A Safety Management System (SMS) provides railway companies with a focused approach to building safety throughout an organization and into every aspect of its day-to-day operations. An SMS is in addition to specific regulations, rules or standards. It is a system that helps companies better comply with federal legislation and is intended to ensure railways have in place processes to identify and address safety concerns before they become situations of non-compliance with safety rules.
Transport Canada monitors a railway company’s SMS through audits. The department advises the railway company as to the scope of the audit, conducts the audit, and provides the company with both an informal debrief of findings and a copy of the audit report. Where specific situations of non-compliance exist, the department can take regulatory action.
Following regular Transport Canada inspections and as part of SMS audits, corrective action plans and actions are requested. Once the corrective action plan is received, it is reviewed to ensure that it conforms to regulations and properly addresses the safety concerns noted. If the corrective action plan is found to be insufficient, the company must resubmit a revised plan.
Transport Canada has revised its inspection and audit plans and follow-up procedures to allow for increased frequency. SMS audits will now be completed on a three-to-five year cycle, or more frequently if required. The department will recruit additional specialized auditors to provide guidance to inspectors on conducting SMS audits and on the elements of an effective SMS.
The department is always working to strengthen railway safety oversight. For example the recently published Railway Safety Administrative Monetary Penalties (AMPs) Regulations introduce new monetary penalties - fines of up to $250,000 – to strengthen our ability to quickly enforce safety requirements for railway companies that violate the Railway Safety Act. Non-compliance with SMS Regulations is also included in these AMPs Regulations.
Furthermore, the proposed Railway Operating Certificate (ROC) Regulations, will provide the department with the authority to suspend or cancel a ROC for non-compliance with SMS Regulations.
Transport Canada proposed amendments to the Railway Safety Management Systems Regulations were published for comment in Canada Gazette, Part I and closed on October 3, 2014. The proposed amendments will better hold railway companies accountable for the safety of their railway and include new or updated process to:
- Require railway companies to implement a non-punitive reporting system for contraventions to the Railway Safety Act;
- Analyze data and trends to identify safety concerns;
- Manage organizational knowledge so that employees can perform their duties more safely;
- Improve work scheduling to prevent employee fatigue;
- Create annual safety targets and select appropriate initiatives to reach those targets.
October 2014
