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December 9, 1999

Ms. Novina Wong

Clerk

City of Toronto

Toronto City Hall

100 Queen Street West

Toronto, Ontario

M5H 2N2

Dear Ms. Wong:

At its meeting on Wednesday, December 8, 1999, the Commission considered the attached report entitled, "Rail Safety Audit Report American Public Transit Association."

The Commission adopted the Recommendation contained in the above report, as listed below:

"It is recommended that the Commission:

(1) receive for information the attached Final Audit Report and Management Corrective Action Plan from the rail safety program of the American Public Transit Association (APTA).

(2) note in particular the APTA Audit Summary (attached as Appendix 1) which provides a succinct overview of the audit findings. A key finding contained in APTA's Audit Summary is:

"TTC management did accomplish a satisfactory response to APTA through all of the corrective actions to which they were committed, following the 1996 audit. The Commission now has a functioning system safety process. The building phase of the program is complete."

(3) request staff to continue participation in the Rail Safety Audit Program and arrange for on-going audits on a three year cycle, with the next audit scheduled for 2001.

(4) request staff to report progress on implementation of the Corrective Action plan on a bi-annual basis.

(5) forward a copy of this report to the Clerk of the City of Toronto for information."

The foregoing is forwarded to City of Toronto Council through the City of Toronto Planning and Transportation Committee for information.

Sincerely,

Vincent Rodo

General Secretary

1-16

Attachments

TORONTO TRANSIT COMMISSION

REPORT NO.

MEETING DATE: DECEMBER 8, 1999

SUBJECT: RAIL SAFETY AUDIT REPORT

AMERICAN PUBLIC TRANSIT ASSOCIATION

RECOMMENDATION

It is recommended that the Commission:

(1) receive for information the attached Final Audit Report and Management Corrective Action Plan from the rail safety program of the American Public Transit Association (APTA).

(2) note in particular the APTA Audit Summary (attached as Appendix 1) which provides a succinct overview of the audit findings. A key finding contained in APTA's Audit Summary is:

"TTC management did accomplish a satisfactory response to APTA through all of the corrective actions to which they were committed, following the 1996 audit. The Commission now has a functioning system safety process. The building phase of the program is complete."

(3) request staff to continue participation in the Rail Safety Audit Program and arrange for on-going audits on a three year cycle, with the next audit scheduled for 2001.

(4) request staff to report progress on implementation of the Corrective Action plan on a bi-annual basis.

(5) forward a copy of this report to the Clerk of the City of Toronto for information.

FUNDING

The cost of participation in APTA's Rail Safety Audit Program, $23.2K (US), is currently budgeted in Safety Department.

BACKGROUND

This is the third rail safety audit conducted by APTA since the TTC joined the program in 1991. The 1993 and 1996 audits helped shape both the safety program and our overall approach to maintaining the system in a state of good repair.

The central thrust of the 1996 audit was that our maintenance practices should be formally documented in order to establish quality standards for all safety critical processes. In response, the major operating departments undertook large-scale systematic programs to write Standard Operating Procedures (SOPs). These SOPs are subject to formal document control including sign-off from all affected groups such as Safety Department. The total Commission effort exceeds many person years annually to develop and maintain these procedures. Each program sets priority for development of SOPs on the basis of passenger safety. The daily safety critical maintenance and inspections for rail cars, track and structures were developed first. The focus now will shift to longer-term project work such as car overhaul, plant and equipment SOPs.

The adoption of SOPs represented the first step toward instituting a quality management approach. In the current audit, APTA focuses on steps that should be taken to continuously improve on that base.

DISCUSSION

The current audit reviewed performance against 57 elements and sub-elements and found 54 (95%) met plan requirements, as compared with 89% compliance in the 1996 APTA audit. This shows continuing improvements in overall performance. As noted above, this improvement was the result of a significant commitment of staff resources and managerial effort. To quote from the APTA Audit Summary:

"TTC's efforts, in achieving a credible degree of Program implementation in all areas of system operation, are due to the effectiveness of its management and a strong commitment to voluntarily comply with all safety recommendations."

