Your Solution for SMART Response Plans

Rail Safety Regulations Implementation, Mitigation and Preparedness

Posted on Thu, Sep 22, 2016

The first officially recorded U.S. railroad accident occurred in 1832 when four people were thrown off a vacant car on the Granite Railway near Quincy, Massachusetts. The victims had been invited to view the freight process of transporting loads of stone when a cable snapped on the return trip. As a result, the observers were thrown off the train and over a 34-foot cliff. One man was killed and the others were seriously injured.

Rail technology, applicable safety regulations and compliance initiatives have significantly changed since 1832. In early 2016, the Federal Railroad Administration (FRA) announced that its heighten enforcement of railroad safety regulations in 2015 led to the highest civil penalty collection rate in the agency’s 50-year history. “Safety must be the number one priority for every railroad, and the Department of Transportation will continue to take aggressive action against railroads who fail to follow safety rules,” said U.S Transportation Secretary Anthony Foxx. “A strong safety enforcement program is critical to prevent accidents, save lives and move our country forward.”

According to the Association of American Railcars, freight railroads operate over a network of nearly 140,000 miles and serve nearly every industry sector of the economy. Two significant safety measures affecting the state of rail safety include the ‘Implementing the Positive Train Control Enforcement and Implementation Act of 2015”, and “FAST Act Requirements for Flammable Liquids and Rail Tank Cars”.

train.jpg
The FRA has been monitoring the progress of the “Implementing the Positive Train Control Enforcement and Implementation Act of 2015”. Positive Train Control (PTC) provides a capable system that prevents train-to-train collisions, over speed derailments, incursions into established work zone limits, and the movement of a train through a main line switch in the wrong position. When active, the PTC can mitigate multiple vulnerabilities and eliminate the need for an emergency response.

The initial December 31, 2015 deadline for Positive Train Control (PTC) enforcements was extended to December 31, 2018 to allow for railroads to achieve full PTC integration. However, rail companies are slow to make the expensive transition.

The PTC integration status update as of the June 30, 2016 is as follows:

PTC Implementation Freight Rail Passenger Rail
Radio Towers Installed 73% 46%
Locomotive Equipped 34% 29%
Training Completed 43% 41%
Route Miles in PTC Operation 9% 22%
Track Segments Completed 11% 12%

 

The law also authorizes up to a two-year additional extension on a case-by-case basis if the railroad can demonstrate that it has fulfilled statutory prerequisites including, but not limited to:

  • Installed all PTC hardware by December 31, 2018
  • Acquired all spectrum necessary for implementation of the PTC system by December 31, 2018
  • Completed employee training required under FRA’s PTC regulations
  • Included in its revised PTC implementation plan an alternative schedule and sequence for implementing PTC as soon as practicable
  • Certified in writing that it will be in full compliance with the requirements of 49 U.S.C. § 20157 on or before the date in the alternative schedule and sequence, subject to FRA approval.

On August 15, 2016, the Pipeline and Hazardous Materials Safety Administration (PHMSA) and the FRA issued a final rule modifying regulations governing trains hauling crude oil and other flammable materials. The potential impacts of a hazardous material incident can be significant.

  • The rule mandates that all new tank cars (specifically, each tank car built to meet the DOT-117 specification, and each non-jacketed tank car retrofit to meet the DOT-117R specification) be equipped with a thermal, insulating protection blanket that has been approved by PHMSA pursuant to 49 C.F.R. 179.18(c).
  • These new tank car requirements are expanded to all trains hauling flammable liquids, regardless of the length of the train.
  • Older tank cars retrofitted to the new design standard (the DOT-117R specification) must be equipped with certain minimum top fittings protections.
  • The rule also requires a faster phase-out of older model tank cars used to transport unrefined petroleum products (e.g., petroleum crude oil), ethanol, and other Class 3 flammable liquids, irrespective of train composition.

As of January 1, 2016, there were 4,613 DOT-117 style tank cars in the manufacturing backlog.

