Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur l'acces a l'information Lui, Rachel From: Hart, Beata Sent: Friday, April 24, 2015 1:57 PM To: Miller, Mark; Conrad, Mark; Lui, Rachel Cc: Raitt, Blair Subject: ARC CP audit review Attachments: Hello, I am contacting you as a member of the audit review committee for the CP Fatigue management national audit. The draft ofthe audit report is now ready for you input. Audit procedure specifies a seven working days timeframe for this review, which would brings us to Monday, May 4th. Please let me know if this is not feasible and if additional time is needed. I will ensure to adjust the schedule accordingly and obtain the necessary approval. Based on the comments received and their complexity, a meeting (conference call) might be required to address your concerns. This will be determined once all comments are received. If, after your review, you would like a meeting nonetheless, please let me know and I will ensure to arrange one. Below, I included the excerpt from the audit procedure that outlines responsibilities ofthe review committee, I hope you?ll find it helpful. if you have any questions please do not hesitate to contact me. Best Regards, Beata Audit Procedure The ARC is responsible for the following: Audit Review Committee (ARC) - Reviews the audit details and provides comments as appropriate; 0 Reviews the audit report and provides feedback regarding the following: supporting evidence (in regards to the findings); additional technical advice (when applicable); format; readability; consistency; and clarity in wording 000001 Record released pursuant to the Access to Information Act/ s.20(1 Document divulgue en vertu de la oi sur l'acces a l'information Audit Report 521 (1 Railway: CP Rail Railway SMS Keith Shearer Representative: GM Regulatory Operating Practices Audit Dates: January 5, 2015 to March 6, 2015 Convening Authority: Stephanie Lines, Director, Operations Management Audit Team Leader: Beata Hart, Safety Oversight and Audit Of?cer Report date: 2015 Executive Summary An audit of the CP Rail (CPR) fatigue management plans (FMP), considering Safety Management System Regulations (SMS), Transport Canada Work Rest Rules for Railway Operating Employees (WRR) and Fatigue Management Plans, Requirements and Assessment Guidelines? was conducted by Transport Canada (TC) from January 5, 2015 to March 6, 2015. The objective of the audit was to evaluate and verify implementation of the Fatigue Management Plan, as required by the WRR, and as defined by CP and submitted to Transport Canada. This was accomplished through a systematic, detailed assessment of railway company FMP to ensure compliance to the WRR as well as their implementation as defined by the Railway. This assessment was carried out through record reviews, observations and interviews with personnel. The initial audit noti?cation and the documentation request were sent to CPR on November 28, 2014. The on?site auditing activities began on January 5, 2015 and the opening meeting was held at corporate of?ces in Calgary. During that meeting, the audit team con?rmed the scope of the audit and the proposed schedule. The audit team then proceeded to review the records provided and interviewed selected members of the management team. Subsequently, TC visited CP corporate offices the week of January 26m and on March 6 to further verify records and to interview personnel. Regional verification activities took place the week of January 19 (Vancouver) and March 3 (Calgary, Toronto and Vancouver). The purpose of these visits were to interview local Management and Operating employees to verify implementation of the FMP. TC recognizes the special circumstances that developed due to the work stoppage caused by the union strike activity the week of February 16. The auditing activities scheduled for that week were postponed and the audit commenced the week of March 2, 2015. A closing meeting summarizing the audit activities was conducted as part of the wrap-up meeting on March 5 at the Calgary Alyth facility. Next steps were presented but, due to audit activities still being performed at other facilities at the same time, no potential ?ndings were communicated. The audit team reviewed the following policies, processes and procedures, which were provided by CPR: 0 General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 2011); 0 Work/rest Rules for Railway Operating Employees, as published by the Railway Association of Canada and provided by CPR (February 2011); 0 Speci?c Fatigue Management Plan, Emergency Situations (March 17, 2003); 0 Specific Fatigue Management Plan, 64 hours in 7 days (March 17, 2003); Page 1 of 15 000002 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information 0 Speci?c Fatigue Management Plan, Work Train Service over 12 hours (March 17, 2003), and; 0 RAC Work/Rest Rules, Interpretation Document (Effective June 29, 2005) Details are provided in the Findings section of this report. Detailed descriptions of those ?ndings are provided in the Findings section of this report. The Railway is encouraged to demonstrate how they intend to enhance railway safety by providing a corrective action plan to each of ?ndings of de?ciency, within 30 days of the issues of this audit report. The Corrective Action Plan should reference the Transport Canada audit ?ndings and detail the Railway?s proposed corrective actions to address them. Each corrective action should describe activities to be completed, identify personnel responsible, and outline timelines for implementation. An example Corrective Action Plan template is attached to this report and it may be used. Introduction Pursuant to the Railway Safety Act, Transport Canada has conducted a systematic, detailed assessment of railway company policies, processes and procedures to evaluate them against the documentation requirements of the RSMS Regulations; and verify the implementation and effectiveness of said policies, processes and procedures. Audit Scope The scope of this audit was to verify the implementation of the Fatigue Management Plans as de?ned by CP, considering the requirements of ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans, Requirements and Assessment Guidelines?. The following components of the Safety Management Systems Regulations were also applicable: 2(b) Safety authorities, responsibilities and accountabilities; 2(d) Compliance with applicable regulations, rules, standards and orders; 2(e) Risk management process; 2(h) Skills, training and supervision, and; 2(i) Collection and analysis of safety performance data (since fatigue is safety?related) All records providing evidence of compliance with the above processes and all policies processes and procedures developed in support of fatigue management, dating back to January 2010 to present. Other Issues Page2 of 15 000003 Page 3 of 15 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information 000004 20(1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Audit Findings 5.21 (1 771571 A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable: railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and; (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions specified in the notice of exemption Page 4 of 15 000005 20 1 7 Record released pursuant to the Access to Information Act/ 5' Document ?divulgue en vertu de la oi sur I'acces a I'information 771601 A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and; (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; Page 5 of 15 000006 20 1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information 771765 203) A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(b) clear authorities, responsibilities and accountabilities for safety at all levels in the railway company General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 2011) 55 55 Page 6 of 15 000007 5 20(1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information 5.21 (1 Page? of 15 000008 Record released pursuant to the Access to Information Act/ s.20(1 Document divulgue en vertu de la oi sur I'acces a I'information 771781 A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component; 2(h) systems for ensuring that employees and any other persons to whom the railway company grants access to its property, have appropriate skills and training and adequate supervision to ensure that they comply with all safety requirements; General Fatigue Management Plan for Canadian Pacific and the Teamsters Canada Rail Conference Operating Employees (November 2011), Page8 of 15 000009 5 20(1 Record released pursuant to the Access to Information Act/ - Document divulgue en vertu de la oi sur I'acces a I'information .. 771786 A railway company shall implement and maintain a safety management system that includes, at a mimmum, the following component: 2(d) systems for identifying applicable: railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and; (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions specified in the notice of exemption. General Fatigue Management he Teamsters Canada Rail Conference Operating Employees (November 2011), .?s?c?r?iptio as indi" Page 9 of 15 000010 Record released pursuant to the Access to Information Act/ 5-20? Document divulgue en vertu de la oi sur I'aoces a I'information Page100f15 000011 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page11of15 000012 Record released pursuant to the Access to Information Act/ 5'20? Document divulgue en vertu de la oi sur I'acces a I'information 771831 2(i) A railway company shall implement and malntam a safety management system that includes, at a minimum, the following component: 2(i) procedures for the collection and analysis of data for assessing the safety performance of the railway company. Genet 31 Fatigue Management Employees (November 2011) Page120f15 000013 Record released pursuant to the Access to Information Act/ 5-20? Document divulgue en vertu de la oi sur I'aoces a I'information Page130f15 000014 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page 14 of 15 000015 Record released pursuant to the Access to Information Act/ . . . . Document dlvulgue en vertu de la sur Iacces a IInformatIon 771875 A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them; and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption. Page150f15 000016 Record released pursuant to the Access to Information Act/ 520? Document divulgue en vertu de la oi sur I'acces a I'information Sm?) Audit Report 521 (1 Railway: CP Rail Railway SMS Keith Shearer Representative: GM Regulatory Operating Practices Audit Dates: January 5, 2015 to March 6, 2015 Convening Authority: Stephanie Lines, Director, Operations Management Audit Team Leader: Beata Hart, Safety Oversight and Audit Of?cer Report date: 2015 Executive Summary An audit of the CP Rail (CP) fatigue management plans (FMP), considering ?Safety Management System Regulations? (SMS), ?Transport Canada Work Rest Rules for Railway Operating Employees? (WRR) and ?Fatigue Management Plans, Requirements and Assessment Guidelines? was conducted by Transport Canada (TC) from January 5, 2015 to March 6, 2015. The objective of the audit was to evaluate and verify implementation of the fatigue management plans, as required by the WRR, and as de?ned by CP and submitted to Transport Canada. This was accomplished through a systematic, detailed assessment of railway company MP to ensure compliance to the WRR as well as their implementation as de?ned by the Railway. This assessment was carried out through record reviews, observations and interviews with personnel. The initial a dit not'f ti th The on?site auditing activities began on January 5, 2015 and the opening meeting was held at corporate of?ces in Calgary. During that meeting, the audit team con?rmed the scope of the audit and the proposed schedule. The audit team then proceeded to review the records provided and interviewed selected members of the management team. Subsequently, TC visited CP corporate of?ces the week of January 26th and on March 6 to ?irther verify records and to interview personnel. Regional veri?cation activities took place the week of January 19 (Vancouver) and March 3 (Calgary, Toronto and Vancouver). The purpose of these visits were to interview local Management and Operating employees to verify implementation of the FMP. TC recognizes the speciai circumstances that developed due to the work stoppage caused by the union strike activity the week of February 16. The auditing activities scheduled for that week were postponed and the audit commenced the week of March 2, 2015. A closing meeting summarizing the audit activities was conducted as part of the wrap-up meeting on March 5 at the Calgary Alyth facility. Next steps were presented but, due to audit activities still being performed at other facilities at the same time, no potential ?ndings were communicated. Page 1 of 16 000017 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information The audit team reviewed the following policies, processes and procedures, which were provided by CPR: 0 General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 0 Work/Rest Rules (WRR) for Railway Operating Employees, as published by the Railway Association of Canada (RAC) and provided by CPR (February 201 0 Speci?c Fatigue Management Plan, Emergency Situations (March 17, 2003); 0 Speci?c Fatigue Management Plan, 64 hours in 7 days (March 17, 2003); 0 Speci?c Fatigue Management Plan, Work Train Service over 12 hours (March 17, 2003), and; RAC Work/Rest Rules, Interpretation Document (Effective June 29, 2005) Eleven ?ndings were reported as a consequence of this audit. Findings 771571 and 771601 were identi?ed as Details are provided in the Findings section of this report. Detailed descriptlons OI tnose rinalngs are prov1c1ea in me rlnulngs section 01 um: repuu. The Railway is encouraged to demonstrate how they intend to enhance railway safety by providing a corrective action plan to each of ?ndings of de?ciency, within 30 days of the issues of this audit report. The Corrective Action Plan should reference the Transport Canada audit ?ndings and detail the Railway?s proposed corrective actions to address them. Each corrective action should describe activities to be completed, identify personnel responsible, and outline timelines for implementation. An example Corrective Action Plan template is attached to this report and it may be used. Introduction Pursuant to the Railway Safety Act, Transport Canada has conducted a systematic, detailed assessment of railway company policies, processes and procedures to evaluate them against the documentation requirements of the SMS Regulations; and verify the implementation and effectiveness of said policies, processes and procedures. Audit Scope The scope of this audit was to verify the implementation of the Fatigue Management Plans as de?ned by CP, considering the requirements of ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans, Requirements and Assessment Guidelines?. The following components of the Safety Management Systems Regulations were also applicable: 2(b) Safety authorities, responsibilities and accountabilities; 2(d) Compliance with applicable regulations, rules, standards and orders; 2(e) Risk management process; Page 2 of 16 000013 Record released pursuant to the Access to Information Act/ s.20(1 Document divulgue en vertu de la oi sur I'acces a I'information 5.21 (1 2(h) Skills, training and supervision, and; 2(i) Collection and analysis of safety performance data (since fatigue is safety?related) The scope includes all records providing evidence of compliance with the above processes and all policies processes and procedures developed in support of fatigue management, from January 2010 to present. Other Issues Page 3 of 16 000019 Audit Findings Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Finding ID: 771571 ProCes?s: 2(d) I A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable: railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and; (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption . 