The role and value-adding model of Transport Canada / Rail Safety in technology-based innovation
- As part of the 2017-18 Railway Safety Act Review
Prepared by: John Coleman
This paper was commissioned to assist the 2017-18 Railway Safety Act Review (Review)in assessing the regulatory framework enabling the deployment of safety-enhancing technology, and its pace of acceptance. It is the product of:
- desk research;
- an analysis of Review submissions;
- a technology workshop;
- personal experience; and
- interviews with Transport Canada, industry representatives (e.g., railways, technology suppliers), and researchers.
Two main purposes are identified (leading to three recommendations): industry and Rail Safety’s role in the safe, timely and efficient advancement of research and technology; and a value-adding model to help Rail Safety assume such a role.
This paper covers six parts:
- Technology innovation principles, and rail sector progress;
- The theoretical framework for understanding how technology reduces failure probability;
- Rail technology case histories and the regulatory framework’s effect on adoption;
- Reasons for railways’ exasperation with perceived regulatory impediments;
- Technology’s future, and how railways will perceive it; and
- A role and value-adding model for Rail Safety.
- Scientific discovery launches technological innovation, which matures through a sequence of “Technology Readiness Levels”. Regulatory impediments prevent maturation by adding delays to adoption and dis-incenting developers from pursuing progress. Railway accident reductions of the past two decades are mainly attributable to the railways’ ability to work outside the regulatory framework to evaluate physical asset performance and detect its impending failure. Of 24 technologies sampled, over 80 percent (by number) are not recognized within the existing regulatory framework. When technology can monitor safety beyond regulatory requirements, railways experience limited success petitioning government for updated regulations. Today, railways argue that regulatory stasis impedes safety-enhancing technologies, as no regulatory framework changes since 2010 appear to have accelerated their adoption.
- Without defining their meaning or setting numerical targets, the Railway Safety Act (Act) uses the terms “safe” and “safety” and speaks vaguely about achieving “the highest levels of safety”. To address this vagueness, regulations de-construct the end-state—“be safe” into subordinate indicators (proxies). Technology’s role is to make safety proxies actionable, although railway critics will argue that dispensations sought from existing methods (proxies) are motivated solely by economic savings. After all, the regulator does not prevent railways from using new technologies. It just superimposes existing methods.
- Eight presented case histories illustrate the variety of situations where technologies get adopted, delayed, or dis-incented. In most cases, the baseline technology is nominally 10 to 20 years old, although refinements continue to be made.
- When the regulator superimposes existing methods over technology-enabled ones, the disproportionate cost increases in return for limited incremental safety benefits exasperate railways. Although not preventing safety improvements, superimposing methods by the regulator could infer dissatisfaction with the progress offered by railways for a proposed technology-upgrade.
- The future lies with railways maintaining declining accident rates, and the regulator providing public assurance that governance mechanisms equally address the public and railways’ safety expectations. While most recent innovations in rail safety technologies have come from the high-tech sector, future progress will likely draw from fields such as mathematics, data analytics, and obsolescence management. Additionally, cyber-security technology will shift safety management priorities from mechanical to communications-network robustness. As industry adapts to changing technology, so too must the regulatory framework.
- Challenging new technology and demonstrating to public satisfaction that the system is safe, are the value-added to the regulator’s traditional role of conducting on-site inspections and audits. To be effective, this role should cover six areas:
- pursuing actionable higher-level proxies;
- establishing safety equivalence criteria;
- championing experiments and pilot projects;
- adjudicating technology for regulatory acceptance;
- sponsoring technology initiatives; and
- updating rules and regulations.
In conclusion, Rail Safety’s cultural characteristics and core capabilities need to emphasize science and technology for more rapid adoption of rail safety-enabling technologies to occur. Rail Safety needs to shift from a predominantly “Guardian” value system to a “Trader” one to avoid a footprint of shrinking relevance. Three recommendations are made to achieve this shift:
- Establish quantitative safety targets in the Act (i.e., percentage-reductions, or maximum-allowable failure rates);
- Build Rail Safety’s organizational culture and core capabilities in science and technology; and
- Create a research and experimentation-friendly framework.