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