453355;; 5'1 ,QOmrnitment; - Work/rest rules for railway operating employees, TC 0 0-140, February 2011 uppoiting Details: Page4 of16 000020 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information . I Finding ID: 771601 I 4 Process; 2(d) Regulatory"'Requ1rement: A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and; (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; Work/rest rules for railway operating employees, TC 0 0-140, February 2011, Description of Findng Supporting Details: Page 5 of 16 000021 Record released pursuant to the Access to Information Act/ 5-20? Document divulgue en vertu de la oi sur I'acces a I'information I 771765 Process: 2(b) Regulate-y A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(b) clear authorities, responsibilities and accountabilities for safety at all levels in the railway company RailWay Commitment: I I General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference (TCRC) Operating Employees (November 201 Description of Findings-5'95 Supporting Detalls. Page6 of 16 000022 Record released pursuant to the Access to Information Act/ s.20(1 Document divulgue en vertu de la oi sur I'aoces a I'information 5.21 (1 Page 7 of 16 000023 Record released pursuant to the Access to Information Act/ . . i i . Document dlvulgue en vertu de la sur Iacces a IInformatIon Finding ID: 771781 Process: I 2(h) Regulatos'z?' A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component; 2(h) systems for ensuring that employees and any other persons to whom the railway company grants access to its preperty, have appropriate skills and training and adequate supervision to ensure that they comply with all safety requirements; 0 Railway Commitment: General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 1) Description efFindingz? Page 8 of 16 000024 Record released pursuant to the Access to Information Act/ 5-20? Document divulgue en vertu de la oi sur I'acces a I'information Finding ID: 771786 -- 2(d) I liegulatory R?Quirementi A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable: railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and; (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption. Railway General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 1), Description Supporting Details: Page 9 of 16 000025 Page 10 of 16 Record released pursuant to the Access to Information Act/ Document divulgu? en vertu de la oi sur I'aoc?s a I'information 000026 5 20(1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page 11 of 16 000027 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aooes a I'information Proeess; 20) 771831 :Fi] Regulatory Requirement: i A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(i) procedures for the collection and analysis of data for assessing the safety performance of the railway company Commitment: 4 General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 1) jettingajijeta?isi? 000028 Page 12 of16 Record released pursuant to the Access to Information Act/ . . . Document dIvulgue en vertu de la sur Iaoces a IInformatIon Page 13 of16 000029 520(1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page 14 of16 000030 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Finding ID: 771875 2 2 Regulatory Requirement: A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them; and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption. Railway Commitment: General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 1) Description of?Findin?g- Page 15 of16 000031 Page 16 of16 Record released pursuant to the Access to Information Act/ Document divulgu? en vertu de la oi sur I'aoc?s a I'information 000032 3.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Audit Report Railway: CP Rail Railway SMS Keith Shearer Representative: GM Regulatory Operating Practices Audit Dates: January 5, 2015 to March 6, 2015 Convening Authority: Stephanie Lines, Director, Operations Management Audit Team Leader: Beata Hart, Safety Oversight and Audit Of?cer Report date: 2015 Executive Summary An audit of the CP Rail (CPR) fatigue management plans (FMP), considering Safety Management System Regulations (SMS), Transport Canada Work Rest Rules for Railway Operating Employees (WRR) and Fatigue Management Plans, Requirements and Assessment Guidelines? was conducted by Transport Canada (TC) from January 5, 2015 to March 6, 2015. The objective of the audit was to evaluate and verify implementation of the Fatigue Management Plan, as required by the WRR, and as de?ned by CP and submitted to Transport Canada. This was accomplished through a systematic, detailed assessment of railway company FMP to ensure compliance to the WRR as well as their implementation as defined by the Railway. This assessment was carried out through record reviews, observations and interviews with personnel. Details are provided in the Findings section of this report. Page 1 of 15 000033 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Introduction Pursuant to the Railway Safety Act, TC has conducted a systematic, detailed assessment of policies, processes and procedures to evaluate and verify their implementation of the Fatigue Management Plans, as de?ned by CP and submitted to Transport Canada, and to verify development, implementation and monitoring of fatigue management methodologies as required by ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans Requirements and Assessment Guidelines?. In addition to the above mentioned requirements, the following components of the SMS Regulations were also used as basis of the audit: 2(b) Safety authorities, responsibilities and accountabilities; 2(d) Compliance with applicable regulations, rules, standards and orders; 2(e) Risk management process; 2(h) Skills, training and supervision, and; 2(i) Collection and analysis of safety performance data The initial audit noti?cation and the documentation request were sent to CPR on November 28, 2014 The on?site auditing activities began on January 5, 2015 and the opening meeting was held at corporate of?ces in Calgary. During that meeting, the audit team con?rmed the scope of the audit and the proposed schedule. The audit team then proceeded to review the records provided and interviewed selected members of the management team. Subsequently, TC visited CP corporate of?ces the week of January 26th and on March 6 to further verify records and to interview personnel. Regional veri?cation activities took place the week of January 19 (Vancouver) and March 3 (Calgary, Toronto and Vancouver). The purpose of these visits were to interview local Management and Operating employees to verify implementation of the FMP. TC recognizes the special circumstances that developed due to the work stoppage caused by the union strike activity the week of February 16. The auditing activities scheduled for that week were postponed and the audit commenced the week of March 2, 2015. A closing meeting summarizing the audit activities was conducted as part of the wrap?up meeting on March 5 at the Calgary Alyth facility. Next steps were presented but, due to audit activities still being performed at other facilities at the same time, no potential ?ndings were communicated. The audit team reviewed the following policies, processes and procedures, which were provided by CPR: 0 General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 Work/rest Rules for Railway Operating Employees, as published by the Railway Association of Canada and provided by CPR (February 2011); 0 Speci?c Fatigue Management Plan, Emergency Situations (March 17, 2003); 0 Speci?c Fatigue Management Plan, 64 hours in 7 days (March 17, 2003); 0 Speci?c Fatigue Management Plan, Work Train Service over 12 hours (March 17, 2003), and; RAC Work/Rest Rules, Interpretation Document (Effective June 29, 2005) A response to this audit is required within 30 days from the issue of this report, and must include a corrective action plan to address each of the ?ndings from this audit. The corrective action plan should describe activities to be com leted identify ersonnel res onsible and outline timelines for implementation Page 2 of 15 000034 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Audit Scope The scope of this audit was to verify the implementation of the Fatigue Management Plans as de?ned by CP, considering the requirements of ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans, Requirements and Assessment Guidelines?. The following components of the Safety Management Systems Regulations were also applicable: 2(b) Safety authorities, responsibilities and accountabilities; 2(d) Compliance with applicable regulations, rules, standards and orders; 2(e) Risk management process; 2(h) Skills, training and supervision, and; 2(i) Collection and analysis of safety performance data (since fatigue is safety-related) All records providing evidence of compliance with the above processes and all policies processes and procedures developed in support of fatigue management, dating back to January 2010 to present. Other Issues Page 3 of 15 000035 Record released pursuant to the Access to Information Act/ s.20(1 Document divulgue en vertu de la oi sur I'acces a I'information Audit The audit ?ndings listed below require corrective actions. The Railway is required to provide a corrective action plan in response to each audit ?nding. Finding ID: 771571 ,Brocess; 2(a) 4 A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable: railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and; (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption Railway Geminitrnent?: - Work/rest rules for railway operating employees, TC 0 0-140, February 2011 Description of Finding: Page4 of 15 000036 20(1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information I I Finding ID: 771601 Processg? 1 2(d) A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and; (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; Description of Fin Page 5 of 15 000037 Record released pursuant to the Access to Information Aet/ Document divulgue en vertu de la oi sur I'acees a I'information .. "Findng 113? 771765 ,2Process: I 2(a) i Regulatory Require A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(b) clear authorities, responsibilities and accountabilities for safety at all levels in the railway company Railway Commitment! 7 General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 2011), Description-gaff Finding: PageSof15 000038 Record released pursuant to the Access to Information Act/ 5-20? Document divulgue en vertu de la oi sur I'aoces a I'information Page 7 of 15 000039 20 1 Record released pursuant to the Access to Information Act/ 5- Document divulgue en vertu de la oi sur l'acces a l'information . Findihg ID: 771781 - 0 Requirem?hti I A railway company shall implement and maintain a safety management system that includes, at a mlmmum, the following component; 2(h) systems for ensuring that employees and any other persons to whom the railway company grants access to its property, have appropriate skills and training and adequate supervision to ensure that they comply with all safety requirements; Railway Commitment: General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 ?D_eSCri'ption of (Finding? Page80f15 000040 5.20? Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information 5.21 (1 Finding ID: 771786 Process: g' 2(d) I A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable: railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and; (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption. Commitment: General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 Description of Finding: Page 9 of 15 000041 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page100f15 000042 Record released pursuant to the Access to Information Act/ 5-20? Document divulgue en vertu de la oi sur I'aoces a I'information 5.21 (1 Page11of15 000043 Record released pursuant to the Access to Information Act/ s.20(1 Document divulgue en vertu de la oi sur I'acces a I'information 771831 2(i) Keg tofy Re?nement: A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(i) procedures for the collection and analysis of data for assessing the safety performance of the railway company. talent-z . 0: General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Page 12 of15 000044 3.21 (1 Page130f15 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information 000045 Record released pursuant to the Access to Information Act/ 5-20? Document divulgue en vertu de la oi sur I'aoces a I'information Page 14 of15 000046 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la sur I'acces a I'information 771875 Process: 2 - Requirement-If" I I A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them; and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption. Railway commitment! General Fatigue ManagementPlan for Canadian Paci?c and the Teamsters Canada Rail Conference Operatlng Employees (November 201 1) Description of Page150f15 000047 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Audit Report Railway: CP Rail Railway SMS Keith Shearer Representative: GM Regulatory Operating Practices Audit Dates: January 5, 2015 to March 6,2015 Convening Authority: Stephanie Lines, Director, Operations Management Audit Team Leader: Beata Hart, Safety Oversight and Audit Of?cer Report date: 2015 Executive Summary An audit of the CP Rail (CPR) fatigue management plans (FMP) and in light of Safety Management System Regulations (SMS), Transport Canada Work Rest Rules for Railway Operating Employees (WRR) and Fatigue Management Plans, Requirements and Assessment Guidelines? was conducted by Transport Canada (TC) from January 5, 2015 to March 6, 2015. The objective of the audit was to evaluate and verify implementation of the Fatigue Management Plan, as required by the WRR, and as de?ned by CP and submitted to Transport Canada. This was accomplished through a systematic, detailed assessment of railway company FMP to ensure compliance to the WRR as well as their implementation as de?ned by the Railway. This assessment was carried out through record reviews, observations and interviews with personnel. Details are provided in the Findings section of this report. Introduction Page1 of 15 000043 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Pursuant to the Railway Safety Act, TC has conducted a systematic, detailed assessment of CPS policies, processes and procedures to evaluate and verify their implementation of the Fatigue Management Plans, as de?ned by GP and submitted to Transport Canada, and to verify development, implementation and monitoring of fatigue management methodologies as required by ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans Requirements and Assessment Guidelines?. In addition to above mentioned requirements, following components of the SMS Regulations were also used as basis of the audit: 2(b) Safety authorities, responsibilities and accountabilities 2(d) Compliance with applicable regulations, rules, standards and orders 2(e) Risk management process 2(h) Skills, training and supervision 2(i) Collection and analysis of safety performance data The on-site auditing activities began on January 5, 2015 and the opening meeting was held at corporate of?ces in Calgary. During that meeting, the audit team con?rmed the scope of the audit and the proposed schedule. The audit team proceeded to review the records provided and interviewed selected members of CP management team. Subsequently, TC visited CP corporate of?ces the week of January 26th and on March 6 to further verify records and to interview personnel. Regional veri?cation activities took place the week of January 19 (Vancouver) and March 3 (Calgary, Toronto and Vancouver). The purpose of these visits was to interview local Management and Operating employees to verify implementation of the FMP. TC recognizes special circumstances that developed due to the work stoppage caused by the union strike activity the week of February 16. The auditing activities scheduled for that week were postponed and the audit commenced the week of March 2, 2015. Closing meeting summarizing the audit activities was conducted as part of the wrap-up meeting on March 5 at the Calgary Alyth facility. Next steps were presented but, due to the activities being performed at other facilities at the same time, no potential ?ndings were communicated. The audit team reviewed the following policies, processes and procedures, which were provided by CPR: - General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 Work/rest Rules for Railway Operating Employees, as published by Railway Association of Canada and provided by CPR (February 201 I). 0 Speci?c Fatigue Management Plan, Emergency Situations (March 17, 2003) 0 Speci?c Fatigue Management Plan, 64 hours in 7 days (March 17, 2003) 0 Speci?c Fatigue Management Plan, Work Train Service over 12 hours (March 17, 2003) 0 RAC Work/Rest Rules, Interpretation Document (Effective June 29, 2005) A response to this audit is required within 30 days from the issue of this report, and must include a corrective action plan to address each of the ?ndings from this audit. The corrective action plan should describe activities to be completed, identify personnel responsible, and outline timelines for implementation. Audit Scope The scope of this audit was to verify the implementation of the Fatigue Management Plans as de?ned by CP and in light of the requirements of ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans, Requirements and Assessment Guidelines?. Page2 of15 000049 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi'sur I'acces a I'information Following components of the Safety Management Systems Regulations were also applicable: 2(b) Safety authorities, responsibilities and accountabilities 2(d) Compliance with applicable regulations, rules, standards and orders 2(e) Risk management process 2(h) Skills, training and supervision 2(i) Collection and analysis of safety performance data (since fatigue is safety-related) All records providing evidence of compliance with the above processes and all policies, processes and procedures developed in support of fatigue management, dating back to January 2010 to present. Other Issues Page30f15 000050 Record released pursuant to the Access to Information Act/ s.20(1 Document divulgue en vertu de la oi sur I'acces a I'information Audit Findings The audit ?ndings listed below require corrective actions. The Railway is required to provide a corrective action plan in response to each audit ?nding. Finding ID: 771571 2(d) Re A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; Railway Commitment: - Work/rest rules for railwa eratin em lo ees TOGO-140 Februa 2011 Supporting?D": ail?sfn I Page4 of 15 000051 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information . . 