Engineering Waiver Management

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Presentation transcript:

Engineering Waiver Management STANDARDS DEPARTMENT Last Updated: 20 November 2018 Version: 1.0

introduction Purpose The purpose of this presentation is to summarise the process for the request, endorsement, approval and implementation of Engineering Waivers. Engineering Waivers allow for variations from mandatory requirements of ARTC Engineering Procedures, Standards, Code of Practice, Specifications and Instructions (known as Engineering Standards). These Engineering Standards are used for design, construction, maintenance and operation of the ARTC network. Note: An ARTC Engineering Waiver does not cover Australian Standards. Standards Department: Engineering Waiver Management

introduction Procedure, Form and Register EGP-02-01 Engineering Waiver Management EGP0201F-01 Engineering Waiver Approval Form EGP0201R-01 Engineering Waiver Approval Register Where to find current versions: https://extranet.artc.com.au/eng_waivers.html#waivers Or follow: Extranet > Waivers & Clearances > Engineering Waivers Standards Department: Engineering Waiver Management

introduction Risks Controlled by EGP-02-01 The procedure aims to minimise risks from waivers by requiring that: Alternate treatments are Safe SFAIRP when existing technical and/or operational controls are waived Records are kept of technical controls being waived and the alternate treatments are in place for the life of the waiver A review is undertaken when there are changed conditions underpinning the waived controls and alternate controls There is evaluation of the cumulative effect of multiple waivers each time a new waiver is approved All nominated alternative treatments for a waiver are fully implemented and recorded. Standards Department: Engineering Waiver Management

