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RS# 1 Rail Safety Introduction Draft date: Oct 5, 2011 Rev 1. Corporate Health and Safety ArcelorMittal. Guidelines, Scope and Purpose. Guidelines
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RS# 1 Rail Safety Introduction Draft date: Oct 5, 2011 Rev 1 Corporate Health and Safety ArcelorMittal
Guidelines, Scope and Purpose Guidelines This power point presentation identified as Rail Safety (RS) PPT #1 provides the AM Rail Safety standard AM ST 004, Fatality Prevention Assessment (FPA) and good practice guidelines to help each ArcelorMittal site to achieve compliance and implement good practice to prevent rail safety incidents. Each site must have specific written procedures, training, and job briefings in place to protect employees when operating and working on or near rail equipment. In addition each site is to have an effective ongoing layered evaluation and shop floor audit process that ensures rail safety practices and conditions are being followed. Scope These guidelines apply to all employees of ArcelorMittal business units, contractors, subcontractors, and hired labour employees performing work for or on behalf of ArcelorMittal on premises owned, rented or otherwise occupied by ArcelorMittal. The guidelines outlined in these trainings are indicative and may not be in contradiction with the local legal regulations nor the AM ST 004. Group Companies will as a minimum, follow the prevailing local regulations for all work in and around rail and rail equipment. Where the AM standard is more demanding, then it will apply. Purpose The objective of these training PPTs are to provide training and understanding regarding the hazards of rail operations and to prevent incidents which may cause harm to people, equipment, environment, or process. They also serve as templates for site customization for specific local regulatory processes or requirements of specific rules or equipment.
References and Links • U.S.Railroad Safety Statistics; Peter W. French, july 29,2008 • BMS Group; railroad • Alberta Transportation; industrial Railway Operating; December 2009 (www.trans.gov.ab.ca) • Wikipedia; the free encyclopedia • CSX Corporation; www.contractorientation.com 2000 • RSSB; rail safety & standards board; handbooks, guidance and recommendations 2010 • USW Railroad Safety 10/06/2008 • http://www.railsigns.co.uk • Emergency & Railway Safety Occurrence Management; 18.02.2011; Australia Western Railroad Pty Ltd www.arg.net.au • Guideline for rail safety training; Victoria Governement
Summary Six Power Point Trainings RS #1- #6 Hazards of Rail Operations AM ST 004 Rail Standard and FPA HIRA Hazard identification and Risk Assessment Traffic Plan Management Responsibilities Site Rail Safety Committee Training, Auditing, and Life Books
Power Point Trainings Rail Safety RS #1- #6 RS # 1 Introduction RS # 2 Rail Safety Vehicles, Equipment, Tools RS # 3 Work Environment RS # 4 Rail Traffic Operations & Instructions RS # 5 Maintenance RS # 6 Emergencies & Incidents Please utilize all of these trainings beginning with this RS #1 Introduction. You may customize these trainings to fit your specific equipment and site rail safety program needs.
Six Power Point Training Summaries - RS 1- 3 RS # 1 Introduction • Six Power Point Trainings - RS #1- #6 • Hazards of Rail Operations • AM ST 004 Rail Standard and FPA • HIRA Hazard Identification and Risk Assessment • Traffic Plan • Management Responsibilities • Site Rail Committee • Training, Auditing and Life Books must update summaries IN PPT 3 kLAUS? RS # 3 Work Environment • Tracks • Switches • Crossings • Traffic signs • In production halls RS # 2 Rail Safety Vehicles, Equipment, Tools • Locomotives • Wagons, rail cars • Miscellaneous equipments • Types of rail cars and wagons
Six Power Point Trainings Summaries - RS #4- #6 RS # 5 Maintenance • General subjects regarding Maintenance • Definitions and terms • FPA Questions • Maintenance tasks on or near Railways • Maintenance tasks on Rail Equipment RS # 4 Rail Traffic Operations & Instructions • Definitions and terms • General subjects regarding crew roles and responsibilites • Alcohol and drugs • Emergency drill • Driving instructions • Procedures and work instructions - PPE • Parking and walk on tracks • Coupling and uncoupling – risk and risk elimination • Switching, shunting • Loading, unloading and dispatching • Audits RS # 6 Emergencies & Incidents • General subjects regarding Emergencies & Incidents • Definitions and terms • FPA Questions • Procedures • Incidents • Alcohol and Drugs