771601 2(a) I Regulatory'gi?equirement: i? A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the tenns or conditions speci?ed in the notice of exemption; Work/rest rules for railway operating employees, TC 0 0-140, February 201 Page 5 of 15 000052 Record released pursuant to the Access to Information Act/ 5'20? Document divulgue en vertu de la oi sur I'acces a I'information I Finding 771765 Process: 2(b) Regulatory Requirement: A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(b) clear authorities, responsibilities and accountabilities for safety at all levels in the railway company - General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 Page6of15 000053 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page 7 of 15 000054 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information . - 520(1? Finding-ID: 771781 201) 5.21 (1 -) RegulatoryiRequirement; -. A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component; 2(h) systems for ensuring that employees and any other persons to whom the railway company grants access to its property, have appropriate skills and training and adequate supervision to ensure that they comply with all safety requirements; . Raile C?f?mitm?nt General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 2011) Description of Finding: Supporting Details; Page 8 of 15 000055 Record released pursuant to the Access to Information Act/ 5-20? Document divulgue en vertu de la oi sur I'acces a I'information ID: 771786 2(d) Regulatory Requirem??g A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; RaliWay Commitment; General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Support. Page 9 of 15 000056 5.21 (1 Page100f15 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information 000057 Record released pursuant to the Access to Information Act/ . . . Document dIvulgue en vertu de la sur Iaoces a IInformatIon Page11of15 000053 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information 5-20? Finding 77183 Regulatory Requirement: A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(i) procedures for the collection and analysis of data for assessing the safety performance of the railway company General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 1) Page 12 of15 000059 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page130f15 000060 s.20(1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page 14 of 15 000061 5-20? Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information findingIDI' 771875 2(a) Regulatory Requirement? .. A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; Railway, Commitment: I General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 Description-e; upporting Details Page150f15 000062 20 1 Record released pursuant to the Access to Information Act/ 5- . . . . Document divulgue en vertu de la sur I'acces a I'Informatlon 'Zliiliilii Audit Report Railway: CP Rail Railway SMS Keith Shearer Representative: GM Regulatory Operating Practices Audit Dates: January 5, 2015 to March 6, 2015 Convening Authority: Stephanie Lines, Director, Operations Management Audit Team Leader: Beata Hart, Safety Oversight and Audit Of?cer Report date: 2015 Executive Summary An audit of the CP Rail (CPR) fatigue management plans (FMP) and in light of Safety Management System Regulations (SMS), Transport Canada Work Rest Rules for Railway Operating Employees (WRR) and Fatigue Management Plans, Requirements and Assessment Guidelines? was conducted by Transport Canada (TC) from January 5, 2015 to March 6, 2015. The objective of the audit was to evaluate and verify implementation of the Fatigue Management Plan, as required by the WRR, and as de?ned by CP and submitted to Transport Canada. This was accomplished through a systematic, detailed assessment of railway company FMP to ensure compliance to the WRR as well as their implementation as de?ned by the Railway. This assessment was carried out through record reviews observations and interviews with personnel. Details are prov1ded 1n the section 0 18 repo . Detail description of those ?ndings is prov1ded 1n the sectlon 18 Introduction Page1 of 15 000063 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur l'acces a l'information Pursuant to the Railway Safety Act, TC has conducted a systematic, detailed assessment of CPS policies, processes and procedures to evaluate and verify their implementation of the Fatigue Management Plans, as de?ned by CP and submitted to Transport Canada, and to verify development, implementation and monitoring of fatigue management methodologies as required by ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans Requirements and Assessment Guidelines?. In addition to above mentioned. requirements, following components of the SMS Regulations were also used as basis of the audit: 2(b) Safety authorities, responsibilities and accountabilities 2(d) Compliance with applicable regulations, rules, standards and orders 2(e) Risk management process 2(h) Skills, training and supervision 2(i) Collection and analysis of safety performance data The initial audit noti?cation and the documentation request were sent to CPR on November 28, 2014 555 The on?site auditing activities began on January 5, 2015 and the opening meeting was held at corporate of?ces in Calgary. During that meeting, the audit team con?rmed the scepe of the audit and the proposed schedule. The audit team proceeded to review the records provided and interviewed selected members of CP management team. Subsequently, TC visited CP corporate of?ces the week of January 26th and on March 6 to further verify records and to interview personnel. Regional veri?cation activities took place the week of January 19 (Vancouver) and March 3 (Calgary, Toronto and Vancouver). The purpose of these visits was to interview local Management and Operating employees to verify implementation of the FMP. TC recognizes special circumstances that developed due to the work stoppage caused by the union strike activity the week of February 16. The auditing activities scheduled for that week were postponed and the audit commenced the week ofMarch 2, 2015. Closing meeting summarizing the audit activities was conducted as part of the wrap-up meeting on March 5 at the Calgary Agincourt facility. Next steps were presented but, due to the activities being performed at other facilities at the same time, no potential ?ndings were communicated. The audit team reviewed the following policies, processes and procedures, which were provided by CPR: 0 General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 0 Work/rest Rules for Railway Operating Employees, as published by Railway Association of Canada and provided by CPR (February 201 0 Speci?c Fatigue Management Plan, Emergency Situations (March 17, 2003) 0 Speci?c Fatigue Management Plan, 64 hours in 7 days (March 17, 2003) 0 Speci?c Fatigue Management Plan, Work Train Service over 12 hours (March 17, 2003) 0 RAC Work/Rest Rules, Interpretation Document (Effective June 29, 2005) A response to this audit is required within 30 days from the issue of this report, and must include a corrective action plan to address each of the ?ndings from this audit. The corrective action plan should describe activities to be completed, identify personnel responsible, and outline timelines for implementation. Audit Scope The scope of this audit was the implementation of the Fatigue Management Plans as de?ned by CP and in light of the requirements of ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans, Requirements and Assessment Guidelines?. Page 2 of 15 000064 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Following components of the Safety Management Systems Regulations were also applicable: 2(b) Safety authorities, responsibilities and accountabilities 2(d) Compliance with applicable regulations, rules, standards and orders 2(e) Risk management process 2(h) Skills, training and supervision 2(i) Collection and analysis of safety performance data (since fatigue is safety-related) All records providing evidence of compliance with the above processes and all policies processes and procedures developed in support of fatigue management, dating back to January 2010 to present. Other Issues Page 3 of 15 000065 Record released pursuant to the Access to Information Act/ 520? Document divulgue en vertu de la oi sur I'acces a I'information Audit 521 (1 The audit ?ndings listed below require corrective actions. The Railway is required to provide a corrective action plan in response to each audit ?nding. I I 77157] Process: 201) Req? dement: A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; Page4 of 15 000066 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Finding ID: 771601 Process: 2(d) Regulatory A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; Railway cemmitment? Work/rest rules for railway operating employees, TC 0 0-140, February 20] Description 'ofF Page50f15 000067 5 20(1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Finding ID: 771765 Process: 2(b) .. .. Regulatory Requir?mspti . . A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: I 2(b) clear authorities, responsibilities and accountabilities for safety at all levels in the railway company K?RailwayCornmitme-nt: General Fatigue Management msters Canada Rail Conference Operating Employees (November 201 1), ofFinding: Supporting Details: Page6 of 15 000068 Record released pursuant to the Access to Information Act/ . . . Document dIvulgue en vertu de la sur Iaoces a IInformatIon 5.21 (1 Page 7 of 15 000069 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Finding ID: 771781 Process?? 2(h) 7 i i I. Regulatory Req?u A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component; 2(h) systems for ensuring that employees and any other persons to whom the railway company grants access to its property, have appropriate skills and training and adequate supervision to ensure that they comply with all safety requirements; i?c and the Teamsters Canada Rail Conference Operating General Fatigue Management Pl Employees (November 201 Dig-?nding: i I i a Supporting Details: Page 8 of 15 000070 Record released pursuant to the Access to Information Act/ 5-20? Document divulgue en vertu de la oi sur I'acces a I'information Finding ID: 771786 Process: . 2(d) I. Regulatory Requirement-m I A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; RailWay commitment General Fatigue Management Plan for Canadian Pacific and the Teamsters Canada Rail Conference Operating Employees (November 201 1) Supporting Details: PagerfiS 000071 Page100f15 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information 000072 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information 5.21 (1 Page110f15 000073 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Finding ID: 771831 Process: 2(1) Regulatory Requirement: A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(i) procedures for the collection and analysis of data for assessing the safety performance of the railway company General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 2011 . ?toeseapmrran, Page 12 of15 000074 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page130f15 000075 20 1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page14of15 000076 20 1 Record released pursuant to the Access to Information ActDocument dIvulgue en vertu de la sur I'acces a I'Informatlon ?finding ID: 771875 Process: 2 Regulatory A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; 'lway nt' General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 1) Supporting Details: Page15of15 000077 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur l'acces a l'information 5.21 (1 Railway: CP Rail Railway SMS Keith Shearer Representative: GM Regulatory Operating Practices Audit Dates: January 5, 2015 to March 6, 2015 Convening Authority: Stephanie Lines, Director, Operations Management Audit Team Leader: Beata Hart, Safety Oversight and Audit Of?cer Report date: 2015 Executive Summaryl Comment [bh1]: This section was updated as beta; 5 .. .. hinstructions from-Elam . An audit of the CP Rail (CPR) fatigue management plans (FMP) and in light of Safety Management System Regulations (SMS), Transport Canada Work Rest Rules for Railway Operating Employees (WR) and Fatigue Management Plans, Requirements and Assessment Guidelines? was conducted by Transport Canada (TC) from January 5, 2015 to March 6, 2015. The objective of the audit was to evaluate and verify implementation of the Fatigue Management Plan, as required by the WRR, and as de?ned by CP and submitted to Transport Canada. This was accomplished through a systematic, detailed assessment of railway company FMP to ensure compliance to the WRR as well as their implementation as defined by the Railway. This assessment was carried out through record reviews observations and interviews with personnel. Details are provided in the Findings section of this report. Detai descrip ion of those gs prov ed the section oItnis report Page 1 of 13 000078 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur l'acces a l'information Introduction Pursuant to the Railway Safety Act, TC has conducted a systematic, detailed assessment of CPS policies, processes and procedures to evaluate and verify their implementation of the Fatigue Management Plans, as de?ned by CP and submitted to Transport Canada, and to verify development, implementation and monitoring of fatigue management methodologies as required by ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans Requirements and Assessment Guidelines?, In addition to above mentioned requirements, following components of the SMS Regulations were also used as basis ofthe audit: 2(b) Safety authorities, responsibilities and acc0untabilities 2(d) Compliance with applicable regulations, rules, standards and orders 2(e) Risk management process 2(h) Skills, training and supervision 2(i) Collection and analysis of safety performance data The initial audit noti?cation and the documentation request were sent to CPR on November 28 201 The on-srte auditing activ1ties began on January 5, 2015 and the opening meeting was held at corporate of?ces in Calgary. During that meeting, the audit team con?rmed the scope of the audit and the proposed schedule. The audit team proceeded to review the records provided and interviewed selected members of CP management team, Subsequently, TC visited CP corporate of?ces the week of January 26?h and on March 6 to further verify records and to interview personnel. Regional veri?cation activities took place the week of January 19 (Vancouver) and March 3 (Calgary, Toronto and Vancouver). The purpose of these visits was to interview local Management and Operating employees to verify implementation of the FMP. TC recognizes special circumstances that developed due to the work stoppage caused by the union strike activity the week of February 16. The auditing activities scheduled for that week were postponed and the audit commenced the week of March 2, 2015. Closing meeting summarizing the audit activities was conducted as part of the wrap-up meeting on March 5 at the Calgary Agincourt facility. Next steps were presented but, due to the activities being performed at other facilities at the same time, no potential ?ndings were communicated. The audit team reviewed the following policies, processes and procedures, which were provided by CPR: 0 General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 2011); Work/rest Rules for Railway Operating Employees, as published by Railway Association of Canada and provided by CPR (February 201 0 Speci?c Fatigue Management Plan, Emergency Situations (March 17, 2003) Speci?c Fatigue Management Plan, 64' hours in 7 days (March 17, 2003) 0 Speci?c Fatigue Management Plan, Work Train Service over 12 hours (March 17, 2003) 0 RAC Work/Rest Rules, Interpretation Document (Effective June 29, 2005) A response to this audit is required within 30 days from the issue of this report, and must include a corrective action plan to address each of the ?ndings from this audit. The corrective action plan should describe activities to be completed identify personnel responsible, and outline timelines for implementation. Audit Scope Page 2 of 13 000079 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information The scope of this audit was the implementation of the Fatigue Management Plans as de?ned by CP and in light of the requirements of ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans, Requirements and Assessment Guidelines?. Following components of the Safety Management Systems Regulations were also applicable: 2(b) Safety authorities, responsibilities and accountabilities 2(d) Compliance with applicable regulations, rules, standards and orders 2(e) Risk management process 2(h) Skills, training and supervision 2(i) Collection and analysis of safety performance data (since fatigue is safety-related) All records providing evidence of compliance with the above processes and all policies processes and procedures developed in support of fatigue management, dating back to January 2010 to present. Other Issues - a - [bh2]: This paragraph per info received from Sue. Page 3 of 13 000080 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Audit Findings The audit ?ndings listed below require corrective actions. The Railway is required to provide a corrective action plan in response to each audit finding. 