The following table summarizes the results relative to those of the previous audit.

Progress Since 1996



# Elements/

Sub-elements



#Audited

#Meet Plan Requirements

(Suggestions)



#Need Improvement

Not Audited

1996 44 44 39 (89%) 5 (11%) 0
1998 62 57 54 (95%) 3 (5%) 5

The increased number of elements reflects changes to the APTA guidelines including the addition of 13 security sub-elements. In addition to noting which items need improvement, APTA also provides suggestions for improvement to elements that meet requirements. A listing of the elements and ratings is attached as Appendix 2.

The corrective action strategy of each of the five departments in Subway Operations, Streetcar Department and Safety and Training Departments follow APTA's Audit Summary. These statements place the specific findings into the broader context of our overall business philosophy and approach to safety.

The remainder of the report is organized into two main sections as follows.

APTA Report

1. An APTA checklist form indicates the rating of each audit element on the following four-point scale.

(1) Meets plan requirements.

(2) Meets plan requirements, with comments (See Supplemental Form)

(3) Needs improvement (See Supplemental Form).

(4) Unable to Audit (See Supplemental Form).

5. The APTA supplemental form provides details on progress since the previous audit and recommendations for future improvement.

TTC Corrective Action Plan

The TTC corrective action form details the action management is committed to take, who is accountable and an implementation schedule.

Of the sixty-two audit elements, three did not meet plan requirements at the time of the audit. TTC has moved to address these three elements as detailed below:

Element 1.5 System Safety Plan

The System Safety Plan should establish performance measures for all elements in the safety management system. The previous plan did not adequately do so. Staff have totally rewritten the Plan and have submitted a draft to APTA for review. Implementation is scheduled to begin in the first quarter of 2000.

Element 2.9 Configuration Management

Effective systems need to be established to ensure all copies of SOPs, technical drawings and specifications are kept current and accurate for all users. TTC has established clear accountabilities for Configuration Management and Document Control in the System Safety Plan. In addition, the requirement for review of all proposed changes to safety critical processes and components has been established in a new Corporate Policy Instruction entitled System Safety Reviews. Finally, the operating departments have developed SOPs on document control to ensure local practices conform.

Element 3.9 Update Fire Safety Plans

Fire safety plans exist for all TTC facilities, however, a number of them had not been reviewed recently. The TTC established a 1999 goal to review and update each of the 97 plans, confirm the fire warden system and conduct drills at all sites. While not all were updated at the time of the audit, this goal has now been achieved. Regular review of plans will be a performance measure reported in the monthly CGM report to the Commission.

The regular cycle of safety audit followed by corrective action plan facilitates the continuous improvement of management processes. As the safety management system matures, the focus shifts from the development of processes to assurance that the standards established are effective and are being uniformly applied.

In light of this, TTC management has adopted a formal protocol with APTA to refine the audit process to ensure future audits focus on two questions:

1. To what extent has management achieved their corrective actions from the previous audit?

2. To what extent has management met the performance standards set out in the System Safety Plan?

This will provide a clear focus on quality control and assurance to support our program to document standards for all safety critical maintenance and operational activities.

SUMMARY

The Rail Safety Audit program is a central element in the safety oversight process recommended in the Coroner's report into the Russell Hill accident. High standards of public safety are assured by the transparency of the audit process and by public reporting of management's progress in implementing its detailed corrective action plan.

Due to the long time frame required to implement many corrective actions, the Rail Safety Audit Program has established a three-year cycle between audits for all participants. APTA supports a three-year schedule for TTC. The words of the Audit Summary,

"In conclusion, the auditors would like to state that TTC has achieved a significant level of implementation of the System Safety Program Plan from its last audit in 1996. TTC also continues to implement recommendations identified by the 1998 safety audit as evidenced and stated in their Corrective Action Plans in this Report."