PROCEDURE TO APPLY FOR AN ENGINEERING WAIVER Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Originator The Originator of the Engineering Waiver obtains the latest version of the EWAF and completes Sections 1 to12: https://extranet.artc.com.au/docs/eng/all/forms/EGP 0201F-01.docx Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Waiver Number If applying for a new waiver, leave this blank. A number will be allocated by the Standards & Procedures Administrator once the complete and endorsed EWAF and supporting documents are submitted to standards@artc.com.au If applying for a renewal or alteration of an existing waiver, enter the existing waiver number. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Waiver Title Include a brief description of the waiver / variation being sought. E.g. “Enlarged Signal Post”, “Reduced Shoulder Ballast”, etc. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Waiver Type Indicate if the application is for a new waiver, or for the renewal or alteration of an existing waiver. If a renewal or alteration, add a reason for the renewal or alteration. Note: Waiver renewal and alteration applications follow the same process as new waivers with consideration of additional risks arising from revised expiry date or alteration to waiver details. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Originator Enter details of person requesting the waiver. If the Originator is not an ARTC employee, include the name of an ARTC contact. Note: The Originator is responsible for ensuring the waiver application is completed accurately and in accordance with EGP-02-01. This includes ensuring that all items are addressed and that sufficient supporting documentation is provided. The Originator must also ensure a copy of the Risk Assessment Report is forwarded to the ARTC Corporate Risk Manager. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Network Details Indicate the Corridor(s), line and location affected by the waiver. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Waiver Duration Indicate whether the request is for a permanent or temporary waiver, and detail the proposed start date and the expiry date (if applicable). Note: Where the nominated start date is prior to the actual approval date, the approval date applies as the effective start date for the waiver. If Regulator Notification is required, the start date will be the date of expiry of the notification period, or upon receipt of confirmation that the Regulator has no objections, whichever is earlier. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Infrastructure Assets Affected Identify the infrastructure assets which will be affected either directly or indirectly by the approval of the waiver. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Relevant Standard Provide details of the Engineering Standard to be waived. This includes the number, clause/section, version and a copy of the mandatory requirement being waived. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Variation Details Describe the variation to the mandatory requirement in the Engineering Standard. Include infrastructure components or equipment which are involved or may be affected. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Existing Waivers Provide details of all existing waivers that impact on the infrastructure asset. Details of existing waivers can be found on the Engineering Waiver Approval Register, also located on the extranet waivers page: https://extranet.artc.com.au/eng_waivers.html Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Risk Assessment The Originator is to ensure that an assessment is undertaken in order to determine the impact of the waiver in relation to the risks and/or hazards that the exact clause/section(s) of the Engineering Standard being waived addresses. Where multiple waivers are already in place, or where multiple waivers are intended to be applied, this assessment shall consider the cumulative impact of these waivers. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Risk Assessment - continued The Risk Management Procedure RSK-PR-001 and supporting Work Instructions can be accessed via the link located on the extranet waivers page: https://extranet.artc.com.au/eng_ waivers.html Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Risk Assessment - continued Section 8 of RSK-WI-002 Determining if Risk Is Reduced So Far As Is Reasonably Practicable (SFAIRP) provides guidance on items to consider and document during this assessment. Where it has been identified that new risks have not been addressed, or that the existing risks and or/hazards will not be sufficiently controlled, additional treatments are to be identified and implemented. Any new risks associated with the application of the waiver and variation to the Engineering Standard are to be identified, assessed and documented in accordance with RSK-PR-001 Risk Management Procedure and associated documents, and copies provided to the ARTC Corporate Risk Manager. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Risk Assessment - continued Risk Assessments shall include input from and/or review by identified stakeholders affected by the waiver. If the issue affects design, then a person with design competency for the respective discipline must be a stakeholder. All new waiver applications shall be supported by a risk assessment that addresses the impact of the waiver at the time of application. In the case of a renewal or alteration, the existing risk assessment for the waiver may be applicable, however this must be reviewed and confirmed that it is still appropriate in support of the waiver. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Risk Assessment - continued The Originator selects the relevant check box on the EWAF to confirm the Risk Assessment is attached, or, in the case of a renewal or alteration, it may be that the existing Risk Assessment has been reviewed and is still appropriate in support of the waiver. The Originator also confirms that the Risk Assessment Report has been submitted to the ARTC Corporate Risk Manager including by whom and on what date. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Treatments to be Implemented Detail the treatments/controls to be implemented to manage any identified risks arising from the variation to the Engineering Standard. The Originator must ensure that any waiver treatments identified in the risk assessment are advised to the person who updates the risk register for the applicable corridor. For further details, see EGP-02-01 Engineering Waiver Management clause 2.2.10 Treatments to be Implemented. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Justification The Originator shall provide justification as to why the mandatory requirement cannot be complied with and give details of the costs/benefits that support the waiver. The removal of a treatment or engineering control (i.e. the waiving of a clause in a Standard) generally requires the implementation of an alternate control. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Attachments List the documents that are attached to support the waiver. E.g. drawings/sketches, technical reports, etc. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Waiver Endorsement Upon completion of the Waiver Request section, the Originator submits the EWAF along with all supporting documents to the Endorsement Authority for their signature at section 13. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Waiver Endorsement - continued The Endorsement Authority is the ARTC Corridor Manager appointed for the Corridor. Where an ARTC Corridor Manager is not appointed for part or all of a Corridor, the equivalent ARTC position (with responsibility for all or part of that Corridor) will be the Endorsement Authority. Waivers against Rolling Stock or Plant and Equipment Standards that involve ARTC owned and operated plant may be endorsed by the Procurement and Contracts Manager. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Waiver Endorsement - continued The Endorsement Authority shall ensure the EWAF has been completed accurately and undertake a technical assessment of the waiver with relevant stakeholders. The risk assessment shall be reviewed for adequacy and appropriate treatments. The Endorsement Authority’s signature in this section states that they are fully aware of the implications of the waiver, they accept the variation on their Corridor and will ensure the treatments are implemented and monitored throughout the life of the waiver. If a waiver is applicable to more than one corridor, review and endorsement from each corridor’s Endorsement Authority is required. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Waiver Submission Upon receipt of the endorsed EWAF, the Originator submits the EWAF along with all supporting documents to standards@artc.com.au. Note: Submit in Word format, with either a PDF showing appropriate signatures or email from the Endorsement Authority confirming endorsement. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Waiver Technical Review, Recommendation and Approval The Standards & Procedures Administrator will number (if applicable) the complete and endorsed waiver application, and register it on the Engineering Waiver Approval Register. The Standards & Procedures Administrator will then organise for technical review (if applicable), recommendation and approval. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Waiver Technical Review, Recommendation and Approval - continued Operational Safety & Environment Review Committee (OSERC) Waivers that also affect Corporate Strategy or Policy will be submitted by the Recommendation Authority to OSERC for approval. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Waiver Technical Review, Recommendation and Approval - continued Regulator Notification Whether or not Regulator notification is required is determined in accordance with the ARTC SMS (Manage Accreditation – Variation & Change). This is determined by the Approval Authority. https://sms.artc.com.au/ Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Waiver Technical Review, Recommendation and Approval - continued Waiver Approval Conditions and Treatments The Technical Reviewer, Recommendation Authority and Approval Authorities may nominate Waiver Approval Conditions and Treatments (or alterations to existing Treatments), in addition to the Treatments already detailed in section 10. The Standards & Procedures Administrator will seek the signature of the Endorsement Authority at section 20 if applicable. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Waiver Notification If the waiver is approved, and Regulator Notification is not required, the Standards & Procedures Administrator will issue a notification via email to the Originator, Endorsement Authority, Recommendation Authority, Approval Authority, applicable Compliance Manager, Internal Auditors and Configuration Manager. If the waiver affects operation of trains, the Endorsement Authority must circulate the notification to the ARTC Operations Planning section for their consideration to the effects on the operational timetable. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Regulator Notification If Regulator notification is required, it is the responsibility of the Endorsement Authority to prepare the notification, and advise standards@artc.com.au of the progress. The Standards & Procedures Administrator will populate section 21 of the EWAF. Note: All Regulator correspondence to be sent via the ARTC Legislation and Regulation Manager (Rail). Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Waiver Treatments Implementation Sections 10 & 19 of the EWAF detail the Treatments and Conditions to be implemented for the Waiver. The Endorsement Authority shall maintain records of how each Treatment and Condition has been implemented. These records shall also include details of how it is ensured that the Treatments and Conditions will continue until the Waiver is closed. These records shall be available for compliance checks, audits and investigations. For examples, see EGP-02-01 Engineering Waiver Management clause 3.3 Waiver Treatments Implementation. Standards Department: Engineering Waiver Management