771571 . moms: 2(d) Regulatory Reguirenienti A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; . Railway Commitment'iw' - Work/rest rules for railway operating employees, TC 0 0?140, February 201] Page4 of13 000081 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur l'acces a l'information - Findingl-DI 771601 3 Process: 2(d) Regulatory Reguir?mcnt; 4 A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; I Railway commitment; Supporting Details: Work/rest rules for railway operating employee TC 0 0 14 February 201 Finding 771765 Process: 2(b) Page 5 of 13 000082 5.21 (1 Regtilatory Requirein; t: Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information A railway company shall implement and maintain a safety management system that includes, at a minimum, the following cemponent: 2(b) clear authorities, responsibilities and accountabilities for safety at all levels in the railway company Ra?lyvay Commitment: General Fatigue Management :13 amsters Canada Rail Conference Operating Employees (November 201 Description ot?F?inding: 4 'y Supporting Details: Page 6 of 13 000083 3.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Finding ID: 77178] Process: 201) I Regulatory Requirement: Page? of13 000084 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur l'acces a l'information 2(h) systems for ensuring that employees and any other persons to whom the railway company grants access to its property, have appropriate skills and training and adequate supervision to ensure that they comply with all safety requirements; A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component; i. Railway Commitment: General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 l) Description'uof?nding: Finding ID: 771786 2(d) Regulatory Reqairementzl Page 8 of 13 000085 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur l'acces a l'information 5.21 (1 A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; I Railway Commitment: General Fatigue Management the Teamsters Canada Rail Conference Operating Employees (November 201 Description of Finding 990??ng Details: Comment l'bh3] Page 9 of 13 000086 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Finding ID: 771831 Process: 2(1) Page100f13 000087 5.21 (1 Regulat' if??me'n't: Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur l'acces a l'information A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(i) procedures for the collection and analysis of data for assessing the safety performance of the railway company Railway Commitment: General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 1) Page 11 of13 000088 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Comment [kz4]: Page 12 of13 000089 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur l'acces a l'information 5.21 (1 Finding ID: 771 875 Process: 2 Reguiatory A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compiiance with the terms or conditions speci?ed in the notice of exemption; Rail-way Commitment: General Fatigue Management it nference Operating Employees (November 201 Comment Supporting Details: Page 13 of13 000090 s.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Audit Report Railway: CP Rail Railway SMS Keith Shearer Representative: GM Regulatory Operating Practices Audit Dates: January 5, 2015 to March 6, 2015 Convening Authority: Stephanie Lines, Director, Operations Management Audit Team Leader: Beata Hart, Safety Oversight and Audit Of?cer Report date: 2015 Executive Summary An audit of the CP Rail (CPR) fatigue management plans (FMP) and in light of Safety Management System Regulations (SMS), Transport Canada Work Rest Rules for Railway Operating Employees (WRR) and Fatigue Management Plans, Requirements and Assessment Guidelines? was conducted by Transport Canada (TC) from January 5, 2015 to March 6, 2015. The objective of the audit was to evaluate and verify implementation of the Fatigue Management Plan, as required by the WRR, and as de?ned by CP and submitted to Transport Canada. This was accomplished through a systematic, detailed assessment of railway company FMP to ensure compliance to the WRR as well as their implementation as de?ned by the Railway. This assessment was carried out through record reviews, observations and interviews with personnel Page 1 of 13 000091 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Introduction Pursuant to the Railway Safety Act, TC has conducted a systematic, detailed assessment of CPS policies, processes and procedures to evaluate and verify their implementation of the Fatigue Management Plans, as de?ned by CP and submitted to TranSport Canada, and to verify development, implementation and monitoring of fatigue management methodologies as required by ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans Requirements and Assessment Guidelines?. In addition to above mentioned requirements, following components of the SMS Regulations were also used as basis of the audit: 2(b) Safety authorities, responsibilities and accountabilities 2(d) Compliance with applicable regulations, rules, standards and orders 2(e) Risk management process 2(h) Skills, training and supervision 2(i) Collection and analysis of safety performance data The initial audit noti?cation and the documentation request were sent to CPR on November 28, 2014 The on-site auditing activities began on January 5, 2015 and the opening meeting was held at corporate of?ces in Calgary. During that meeting, the audit team con?rmed the scope of the audit and the proposed schedule. The audit team proceeded to review the records provided and interviewed selected members of CP management team. Subsequently, TC visited CP corporate of?ces the week of January 26th and on March 6 to further verify records and to interview personnel. Regional veri?cation activities took place the week of January 19 (Vancouver) and March 3 (Calgary, Toronto and Vancouver). The purpose of these visits was to interview local Management and Operating employees to verify implementation of the FMP. TC recognizes special circumstances that developed due to the work stoppage caused by the union strike activity the week of February 16. The auditing activities scheduled for that week were postponed and the audit commenced the week of March 2, 2015. Closing meeting summarizing the audit activities was conducted as part of the wrap~up meeting on March 5 at the Calgary Agincourt facility. Next steps were presented but, due to the activities being performed at other facilities at the same time, no potential ?ndings were communicated. The audit team reviewed the following policies, processes and procedures, which were provided by CPR: 0 General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 Work/rest Rules for Railway Operating Employees, as published by Railway Association of Canada and provided by CPR (February 2011). 0 Speci?c Fatigue Management Plan, Emergency Situations (March 17, 2003) 0 Speci?c Fatigue Management Plan, 64 hours in 7 days (March 17, 2003) 0 Speci?c Fatigue Management Plan, Work Train Service over 12 hours (March 17, 2003) - RAC Work/Rest Rules, Interpretation Document (Effective June 29, 2005) A response to this audit is required within 30 days from the issue of this report, and must include a corrective action plan to address each of the ?ndings from this audit. The corrective action plan should describe activities to be completed identify personnel responsible and outline timelines for implementation. Page2 of13 000092 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur l'acces a l'information Audit Scepe The scope of this audit was the implementation of the Fatigue Management Plans as de?ned by GP and in light of the requirements of ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans, Requirements and Assessment Guidelines?. Following components of the Safety Management Systems Regulations were also applicable: 2(b) Safety authorities, responsibilities and accountabilities 2(d) Compliance with applicable regulations, rules, standards and orders 2(e) Risk management process 2(b) Skills, training and supervision 2(i) Collection and analysis of safety performance data (since fatigue is safety-related) All records providing evidence of compliance with the above processes and all policies processes and procedures developed in support of fatigue management, dating back to January 2010 to present. Other Issues Page 3 of 13 000093 Record released pursuant to the Access to Information Act/ s.20(1 Document divulgue en vertu de la oi sur I'acces a I'information Audit Findings The audit ?ndings listed below require corrective actions. The Railway is required to provide a corrective action plan in response to each audit ?nding. Finding ID: 771571 4 2(d) Regulatory Requirement: A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; RaiIWay commitment:- - Work/rest rules for railway operating employees, TC 0 0-140 February 2011 Description of Finding? Page4 of 13 000094 - Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Finding ID: 771601 Process: 2(d) {egulatory Requirement; - A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; commitment; Work/rest rules for railway operating employees, TC 0 0-140, February 2011, Page 5 of 13 000095 5 20(1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information 5.21 (1 771765 was; I 2(b) A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(b) clear authorities, responsibilities and accountabilities for safety at all levels in the railway company Ranway?comniitme?t: General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 1 Description emanate: Page 6 of 13 000096 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page7 of 13 000097 Record released pursuant to the Access to Information Act/ 520? Document divulgue en vertu de la oi sur I'acces a I'information s21 (1 Finding ID: 771781 I: 2(h) A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component; 2(h) systems for ensuring that employees and any other persons to whom the railway company grants access to its property, have appropriate skills and training and adequate supervision to ensure that they comply with all safety requirements; {Railway . i -- General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 1), ?Descript Supportmg D'e't'alls: 5. Finding 771786 Prece_ss;__ 2(a) Page80f13 000098 520? Record released pursuant to the Access to Information Aet/ Document divulgue en vertu de la oi sur I'aoees a I'information A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; a?Way Commitment General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 1), Descript-ierirzgaef Finding: Supporting I Page 9 of 13 000099 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page100f13 000100 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Finding 771831 2(i) Regulatory Requirement: A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(i) procedures for the collection and analysis of data for assessing the safety performance of the railway company Railway General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 2011) Description Of Page110f13 000101 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Finding ID: 771875 Process: 2 Re glittery-Requirement: A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; Page120f13 000102 20 1 Record released pursuant to the Access to Information ActDocument dIvulgue en vertu de la sur Iaoces a I'Informatlon Railway Commitment: General Fatigue ManagementPlan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 [porting Details: 0 Page13of13 000103 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Audit Report Railway: CP Rail Railway SMS Keith Shearer Representative: GM Regulatory Operating Practices Audit Dates: January 5, 2015 to March 6, 2015 Convening Authority: Stephanie Lines, Director, Operations Management Audit Team Leader: Beata Hart, Safety Oversight and Audit Of?cer Report date: 2015 Executive Summary An audit of the CP Rail (CPR) fatigue management plans (FMP) and in light of Safety Management System Regulations (SMS) and Transport Canada Work Rest Rules for Railway Operating Employees (WRR) was conducted by Transport Canada (TC) from January 5, 2015 to March 6, 2015. The objective of the audit was to evaluate and verify implementation of the Fatigue Management Plan, as required by the WRR, and as de?ned by CP and submitted to Transport Canada. This was accomplished through a systematic, detailed assessment of railway company FMP to ensure compliance to the WRR as well as their implementation as de?ned by the Railway. This assessment was carried out through record reviews, observations and interviews with personnel. Deta1 are prov1 Page 1 of 13 000104 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur l'acces a l'information Introduction Pursuant to the Railway Safety Act, TC has conducted a systematic, detailed assessment of policies, processes and procedures to evaluate and verify their implementation of the Fatigue Management Plans, as de?ned by GP and submitted to Transport Canada, and to verify development, implementation and monitoring of fatigue management methodologies as required by ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans Requirements and Assessment Guidelines?. In addition to above mentioned requirements, following components of the SMS Regulations were also used as basis of the audit: 2(b) Safety authorities, responsibilities and accountabilities 2(d) Compliance with applicable regulations, rules, standards and orders 2(e) Risk management process 2(h) Skills, training and supervision 2(i) Collection and analysis of safety performance data The initial audit noti?cation and the documentation request were sent to CPR on November 28, 2014 The on-site auditing activities began on January 5, 2015 and the opening meeting was held at corporate of?ces in Calgary. During that meeting, the audit team con?rmed the scope of the audit and the proposed schedule. The audit team proceeded to review the records provided and interviewed selected members of CP management team. Subsequently, TC visited CP corporate of?ces the week of January 26th and on March 6 to further verify records and to interview personnel. Regional veri?cation activities took place the week of January 19 (Vancouver) and March 3 (Calgary, Toronto and Vancouver). The purpose of these visits was to interview local Management and Operating employees to verify implementation of the FMP. TC recognizes special circumstances that developed due to the work stoppage caused by the union strike activity the week of February 16. The auditing activities scheduled for that week were postponed and the audit commenced the week of March 2, 2015. Closing meeting summarizing the audit activities was conducted as part of the wrap-up meeting on March 5 at the Calgary Agincourt facility. Next steps were presented but, due to the activities being performed at other facilities at the same time, no potential ?ndings were communicated. The audit team reviewed the following policies, processes and procedures, which were provided by CPR: 0 General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees movember 201 0 Work/rest Rules for Railway Operating Employees, as published by Railway Association of Canada and provided by CPR (February 201 0 Speci?c Fatigue Management Plan, Emergency Situations (March 17, 2003) 0 Speci?c Fatigue Management Plan, 64 hours in 7 days (March 17, 2003) 0 Speci?c Fatigue Management Plan, Work Train Service over 12 hours (March 17, 2003) RAC Work/Rest Rules, Interpretation Document (Effective June 29, 2005) A response to this audit is required within 30 days from the issue of this report, and must include a corrective action plan to address each of the ?ndings from this audit. The corrective action plan should describe activities to be completed identify personnel responsible, and outline timelines for implementation. Page 2 of 13 000105 3.