Receive TRP's free resource: Crisis Management Framework

Corporate Crisis Management

Tags: Crude by Rail

Crude by Rail: Cooperative Preparedness Planning and Training

Posted on Thu, Oct 23, 2014

CSX, a North American leading supplier of rail-based freight transportation, recently hosted a crude-by-rail (CBR) incident response training session at the Security and Emergency Response Training Center (SERTC) in Pueblo, Colorado. The training consisted of 40 first responders representing 12 states.  According to CSX, “The three-day training session focused on preparation for and emergency response to railroad incidents involving crude oil, and included an overview of the history of crude oil extraction, chemical and physical properties of different types of crude oil currently being transported, incident site and damage assessment, and tank car design and construction. Participants also practiced specialized response techniques and incident command scenarios during mock derailments.”

According to the Association of American Railroads’ October 4, 2014 Weekly Report, petroleum and petroleum products shipped by rail was up 12.8% from the same time frame in 2013 (1). As CBR shipments continue to increase, companies must prioritize response and safety training, as well as coordinated planning and preparedness efforts. Because a single incident can have a significant or catastrophic impact, it is imperative that pre-planning and training be incorporated with coordinated response efforts.

In May 2014, the Department of Transportation (DOT) mandated initial coordination by instituting an emergency order for railroads to communicate specific information to each State Emergency Response Commission (SERC). The notifications must provide information regarding the estimated volumes and frequencies of train traffic implicated. Rail companies that transport 1,000,000 gallons or more of Bakken crude oil must adhere to the emergency order.

Specifically, the emergency order dictated that the notifications must: 

  1. Provide a reasonable estimate of the number of trains expected to travel, per week, through each county within the state
  2. Identify and describe the petroleum crude oil expected to be transported in accordance with 49 CFR part 172, subpart C
  3. Provide all applicable emergency response information required by 49 CFR part 172, subpart G
  4. Identify the routes over which the material will be transported.

Communication and cooperative pre-incident planning provides a tool for railroad companies and response agencies to begin the collaborative process of preparedness. This endeavor should be a coordination of overall response strategies that are made part of CBR response plans, training, drills, and exercises. A derailment that includes crude may require mutual aid efforts and a clear, yet robust Incident Management System.

In order for an incident management system to be effective, specific situational checklists should be created.  Rail employees, and local incident responders must be trained in applicable emergency procedures, communications cycles, and documentation requirements.  Rail incidents should be managed through clearly identified and communicated objectives. These objectives may include, but are not limited to:

  • Establishing specific and step-by-step incident objectives
  • Developing strategies based on incident objectives
  • Developing and issuing assignments, plans, procedures, and protocols
  • Establishing specific, measurable tactics or tasks for various incident management functional activities, and directing efforts to accomplish them, in support of defined strategies
  • Documenting results to measure performance and facilitate corrective actions

Maintaining an accurate and up-to-date picture of resource utilization is a critical component of incident management and emergency response. This may be especially challenging on select high or low density rail routes.  Each real-time incident management status update should include the following information in order to clarify response status:

  • Time of update (timestamp)
  • Incident or event name
  • Elapsed time of incident from initiation
  • Name/position of responder making status updates
  • Current planning phase and/or specific status update
  • Tasks assigned, both internally and externally, and resources used or required
  • Emergency Operations Center location and contact information

Improving rail car emergency response training, reactive decision management, timeliness of an ongoing response, and swift implementation of recovery strategies can limit resulting effects of any CBR emergency situation. As the shipments of CBRl continue to increase, it is imperative that companies, in conjunction with local responders prioritize well-coordinated preparedness initiatives.

NOTE: SERTC was established in 1985 to train railroad officials to safely handle accidents involving tank cars carrying hazardous materials. Because the initial endeavors were so successful, hands-on training courses were extended to serves the public sector emergency response community, the chemical industry, government agencies, and emergency response contractors from all over the world.  

(1)   Association of American Rail Traffic Weekly Rail Traffic Report, Oct. 9, 2014.

For enterprise-wide response planning guidance, click here or the image below:

Multiple Facility Response Planning Company Preparedness Guide DOWNLOAD

 

Tags: Response Plans, Oil Spill, Training and Exercises, Safety, Crude by Rail