Part G – Documentation, Records and Audit of BSMP
6.1 - Scope
Each railway authority’s BSMP should provide for the verification of the effectiveness of the program and the accuracy of the resulting information, including the validity of bridge inspection reports and bridge inventory data, and the correct application of movement restrictions to railway equipment of exceptional weight or configuration.
6.2 – Audits, General
A railway company shall18 implement and maintain procedures for periodic internal safety audits, reviews by management, monitoring and evaluations of it's BSMP to determine whether it:
- Meets the requirements of this guideline;
- Has been properly implemented and maintained; and
- Is effective in continually reducing the risk associated with bridges.
Section Analysis 6.2 - Audits, General
From the "Railway Safety Management System Guide February 2001" (TP13548):
Part J) Safety Audit and Evaluation
2. (j) procedures for periodic internal safety audits, reviews by management, monitoring and evaluations of the safety management system;
Safety audits and evaluations of the Safety Management System are important mechanisms for ensuring that all of the organizational elements, functions and procedures in the Safety Management System are working well. Internal audits and evaluations are one of the key feedback loops for identifying required changes to the system.
The Safety Management System should include
- periodic audits of the performance of the components of the organization’s Safety Management System, including audit frequencies, methodologies, responsibilities and reporting processes;
- audits by suitably qualified personnel who are impartial and objective;
- use of recognized audit methodologies that include validation through interviews, random spot checks, etc.;
- audit reports that include recommendations for corrective action;
- reporting of audit results to senior management;
- retention of audit reports for review by Transport Canada;
- periodic evaluations of the Safety Management System to ensure the continued suitability, adequacy and effectiveness of the policy, annual safety targets, procedures and other components of the System, taking into account changing circumstances and the results of compliance evaluations, risk assessments, accident/incident investigations, safety performance analyses and audits;
- feedback gathered from employees and other relevant stakeholders; and
- consideration and approval of evaluation reports as well as the resulting recommendations by senior management.
Audit and evaluation frequencies are expected to vary depending on the size and complexity of the railway, the risks involved, and the railway’s safety performance history.
6.3 - Audits of Inspections
- Each railway authority's BSMP should incorporate provisions for an internal audit to determine whether the inspection provisions of the program are being followed, and whether the program itself is effectively providing for the continued safety of the subject bridges.
- The inspection audit should include an evaluation of a representative sampling of bridge inspection reports at the bridges noted on the reports to determine whether the reports accurately describe the conditions of the bridge.
Section Analysis 6.3 - Audits of Inspections
One of the most important indicators of the effectiveness of a BSMP is a comparison of recent bridge inspection reports against actual conditions found at the subject bridges. It is therefore important that the Railway Bridge Engineer, who evaluates the condition of the bridge based on the inspection report that he receives from the Railway Bridge Inspector, carry out an internal audit on his own on a yearly basis. This is fundamental to an effective audit of a BSMP. Therefore, in this section, it is proposed that each BSMP incorporate provisions for an internal audit to determine whether the inspection provisions of the BSMP are being followed, and whether the BSMP itself is effectively providing for the continued safety of the subject bridges. Additionally, the inspection audit should include an evaluation of a representative sampling of bridge inspection reports at the bridges noted on the reports to determine whether the reports accurately describe the condition of the bridge.
6.4 - Documents and Records
Each railway authority should document their BSMP and keep records under this part. The BSMP documents and records shall19 be made available to Transport Canada’s Rail Safety Inspector, in Canada, upon request, as soon as reasonably practicable.
The railway authority should retain, where possible, pertinent drawings for as long as they are responsible for or own the bridge and inspection records as per Section 4.8 of this guideline.
When maintenance responsibilities for track and bridges are assigned to another railway company, it should be assigned or given access to pertinent bridge documents and drawings.
Section Analysis 6.4 - Documents and Records
Each railway authority should keep records (standards, procedures, drawings, inspection reports, evaluations, ratings, etc.) under this part and make those documents and records available for inspection and reproduction upon request as per section 28 of the Railway Safety Act. Access to the documents and records of the Bridge Safety Management Program is required for carrying out regulatory oversight.
6.5 - Electronic Record Keeping
A railway authority should make it known to Transport Canada, upon request, whether they are maintaining paper or electronic records, or a combination thereof.
A railway authority may create and maintain any of the records required by this part through electronic transmission, storage, and retrieval provided that all the following conditions are met:
- The system used to generate the electronic record meets all requirements of this subpart;
- The electronically generated record contains the information required by this part;
- The railway authority should train its employees who use the system on the proper use of the electronic record keeping system; and
- The railway authority maintains an information technology security program adequate to ensure the integrity of the system, including the prevention of unauthorized access to the program’s logic or individual records.
(b) System security
Where applicable, the integrity of the bridge inspection records should be protected by a security system that incorporates a user identity and password, or a comparable method, to establish appropriate levels of program and record data access meeting all of the following:
- No two individuals have the same electronic identity;
- A record cannot be deleted or altered by any individual after the record is certified by the employee who created it;
Any amendment to a record is either:
- Electronically stored apart for the record that it amends, or
- Electronically attached to the record as information without changing the original record.
- Each amendment to a record uniquely identifies the person making the amendment; and
- The electronic system provides for the maintenance of inspection records as originally submitted without corruption or loss of data.
Section Analysis 6.5 - Electronic Record Keeping
(a) and (b) TC proposes minimum requirements for electronic record-keeping provisions that a railway authority may elect to utilize to comply with the record-keeping provisions of this part.
For clarity, paragraph (a) provides that a railway authority express to TC beforehand whether or not it considers its record keeping system to be electronic. This will prevent any confusion or misunderstanding when reviewing records by TC as part of its regulatory activities. If electronic record keeping is in place, the provisions of this section will apply. If not, then TC will consider the railway authority to be maintaining paper-based records, which may be generated using a computer, when carrying out its activities. It is not expected that a railway authority will be changing from paper to electronic to paper, etc.
18 Section 2(J) of Safety Management System Regulations
19 Section 28 of the Railway Safety Act
Part F – Requirements of Section 11 – Railway Safety Act
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