Why? .....hazards of rail equipment operations Prevent Rail Incidents! ...Many Fatal Accidents from 2004-2010 Vehicle drivers at risk • Few employees are involved in rail equipment collisions • Low probability of serious injury or equipment damage • Very high severity of injury or equipment damage • Nearly all collisions with rail incidents result in serious injuries to the driver or passengers • Persons on foot or on driving must be diligent at all times for rail movements Rail workers at risk • Few employees perform rail operations • Very few minor injuries • Low probability of serious injury or equipment damage • Very high severity of injury or equipment damage when there is an incident • Switching and coupling and uncoupling and movements over crossings are critical tasks
Hazards of rail equipment operations....... ...Most fatal accidents happen....... at Crossings and during Switching/Shunting Coupling activities During.... At.... Switching Shunting & Coupling Crossings
Always give priority to rail traffic! Gandrange, France – September 2007 Pretoria, South Africa - March 2007 Fatal Accident Crossings
Always give priority to rail traffic! Galati, Romania – July 2009 Galati, Romania 2007 Crossings Place where the victim was caught
Always give priority to rail traffic! Newcastle, South Africa –April 2007 Crossings Florange, France – January 2008
KRAKOW / Pinch Point / Crush - Railway / 17/02/2010 Follow safe switching and movement practices! • lack of protection for a tank, no safety runners which could stop a tank • walking into the forbidden zone by the victim Switching Shunting & Coupling Distribution Solutions / Struck By Moving Object / Locomotive / Railway / Train / 08/09/2008 Together with the driver of the locomotive, the victim had to attach 2 railway wagons to 3 other ones on the railway tracks inside the warehouse. The driver was in constant radio contact by walkie-talkie with the victim, carrying out only the instructions he received. According to his testimony, he clearly got the instruction: “Move back, slowly, stop”……………
DUNKERQUE / Multiserv / Pinch Point / Crush - Person in dangerous area / 23/12/2009 Follow safe switching and movement practices! An operator was found crushed between the bumper stopping devices of the rail-road motorised engine and the supporting scraps charging box wagon Switching Shunting & Coupling ArcelorMittal Centre Logistique Européen SA. Struck By Moving Object Train / 25/05/2010
AM ST 004 Rail Safety Standard (12 20 2007 V1) FPA Rail Safety
AM ST 004 Rail Safety Standard (12 20 2007 V1) 1. Scope 1.1. Group Companies will, as a minimum, follow the prevailing local regulations for all work in and around rail and rail equipment. Where this AM standard is more demanding, then it will apply. 1.2. This standard applies to all work on or near railway equipment and lines. 2. Work on rail and tracks 2.1. Every one that is required to work on or within 3 meters (10 feet) of a railway track must be protected from rail movements by track isolation using derail or switch locks. 2.2. Prior to beginning work where railroad track isolation is necessary, the supervisor, or designee, must notify those responsible for rail operations to alert them of the work to be performed. 3. Operations 3.1. All people involved in the operation of rolling stock must be trained and competent. No other person is allowed to ride on cars or locomotives. 3.2. A documented risk assessment must be carried out to establish maximum safe speeds. 3.3. The risk assessment must also identify any close clearances around the track. These must be identified and signed.
AM ST 004 Rail Safety cont. 3. Operations 3.4. There must be a procedure for inspections to establish that equipment is in good working order before operating. This inspection must encompass all equipment highlighted in a risk assessment. 3.5. Locomotives must be fitted with headlights and audible devices such as a siren. Prior to moving the locomotive, the audible device must be sounded and headlights must be kept on while the locomotive is moving. 3.6. Procedures for getting on and off trains must include the use of engineered sill steps, handles and ladders/steps placed so to prevent injury to legs, feet and hands. 4. Pedestrians and vehicles 4.1. Rolling stock must have right of way at all times. Appropriate induction training and signage must be available to ensure that all employees, contractors and visitors are aware of this rule. 4.2. Only approved crossings may be used. These must be signed and adequately illuminated. The line must not be crossed between standing cars or standing cars and bumpers where separation is less than 3 meters (10 feet) unless the track is isolated. 4.3. Vehicles must come to a complete stop prior to crossing any rail track. 4.4. Walking on the tracks is prohibited. 4.5. No person or vehicle is allowed in close clearance areas unless the track is isolated. Any access to close clearance areas can only be made using a documented procedure developed from a risk assessment.
