By David Morgan, DDM Consulting Services
As I wrote in my last article, I believe just because a regulation does not apply does not mean we shouldn’t voluntarily use it. I’m not suggesting to voluntarily comply to an entire regulation(s) that we are excluded from, but rather to review it and incorporate those parts that make sense to our operation. Rules and regulations are the safety core in this business known as railroading. It has been said that rules and regulations are written in blood. I have been asked many times what does this mean? It’s really very simple, rule and regulations were and continue to be written as a result of accidents and loss of life. These rules and regulations are written to prevent the accident, situation or circumstance from happening again.
No matter how we look at our individual operations, SAFETY is at the heart of each of them. In a perfect world there would be no injuries, incidents or accidents, but we do not live in a perfect world. These things do happen. It is our job to try and eliminate potential issues, reducing the risk and severity of any incidents before they happen. By being prepared to respond quickly, effectively and efficiently to an accident or incident, we can potentially reduce the severity of that incident.
One of the benefits that guests get when they ride on a scenic or excursion train is the beauty of the back country that they typically cannot see. However, this can present challenges in the event of an emergency, as these areas can be isolated and hard to access. So, how prepared are you to respond to an emergency if one were to occur? Do you have a plan to deal with an emergency, whether it’s a derailment or an on-board medical emergency? Also have you trained your employees, volunteers and contract staff on what they need to do, and finally have you performed simulated drills to test the plan?
The FRA developed and promulgated 49 CFR PART 239—PASSENGER TRAIN EMERGENCY PREPAREDNESS with these things in mind. The purpose and scope of this regulation as defined by the FRA is addressed in §239.1:
- The purpose of this part is to reduce the magnitude and severity of casualties in railroad operations by ensuring that railroads involved in passenger train operations can effectively and efficiently manage passenger train emergencies.
- This part prescribes minimum Federal safety standards for the preparation, adoption, and implementation of emergency preparedness plans by railroads connected with the operation of passenger trains, and requires each affected railroad to instruct its employees on the provisions of its plan. This part does not restrict railroads from adopting and enforcing additional or more stringent requirements not inconsistent with this part.
The regulation clearly states this does not apply to tourist, scenic, historic, or excursion operations, whether on or off the general railroad system (49 CFR 239.3 (b) (3)). But if you look at what the regulation is trying to accomplish, isn’t this something that we should do?
Another question I’ve been asked frequently is why should we do this? The answer again is a simple one, developing an Emergency Preparedness Plan is a PROACTIVE approach to safety!! When an emergency occurs is the wrong time to try and figure who does what. General Dwight David Eisenhower, Commander in Chief, Allied Forces, Europe once said “The Plan is nothing, planning is everything.”
Let’s talk about what goes into Emergency Preparedness Planning. In the development of an emergency preparedness plan some things that need to be considered include:
-Coordination with Outside Agencies
The plan needs to address the assignments and responsibilities of employees during an emergency and how coordination will occur with first responders. Employee must be trained in emergency preparedness and provided an overview of how the plan will be tested in emergency simulations.
Before we dig into what is involved in drafting an Emergency Preparedness Plan, I want to provide you with some definitions that are typical associated with these plans:
|Crewmember:||Means a person, other than a passenger, who is assigned to perform on-board functions connected with the movement of the train (i.e., an employee of a railroad, or of a contractor to a railroad, who is assigned to perform service subject to the Federal hours of service laws during a tour of duty)|
|Emergency:||A situation which is life threatening to passengers, employees, or other interested citizens or which causes damage to any railroad vehicle or facility and reduces the ability of the system to fulfill its mission.|
|A uniform basis for operating policies and procedures for mobilizing railroad and other public safety resources to assure rapid, controlled, and predictable responses to various types of emergencies.|
|Emergency or emergency
|Means an unexpected event related to the operation of passenger train service involving a significant threat to the safety or health of one or more persons requiring immediate action, including:
(1) A derailment,
(2) A fatality at a grade crossing,
(3) A passenger or employee fatality, or a serious illness or injury to one or more passengers or crewmembers requiring admission to a hospital,
(4) An evacuation of a passenger train, and
(5) A security situation (e.g., a bomb threat).