EGP0201F-01 Engineering waiver approval form (EWAF) Waiver Close Out When a waiver is no longer required the ARTC Endorsement Authority provides a close out statement which details why the waiver is no longer required and signs and dates the EWAF or provides these details by email. The EWAF is returned to standards@artc.com.au. If the waiver is no longer required due to an update to an Engineering Standard the waiver close out may be completed by the appropriate Standards Engineer. The proposed close out is reviewed by the Approval Authority for approval. If accepted, the Standards & Procedures Administrator updates the Engineering Waiver Approval Register and issues a waiver close out notification. Standards Department: Engineering Waiver Management

ONGOING REVIEW OF WAIVERS Expired Waivers The Endorsement Authority is responsible for ensuring that waivers do not exceed the expiry date. All renewal applications must be on the most recent version of the EWAF available on the Extranet at the time of application: https://extranet.artc.com.au/docs/eng/all/ forms/EGP0201F-01.docx Standards Department: Engineering Waiver Management

ONGOING REVIEW OF WAIVERS Review of the Engineering Waiver Approval Register The Endorsement Authority (or nominated representative) is responsible for the regular review of temporary waivers applicable to their corridor of responsibility and for periodic review of permanent waivers. Standards Department: Engineering Waiver Management

Questions? Email: standards@artc.com.au