AM FPA Rail Safety Version 3.2 Feb 2010 Eliminating fatalities through better compliance with assessment requirements:Level 0 Not organized and not yet under control. The plant has analyzed the legal requirements and the ArcelorMittal standard for Rail Safety.Level 1 An organization is in place. The plant has evaluated its gaps to comply with law and the ArcelorMittal standard and the necessary means.Level 2 All the rail activities are carried out in compliance with the defined organization. The plant has planned its compliance with law and the ArcelorMittal standard.Level 3 The organization complies with law and with the ArcelorMittal StandardLevel 4 A monitoring system is defined with precise criteria for Rail Safety evaluationLevel 5 Excellence - The organization is under PDCA. Fatality Prevention Assessment (FPA) is a self-assessment process that will help each site to improve. For Rail Safety, this was to be completed and all sites are to be at Level 3. All sites are ultimately to achieve Level 5 for improved performance. Complete listing of all questions for Rail Safety FPA are shown in the Appendix
HIRA Risk Management Principles: • To identify actual and theoretical rail safety risk sources • To determine the level of risk • To prioritize action having ranked risks • To put in place treatments to manage the risk • To regularly monitor to ensure treatments are effective Identify stakeholders in the process: • Experts from within or outside the organization; • Staff and/or unions • Business partners • Customers, suppliers, contractors and service providers • Regulators and • Public groups and/or local community Many ways of identifying risks including: • Group Identification • Physical Inspections • Ad-hoc Risk Identification • Checklists • Existing Controls • Structured Techniques • Use of Previous Similar Studies • Use of Performance Statistics Risk Identification • normal operations • abnormal/emergency operations • maintenance • planned changes (either permanent or temporary) • activities of third parties (e.g. trespass and vandalism) • other non-routine activities • combination or sequence of events
HIRA Version 1 014 May 31, 2011 • The quality of both the identification and assessment of hazards and risks is dependent upon a comprehensive understanding of what makes the system work in terms: • human factors, equipment, infrastructure and relationships between them • understanding of the causes of a risk is essential if we are to treat risks properly The level of detail of the assessment should be sufficient to give confidence that all significant contributors to risk have been evaluated and that the controls/mitigation necessary to combat the risks have been identified • First of all identify the scope, context and affected parties involved in the risk management process and should include: • what is (and isn’t) to be covered • where the risks are being considered and when they apply • who is involved or affected and • the type of risks being considered FPS, OHSAS Step by Step, Rail Safety HIRA IS REQUIRED 18 TIMES BY THE FPA FOR RAIL SAFETY
Transport of Hot Metal and Slag - Examples Torpedo (bottle) cars and Slag Pot Carriers • HIRA must be done which consider all risks related with this special transport; • Speed limits • Break trough of hot metal • Collision with heavy traffic High risks demand a HIRA
Transport of Chemical Substances- Examples • When handling and shunting tank wagons with chemicals according to RID, the employees must take extra care. (sulphuric acid, lime hydrate, CaD, …) Perform a Transportation Risk Analysis to accurately assess the risk associated to rail transportation of hazardous materials transport by rail. Establishes the safety requirements for the transportation and discharging of dangerous goods Provide the information needed by emergency response personnel to deal with transportation accidents and spills. Wagons must have placards and labels to identify dangerous goods. High risks demand a HIRA
Traffic Plan • Conduct comprehensive survey of plant site with mapping • Identify hazards and action steps to eliminate • Eliminate or reduce vehicle and pedestrian crossings as much as possible • Identify high traffic vehicle and pedestrian areas and install safety measures and controls • Install proper signs and crossing information • Involve all necessary stakeholders as required in mapping, hazard identification and follow-up actions
Traffic Plan (Example) L1Q2 FPA
Management responsibilities • Ensure that elements of this training and other trainings are carried out • Ensure comprehensive survey of plant site traffic plan with mapping • Identify hazards and action steps to eliminate and eliminate or reduce crossings as much as possible • Identify high traffic areas and install safety measures and controls with installation of proper signs and crossing information • Involve all necessary stakeholders as required in mapping, hazard identification and follow-up actions • Ensure rail safety requirements are being met, equipment is provided along with training and auditing of procedures • Ensure person responsible for rail at the site (L2Q1 FPA) • Incident & accidents are to be thoroughly investigated and followed-up • Depending on the size of site it is recommended a rail safety committee is in place