|Emergency preparedness plan:||Means one or more documents focusing on preparedness and response in dealing with a passenger train emergency.|
|Fatality:||A death that occurs within 30 days of the incident.|
|Injury:||Any physical damage or harm to a person that requires immediate medical attention and hospitalization.|
|Safety:||Freedom from unintentional danger.|
|Security:||Freedom from intentional danger|
|System:||A composite of people (employees, volunteers, passengers, others), property (facilities and equipment), environment (physical, social, institutional), and procedures (standard operating, emergency operating, and training) which are integrated to perform a specific operational function in a specific environment.|
|Any condition or act that endangers life or property.|
The steps involved in Emergency Preparedness include:
1) Development of the Emergency Preparedness Plan. Information on drafting a plan has been compiled by several federal agencies, which include, but is not limited to:
a. The Federal Railroad Administration (49 CFR Part 239),
b. The Federal Transit Administration (FTA),
c. The National Transit Institute (NTI),
d. The Federal Emergency Management Agency (FEMA), and
e. The Occupational Health and Safety Administration (OSHA).
2) When developing your plan, the following areas need to be considered and included:
a. An overview of your system, to include a description of all facilities, all equipment, and a detailed description of the system trackage. When describing the system trackage be sure identify locations that are hard to access.
b. Develop a list of potential types of emergencies, as described previously, and their potential solutions.
c. Identify all jurisdictions you operate through, identifying the first responders for each.
d. Describe the responsibilities of each class of employees, i.e.: train crews, maintenance crews, managers, etc.
e. Describe the training required for each class of employees. (More on this below.)
f. Describe how and when emergency preparedness drills will be conducted to test the plan. (More on this below.)
3) Training – No plan is complete until all responsibilities have been identified, and the necessary training has been provided. This training should include what the plan is, an overview of what the plan is for, and the activities employees will be required to perform. Additionally, the training should include the following:
a. Equipment familiarization
b. Situational awareness
c. Passenger evacuation
d. Coordination of functions with internal departments/stakeholders and first responders
e. ‘‘Hands-on’’ instruction concerning the location, function, and operation of on-board emergency equipment.
4) Finally, the plan needs to be tested.
There are three different ways in which a plan can be tested, and these include:
- First responder familiarization – Before any emergency preparedness exercises are conducted, first responders should be given equipment familiarization training. This training provides them with an overview of your basic operations, your facilities and how to access to the equipment in the event of an emergency.
- Tabletop Exercises – This is a facilitated emergency exercise, which is conducted in a stress-free environment. The purpose of this type of drill is to review and identify where the plan needs to be improved and updated through discussions related to emergencies.
- Full Scale Emergency Exercises – As the name implies, this type of drill is conducted to be as real as possible with first responders actually responding to a simulated emergency as though it was a real emergency.
Each of these drills should be designed to grow in depth and build on the exercise before it. At the end of the day, all these exercises have one thing in common – To help you find out if the plan works, find its weakness and where improvements need to be made in the plan.
Emergency Preparedness drills cannot be conducted in a vacuum, they must include your local first responders and other external agencies as required, possibly the County Office of Emergency Management. If you operate through multiple jurisdictions, then you need to have representatives from each of the various jurisdictions participating. Conducting Emergency Preparedness drills provides numerous benefits, which include:
- Getting the railroad and the first responders acquainted with each other before an emergency occurs
- Knowing each other’s capabilities
- Understanding the responsibilities of each organization
- Providing first responders with an understand of your operation, system, and equipment
- Helps determine what works and what does not work in your Emergency Preparedness Plan and how to improve it.
These plans are living documents. The process does not end with just writing the plan, things are consistently changing, and it is important to make sure that the plans are kept up to date. This is a form of continual improvement. Once the plan is written, it’s time to train the employees, then test the plan through emergency preparedness drills. Identify the plans weakness and areas where the plan can be improved upon, and finally update the plan and start the process over again.
Are you ready and prepared to deal with an emergency if one should occur? More importantly are your staff, employees and volunteers ready? Will they know what to do and what they are expected to do? If you haven’t already done so, now is the time to prepare for an emergency! Now is the time to develop your Emergency Preparedness Plan.
I hope this has been beneficial for you. Remember – Safety does not occur by Accident! I would love to hear from you and hear your thoughts. I can be reached at David.Morgan@DDMSafety.com.