Rail Safety

April 7, 2015

Knut OhmRail Safety Officer

Dangerous Goods, Rail Safety and 511

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• 326 Industrial Railways

• 132 Industrial Railways DG transload sites

• 2 Short Line Railways and

• 4 Heritage Railways

Railway Scene In Alberta

Definition“Industrial railway” means a railway that

• transports only goods or commodities that are

manufactured, refined or otherwise produced,

processed or handled by the person who operates the

railway or on whose behalf the railway is operated,

And

• is operated wholly or in part within the confines of

the industrial site on which goods or commodities are

manufactured, refined or otherwise produced,

processed or handled, and is not operated for the purpose of transporting goods or commodities for a toll or a fee or of being a common carrier

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Federal or Provincial? • A railway is regulated by either a province or federally,

not both with the exception when considered to be a

local railway company.

• A railway that crosses a provincial or territorial border is

regulated by Transport Canada.

• Industrial railways, with a siding agreement or that own

track, that operate within the borders of the province

are regulated by Alberta Transportation by way of the

Railway (Alberta) Act.

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Provincially Regulated Transload Sites

• 22 crude oil transload sites in operation;• 3 loop train in operation• Remainder vary in size

• More may be added in 2015

• 1 current short line & 1 more planned to be added in 2015 to haul crude

• Federal Sites – Service Agreements

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Transportation Safety Services

• Dangerous Goods

• 7 Dangerous Goods Inspectors

• Can inspect transload sites for rail compliance

• Will inspect for dangerous goods compliance

• Rail Safety

• 2 Rail Safety Officers

• Will inspect all sites for regulatory compliance

• Will review / verify railway audits

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Regulatory Requirements

• Railway (Alberta) Act and Regulations

• Federal Transportation of Dangerous Goods Act & Regulations

• Provincial Dangerous Goods Transportation & Handling Act

• CAN/CGSB 43.147 – Railway Car Tank Standards

• Alberta Industrial Railway Regulations – Jan. 01/10

Making Railways Operations Safer In Alberta

• Railway (Alberta) Act came into force 2003

• Training Programs – CHTR & SAIT – 2004 &2005

• Contractors Utilized - 2003 to 2012

• Clear Language Regulations – Jan 01, 2010

• Safety Management System – Apr 01, 2011

• Railway Audit Program - Jun 30, 2013

• Circulars 1 - 2012 and Circular 2 – 2013

• Webinars planned for 2015

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Circulars

• Circular 1

• Guideline for the transfer of dangerous goods to or from a railway vehicle. (section 7)

• Circular 2

• Guideline for the development of security management program for the transfer of dangerous goods.

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General Operating Instructions (GOI)

• Every company is required to submit a GOI for their rail operation as part of the safety management system.

• The GOI will vary by complexity of the railway operation but must accurately give rail employees proper instruction to allow for a safe railway operations.

• The GOI must contain railway instructions only; Product transfer and OH&S are not to be included in the GOI.

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Insurance

The Alberta Railway Regulations require

• The operator of a railway must maintain third party liability insurance of at least $25 million for each occurrence

• Currently the highest provincial insurance requirement in Canada

• Saskatchewan proposing $50 million for industrial railways transloading ERAP products, $25 million for non EARP sites but transload a dangerous goods and $10 million for railways that do not transload dangerous goods

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What Are the Risks?

• The Director General Transport Canada for Rail once said you can have a 100% safe railway, however, you could never turn a wheel

• Risks vary by the scope of the railway operation and the commodity being transloaded

• There is no railway operation that does not have an associated risk

• Railways must have a risk mitigation strategy

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Reactive Safety Management

• Dependent on

• Corporate culture - Dupont

• Resources of the company

• Regulatory knowledge

• Risk management

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Safety Management System

Safety management implies a systematic

approach to managing safety, including the

necessary organizational structure,

accountabilities, policies and procedures.

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Safety Management System

• All railways under provincial jurisdiction

must have a safety management system

accepted by Alberta Transportation

• Operating approvals will not be issued

before the safety management system is

accepted

Introducing Railway Safety Management System in Alberta

• No need to add SMS requirement to the Act as it was already in place

• SMS development – stakeholder consultation

• Existing SMS reviewed included:

Federal rail & aviation

• Other provinces rail SMS

• Prescriptive – over 300 submission expected

• All railway must have submitted their SMS by

April 01, 2011

• Must audit their SMS annually

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SMS Audits

• A SMS self audit must be performed on the railway operation 6 months after the issuance of the operating approval

• Self audits must be conducted by an auditor trained to perform railway audits

• Self audits must be conducted annually

• Every three years a third party audit must be submitted with the operating renewal application

• Audits must be conducted utilizing Alberta Transportations audit protocols

Safety Management Systems Are Working

• Conversations with industry indicates they have a better understanding of what is required to run a safe railway operation (forced to develop)

• Is considered to be a legacy document• Makes good business sense, SMS implement is

other company locations outside Alberta• No major derailments or injuries since the SMS

requirement came into force

• Measurable by annual audits

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EnforcementAdministrative Penalties

We prefer conversation not confrontation; however, there may come a time when enforcement action is required• Who – The railway responsible for the

contravention• What – Any contravention of the Railway

(Alberta) Act • Where – Any railway under Provincial jurisdiction• When – Progressive in nature• Why – To ensure safe railway operations• Administrative Penalty of up to $10,000 per

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Partnership

• Outcome is linked to input by the parties involved, Alberta Transportation believes in a collaborative approach – partnerships are invaluable, some examples are;

• Keyera – Railway Safety Video

• Kinder Morgan – Transload Committee

• CHTR and SAIT

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Leading In Canada

Alberta leads the way in Canada and in North America.

• No Cost Operating Approvals

• $25 Million Dollars Third Party Liability Insurance

Required

• Regulatory Development Collaboration

• Safety Management System & GOI

• Circulars

• Annual Self Audits and External Every 3 Years

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Basic Transloader

Basic Method – Susceptible to Overfilling – Product Vapors – Employee Exposure – Minimal Spill Containment

Weak Point - Relies On Human Shut Down of Pump on Super B

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Better Transloader

Product Metered – Scully Warning / Shut Off System – Vapor Capture

Week Point – Relies On Human Shut Down of Pump on Super B

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Best Transloader

Auto Shut Off – Spill Catchment – Enhanced Grounding – Vapor Capture – Long Term Facility Usually In An Industrial Area

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QUESTIONS?