Site Rail Safety Committee • Depending on the size of the site, a Rail Safety Committee should be in place at each site • Committee objectives and activities must be defined and documented • Person on site who is appointed as responsible for the rail activities must serve on committee • Size of group, stakeholders, and meeting frequency determined by site • Some Committee activities may include but are not limited to: • Incident and incidents are to be thoroughly investigated and followed up • Share any worldwide incidents and accidents • Conducting comprehensive survey of plant site with mapping • Identification of hazards and action steps to eliminate • Determining ways of improving rail safety at the site • Identify high traffic areas and install safety measures and controls • Developing good training programs and developing systems for instructions of experienced and new personnel • Interface with plant operations and security on movements and traffic issues
Training • Supervisors, rail crews and maintenance personnel must receive adequate training for their responsibilities • Training must be conducted in accordance with and as required by local law • Wherever possible training must be accompanied by a written or oral quiz or exam to determine understanding of training by the individual; additional training may be necessary for the individual based on outcomes of written examinations • Training must be documented • Hands-on training must be provided as necessary and an evaluation of the hands-on training must be documented as well • Training material must be kept up to date with changes in procedures and standards • Training must be directed at high risk operations and tasks, and should be appropriate for routine and non-routine tasks and situations • Vehicle operators, contractors and visitors must have awareness training of safety rules and procedures within the plant site
Auditing • In addition to audits and observations required by local regulations, each site is to have an effective ongoing layered evaluation and shop floor audit process that ensures rail safety practices and safe conditions are in place. • A system must be in place for tracking findings during the audit processes and ensuring corrective actions are completed.
Life Book (example) Rail Safety - Risk Assessment Buffer Stop or Arresting Device Collision (first page) Arresting Device and Buffer Stop • Arresting Device; An assembly provided at the end of a track to arrest an overrunning train, other than a buffer stop • Buffer Stop; An assembly provided at the end of a track to arrest an overrunning train, designed to take the impact of the train at buffer or coupling height Types of buffer stops • Fixed; mass concrete, steel, single mode energy absorbing; friction, hydraulic, visco-elastic, dual mode energy absorbing; Risk Assessment • Consider the different effects of a buffer stop collision, average approaches per day, risk to workforce on train, hazardous products, historical buffer stop collisions, etc Options • Improve compatibility rolling-stock and buffer stop • Increase distance, reduce approach speeds, move buffer to increase distance behind the buffer • Provide end impact walls
Y Y Y Y Y Y Y Y Y Y Y Y N N N N N N N N N N N N NA NA NA NA NA NA NA NA NA NA NA NA Life Book (example) Rail Safety - Risk Assessment Buffer Stop or Arresting Device Collision (second page) This document has to be used as a help before starting the work or performing a SFA
Appendix AM Rail Safety FPAVersion 3.2 Feb 2010
AM RS Fatality Prevention Assessment (FPA) Level 0Not organized and not yet under control. The plant has analyzed the legal requirements and the ArcelorMittal standard for Rail Safety. 1. Does the plant know and understand the legal requirements applicable to them regarding Rail Safety and listed and distributed it to the personnel concerned? 2. Does the plant know and understand the ArcelorMittal standard for Rail Safety and distributed the information to the personnel concerned? 3. Is there a clear traffic signaling at all plant entrance (s), which informs people there is rail traffic on site as well as? - the rule of absolute right of way to rail traffic - the rule of complete stop prior to crossing any rail track for all vehicles 4. Have all rail crossings for vehicles as well for pedestrian been identified? Have safety rules been written on the basis of a Hazard Identification and Risk Assessment (HIRA) for all railway crossings? 5. Is each railway crossing clearly announced with the adequate signaling? Are all the railway crossings adequately illuminated? Is the visibility on the track left and right of the road good for all vehicles and pedestrian approaching the railway crossings? AM Rail Safety FPA Version 3.2 Feb 2010
