Safety Management Systems: an additional layer of safety

What is an SMS?

A safety management system (SMS) is a documented framework for integrating safety into day-to-day company operations. A safety management system generally includes several elements such as a safety policy, safety targets, a risk assessment process and monitoring procedures.

An SMS are important because they provide a proactive approach to identifying safety risks and to taking action to eliminate or mitigate those risks in order to prevent accidents and other dangerous situations. Once fully integrated in an organization, an SMS becomes part of the culture and the way people do their jobs.

An SMS is not self-regulation. It does not eliminate or replace any other regulatory requirements. Rather, it increases safety by having companies put formal processes in place to proactively identify and address safety concerns before Transport Canada's intervention, and before concerns become major safety issues.

New regulations for SMS

The Railway Safety Management System Regulations, 2015, which came into effect on April 1, 2015, provide a framework for companies to integrate safety into their day-to-day railway operations. They build on 12 years of lessons learned in providing regulatory oversight of safety management systems in the rail industry.

The Regulations establish the minimum SMS requirements a company must develop and implement for the purpose of achieving the highest level of safety in its railway operations. The scope of application of the Regulations is divided into three categories of companies (ie., railway companies; local railway companies on main track; and local railway companies on non-main track) with a corresponding list of processes they must develop and implement:

Railway companies:

Under the Regulations, federal railway companies must develop and implement a safety management system, create an index of all required processes, keep records, notify the Minister of proposed changes to their operations, and file safety management system documentation with the Minister when requested.

More specifically, federal railway companies must develop and implement a safety management system that includes 12 processes:

  1. Process for accountability: To designate an executive who is responsible for the operations and activities of the company to be accountable for the extent to which the company meets regulatory requirements for SMS, including the effectiveness in achieving the highest level of safety in its railway operations.
  2. Process with respect to a safety policy: To create a policy that reflects the company's commitment to promoting railway safety.
  3. Process for ensuring compliance with regulations, rules and other instruments: To provide a framework for identifying legal obligations, monitoring changes to them, and verifying compliance with them.
  4. Process for managing railway occurrences: To establish procedures for reporting and reviewing railway occurrences.
  5. Process for identifying safety concerns: To conduct analyses to identify safety concerns, including trends or repetitive situations.
  6. Risk assessment Process: To conduct risk assessments to identify risks and required remedial action.
  7. Process for implementing and evaluating remedial action: To ensure that the remedial action for treating an identified risk is implemented and that the effectiveness of the action be evaluated.
  8. Process for establishing targets and developing initiatives: To establish targets and develop related initiatives to achieve those targets each calendar year.
  9. Process for reporting contraventions and safety hazards: To provide a framework for employees to report contraventions and safety hazards without fear of reprisal for having reported.
  10. Process for managing knowledge: To ensure that employees and non-employees have the knowledge they need, and that employees have the skills and qualifications they need, to carry out their duties or activities safety.
  11. Process with respect to scheduling: To apply the principles of fatigue science when scheduling the work of the employees who work certain schedules.
  12. Process for continual improvement of the SMS: To conduct internal monitoring and audit activities to monitor and evaluate the implementation and effectiveness of the SMS.

Local railway companies:

Under the Regulations, local railway companies must develop and implement a safety management system, create an index of all required processes, keep records, notify the Minister of proposed changes to their operations, and file safety management system documentation with the Minister when requested.

Local railway companies that operate on main track must have an SM that includes processes for:

  • Accountability;
  • A safety policy;
  • Ensuring compliance with regulations, rules and other instruments;
  • Identifying safety concerns;
  • Risk assessment;
  • Implementing and evaluating remedial action;
  • Establishing targets and developing initiatives; and
  • Continual improvement of the Safety Management System.

Local railway companies that operate on non-main track must have an SMS that includes processes for:

  • A safety policy;
  • Ensuring compliance with regulations, rules and other instruments;
  • Identifying safety concerns;
  • Risk assessment; and
  • Implementing and evaluating remedial action.

The full requirements for all companies are detailed in the Railway Safety Management System Regulations, 2015.

Audits and enforcement

Transport Canada has a responsibility to oversee the SMS regulations through comprehensive audits.

We do these on a 3 to 5 year cycle, or more frequently if needed. For some railway companies, we may conduct a comprehensive audit over multiple years, with several processes audited each year.

During an audit, a safety system oversight inspector may find a non-compliance. If this happens the railway company must respond with a corrective action plan. The plan identifies actions the company will take to correct the non-compliance, the person responsible for each action and when the company will correct the situation. The inspector verifies whether or not the company completes the actions as planned.

Failing to comply with the findings of an SMS audit is a serious matter. Remedies available to Transport Canada include:

  • administrative monetary penalties
  • prosecution
  • cancelling the railway company’s operating certificate

If Transport Canada finds that the SMS is deficient in a way that could risk railway safety, we may also issue a Ministerial Order under the Railway Safety Act to compel a railway company to take a specific corrective action.

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