It’s safety first on America’s passenger railroads

Two weeks ago, the Federal Railroad Administration (FRA) issued its final rule on the establishment of System Safety Programs (SSPs). According to FRA sources, this rule has been a long time in the making. (The FAA has had similar rules for almost two decades.) The rule primarily seeks to address defined methods of identifying potential safety hazards in the passenger railroad environment, clear ways of defining progress towards eliminating those hazards, and a paper trail that will demonstrate how the railroads are moving towards compliance with all FRA regulations.

To the uninitiated, railroad safety, like all industrial safety programs, looks like a simple matter of training. You either have safety or you don’t, and the outcome in terms of both employee and public accidents is a clear indicator of which is which. But it’s not that simple.

When I became a transportation specialist in the insurance business, I had to deal with all kinds of safety programs created by all manner of executives, managers, middle managers, and simply by workers who held meetings and reached a consensus on what is and is not safe. It may be cynical to say so, but those businesses, transportation among them, that had the most exposure to public liability for their unsafe actions, also had, by far, the best safety programs. It seems that exposure to public liability and the “bad press” that goes with it often provided the incentive for serious consideration of safety. This is anecdotal and not supported by any studies of which I am aware.

Often, the simplest of businesses, small manufacturing plants with under fifty workers, for example, had the worst safety programs. On the other end of the spectrum, railroads, even the smallest of transportation districts, are complex entities that operate some of the heaviest of imaginable machinery outdoors and under unpredictable and widely variable conditions. Should I expect them to have among the best of safety programs?

Though most would like to be, and should be if they are managing risk properly, most are not fenced off or hidden away from general public access. The average customer for passenger rail service does not have a safety background and assumes that his safety is taken care of no matter where he or she is in the train or on the railroad’s property. The general public that does not ride the train is even less predictable, often never having had even the brief physical taste enjoyed by the railroad passenger of what immense forces are in play when a train has to go into emergency braking.

Which brings me to SSPs. System Safety as a discipline had its roots in the military management of safe ordinance systems and in nuclear power and other complex systems with high risk potential. SSPs have been refined to ultimately become a sub-discipline of systems engineering.

Here’s what’s to like about SSPs and their offshoots, SSPPs, or System Safety Program Plans: SSPs say that we don’t have to wait to plan for safety until something unsafe happens. In the passenger railroading business, this means that all personnel should be engaged in identifying hazards. A dining car chef, for example, might see a hazard in the way that frozen foods are loaded into the train.

For another example, take a car inspector, a key safety player who you would expect to focus on defects and hazards in the passenger carrying equipment. But he might also see a hazard in the way the train is spotted for inspection, or in the way his inspections are digested and made manifest to repair and maintenance personnel.

In a system safety environment, identify hazards takes on equal importance with implementing solutions, defining progress, and documenting the success of the system. Although nobody can ignore when things go wrong, system is not as focused on what went wrong and why as it is on what can go wrong and how to stop it.

SSPs are ongoing, interrelated, and virtually as complex as the railroad environment itself. Under the perfectly functioning SSP, no railroad accident should ever happen. The only thing different about an FRA mandated approach to SSP is that the FRA takes it for granted that regulatory compliance is equivalent to a perfectly functioning program.

Whether that is true or not, this is a bold step in the right direction for safety on all passenger railroads.

For an excellent example of an SSPP for passenger rail, see the American Public Transportation Association’s manual for development at http://www.apta.com/resources/reportsandpublications/Documents/commuter_rail_manual.pdf

©2016 – C. A. Turek – mistertrains@gmail.com

(Charles A. Turek is a writer and novelist based in Albuquerque, NM. After four decades working in areas of the insurance industry related to transportation, he now writes on all aspects of American railroading. Charles is a political conservative but believes in public funding of passenger rail as a part of the federal government’s constitutionally conservative obligation to provide for defense and public infrastructure so that private enterprise may flourish.)