AM RS Fatality Prevention Assessment Level 1An organization is in place. The plant has evaluated its gaps to comply with law and the ArcelorMittal standard and the necessary means. 1. Has an HIRA been conducted to identify all hazards and risks associated with rail operations and rolling stock taking? 2. Has a plan for rail traffic (with all the tracks for traffic, parking and marshalling, level crossings and line equipments) been defined in the basis of the HIRA with a clear signaling? Have adequate and safe speed limits been defined for all rail lines in all areas? 3. Have safety rules been written on the basis of the HIRA for coupling and uncoupling operations, depending on the vehicle hitching system? 4. Have safety rules for the access into or from vehicles (locomotive and wagons) been written?- ban on getting on and off while going, ban on going between 2 vehicles,- ban on getting off a vehicle face to space- obligation to get on and off using engineered sill steps, handles and ladders / steps,- ban to cross the line between standings cars or standing cars and bumpers where separation is less than 3 meters (10 feet) unless the track is isolated AM Rail Safety FPA Version 3.2 Feb 2010
AM RS Fatality Prevention Assessment Level 1 contAn organization is in place. The plant has evaluated its gaps to comply with law and the ArcelorMittal standard and the necessary means. 5. Have safety rules been written on the basis of the HIRA for shunting operations? 6. Have safety rules written on the basis of the HIRA for rolling stock parking (including braking and wedging rules)? Have safety rules been written on the basis of the HIRA for coupling and uncoupling operations, depending on the vehicle hitching system? 7. Have safety rules been written on the basis of a HIRA for loading and unloading operations on and from wagons? Do those rules take into account the vehicles gross weight, the necessary load sharing out, wedging and stowing in the wagon? 8. Have safety rules been written for situations when duties require people to go on the lineside? The lineside is within the area between the rail boundary fencing and the point that is called “on or near the line”. Have those rules been written on the basis of a HIRA? Do those rules ensure the concerned people are protected from rail movements? AM Rail Safety FPA Version 3.2 Feb 2010
AM RS Fatality Prevention Assessment Level 1 contAn organization is in place. The plant has evaluated its gaps to comply with law and the ArcelorMittal standard and the necessary means. 9. Is it forbidden to walk on tracks? Have safety rules been written for situations when duties require people to go on or near the line (on or within 3 meters / 10 feet of a railway track)? Have those rules been written on the basis of a HIRA? Do those rules ensure the concerned people are protected from rail movements by track isolation using derail or switch locks? 10. Prior to beginning any work for which railroad track isolation is necessary, does the supervisor, or designee, notify the responsible for rail operations of the work to be performed? 11. Has a HIRA been conducted to identify close clearance areas around the track (limited clearance between the line on which trains or movements may approach and adjacent structures)? Are those close clearance areas clearly indicated with ban on entrance for vehicles and people? 12. When someone is required to enter into close clearance, is it only allowed by using a documented procedure developed from a risk assessment? AM Rail Safety FPA Version 3.2 Feb 2010
AM RS Fatality Prevention Assessment Level 1 contAn organization is in place. The plant has evaluated its gaps to comply with law and the ArcelorMittal standard and the necessary means. 13. Have the necessary PPE been defined on the basis of a HIRA for all the rail activities? Are they provided to workers and worn? Are special conditions as outside work and work by night taking into account?- Does rail activities staff wear ankle safety boots?- Do they use clean high-visibility and thermal clothing when necessary? 14. Have emergency response plans been written for rail related incidents that address the following? - incidents to people- derailment incidents- fire - spillage of products- obstacles or damage on the track- power unit breakdown- coupling breaking and vehicles drifting- breakdown and damage on level crossing 15. Have formal communications been done to all employees on the emergency procedures and have those been addressed in induction (to employees, contractors and visitors)? 16. Is the location of the following train’s emergency equipments clearly indicated on trains and known? - first-aid equipment- emergency equipment - fire-fighting equipment AM Rail Safety FPA Version 3.2 Feb 2010
AM RS Fatality Prevention Assessment Level 2All the rail activities are carried out in compliance with the defined organization. The plant has planned its compliance with law and the ArcelorMittal standard. 1. Has one person been appointed as responsible for Rail activities? Is his/her mission defined and properly documented? Has he/she the authority, skills, training and means to ensure safety for rail activities? 2. Have the following positions been defined as well as the corresponding safety rules they have to abide by? - driver - leader of operations – hitcher - switchman - level-crossing keeper - maintenance and control staff - look-out or signaler - dispatcher 3. Have rules for the line-up and positioning of rail maneuver teams been defined (driver, leader of operations, hitcher) and written down (depending on the maneuvers to be performed)? 4. Have people working on those positions been trained on the following? - HIRA - safe working procedures - operations on various types of rolling stock and locomotives - audible and signaling devices - isolation procedures including rail lines and rolling stock isolation - inspection systems - emergency response plans After training completion, does the employer ensures that the concerned workers have acquired the understanding, knowledge and skills necessary to safely perform their duties AM Rail Safety FPA Version 3.2 Feb 2010
