How railroad companies can take the next step in compliance with FRA safe work practices
Ask any railroad—Class I railroad, a short line, or regional—and you’ll find that compliance with the Federal Railroad Administration (FRA) and OSHA rules for safety and compliance is a top priority—from an operational, financial, and cultural standpoint.
It’s a priority that reflected in the mission of the FRA itself, to enable the safe, reliable, and efficient movement of people and goods. This ranges from safe operating practices that protect an engineer running the train, to the protection of roadway workers or MOW employees. To make sure these safe practices are followed, the FRA has developed operating and safety rules that all railroads nation-wide must follow.
Safe operating practices control for variables in human behavior, ensuring that each and every railroad employee complies with FRA safety regulations and works in a safe manner while going about their day-to-day tasks. From operational testing to enforcement procedures and building of a safety culture, railroads today can ensure optimal compliance with FRA requirements without sacrificing efficiency in the process.
Let’s dive into each factor ensuring FRA safety practice compliance, and the technology enablers that you can apply along with them within your organization:
1. Operational factors
Safe practices and operating rule compliance with the FRA go hand-in-hand. For example, applicable railroad employees can be tested for safe operating practices for hazmat handling, or if an employee is wearing all their required personal protective equipment (PPE).
As a result, railroads develop operational testing programs that shift their organization towards becoming a safer workplace. Digital operational testing programs that move testing data to the cloud offer a single source of truth and increased visibility into the success of your FRA safety compliance, as well as compliance with other regulatory rules like GCOR.
Access to pre-imported rules libraries help you become more adaptable to changes in regulations, and automated workflows enable repeatable, uniform, and intelligent master-plan creation that factor in rates of higher accidents or incidents in a location, or repeated failure in testing of a specific safety rule within a department. BI and analytics offer a level of insights into your testing that difficult to achieve with paper-based testing and compliance reporting is quicker-telling you if, for example, drug and alcohol testing failures are higher in a specific location or department.
Another critical operational-related compliance factor is on-the-job training and onboarding. Under 49 CFR Part 243, railroads are required to conduct on-the-job training for employees involved in safety-related tasks—ensuring that they’re knowledgeable about and equipped to follow best safety practices that are compliant with federal safety rules. From an operational standpoint, it’s most effective to align your ops testing goals with your on-the-job training strategies to best set up your employees for success
3. Regulations and compliance factors
Compliance is enforced through sanctions, such as penalties (with a cost associated with them). Other enforcements that the FRA has outlined include voluntary and mandatory agreements or civil penalties, as well as more collaborative tools like education, coaching, grants, and field testing utilizing new technologies and safety processes.
Railroads can best approach safety compliance as a collaborative effort with other industry stakeholders to prevent harm from occurring. This starts by identifying what operations your railroad is finding it challenging to ensure compliance with, test failures for specific operational rules, and directly address the factors leading to human-caused accidents and incidents.
On the one hand, avoiding sanctions and penalties is a priority for any railroad. Who wants to face the cost of a fine resulting from a violation, or pick up the cost of damaged equipment? And on the other hand, following safe work practices on a daily basis can translate into increased efficiencies, as you find that you’re pouring less time and man-hours in managing what were once manual, time-consuming p-programs and processes.
3. Cultural factors
Any successful operational or efficiency testing program should factor in tools and approaches that will help to build a strong safety culture. Within a safety culture, each employee knows and makes best efforts towards identifying and disclosing railroad safety issues, follows best practices, and complies with safety rules. Before you build a digital testing program and apply digital tools to reduce safety risk, it’s critical to build a safety culture that will be at the foundation of every safety initiative in your organization.
Within this safety culture, employees are empowered to comply with FRA safety rules. There are systems and process in place to ensure organization-wide deployment of safety initiatives, enforcements, penalties, and rewards are in place, and leadership continuously demonstrates that safety is a top priority.
Federal regulations and 49 CFR
Railroad companies are not alone in their quest to identify how they can adhere to FRA safety practices and rules in the most efficient, effective manner.
Looking to build upon already stellar records of safety that the rail industry has achieved, the FRA has developed the Risk Reduction Program. With this program, the FRA is exploring “new approaches” to safety improvements through partnering with the industry in the development of performance-based regulations, and are developing a “comprehensive approach to managing safety” through partnering with the industry to leverage the knowledge railroads already have about their own operations.
The U.S. Department of Transportation and the FRA address the minimum standards expected of the railroads and their employees in 49 CFR Part II, including operating practices and handling of hazardous materials, as well as safety practices at highway-rail grade crossings. As the FRA monitors compliance with regulations, they simultaneously look at data surrounding accidents and incidents and reportable events, and then analyze this data to identify gaps in the regulations.
Technology-based solutions to safety compliance
What do recent technology changes prognose for the rail industry?
The agility and flexibility of innovative technologies is that they address gaps in your safety compliance, help you streamline programs that enforce safety rules and procedures, and make reporting for the FRA quicker along with increased visibility into testing data.
Diving in a bit deeper, technology-based, problem-specific technology solutions offer a unique advantage in that they help you to manage the risk associated with variability in human performance. In addition, they make it easier to comply with FRA safe practices, as you can see with advances in Positive Train Control (PTC), or the remote use of locomotives.
While it’s a given that these technologies are disruptive, it helps to look at technology tools as enablers that support and enhance already existing operating practices.
There’s truly a wealth of information about technology enablers and tools when it comes to compliance with FRA safe work practices, rules, and regulations. If you’re looking to accelerate your own safety goals and initiatives with technology tools, we’d love to have a conversation and see what your upcoming and long-term plans are. You can talk with one of our rail experts here.