1. System Safety Regulation
Initial Overview
System Safety/ RRP
Implementation Team

2. New(different?) Approach to Safety
System Safety Program (SSP)/Risk Reduction Program (RRP), are not prescriptive and are different from traditional safety strategies which rely on results from and investigation of past accidents/incidents.
Proactive
Systematic
Actively promoting continuous safety improvement
Directly affecting safety culture
System Safety/Rick Reduction strategies are designed to be proactive by identifying hazards before accidents or incidents occur, ensure programs and procedures are in place and focus on organizational management, implementation and promotion of safety culture

3. Application (SSP) SSP (Part 270) applies to:
Railroads that operate intercity or commuter passenger train service
Railroads that provide commuter or other short-haul rail passenger train
Public authorities operating passenger train service

4. Application (RRP)
RRP (Part 271) applies to:
Class 1 Railroads
Class II and III Railroads determined by FRA to have inadequate safety performance
Railroads that voluntarily comply
Includes railroads that are part of the general railroad system of transportation

5. 49 CFR PART 270 System Safety Program
Requires commuter and intercity passenger railroads (passenger railroads) to develop and implement a system safety program (SSP).

6. Promotes Safety Culture
SSP encourages a railroad and its employees to work together to proactively identify hazards and to jointly determine what, if any, action to take to mitigate or eliminate the resulting risks.

7. Flexible
The rule provides each railroad with a certain amount of flexibility to tailor its SSP to its specific operations.

8. So What is System Safety?

9. System Safety
The application of management and engineering principles, and techniques to optimize all aspects of safety, within the constraints of operational effectiveness, time, and cost, throughout all phases of a system life cycle

10. System Safety Program
Represents the railroad’s safety philosophy and cultivates a robust safety culture from the most senior officer throughout all levels of the organization.

11. System Safety Program Plan
A system safety program is adopted and implemented through a written system safety program plan.
Plan is not required to be submitted until February 8, 2018
Full implementation is required 36 months after approval of plan by FRA

12. System Safety Plan
As part of its SSP plan, a railroad will also be required to describe the various procedures, processes, and programs it has in place that support the goals of the SSP.

13. FRA System Safety Program Plan Contents (Elements) Final Rule Part 270
Program Policy Statement
Program Goals
Railroad System Description
Railroad Management and Organizational Structure
Program Implementation Process
Maintenance, Repair & Inspection Program
Rules Compliance & Procedures Review
Employee/Contractor Training
Emergency Management
Workplace Safety
Public Safety Outreach
Accident/Incident Reporting & Investigation
Safety Data Acquisition
Contract Procurement Requirements
Risk-Based Hazard Management
Risk-Based Hazard Analysis
Technology Analysis & Implementation Plan
Safety Assurance
Change Management
Configuration Management
Safety Certification
Safety Culture

14. 49 CFR 270 SSP Key Dates August 12, 2016
Final Rule Published
August 12, 2016
Rule Effective – October 11, 2016
Preliminary Meeting with Employees/ Labor
No later than April 10, 2017
Notice sent to employees/labor no less than 60 days before meeting
Railroads with contractor employees are to be included
Submittal of System Safety Program Plan
No later than February 8, 2018
Full SSP Implementation
3 Years After FRA Approval of SSP (2020 – 2022)

15. So What is FRA doing to Roll Out this Regulation
Implementation Guide
Sample SSP plans
Process for electronic plan submittal
Consistent process for FRA reviewing plans
Internal Audit process review
External Audits (Focused and Full)

16. What are we doing? Guidance Documents Conduct internal training
Conduct external outreach
Hire Staff
Process for Reviews and Audits

17. Proposed Training Training
FRA headquarters
Principles of System Safety for Executives e-Learning (1-2 hour virtual live training)
High level Senior Managers
Headquarters & Regional RAs and DRAs
Principle of System Safety and Management of Safety for FRA HQ Staff (1 day Instructor-Led Training)
Staff Directors
FRA System Safety - (4-5 day Instructor-Led Training)
Managers and Contractors Responsible for Implementation
Passenger Rail Regional Staff
Rank and File including FRA and Railroad (Safety) Personnel
Available to appropriate FRA Regional Staff
Short-Term Technical Assistance Guidance (Training) to Railroads

18. Federal Railroad Administration System Safety Implementation Guide
This basic guide outlines what is required in a system safety program plan (“plan”) to assist railroads in developing their plans
is intended to be a tool
in conjunction with the two examples of SSP plans

19. Audit Processes Internal Audit process review
External Audits (Focused and Full)

20. Internal System Safety Program Assessment
Railroads annually measure how well they are implementing and complying with their System Safety and Risk Reduction program and plan
Identify areas in need of improvement
Recommend corrective actions
Measure the effectiveness of achieving program goals
Annually submit internal assessment report to FRA

21. External Audits External safety audit
FRA conduct external audits of a railroad’s system safety and risk reduction program.
Evaluate the railroad’s compliance with the elements of railroad’s approved SSP/RRP plan.
FRA shall provide the railroad written notification of the results of any audit.
Follow-up on corrective action.

22. FRA SSP Team Any questions contact: Daniel Knote Robert Adduci
Robert Adduci
Larry Day
Michael Ramsey

23. Questions?