AM RS Fatality Prevention Assessment Level 2 cont All the rail activities are carried out in compliance with the defined organization. The plant has planned its compliance with law and the ArcelorMittal standard. 5. Have formal communications been done to all employees on the rules of railway crossings and have those been addressed in induction (to employees, contractors and visitors)? 6. Are all the lines, points, level-crossings, signaling and rolling stock listed? Is there a planning for regular inspections and maintenance on lines, points, ballasts, level-crossings, signaling and rolling stock? Is the planning followed? Are the results of those inspections formalized? 7. Is there a written procedure for pre use inspections on rolling stock (locomotives and wagons)? 8. Are locomotives fitted with headlights for both directions and audible devices such as a siren? Prior to moving the locomotive, Is the audible alarm sounded and are the headlights tested and then kept on in the direction of movement whilst the locomotive is moving?Is the audible device used when crossings of roads and pedestrian walkways? 9. Is there a formalized system for anomalies reporting (obstacles on lines, breakdown on signaling or level-crossing barriers…) accessible and reliable which ensure a quick processing / remedying? AM Rail Safety FPA Version 3.2 Feb 2010
AM RS Fatality Prevention Assessment Level 3The organization complies with law and with the ArcelorMittal Standard 1. Are all the legally required periodical verifications identified? Are they performed by trained and authorized people? Are the results of those controls formalized? 2. Does the plant know and understand the ArcelorMittal standard for Rail Safety and distributed the information to the personnel concerned? 3. Is the responsible person for rail activities always informed prior any work when isolation is necessary by the supervisor or his designee? Is a HIRA always performed before starting any work? Is a safety plan defined on the basis of the HIRA including the necessary safety actions to protect workers from rail traffic movements? Are formalized audits regularly performed to check compliance with the safety plan (particularly concerning the isolation procedure respect)? AM Rail Safety FPA Version 3.2 Feb 2010
AM RS Fatality Prevention Assessment Level 3The organization complies with law and with the ArcelorMittal Standard 3. Are the compliance and respect of the safety rules periodically audited? - pre use inspections on locomotives and rolling stock - lines, points, ballasts, level-crossings, signaling inspections, rail crossings lighting - rules for crossing rail tracks, coupling and uncoupling activities, loading and unloading operations on and from wagons, switching, PPE use, respect of complete stop for vehicles prior crossing railways, safety rules to get on and of trains, use of audible sirens when locomotives move through crossings and using of lights on locomotives Are the audits planed and formalized? 4. Are: - incidents investigations, reported anomalies, information coming from inspections and maintenance operations, audits reports, periodical HIRA done on the rail activities - analyzed and treated efficiently with( corrective actions with identified pilots and deadlines for each action)? AM Rail Safety FPA Version 3.2 Feb 2010
AM RS Fatality Prevention Assessment Level 4A monitoring system is defined with precise criteria for Rail Safety evaluation 1. Is there a general traffic plan with the inside and outside different traffics (all vehicles and pedestrian) on site? Is the rail network on the plan with all the traffic rules (speed limit, priority…)? 2. Are yearly emergency drills conducted to test rail emergency response plan? 3. Are the lessons learnt from emergency drills included in corrective action plans and the deviations communicated to all people involved? Are they taken into account for the emergency response plan review? 4. Are there awareness programs about consequences of alcohol and drugs consumption on health and safety? Is Alcohol and drugs consumption forbidden for people involved on rail and related activities? AM Rail Safety FPA Version 3.2 Feb 2010
AM RS Fatality Prevention Assessment Level 5Excellence - The organization is under PDCA. 1. Does the site review all the established procedures for rail activities annually and revise them as necessary taking into account? - the incident investigations, - reported anomalies and inspections, - audits 2. Are people working in the following positions yearly retrained?, - driver, - leader of operations, - hitcher, - switchman, - level-crossing keeper, - maintenance and control staff. After retraining completion, does the employer ensures that the concerned workers have acquired the understanding, knowledge and skills necessary to safely perform their duties? 3. Are there awareness programs to enforce the respect of safety rules? 4. Are the violations of rules treated in a disciplinary system? AM Rail Safety FPA Version 3.2 Feb 2010