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Audit Scope The scope of this audit was the implementation of the Fatigue Management Plans as de?ned by GP and in light of the requirements of ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans, Requirements and Assessment Guidelines?. Following components of the Safety Management Systems Regulations were also applicable: 2(b) Safety authorities, responsibilities and accountabilities 2(d) Compliance with applicable regulations, rules, standards and orders 2(e) Risk management process 2(h) Skills, training and supervision 26) Collection and analysis of safety performance data (since fatigue is safety-related) All records providing evidence of compliance with the above processes and all policies processes and procedures developed in support of fatigue management, dating back to January 2010 to present. Other Issues Page 3 of 13 000106 Record released pursuant to the Access to Information Act/ 320? Document divulgue en vertu de la oi sur I'acces a I'information Audit Findings The audit ?ndings listed below require corrective actions. The Railway is required to provide a corrective action plan in response to each audit ?nding. Finding ID: 771571 Process: 2(d) qr A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; Commitment: 7 - Work/rest rules for railway operating employees TC 0 0-140 February 2011 Page4 of 13 000107 Record released pursuant to the Access to Information Act/ s.20(1 Document divulgue en vertu de la oi sur I'acces a I'information 5.21 (1 Figging 771601 it Requirement: I ,4 A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; Railway commitm; Work/rest rules for railway operating employees, TC 0 0-140, February 2011, Description of Findin Supporting Details: Page 5 of 13 000108 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Fmdl?g?ID: 771765 203) i Regulatory filament: 0, A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(b) clear authorities, responsibilities and aceountabilities for safety at all levels in the railway company General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 2011 Description of Finding: Supporting Details: 4; Page6 of 13 000109 Record released pursuant to the Access to Information Act/ 5-20? Document divulgue en vertu de la oi sur I'aoces a I'information Page 7 of 13 000110 Record released pursuant to the Access to Information Act/ 820? Document divulgue en vertu de la oi sur l'acces a l'information Finding 771781 I Process: 2(h) Regulatory Requirement A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component; 2(h) systems for ensuring that employees and any other persons to whom the railway company grants access to its property, have appropriate skills and training and adequate supervision to ensure that they comply with all safety requirements; Railway Commitment: Supporting Detailsjz-?f: . Page80f13 000111 Record released pursuant to the Access to Information Act/ s.20(1 Document divulgue en vertu de la oi sur I'acces a I'information FindingID-z-r-rrs 771786 I. {Processf?i? 2(a) =__Regulatory__ Requirementrailway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; I Commitment: -. General Fatigue Management Teamsters Canada Rail Conference Operating Employees (November 201 Description of Finding; Supporting Diet; Page 9 of 13 000112 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page100f13 000113 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information 5.21 (1 )(bl 771831 2(i) Regulam eqtih?ememf A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(i) procedures for the collection and analysis of data for assessing the safety performance of the railway company Railway Commitment: General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 1 Supportmg Page1?l of13 000114 20 1 Record released pursuant to the Access to Information Act/ 5' Document divulgue en vertu de la oi sur I'aoces a I'information Page12 of13 000115 20(1 Record released pursuant to the Access to Information Act/ . Document divulgue en vertu de la oi sur I'acces a I'information 5.21 (1 Emdingro; 771875 Process; 2(a) Eatery?R?quire'ih?nt? A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, mles, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions specified in the notice of exemption; i?c and the Teamsters Canada Rail Conference Operating PagetSof13 000116 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information 5.21 (1 Audit Report Railway: CP Rail Railway SMS Keith Shearer Representative: GM Regulatory Operating Practices Audit Dates: January 5, 2015 to March 6 2015 Convening Authority: Stephanie Lines, Director, Operations Management Audit Team Leader: Beata Hart, Safety Oversight and Audit Of?cer Report date: 201 5 Executive Summary An audit of the p12 A Regulations (SMS) was conducted by Trans ort Canada (TC) from January 5, 2015 to March 6, 2015. The objective of the audit was to evaluate and verify implementation of the Fatigue Management Plan, as a de?ned by GP and submitted to Transport Canada. This was accomplished through a systematic, detailed assessment of railway company FMP to ensure compliance to the WRR as well as their implementation as defined by the Railway. This assessment was carried out through . d?in lights! ?afsiy n, ement plans?CFli/I nag The following provides an overview of the ?ndings. Comment [bh3] Page 1 of 14 000117 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur l'acces a l'information Com Introduction Pursuant to the Railway Safety Act, TC has conducted a systematic, detailed assessment of CPS policies, processes and procedures to evaluate and verify their implementation of the Fatigue Management Plans, as de?ned by CP and submitted to Transport Canada, and to verify development, implementation and monitoring of fatigue management methodologies as required by ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans Requirements and Assessment Guidelines?. In addition to above mentioned requirements, following components of the SMS Regulations were also used as basis of the audit: 203) Safety authorities, responsibilities and acc0untabilities 2(d) Compliance with applicable regulations, rules, standards and orders 2(e) Risk management process 2(h) Skills, training and supervision 2(i) Collection and analysis of safety performance data Page 2 of 14 000118 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information The initial audit noti?cation and the documentation request were sent to CPR on November 28, 2014. began on January 5, 2015 and the opening meeting was held at corporate of?ces in Calgary. During that meeting, the audit team con?rmed the scope of the audit and the proposed schedule. The audit team proceeded to review the records provided and interviewed selected members of CP management team. Subsequently, TC visited CP corporate of?ces the week of January 26?h and on March 6 to further verify records and to interview personnel. Regional veri?cation activities took place the week of January 19 (Vancouver) and March 3 (Calgary, Toronto and Vancouver). The purpose of these visits was to interview local Management and Operating employees to verify implementation of the FMP. TC recognizes special circumstances that developed due to the work stoppage caused by the union strike activity the week of February 16. The auditing activities scheduled for that week were postponed and the audit commenced the week of March 2, 2015. Closing meeting summarizing the audit activities was conducted as part of the wrap-up meeting on March 5 at the Calgary Wmfac?i?l Next steps wars. performer! a comment-t facilities at the same time, no potential ?ndings were communicated. Ogden? The audit team reviewed the following policies, processes and procedures, which-were provided by CPR: General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 Workfrest Rules for Railway Operating Employees, as published by Railway Association of Canada and provided by CPR. - Speci?c Fatigue Management Plan, Emergency Situations (March 17, 2003) 0 Speci?c Fatigue Management Plan, 64 hours in 7 days (March 17, 2003) 0 Speci?c Fatigue Management Plan, Work Train Service over 12. hours (March 17, 2003) - RAC Work/Rest Rules, Interpretation Document (Effective June 29, 2005) A response to this audit is required within 30 days from the issue of this report, and must include a corrective action plan to address each of from this audit. The corrective action plan should b] tline timelines for im lementation Audit Scope The scope of this audit was the implementation of the Fatigue Management Plans as de?ned by CP and in light of the requirements of ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans, Requirements and Assessment Guidelines?. Following components of the Safety Management Systems Regulations were also applicable: 2(b) Safety authorities, responsibilities and accountabilities 2(d) Compliance with applicable regulations, rules, standards and orders 2(e) Risk management process 2(h) Skills, training and supervision 2(i) Collection and analysis of safety performance data (since fatigue is safety-related) All records previding evidence of compliance with the above processes and all policies processes and procedures developed in support of fatigue management, dating back to January 2010 to present. Page 3 of 14 000119 Record released pursuant to the Access to Information Act/ 320? Document divulgue en vertu de la oi sur I'acces a I'information s.21 (1 Other Issues Oh ent [bth]: I?ve already amended this and added the following te Audit Findings The audit ?ndings listed below require corrective actions. The Railway is required to provide a corrective action plan in response to each audit ?nding. ID: 771571 Process: 2(d) - RegulatoryRequirementf A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable (1) railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; I Railway Commitment: '1 TC 0 0-140 Februa 2011 eruption omedmg; Comment [bh11]: These forms are asa per therefore templates Supportin'jgipet'ails: Page 4 of 14 000120 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page 5 of 14 000121 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur l'acces a l'information 5.21 (1 Finding 771601 Process: 2(d) Regulatory Requirement: A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, mics, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions specified in the notice of exemption; Ra' we; commitment: railway operating employee TC 0 0 140 February 201] Description of Findm Supporting Details: Page 6 of 14 000122 Record released pursuant to_the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information 5.21 (1 FindingID: 771765 2(b) Regulatory-Reg. fen-lent: A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(b) clear authorities, responsibilities and accountabilities for safety at all levels in the railway company 1' Railway Commitment: General Fatigue Management amsters Canada Rail Conference Operating Employees (November 201 l) Description of indin Supporting Detalls: Page 7 of 14 000123 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page 8 of 14 000124 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur l'acces a l'information Finding ID: 771781 1- =1"_Process: Training Reguiatoryi?equirement; following component; safety requirements; A railway company shall implement and maintain a safety management system that includes, at a minimum, the 2(h) systems for ensuring that employees and any other persons to whom the railway company grants access to its property, have appropriate skills and training and adequate supervision to ensure that they comply with all Railway Commitment: General Fatigue Management Employees (November 20] 1) Teamsters Canada Rail Conference Operating Descripticm of Findin . Supporting Details: Page 9 of 14 000125 Record released pursuant to the Access to Information Act/ Document divulgu? en vertu de la oi sur l'acc?s a l'information 771786 Process: 5 2(d) i Regulatory Requirement: A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; "Railway Commitment: General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 l) Supporting Detalls: Page 10 of14 000126 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page 11 of 14 000127 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur l'acces a l'information 5.21 (1 Finding ID: 771831 Process: 2(i) A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(i) procedures for the collection and analysis of data for assessing the safety performance of the railway company 'Ra'l General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 Supporting Details: Page 12 0H4 000128 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page 130f14 000129 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur l'acces a l'information Finding ID: 771875 2 I A railway company shall implement and maintain a safety management system that inlcudes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; General Fatigue Management Plan for Canadian Pacific and the Teamsters Canada Rail Conference Operating Employees (November 20] 1) 5 I Description of Findi Page 14 of 14 000130 Record released pursuant to the Access to Information Act/ 520? Document divulgue en vertu de la oi sur I'acces a I'information smmb) AUdit Report Railway: CP Rail Railway SMS Keith Shearer Representative: GM Regulatory Operating Practices Audit Dates: January 5, 2015 to March 6, 2015 Convening Authority: Stephanie Lines, Director, Operations Management Audit Team Leader: Beata Hart, Safety Oversight and Audit Of?cer Report date: 2015 Executive Summary An audit of the CP Rail (CPR) fatigue management plans (FMP) and in light of Safety Management System Regulations (SMS) and Transportii?anada Work ReSttRules for Railway Operating Employees was conducted by Transport Canada (TC) from January 5, 2015 to March 6, 2015. The objective of the audit was to evaluate and verify implementation of the Fatigue Management Plan, as de?ned by GP and submitted to Transport Canada. This was accomplished through a systematic, detailed assessment of railway company FMP to ensure compliance to the Work Rest Rules (WRR) as well as their implementation as de?ned by the Railway. This assessment was carried out through record reviews and interviews with personnel. 11 these are reported as ?ndings 1n this report The followmg provides an overview of the ?ndings. Each one requires a corrective action: Page1 of 13 000131 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Introduction Pursuant to the Railway Safety Act, TC has conducted a systematic, detailed assessment of CPS policies, processes and procedures to evaluate and verify their implementation of the Fatigue Management Plans, as de?ned by CP and submitted to Transport Canada, and to verify development, implementation and monitoring of fatigue management methodologies as required by ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans Requirements and Assessment Guidelines?. In addition to above mentioned requirements, following components of the SMS Regulations were also used as basis of the audit: 2(b) Safety authorities, responsibilities and accountabilities 2(d) Compliance with applicable regulations, rules, standards and orders 2(6) Risk management process 2(b) Skills, training and supervision 2(i) Collection and analysis of safety performance data The initial audit noti?cation and the documentation request were sent to CPR on November 28, 201 The on-site auditing activities began on January 5, 2015 and the opening meeting was held at corporate of?ces in Calgary. During that meeting, the audit team con?rmed the scope of the audit and the proposed schedule. The audit team proceeded to review the records provided and interviewed selected members of CP PageZ of13 000132 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information management team. Subsequently, TC visited CP corporate of?ces the week of January 26th and on March 6 to further verify records and to interview personnel. Regional veri?cation activities took place the week of January 19 (Vancouver) and March 3 (Calgary, Toronto and Vancouver). The purpose of these visits was to interview local Management and Operating employees to verify implementation of the FMP. TC recognizes special circumstances that developed due to the work stoppage caused by the union strike activity the week of February 16. The auditing activities scheduled for that week were postponed and the audit commenced the week of March 2, 2015. Closing meeting summarizing the audit activities was conducted as part of the wrap-up meeting on March 5 at the Calgary Agincourt facility. Next steps were presented but, due to the activities being performed at other facilities at the same time, no potential ?ndings were communicated. The audit team reviewed the following policies, processes and procedures, which were provided by CPR: 0 General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 0 Work/rest Rules for Railway Operating Employees, as published by Railway Association of Canada and provided by CPR (February 2011). 