Rail Safety
April 7, 2015
Knut Ohm
Rail Safety Officer
Dangerous Goods, Rail Safety and 511
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Railway Scene In Alberta
• 326 Industrial Railways
•
132 Industrial Railways DG transload sites
• 2 Short Line Railways and
• 4 Heritage Railways
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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
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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
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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
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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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Enforcement
Administrative 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
infraction
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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?
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