System Safety Regulation Initial Overview System Safety/ RRP Implementation Team

New(different?) Approach to Safety System Safety Program (SSP)/Risk Reduction Program (RRP), are not prescriptive and are different from traditional safety strategies which rely on results from and investigation of past accidents/incidents. Proactive Systematic Actively promoting continuous safety improvement Directly affecting safety culture System Safety/Rick Reduction strategies are designed to be proactive by identifying hazards before accidents or incidents occur, ensure programs and procedures are in place and focus on organizational management, implementation and promotion of safety culture

Application (SSP) SSP (Part 270) applies to: Railroads that operate intercity or commuter passenger train service Railroads that provide commuter or other short-haul rail passenger train Public authorities operating passenger train service

Application (RRP) RRP (Part 271) applies to: Class 1 Railroads Class II and III Railroads determined by FRA to have inadequate safety performance Railroads that voluntarily comply Includes railroads that are part of the general railroad system of transportation

49 CFR PART 270 System Safety Program Requires commuter and intercity passenger railroads (passenger railroads) to develop and implement a system safety program (SSP).

Promotes Safety Culture SSP encourages a railroad and its employees to work together to proactively identify hazards and to jointly determine what, if any, action to take to mitigate or eliminate the resulting risks.

Flexible The rule provides each railroad with a certain amount of flexibility to tailor its SSP to its specific operations.

So What is System Safety?

System Safety The application of management and engineering principles, and techniques to optimize all aspects of safety, within the constraints of operational effectiveness, time, and cost, throughout all phases of a system life cycle

System Safety Program Represents the railroad’s safety philosophy and cultivates a robust safety culture from the most senior officer throughout all levels of the organization.

System Safety Program Plan A system safety program is adopted and implemented through a written system safety program plan. Plan is not required to be submitted until February 8, 2018 Full implementation is required 36 months after approval of plan by FRA

System Safety Plan As part of its SSP plan, a railroad will also be required to describe the various procedures, processes, and programs it has in place that support the goals of the SSP.

FRA System Safety Program Plan Contents (Elements) Final Rule Part 270 Program Policy Statement Program Goals Railroad System Description Railroad Management and Organizational Structure Program Implementation Process Maintenance, Repair & Inspection Program Rules Compliance & Procedures Review Employee/Contractor Training Emergency Management Workplace Safety Public Safety Outreach Accident/Incident Reporting & Investigation Safety Data Acquisition Contract Procurement Requirements Risk-Based Hazard Management Risk-Based Hazard Analysis Technology Analysis & Implementation Plan Safety Assurance Change Management Configuration Management Safety Certification Safety Culture

49 CFR 270 SSP Key Dates August 12, 2016 Final Rule Published August 12, 2016 Rule Effective – October 11, 2016 Preliminary Meeting with Employees/ Labor No later than April 10, 2017 Notice sent to employees/labor no less than 60 days before meeting Railroads with contractor employees are to be included Submittal of System Safety Program Plan No later than February 8, 2018 Full SSP Implementation 3 Years After FRA Approval of SSP (2020 – 2022)

So What is FRA doing to Roll Out this Regulation Implementation Guide Sample SSP plans Process for electronic plan submittal Consistent process for FRA reviewing plans Internal Audit process review External Audits (Focused and Full)

What are we doing? Guidance Documents Conduct internal training Conduct external outreach Hire Staff Process for Reviews and Audits

Proposed Training Training FRA headquarters Principles of System Safety for Executives e-Learning (1-2 hour virtual live training) High level Senior Managers Headquarters & Regional RAs and DRAs Principle of System Safety and Management of Safety for FRA HQ Staff (1 day Instructor-Led Training) Staff Directors FRA System Safety - (4-5 day Instructor-Led Training) Managers and Contractors Responsible for Implementation Passenger Rail Regional Staff Rank and File including FRA and Railroad (Safety) Personnel Available to appropriate FRA Regional Staff Short-Term Technical Assistance Guidance (Training) to Railroads

Federal Railroad Administration System Safety Implementation Guide This basic guide outlines what is required in a system safety program plan (“plan”) to assist railroads in developing their plans is intended to be a tool in conjunction with the two examples of SSP plans

Audit Processes Internal Audit process review External Audits (Focused and Full)

Internal System Safety Program Assessment Railroads annually measure how well they are implementing and complying with their System Safety and Risk Reduction program and plan Identify areas in need of improvement Recommend corrective actions Measure the effectiveness of achieving program goals Annually submit internal assessment report to FRA

External Audits External safety audit FRA conduct external audits of a railroad’s system safety and risk reduction program. Evaluate the railroad’s compliance with the elements of railroad’s approved SSP/RRP plan. FRA shall provide the railroad written notification of the results of any audit. Follow-up on corrective action.

FRA SSP Team Any questions contact: Daniel Knote Robert Adduci Daniel.Knote@dot.gov Robert Adduci Robert.Adduci@dot.gov Larry Day Larry.Day@dot.gov Michael Ramsey Michael.Ramsey@dot.gov

Questions?