0 Speci?c Fatigue Management Plan, Emergency Situations (March 17, 2003) 0 Speci?c Fatigue Management Plan, 64 hours in 7 days (March 17, 2003) 0 Speci?c Fatigue Management Plan, Work Train Service over 12 hours (March 17, 2003) RAC Work/Rest Rules, Interpretation Document (Effective June 29, 2005) A response to this audit is required within 30 days from the issue of this report, and must include a corrective action plan to address each of the ?ndings from this audit. The corrective action plan should describe activities to be completed, identify personnel responsible, and outline timelines for implementation. CPR will be responsible for submitting evidence of implementation of planned corrective actions per the timelines outlined in their corrective action plan. TC must be noti?ed of any changes to the corrective action plan. Audit Scope The scepe of this audit was the implementation of the Fatigue Management Plans as de?ned by CP and in light of the requirements of ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans, Requirements and Assessment Guidelines?. Following components of the Safety Management Systems Regulations were also applicable: 2(b) Safety authorities, responsibilities and accountabilities 2(d) Compliance with applicable regulations, rules, standards and orders 2(e) Risk management process 2(h) Skills, training and supervision 2(i) Collection and analysis of safety performance data (since fatigue is safety-related) All records providing evidence of compliance with the above processes and all policies processes and procedures developed in support of fatigue management, dating back to January 2010 to present. Other Issues Page 3 of 13 000133 Record released pursuant to the Access to Information Act/ 820? Document divulgue en vertu de la oi sur I'acces a I'information Audit Findings The audit ?ndings listed below require corrective actions. The Railway is required to provide a corrective action plan in response to each audit ?nding. Finding 771571 Ila-recess: 2(a) eggplatory? I A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; Railway 44 - Work/rest rules for railway operating employees, TC 0 0-140, February 2011 :e-S-criptioin 0f Page 4 of 13 000134 Record released pursuant to the Access to Information Act/ s.20(1 Document divulgue en vertu de la oi sur I'acces a I'information 5.21 (1 Finding ID: i 771601 Pmcess: 2(d) Regulatory?RequirernentE A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; commitmentz, Work/rest rules for railway operating employees, TC 0 0-140, February 2011, Page 5 of 13 000135 5 20(1 Record released pursuant to the Access to Information Act/ - Document divulgue en vertu de la oi sur I'acces a I'information 771765 Proee?ssr -- 2(b) A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(b) clear authorities, responsibilities and accountabilities for safety at all levels in the railway company Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 1), Page 6 of 13 000136 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page? of13 000137 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information 771781 Process; 2(h) Regulatory Requirement: A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component; 2(h) systems for ensuring that employees and any other persons to whom the railway company grants access to its property, have appropriate skills and training and adequate supervision to ensure that they comply with all safety requirements; Railwaytgommitment: a General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 2011), Page8 of13 000138 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information 5.21 (1 ID: - 771786 Process: 2(d) ??033er Requirement-z . -- A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; Pa 'f a the Teamsters Canada Rail Conference Operating General Fatigue Management P1 Employees (November 2011) 35D35?fip:?ion Finding; Details: Page9 of 13 000139 Record released pursuant to the Access to Information Act/ 5-20? Document divulgue en vertu de la oi sur I'aoces a I'information Page100f13 000140 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information 5.21 (1 771831 20) Requirement; A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(i) procedures for the collection and analysis of data for assessing the safety performance of the railway company Page11of13 000141 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page120f13 000142 Record released pursuant to the Access to Information Act/ 520? Document divulgue en vertu de la oi sur I'acces a I'information 5.21 (1 Finding}Isa-rig; 771875 . Process: 2 ,EREg?ulatoryR?qui?rementzl 4 A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; Railway-Commitment: General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 1) Description of Supporting Details: Page13of13 000143 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Audit Report Railway: CP Rail Railway SMS Keith Shearer Representative: GM Regulatory Operating Practices Audit Dates: January 5, 2015 to March 6, 2015 Convening Authority: Stephanie Lines, Director, Operations Management Audit Team Leader: Beata Hart, Safety Oversight and Audit Of?cer Report date: 2015 Executive Summary An audit of the CP Rail (CPR) fatigue management plans (FMP) and in light of Safety Management System Regulations (SMS) was conducted by Transport Canada (TC) from January 5, 2015 to March 6, 2015. The objective of the audit was to evaluate and verify implementation of the Fatigue Management Plan, as de?ned by and submitted to Transport Canada. This was accomplished through a systematic, detailed assessment of railway company FMP to ensure compliance to the WRR as weil as their implementation as de?ned by the Railway. This assessment was carried out through record reviews and interviews with personnel. The following provides an overview of the ?ndings. Each one requires a corrective action Page 1 of 13 000144 Record released pursuant to the Access to Information Act/ 5-20? Document divulgue en vertu de la oi sur l'acces a l'information Introduction Pursuant to the Railway Safety Act, TC has conducted a systematic, detailed assessment of CPS policies, processes and procedures to evaluate and verify their implementation of the Fatigue Management Plans, as defined by CP and submitted to Transport Canada, and to verify development, implementation and monitoring of fatigue management methodologies as required by ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans Requirements and Assessment Guidelines?. In addition to above mentioned requirements, following components of the SMS Regulations were also used as basis of the audit: 2(b) Safety authorities, reSponsibilities and accountabilities 2(d) Compliance with applicable regulations, rules, standards and orders 2(e) Risk management process 2(h) Skills, training and supervision 2(i) Collection and analysis of safety performance data The initial audit noti?cation and the documentation request were sent to CPR on November 28, 2014 i The on-site auditing activities began on January 5, 2015 and the opening meeting was held at corporate of?ces in Calgary. During that meeting, the audit team con?rmed the scope of the audit and the proposed schedule. The audit team proceeded to review the records provided and interviewed selected members of CP Page 2 of 13 000145 3.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information management team. Subsequently, TC visited CP corporate of?ces the week of January 26';h and on March 6 to further verify records and to interview personnel. Regional veri?cation activities took place the week of January 19 (Vancouver) and March 3 (Calgary, Toronto and Vancouver). The purpose of these visits was to interview local Management and Operating employees to verify implementation of the FMP. TC recognizes special circumstances that developed due to the work stoppage caused by the union strike activity the week of February 16. The auditing activities scheduled for that week were postponed and the audit commenced the week of March 2, 2015. Closing meeting summarizing the audit activities was conducted as part of the wrap-up meeting on March 5 at the Calgary Agincourt facility. Next steps were presented but, due to the activities being performed at other facilities at the same time, no potential ?ndings were communicated. The audit team reviewed the following policies, processes and procedures, which were provided by CPR: General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 Work/rest Rules for Railway Operating Employees, as published by Railway Association of Canada and provided by CPR. Speci?c Fatigue Management Plan, Emergency Situations (March 17, 2003) Speci?c Fatigue Management Plan, 64 hours in 7 days (March 17, 2003) Speci?c Fatigue Management Plan, Work Train Service over 12 hours (March 17, 2003) RAC Work/Rest Rules, Interpretation Document (Effective June 29, 2005) A response to this audit is required within 30 days from the issue of this report, and must include a corrective action plan to address each of the ?ndings from this audit. The corrective action plan should describe activities to be completed, identify personnel responsible, and outline timelines for implementation. CPR will be responsible for submitting evidence of implementation of planned corrective actions per the timelines outlined in their corrective action plan. TC must be noti?ed of any changes to the corrective action plan. Audit Scope The scope of this audit was the implementation of the Fatigue Management Plans as de?ned by CP and in light of the requirements of ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans, Requirements and Assessment Guidelines?. Following components of the Safety Management Systems Regulations were also applicable: 2(b) Safety authorities, reSponsibilities and accountabilities 2(d) Compliance with applicable regulations, rules, standards and orders 2(e) Risk management process 2(h) Skills, training and supervision 2(i) Collection and analysis of safety performance data (since fatigue is safety-related) All records providing evidence of compliance with the above processes and all policies processes and procedures developed in support of fatigue management, dating back to January 2010 to present. Other ssues Page 3 of 13 000146 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la sur I'acces a I'information Audit Findings The audit ?ndings listed below require corrective actions. The Railway is required to provide a corrective action plan in response to each audit ?nding. 771571 Press? 4, 5: Regulatory Reduirement: A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; Railway - Work/rest rules for railway operating employees, TC 0 0-140, Februaiy 201] Page4 of 13 000147 Record released pursuant to the Access to Information Act/ s.20(1 Document divulgue en vertu de la oi sur I'acces a I'information Finding ID: 771601 4 44 Process; 2(d) Requirement; I A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; Railwaycommitment: Work/rest rules for railway operating employees, TC 0 0-140, February 2011, Description of Findin Page 5 of 13 000148 Record released pursuant to the Access to Information Act/ 320? Document divulgue en vertu de la oi sur I'acces a I'information Finding 771765 2(b) A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(b) clear authorities, responsibilities and accountabilities for safety at all levels in the railway company Commitment: General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 2011 Des nofFintling: supportingetails Page6 of 13 000149 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page7of13 000150 Record released pursuant to the Access to Information Act/ s.20(1 Document divulgue en vertu de la oi sur I'acces a I'information 5.21 (1 Finding 771781 5 Process; Training Regulatory Redhif?ment: A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component; 2(h) systems for ensuring that employees and any other persons to whom the railway company grants access to its property, have appropriate skills and training and adequate supervision to ensure that they comply with all safety requirements; RailWay c'ommiun??t: General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 l) ofFinding: Page 8 of 13 000151 Record released pursuant to the Access to Information Act/ s.20(1 Document divulgue en vertu de la oi sur I'acces a I'information Finding mg" 771786 - 1311906351.. . 2(d) Regulatory ReiCiuirementz? A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; Ram; General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 I??-Scription of Find'in Page90f13 000152 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information PagetOof13 000153 . Record released pursuant to the Access to Information Act/ 520? Document divulgue en vertu de la oi sur I'acces a I'information 5.21 (1 2(i) Finding ID: 771831 . Re?uirementit A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: - 2(i) procedures for the collection and analysis of data for assessing the safety performance of the railway company Railway Commitment: dR'lC General Fatigue Managementfl Employees (November 2011 Operating Page11of13 000154 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page 12 of13 000155 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information s.21 (1 Finding 771875 2(d) Regula - Requireni??mtzi A railway company shall implement and maintain a safety management system that inlcudes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; Commitment: General Fatigue Management Plan for Canadian Paci?c '1 conference Operating Employees (November 20} Description Page130f13 000156 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Audit Report Railway: CP Rail Railway SMS Keith Shearer Representative: GM Regulatory Operating Practices Audit Dates: January 5, 2015 to March 6 2015 Convening Authority: Stephanie Lines, Director, Operations Management Audit Team Leader: Beata Hart, Safety Oversight and Audit Of?cer Report date: 2015 Executive Summary An audit of the CP Rail (CPR) fatigue management plans (FMP) and in light of Safety Management System Regulations (SMS) was conducted by Transport Canada (TC) from January 5, 2015 to March 6, 2015. The objective of the audit was to evaluate and verify implementation of the Fatigue Management Plan, as de?ned by GP and submitted to Transport Canada. This was accomplished through a systematic, detailed assessment of railway company FMP to ensure compliance to the WRR as well as their implementation as de?ned by the Railway. This assessment was carried out through record reviews and interviews with personnel. The following provides an overview of the ?ndings. Each one requires a corrective action: Page 1 of 14 000157 Record released pursuant to the Access to Information Act/ s.20(1 Document divulgue en vertu de la oi sur I'acces a I'information Introduction Pursuant to the Railway Safety Act, TC has conducted a systematic, detailed assessment of CPS policies, processes and procedures to evaluate and verify their implementation of the Fatigue Management Plans, as de?ned by CP and submitted to Transport Canada, and to verify development, implementation and monitoring of fatigue management methodologies as required by ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans Requirements and Assessment Guidelines?. In addition to above mentioned requirements, following components of the SMS Regulations were also used as basis of the audit: 2(b) Safety authorities, responsibilities and accountabilities 2(d) Compliance with applicable regulations, rules, standards and orders 2(e) Risk management process 2(h) Skills, training and supervision 2(i) Collection and analysis of safety performance data The initial audit noti?cation and the documentation request were sent to CPR on November 28, 2014. The on-site auditing activities began on January 5, 2015 and the opening meeting was held at corporate of?ces in Calgary. During that meeting, the audit team con?rmed the scope of the audit and the proposed schedule. The audit team proceeded to review the records provided and interviewed selected members of CP Page 2 of 14 000158 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information management team. Subsequently, TC visited CP corporate of?ces the week of January 26?h and on March 6 to further verify records and to interview personnel. Regional veri?cation activities took place the week of January 19 (Vancouver) and March 3 (Calgary, Toronto and Vancouver). The purpose of these Visits was to interview local Management and Operating employees to verify implementation of the FMP. TC recognizes special circumstances that developed due to the work stoppage caused by the union strike activity the week of February 16. The auditing activities scheduled for that week were postponed and the audit commenced the week of March 2, 2015. Closing meeting summarizing the audit activities was conducted as part of the wrap-up meeting on March 5 at the Calgary Agincourt facility. Next steps were presented but, due to the activities being performed at other facilities at the same time, no potential ?ndings were communicated. The audit team reviewed the following policies, processes and procedures, which were provided by CPR: 0 General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 Work/rest Rules for Railway Operating Employees, as published by Railway Association of Canada and provided by CPR. 0 Speci?c Fatigue Management Plan, Emergency Situations (March 17, 2003) 0 Speci?c Fatigue Management Plan, 64 hours in 7 days (March?17, 2003) 0 Speci?c Fatigue Management Plan, Work Train Service over 12 hours (March 17, 2003) 0 RAC Work/Rest Rules, Interpretation Document (Effective June 29, 2005) A response to this audit is required within 30 days from the issue of this report, and must include a corrective action plan to address each of the ?ndings from this audit. The corrective action plan should describe activities to be completed, identify personnel responsible, and outline timelines for implementation. CPR will be responsible for submitting evidence of implementation of planned corrective actions per the timelines outlined in their corrective action plan. TC must be noti?ed of any changes to the corrective action plan. Audit Scope The scope of this audit was the implementation of the Fatigue Management Plans as de?ned by CP and in light of the requirements of ?Work/rest rules for railway operating employees? and ?Fatigue Management Plans, Requirements and Assessment Guidelines?. Following components of the Safety Management Systems Regulations were also applicable: 2(b) Safety authorities, responsibilities and accountabilities 2(d) Compliance with applicable regulations, rules, standards and orders 2(e) Risk management process 2(h) Skills, training and supervision 2(i) Collection and analysis of safety performance data (since fatigue is safety?related) All records providing evidence of compliance with the above processes and all policies processes and procedures developed in support of fatigue management, dating back to January 2010 to present. Other Issues Other issues to be reported here, if any. Audit Findings Page 3 of 14 000159 Record released pursuant to the Access to Information Act/ 820? Document divulgue en vertu de la oi sur I'acces a I'information s_21 (1 The audit ?ndings listed below require corrective actions. The Railway is required to provide a corrective action plan in response to each audit ?nding. 