- - - - - - - - - - - -

December 8, 1999

13.3

Attachments:

1. Appendix 1 - Audit Summary

2. Appendix 2 - Listing of Elements & Sub-Elements with Rating

3. Final Audit Report for the Toronto Transit Commission, October 14-30, 1998, Rail Safety Audit Program, American Public Transit Association.

4. Protocol: Rail Safety Audit Program

Appendix 2

Listing of Elements & Sub-Elements With Rating

ITEM DESCRIPTION 1 2 3 4
1.1 System Safety Program Plan approved by CGM X
1.2 System Safety Program Goals and Objectives X
1.3 Document Compliance with Prescribed TTC Policies X
1.4 TTC System Safety Policy clearly stated and disseminated X
1.5 Plans/Programs in place to attain safety program Goals, Objectives & Policies X
1.6 Procedures established to modify/revise the TTC System Safety Program Plan X
2.1 Document System Modification Review and Approval Process X
2.2 Document Transit Control Center's Coordination X
2.3 Document Emergency Response Planning, Coordination and Training X
2.4 System Safety Program Plan distributed and Implemented throughout System X
2.5 Document Streetcar Surface Transportation X
2.6 Document Streetcar/Light Rail Fleet Inspection and Repair Process X
2.7 Understanding of mngt's role & responsibilities of System Safety throughout TTC X
2.8 Document Subway/SRT Fleet Inspections/Repair process X
2.9 Review configuration management process for operational equipment and facilities X
2.10 Document TCC's coordination of inspection and maintenance scheduling programs X
2.11 Document Control & Configuration Management established X
2.12 Document Streetcar Department Surface Track Maintenance X
2.13 Document Service Planning Department X
2.14 Document Legal and Claims Departments X
2.15 Marketing and Public Affairs X
3.1 Document Review Process and Implementation of Emergency Procedures X
3.2 Document Accident/Incident Investigation Activities X
3.3 Responsibility for Administration of the System Safety Program Plan established X
3.4 Authority of the Safety Department Established X
3.5 Safety's Responsibilities, functions, & authority recognized by other departments X
3.6 Review process established to Identify, Analyze, and Resolve Hazards X
3.7 Review Development of Safety Awareness programs X
3.8 Document Compliance with Prescribed Employee Safety Programs X
3.9 Document Fire Protection and Prevention Systems Inspections and Maintenance X
3.10 Review Safety Data Acquisition, Analysis, and Reporting X


ITEM DESCRIPTION 1 2 3 4
3.11 Document Periodic System Safety Tests and Inspections X
4.1 Document Safety's Participation in TTC Committees Task Forces and Processes X
4.2 Document Interface with Outside Agencies X
4.3 Document Surface Vehicle Engineering Department process X
4.4 Document Internal Audits X
4.5 Document Coordination of Interdepartmental Safety-Related Activities X
4.6 Document Station Maintenance Activities X
4.7 Review Procurement Process/Safety Interface Specifications X
4.8 Document Operational Training X
4.9 Document Shop/Carhouse Equipment X
4.10 Document Subway Operations Inspection/Repair Processes X
4.11 Document Maintenance Training X
4.12 Document Safety Training and Programs X
4.13 Document Quality Assurance Process X
5.1 Document Internal Safety Section's Audit process X
6.1 Document Review Process and Implementation of Operating Rules X
6.2 SSP's involvement Design/Construction of systems, extensions, equip. & facilities X
6.3 Document Drug and Alcohol Abuse Program X
7.1 Security Plan Established X
7.2 Safety awareness/education programs for passenger and employees X
7.3 Security task force established X
7.4 System security goals/responsibilities and SOPs established X
7.5 Security equip. inspected/mntd. Including personal equip. for security personnel X
7.6 Track safety/trespasser program established X
7.7 Contingency SOPs developed for extraordinary circumstances X
7.8 Interface of external agencies, state/local police & federal agencies with jurisdiction X
7.9 Coord. with eng. for facilities construction/redesign & for security enhancement proj X
7.10 Transportation Coordination with Security X
7.11 Security Reports, X
7.12 Security SOPs reviewed regularly and updates made as needed to security plan X
7.13 Training for Employees X


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