equipment.
Railway Web Page Review:
- The following items on BCSA’s Railway web page were reviewed:
- Annual Statistics
- Railway Safety Directives on Blue Flags and Clearance
- Consultant Matrix
- Railway Supervisor Transfer Process
- Railway Risk Assessment Form
- Annual Statistics (Railway Statistics on webpage)
- The first graph shows that the number of Industrial Railways and Sidings and Spurs has remained steady since 2014. This is because we have pulled back in our efforts to identify new rail operations in the province due to limited resources. We have surveyed most of the province and will focus on capturing those operations that are not part of the system in the new year. The last area we will focus on is the Greater Vancouver area.
- The Accidents and Incidents graph shows that there has been a decrease in accidents year to date in 2015. This can be attributed in part due to a lockout at Southern Railway Vancouver Island (SRYVI) which saw the company cut services and operate with management personnel. One possible explanation for SRYVI's dramatic drop in accidents was that management crews were shadowed by locked out union members who scrutinized their switching. We believe this speaks to the effectiveness of proficiency testing and having trained supervisors observe their rail crews working.
- The Injury graph shows that there was a marked decline in the number of railway related injuries to date in 2015.
- The Audit and Recommendation graph shows that we have done three audits year to date. We will have 6 audits complete by the end of 2015.
- The Assessment, Non-compliances and Recommendations graph shows there have been fewer assessments conducted year-to-date, although by the end of the year the numbers will be the same. Non-compliances are up marginally and recommendations are up. Recommendations are at the discretion of safety officers and reflect their belief that the infractions are minor in nature and do not warrant non-compliances.
- The Railway Enforcement graph shows that we have issued four notices and orders this year in comparison to none for the previous year.
- The As Found Condition graph gives the level of the hazard found in the non-compliances that were issued. The as found numbers are down year to date, however we expect to have similar numbers at year's end..
The 2015 Railway Safety Assessment topics included:
- Proficiency Testing/Job Observation Records
- Accident Record Review
- Track Inspections
- Railway Employee Survey
- Annual SMS Audit
- Rail Crew Training Certification
- Locomotive or Car Moving Equipment Inspection Records
- Confirmation of Railway Employee Medical Exams
- Review of any Risk Assessment Conducted by the Railway in the last year
Annual Assessment – Observations from the Safety Officers from their Assessments:
- Annual SMS Audits are still not being performed. Annual audits of each railways SMS is a requirement of the SMS Guidelines and necessary to ensure the SMS remains relevant.
- Qualifications of railway trainers. BCSA noticed that not all employees performing the role of training supervisors were qualified to do the job.
- Railways should be cognizant of the qualifications of the people they employ to train their railway employees, see the new BCSA Consultant Matrix available on our webpage.
- Some railway consultants have been training IROR not CROR. IROR is an Alberta based rules package and is not recognized in BC. CROR training is required as it is consistent with the rules the service providers, CN & CP use.
- Railways are often not familiar with the training requirements supplied in the matrix in the Railway Employee Qualification Standards regulation. CROR is being taught every 3 years, but employees are not getting the refresher in air brakes, TDG and Trackmobile Operation.
- BCSA is still finding that remedial action dates are missing from track inspections reports. Ensure you go over your track inspections with your inspector and understand which items have to be dealt with immediately and document the repair dates.
- BCSA safety officers have found that not all railway accidents are being reported to BCSA. This is a legal requirement and failure to report an accident can result in your risk level being raised to high with the attached fees.
- Supervisor handovers still not occurring in industry. New supervisors are put in place with little or no knowledge of the Railway Safety Program. BCSA has drafted a Railway Supervisor Transfer Process document available on our webpage to help railways understand what information is required to be transferred to the incoming supervisor.
- Not all railway supervisors have undergone the training program provided to the employees they supervise. Often the railway supervisor is not qualified to supervise the employees doing the job, and not able to perform job observations on the employees.
Preparation for your annual railway safety assessment affects your annual fees. BCSA scores each railway on the result of their annual assessment. If you are not prepared for the Railway Safety Officer’s visit this will work against your score. Railway Safety Officers continue to encounter new railway supervisors who have not received an adequate transfer of information from their predecessor. It is essential to railway safety on each industrial and heritage site that new supervisors are made familiar with the railway program and their obligations under their SMS. BCSA has created a Railway Supervisor Transfer Process document available on our webpage to assist railways in the smooth transfer of knowledge to the incoming railway supervisor.
- Training standards continue to be scrutinized by Railway Safety Officers. It is the railway’s responsibility to ensure their employees are adequately trained to the standards set out in the regulations. It is also the railway’s responsibility to exercise their due diligence when hiring consultants to train their employees. To that end BCSA has developed a railway Consultant Matrix to assist railways in this process. Railways will be held accountable regarding who they hire to do their training. If a Railway Safety Officer after reviewing your documentation determines you have employed an unqualified consultant to train your employees you may be required to redo your training with a qualified individual.
- Since Lac Mégantic Transport Canada has issued numerous changes to railway rules and regulations, which include the Grade Crossing regulation among others. Currently these changes have not been adopted by the province of BC and BCSA’s webpage continues to reflect the old rules and regulations. In the new year BCSA will review the changes made to the rules and regulations and recommend the province adopt the new versions. The exception being the new SMS regulation. BCSA has reviewed the new railway SMS regulation and decided to recommend the province not adopt it. It is BCSA’s opinion that the changes made to this regulation do not provide a higher level of safety to the Industrial and Heritage railways and do not warrant the time required by both BCSA and our railway clients for its implementation.
- Railway Association of Canada (RAC) has recently issued a new version of CROR to become effective on October 14, 2015. BCSA has yet to review the difference package between the existing CROR and the new version regarding its effect on Industrial and Heritage railways. Once we have done so we will advise all concerned of the relevant changes to the applicable rules.
- One of the changes made to the new railway SMS regulation is a significant emphasis on risk assessment. While BCSA will not be adopted the new SMS regulation we will be looking at risk assessment on the railways we regulate. All railways are expected to conduct and document risk assessments when applicable. BCSA’s website now has a risk assessment form that railways may use to document this process.