771571 Processf 2(a) A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; Railway Commitment:- - Work/rest rules for railway operating employees, TC 0 0-140, February 201 1 I Description 'ofFinding: Page 4 of 14 000160 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page 5 of 14 000161 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information 5.21 (1 Finding ID: 771601 Process; 2(a) Regulatory Requirement: following component: 2(d) systems for identifying applicable them, and of exemption; A railway company shall implement and maintain a safety management system that includes, at a minimum, the railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice commitment; :._D__e__scription of 'Fin? ng: Work/rest rules for railway operating employees, TC 0 0-140, February 2011, Page 6 of 14 000162 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information {Finding ID: 771765 3i ProceSS: 4 2(b) Regulatory a A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(b) clear authorities, responsibilities and accountabilities for safety at all levels in the railway company Railway-cammnu General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 1 Description wading; 1 Page 7 of 14 000163 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page 8 of 14 000164 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information Finding ID: 771781 Process: Training Re?nement: A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component; 2(h) systems for ensuring that employees and any other persons to whom the railway company grants access to its property, have appropriate skills and training and adequate supervision to ensure that they comply with all safety requirements; I .5 Commitment: General Fatigue Management Plan for Fanadian Paci?c and the amsters Canada Raj] Conference Operating Employees (November 2011) Page 9 of 14 000165 20 1 Record released pursuant to the Access to Information Act/ 5_ . . . . Document divulgue en vertu de la sur I'acces a I'Informatlon 771786 Process: 2(d) Regulatorychuirement: A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; Railway General Fatigue Management Teamsters Canada Rail Conference Operating Employees (November 2011) riptiOn of Finding: Page 10 of14 000166 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page 11 of14 000167 Record released pursuant to the Access to Information Act/ 5-20? Document divulgue en vertu de la oi sur I'acces a I'information Finding ID: 771831 Process: 20') -.: A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(i) procedures for the collection and analysis of data for assessing the safety performance of the railway company Page 12 of 14 000168 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page130f?l4 000169 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information 5'21 (1 Finding 771875 7 Precess: 2 -- A railway company shall implement and maintain a safety management system that inlcudes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption; Railway Commitment; iorting'Details: Page 14 of14 000170 Record released pursuant to the Access to Information ActDocument divulgueen vertu de la loi sur I'aooes?l?information Hart,Beata - . Sent: - - Wednesday, April 29, - .Boan, Susan -- [Subject - -- RE: ARC CP audit review . sr?atirhanks! - . . From: Beam-Susan - Sent: Wednesday, Apri129, 2015 2:06 PM To: Hart, Beata Subject: RE: ARC CP audit review i I. Oki-good, I I From: Hart, Beata . . . Sent: Wednesday, April '29, 2015 10:59 AM - susan; Zimmermann, Kyla; LeFort, Pierre; Couture, Paul-Simon; Nadon, Christine Subject: RE: ARC CP audit review - "Thanks so muchisue for taking the time to review. Please find my comments below - .. ?From: .Boan, SuSan Sent: Wednesday, April 29, '2015'12:50 PM A To: Hart, Beata; 'Zimmermann, Kyla; LeFort, Pierre; Couture, Christine "Subject: RE: ARC CP'audit'review .. Mil/comments .on' a "few of. Mark?s-comments. He d'id'have some good comments. 000171' '5 20(1 - - Record released pursuant to the Access to Information Act/ . - - Document divulgue en vertu de la oi sur l'acces a l'information . Sue From: Hart, Beata sent: Wednesday,-April 29, 2015 . .. To: Beam-Susan; Zimmerman'n, Kyla; LeFort, Nadon, Christine Subject: .FW: ARC CP audit review FYI comments from Mark Con-rad. EXCellent and net too many; which is greati? From: Conrad, Mark . Sent: Wednesday, April 29, 2015 10:58 AM To: Hart, Beata; Lui,-Rachel Cc:-Miller, Lines, Stephanie . Subject: FW: ARC CP audit review _Hi; added my comments directly into Rachel?s additionsabove. - Beata;" Good audit work. tea-pie of items l-wa's concerned about and noted in'the margin notes, but again, Some importantfindings-iniithis I . - . 'j . 'Thafn ks . .1 - From: Lui, Rachel - . 'SenttTuesday, 8:17 AM - . Beata; Miller, Mark;-Conrad, Mark - Lines, Stephanie 3 Subject: CP audit review - g. I Goad you for the opportunity'to proVide comments. Please find attached my cemme'nts for consideration; If'you have any questions, please don?t hesitate to let me know. Thanks again. From: Hart, Beata . . April 24,2015 1:57 PM -- . "To: Miller,- Mark; Conrad, Mark; Lui, Rachel Cc: Raitt, Blair Subject: ARC CP audit reView Hello, I I. i am contacting you as a member of the-audit re'VieW'COrnmitteie'fo'r the CP Fatigue management national audit'The ',draft of the audit report is now ready for you input. - Audit procedure specifies-a seven working days timeframe for this review, which Would brings us to Monday, May 4th.. Please let me know if this is not feas-Ebie'and if additional time is needed-I will ensure to-adjust the-schedule accordingly and obtain the necessary approvai. 3 '000172 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur l'acces a l'information Based on the comments received and their com?piexity, a meeting (Conference call) might be required to address your concerns-This wiil be'determined once ali comments are received. if, after your review, you would like a meeting nonetheless, please let me know and i will ensure to arrange one. Below, 1 included the excerpt from the audit procedure that outlines responsibilities of the review committee, I hope you?ll find it heipful. . . if you have any questions please do not hesitate to contact me. Best Regards, Beata .. -AUdit'ProCedure 3' The ARC is responSiblefo?r the following: . Audit Review "committee Reviews the audit details-and proVides comments as appropriate; Reviews-the audit report and provides feedback regarding the following: supporting evidence (in regards to the findings); additional technical advice (when applicable); format; - readability; - - consistency; and clarity in wording 000173 55.20? I I . An audit of the CP Rail (CPR) fatigue management plans (FMP), 'eensideiingagainst Safety Management System compliance to theWRR as' well as veri?y their implementation as defined by the Railway. This'assessment was carried out through record reviews, observations and interviews with perscinnel. . of?cesin Calgary. During that meeting, the audit team con?rmedthe scope of the audit and the proposed further verify records and to interview personnel. .- Vancouver). The purpose of these visits were to interview local Management and Operating employees to verify - TC recognizes the special circumstances that developed due to the work stoppage-caused by the union strike the Calgary Alyth facility. Next steps were presented but, due to audit activities still being performed at other facilities at the same time, no potential ?ndings were communicated. - Record released pursuant to the Access to Information Act/ Document divulgue en vertu _de la _Ioi sur I'accesa I'information Railway: CP Rail - Railway SMS Keith Shearer . - Representative: - GM Regulatory Operating Practices Audit'natesz' . Jammy 5, 2015 to March 6,2015 . . Convening Authority: I Stephanie Lines, Director, Operations Management Audit "Team Leader: Beat'a Hart, Safety Oversight and Audit Of?cer 2015 Report date: Regulations (SMS), Transport Canada Work Rest Rules (WRR) for Railway Operating Employees and. :Fatigue Management Plans,"Requirements and Assessment Guidelines?. was Conducted by Transport Canada (TC) from January 5, 2015 to March 6,2015. The objective of the audit was to evaluate and verify 1 - .implemeatation 01? asrsaet?dhx the V. .defmed and submitted to TranSport Canada by . a - . This was accomplished through a systematic, detailed assessment of railway co -.- . I. I. l?l P311373 .FMP to ensure . The initial audit noti?cation and the documentation request Were?Was sent to CPR on Noyember'28, 20 The on~site auditing activities began on January 542015 andthe Opening meeting-Was held at corporate schedule. The audit team then proceeded to review the interviewed selected members of the management" team. Subsequently, TC Visited CP corporate of?ces the week of January 26:21 and on March 6 to -- Regional veri?catiOn activities took place the week of January 19 (Vancouver) and March-3 (Calgary, Toronto and v: implementation of the EMP. activity the week of February 16. The auditing activities scheduled for that week were postponed and the audit commenced the week of March 2, 2015. A closing meeting summarizing the audit activities was eonducted as part of the-wrap-up meetingon March 5 at The audit team reviewed the following policies, precesses and procedures, which were previded by CPR: Page1 ?of 15 000174 I company policies, processes and procedures to evaluate them against the documentation requirements of the Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la sur I'acces a I'information 0 General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating I Employees (November 201 . I Work/ressRest Rules for Railway Operating Employees, as published by the Railway Association of Canada and provided by CPR (February 201 0 Specific Fatigue Management Plan, Emergency Situations (March 17, 2003); 0 Specific Fatigue Management Plan, 64 hours in 7 days (March 17, 2003); I - 0 Speci?c Fatigue Management Plan, Work Train Service over 12 hours (March 17, 2003), and; - RAC Work/Rest Rules, Interpretation Document (Effective June 29, 2005) Eleven ?ndings were reported as a consequence of this audit. Findings 771571 and 77-1601 were identi?ed a' De ls are provided the Findings section of this report. Detailed descriptions or those findings are provided in the Findings section of this report. The Railway is encouraged to demonstratehow they intend to enhance railway safety by previdi'n'g a corrective action pian to each of ?nding within 30 days of the issues of this audit report. The Corrective . Action Plan should reference the ransport Canada audit findings and detail the Raiiway?s proposed corrective actions to address them. Each corrective action should describe activities to be completed, identify personnel! . responsible,- and outline timelines for implementation. An example Corrective Action Plan template is attached to this reportand it may be used. Pursuant to the Railway Safety Act, Transport Canada has conducted a systematic, detailed assessment of raiIWay Regulations andtbuedfr the implementation i . procedures. - - . Audit Scope - The scope of this audit was to verify the implementatiOH of the considering the requirements of ?Work/reseRest rules for railway operating empl Management Plans, Requirements and AsSessment Guidelines? damning: oyees and ?Fatigue The foilowing components of the Safety Management Systems" Regulations were also applicabie: - 2(b) Safety authorities, responsibilities and I I - 2(d) Compliance with applicable regulations, rules, standards and orders;- 2(e) Risk management process; 2(a) Skills, training and supervision, and; 2(i) Collection and analysis of safety performance data (since fatigue is safety-related) - Page 2. of 15 000175 - Record released pursuant to the Access to Information Act/ Document divulgu? en vertu de la oi sur I'acc?s a I'information The seoge iheiudes' records providing evidence of compliance with the above proceSses and all policies; processes; and procedures developed in support of fatigue management, January 2010 to . present. 1. . _'I_Pa'ge3o'f15 000176 Record released pursuant to the Access to Information Act/ . 320(1 - . - Document divulgue en _vertu de la oi sur I'acces a I'information - A raiiway company shall implement and maintain a safety management s?yStem that includes, at a minimum, the I following cemponent: 2(d) systems for identifying applicable: . . railway safety regulations; rules, standards and orders, and the procedures for demonstrating compliance with them, andexemptions and the procedures for. demonstrating compliance with the terms or conditions speci?ed in the notice 'of - exemption Work/rest rules for railway operating employees, TC 0 0-140, February 2011' Page4of15 000177 1 Record released pursuant to the Access to Information Act/ 320? . I I I. Docoment-dIv-ulgue en vertu de la sur Iacces a IInformatIon j. 771601 3 A railway company shall implement and mamtam a safety management system that includes, at a minimum, the following component: - I 2(d) systems for identifyin'gepplicable railway safety regulations, rules, standards and orders, and'the procedures 'for demonstrating compliance with them, and; (ii) exemptions and the procedures for demonstrating compliance with the terms 'or conditions speci?ed in the Inotice of exemption; I Work/rest rules for railway operating employees, TC 0 0-140, February 201' Page5 of15 000178 . Record released pursuant to the Access to Information Act/ I 5.20Document divulg-ue- en vertu de la sur Iacces a IInformatI-on .771765 A raiiway company Shall implement and maintain a safety management system that includes, at a minimum, the following component: I 2(b) clear authorities, and for Safety at ail ievets in the railway company Page 6'of 15 . 000179 I Record released pursuant to the Access to Information Act/ Document divulgue en vertu de a_ oi sur I'aoces a I'information Page 7 of 15' 000180 - - Record released pursuant to the Access to Information Act/ . Document divulgue en vertu de la sur I'aoces a l'information s.20(1_ (1 5.21 (1 771781 2(h) - A railway company shall implement and maintain a safety management'system that includes, at a minimum, the following component; - - 2(h) systems for ensuring that employees and any other personsto whom the railway company grants access to .its property, have appropriate skilIs and training and adequate supervision to ensure that they'comply with all - safety requirements; - - . - General Fatigue Management I Teamsters Canada Rail Conference Operating Employees {November 2011),; . . Page 8 of 15 I 000181 . i . Record released pursuant to the Access to Information Act/ s_20(1 - . - Document divulgue en-Ivertu dela oi sur I'aoces I'information - 7 General Fatigue-Menagemeht Teamsters Canada Rail Conference Operating 3 Employees (November 20} Page 9 of 15 000182 Record released pursuant to the Access to Information Aot/ Document divulgue en vertu de la oi sur I'aoces a I'information Page 100f_15 -- 000183 Record released pursuant to the Access to Information Act/ .. I I . . Document divulgue en vertu de la oi sur '_aoces a I'information I. - "Page?'cfds 000184' Record released pursuant to the Access to Information Act/ . I - . Document divulgue en vertu de la oi sur I'acces a I'information 5.21 (1 771831 A railway company shall implement and maintain a safety management system that includes, at a minimum; the . - following component: - 2(i) procedures for the collection and analysis of data for assessing the safety performance of the railway company. GeneralLFatigue Management 'Plan for Canadian Paci?c and the Teamsters Canada 'Rail Conference Operating Employees'(November 2011 Page .12 of 15 000185 . - . Record released pursuant to the Access to Information Act/ 5-20? I . I I . Document dryulgue en vertu de la sur Iaoces a IInformatIon Page 13 of 15 000186 5.21 (1 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information Page 14 01?15 '000197 Record released pursuant to the Access to Information Act/ . . Document divulgue en vertu de la oi sur I'acces a I'information 771875 A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable I - . railway safety regulations, rules, standards and orders, and the procedures for demonstrating eompiianee with them; and (ii) exemptions and the procedures for demonstrating compliance With the terms or conditions speci?ed in the notice . of exemption. Genera} Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating - Emplo ees (November 2011) Page'15ot15' 000188 Record released pursuant to the Access to Information Act/ - 3-21 I I - Document divulgue en vertu de_ la oi sur l'aoces a l'information _s2unm) Beahysusan"' From; . Boan, Susan I Sent: - - 'Wednesday, April 29, 201-511:44 AM To: . - . Hart, Beata Subjectaudit review For Rachel?s comments: Page 4 to last Comments. Beata- . SentTo': Boan; Susan; Zimmermann, Kyla; LeFort, Pierre; Couture, Paui~Simon;iiNadon, Christine Subject: FW: ARC CP audit reView - - . comments from Mark C-Onrad. EX?cellent and not too many, which is great! - _'Fro_m: Conrad,_Mark Sent: Wednesday, 10:58 AM- -- . To: Hart, Beata;'Lui, Rachel Cc: Miller, Mark; Raitt, Blair; Lines, Stephanie Subject: CP 'audit- review . I 'Hi; added my comments d'i'rectlyinto Rachel?s additionsabove. A Beam;- Good andit Work; . couple at items'lwasi Concerned about and noted in the margin-netes, but again, some impertant findings in this . work.- - I - - 'f Thanks a -. Rachel - Sent: Tuesday, April '28, 2015 8:17 AM To: Hart, Be'ata; Miller, Mark; Conrad, Mark Cc: Raitt, Blair; Lines, Stephanie Subject: CP audit review - Good morning Beata, thank you for the oppOrtunity to proVide comment; Please-find attached my comments for I . . consideration.- If you have any questions, please don?t. hesitate to let me know. Thanks again. . . . .Beata Sent: Friday, April 24,- 2015 1:57 PM . - To: Miller, Mark; Conrad, Mark; Lui, Rachel Cc: Raitt, ARC audit review Hello, 000189 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur l'acces a l'information - iam Contacting you as a member of the audit review committee for the CP Fatigue management national audit. The I draft of the audit report is now ready for you input. Audit procedure Specifies a seven working days timeframe for this review,lwhich' would brings us to' 4th. Piease'let me know if this is not feasible and if additional time is needed. i will ensure to adjust the schedule accordingly and'obtain the necessary approval. Based on the comments received and their?complexity, a- meeting (conference call) might be required to address your . concerns. This will be determined once all comments arereceived. if, after your review, you would like a meeting nonetheless, please let me know and wiil ensure to arrange one. Below, .l included the excerpt from the audit procedure that outlines responsibilities of'the review committee, I hope y0u?ll find it helpful. I if you'have' any questions please do not hesitate to contact me. . Best Regards, Beata - Audit ProCedUre The ARC is responsible for the-following: - Audit Review Committee (ARC) RevieWS the audit details and provides "comments as appropriate; 0 . "Reviews the audit report and provides feedback regarding the following: 5- supporting evidence (in regards to the findings); additional technical advice (when applicable); format; readability; I consistency; and . "Clarity in wording 000190 - i . Record released pursuant'to the Access to Information Aot/ 5-20? - - Document divulgue en vertu de la loi sur l'acoes a l'information 5-20l1llcl - . Susan .. .211 . Hm: . - - Boan, Susan - Sent: . . Wednesday, April 29; 2015 11 :05 AM To: - Hart, Beata 5 Subject: RE: ARC CP audit review 'For sure. . From: Hart, Beata April 29,2015 11:04- AM . - - To: BOan,-Susan; Zimmermann, Kyla; Couture, Paul-Simon; Na'don, Christine Subject: RE: ARC CP audit review . lam glad he addressed some-Of Rachel's issues, saved us some ti_me?. 'Fromr-Boan, Susan - - .. . sent: Wednesday; PM - Hart, 'Beata; Zimmermann,? Kyla; LeFort, Pierre; Coutiire, Christine Subject: RE: ARC CP audit review . My comments on a?few of Mark?s comments. I He did have some good comments;- See- From: Hart, Beata . . 29', 2015 8:09 AM To: Beat], Susan; Zimmermann, Kyla; LeFort, Pierre; Couture; Paul-Simon; Nadon, Christine Subject: FW: ARCCP'audit review - - comments from Mark Conrad. Excellent and not too many, which is great! 000191 Record released pursuant to the Access to Information ActDocument divulgue en vertu de la loI sur lacces a llnformatlon . From: Conrad, Mark - Sent: Wednesday, April 29,2015 10:58 AM Hart, Beata; Lui, Rachel Cc: Miiler, Mark; Raitt, Blair; Lines, Stephanie Subject: FW: ARC CP audit review - 'i-li; added my'comments directly irate-Rachel?s additions above.- . Beata; Good audit work . A couple of items l-was concerned about and noted in the margin notes,- but again, some important findings in this work. - [Thanks ?From: Lui, Rachel - . -. Sent: Tuesday, April 28, 2015 8:17 AM To: Hart, Beata; Miller, Mark; Conrad, Mark Cc: Raitt, Blair; Lines, Stephanie Subject: RE: ARC CP audit review Good :morning Beata, thank you for the opportunity'to provide?comme-nts. Please find attached-my comments for consideration. if you have any questions, please don?t hesitate to let me know. Thanks again. - From: Hart, Beata - Sent-Friday, April 24,2015 1:57 PM To: Miller, Mark; Conrad, Mark; Lui, Rachel . . Cc: Raitt, Blair . Subject: ARC CP audit review . Hello, am contacting yOu as a' member of-the audit review comm'ittee'fo'r'the .CP Fatigue management national audit. The . [draft of the audit report is now ready for you input. - Audit procedure specifies a seven working days? timeframe for this review, which would brings Us to Monday, 'IViay 4th. 3. i Please let me know if this is not feasible and if additional time is needed. I will ensure to adjust the schedule accordingly and obtain the necessary approval. - - Based on the comments received and their compiexity, a meeting (conference call) might be'required to'ad'd're'ss your - concerns. This will be determined once all comments are received. If, after your review, you would iike'a meeting nonetheless, please let me know and I will ensure to arrange one. . . Below, I included the excerpt from the audit procedure that outlines responsibilities of the review committee, I hope you?ll find it helpful. . 5 If you have any questions please 'do not hesitate to contact me. Best Regards, Beata I Audit Procedure . The ARC 'is responsible for'the following: 000192 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la sur I'acces a '_information AUdit'Review committed-ARC} - Io RevieWs'the audit details'and provides comments as- appropriate; '0 RevieWs the audit report'and provides feedback-regardingthe following: suppertin'g evidence (in regards to the findings); . additional technical advice (when applicable); fornnat; ?v -readab?ny; I. consistency; and clarity in'wo'rding" 000193 . Record released pursuant to the Access to Information Act/ $.20(1 . Document divulgue en vertu de la oi sur I'acces a I'information .. H. awn? Railway: Ci3 Rail I Railway SMS - . Keith Shearer . Representative: . - . GM Regulath Operating Practices "Audit Dates: - January 5, 2015 to Match 2015 Convening Authority: . Stephanie Operations-Management Audit Team Leader: Beata Hart, Safety Oversight and Audit Of?cer . Report date: 3- 2015' An audit of the CP Rail (CPR) fatigue management plans (F MP), eensideringagainst Safety Management System. Regulations (SMS), Transport Canada Work Rest Rules for Railway Operating Employees (WRR) and :Fatigue Management Plans, Requirements and Assessment Guideiines? was conducted by Transport Canada'(TC) - from January 5, 2015 to March 6, 2015. The objective of the audit was to evaluate and verify . . implementation of assailant)! the angles de?ned and submitted to Transmit Canada by This was accomplished through a systematic, detailed assessment page railway companyis. FMP to ensure compliance to the WRR as Well as verify their implementation as de?ned by the Railway. This assessment was carried out through record reviews, observations and interviews with personnel. The initial audit noti?cation the doouln'entation request Wewas sent to CPR on November-28, 20 1 The on?site auditing activities began on January 5, 2015 and the opening meeting Was heid at corporate . Of?ces in Calgary. During that meeting, the audit team con?rmed the scope of the audit and the proposed schedule. The audit team then proceeded to review the records provided and interviewed selected members 0f the I (317?1 management team. Subsequently, TC visited CP corporate offices the week of January 26th and on March 6 to further verify recordsand to interview personnel. . . - Regional veri?cation activities took piace the week of January 19 (Vancouver) and March 3 (Calgary, Toronto and Vancouver). The purpose of these visits were to interview local Management and Operating employees to verify implementation of the FMP. . TC recognizes the special circumstances that developed due to the-Work stoppage caused by the union strike activity the week of February 16. The-auditing activities scheduled for that week were postponed and the audit commenced the weekof March 2, 2015. A closing meeting summarizing the audit activities was conducted as part of the wrap-up meeting 011 March 5 at the Calgary Alyth facility. Next steps were presented but, due to audit activities still being performed at other facilities at the same time, no'potentiai ?ndings were communicated. The audit team reviewed the following policies, processes and procedures, which were provided by . PageioHs' 000194 - . Pursuant to the Railway Safety Act, Transport Canada has. conducted a I pros Audit Scope I?l?h?e foliowing components of the Safety Management Systems Regulations We're also appiicable: I Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la loi_ sur I'acces a I'information - ?0 Genera'i Fatigue Management Plan for Canadian Pacific and the Teamsters Canada Rail Conference Operating I . Employee's (November 2011); . oi .. Work/asseRest Rules fer Railway Operating Employees, as pnblished by the Railway Aesociation of Canada gRAC1and-provided by CPR (February 2011); '0 Speci?c. Fatigue Management Plan, Emergency Situations (March 17, 2003); - 0 - Speci?c Fatigue Management Plan, 64 hours in 7 days (March 17, 2003); .0 Specific Fatigue Management Plan, Work Train Service over 12 hours (March l7 and; I 0' RAC WorkfRest Rules, Interpretation Document (Effective June 29, 2005) Eleven fmdin'gs were reported as a con-sequence of this audit. Findings 771571'and 771601 were'identi?ed a I Details are prov1ded in the Findings section of this report. - Detailed deseriptio'ns of those I-?ndings are provided in the Findings section of this report.- The Railway is encouraged to demonstrate how they intend to enhance railway safety by providing a corrective - action plan to each of ?ndings of de?ciency, within 30 days of'the issues of this audit report. The Corrective Action Plan shnuld reference the Transport Canada audit ?ndings and detail the Raiiway?s proposed corrective. actions to address them. Each Corrective action should describe activities to be completed, identify personnel . responsible, and outline timelines for implementation. An example Corrective Action Plan temptate is attached to this report'and it may be used. ematic, detailedas'sessme'nt of railway company policies,- processes and procedures to evaluate them against the documentation requirements of the . Readiness,matinee): u. edures. - The scope of this audit was to verify the implementation of the considering the requirements of ?Work/restRest rules for railway oper Management Plans, Requirements and Assessment Guidelines?. anngjemployees and- 2(b) Safety authorities, responsibilities and .accountabilities; 2(d) Compliance with applicable regulations, rules, standards and orders; 2(e) Risk management process; Collection and analysis of safety performance data (since fatigue is safety-related) Page 2 of 15 - 2(h) Skins, training and supervision, and; . 000195 . I Record released pursuant to the Access to Information Act/ . . Decument divulgu? en vertu de la sur I'acc?s a I'information The sec]; i?cludes Mag records providing evidence of cempliance With the aboVe processes and all policies; processes; and procedures developed in support of fatigue management, ?a?eg?beel?e?om January 2010 to present. Other Issues 5' I Page 3 of 15' 000196 - . . . Record released pursuant to the Access to Information Act/ . . . - . Document divulgue' en vertu de la oi sur I'acces a I'information - . Audit Findings - A railway company shat] implement and mamtain-a safety management system that includes, at'a minimum, the . .. following component: - 2(d) systems for identifying applicable: . . railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance With them, - .- and; (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed 'm't'he'noti'ce of exemption Work/rest rules for railway operating employees TC 0 0-140 February 2011 Page 4 ms 000197" i Record released pursuant to the Access to InformatiOn Act] . Document divulgu? en vertu de la sur I'acc?sa I'information A ra11way company shall implement and mamtain a safety management'system that includes; at a minimum; the following component: 2(6) systems for identifying applicable . railway safety regulations,- rules, standards and ordefs, and the procedures for demonstrating compliance with them, and; . . (ii) exemptions and'the procedures for demonstrating compliance with the terms or Conditions speci?ed in the notice I of exemption; Work/rest rules for railwav operath emolovees. TC 0 0-140. Februarv' 201 Page '5 of 15 000198 . - . . Record released pursuant to the Access to Information Act/ . . . . Document dlvulgue en vertu de la sur Iaoces a IInformatIon 771765 A railway company shall implement and maintain a-safety management system that includes, at a minimum, the following component: 2(b) clear authorities, responsibilities and accOuntabilities for safety at 2111 levels in the railway company Page 6'of15 000199 . Record released pursuant to the Access to Information Act/ . . Page 7 of15 I - .. 000200 Record released pursuant to the Access to Information Act/ Documentdivulgue en vertu de la oi sur I'acces a I'information I - A raiiw'ay'comp'any shall implem foliowing component; I 2(h) systems for ensuring that employees and any other persons to Whom the railway company grants access to its property; have appropriate skills and training and adequate supervision to ensure that they comply with ali . safety requirements; . - cut and maintaia a safety manageme?t's'ystem that includes, at a minimum, the General Fatigue Management Pian for Canadian Paci?c and the Teamsters Canada Rail Conference OperatingPage 8 of 15' 000201 - - . Record released pu_rsuant to the Access to Information ActDocoment divulgue en vertu de la IoI-sur Iaoces a Ilnformatlon I s_.2f1 (1 2(3) General Fatigue Management Pian for Canadian Paci?o arid the Teamsters Canacfa Rail Conference Operating Employees (November 201 I), .. I Page 9 of 15 '000202 . - - Record released pursuant to the Access to Information Act/ . . . Page 10 051-5 000203 Record released pursuant to the Access to Information Act/ 520(1 . - Document divulgue en vertu de la oi sur I'aoces a I'information Page '11 of 15 000204 - . I Record released pursuant to the Access to Information Actvertu delalo-IsurIaocesallnformatlon . A railway company shallimplement and maintain a safety management system that includes, at a minimum, the following component: . . - procedures for the 'coilectiOn and analysis of data for assessing the safety performance of the'railway company. Generai Fatigue Employees (NoVember 20 11 Page12of15 000205 - Page 13 0f 15 Record released pursuant to the Access to Information Act/ Document divulgu? en vertu de la oi sur I'aoces l'information '000206 Record released pursuant to the Access to Information Act/ Document divulgu? en vertu de la oi sur I'aoces a-I?information Page 14 of15 000207 . Record released pursuant to the Access to Information Act/ 520? - . . . Document divulgue en vertu de la sur l'acces a I'information . - 771875 2 - . A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: - systems for identifying applicable railway safety regulations,- rules, standards and orders, and the procedmes for demonstrating compliance with them;and. . . - . (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption. General Fatigue Management Plan for Canadlan Pacr?c and the Teamsters Canada Rall Conference Operating Employees (November 2011 Page 15 of15 _000208 - Record released pursuant to the Access to Information Act/ 5.21 (1 . - Document divulgueen vertu de la oi sur I'aoces a I?information From: . . Hart, Beata . .- Sent: Friday, April 17, 2015 12:=Boan, Susan; Zimmerr?nann; Kyla; LeFort,' Pierre; Couture, Paul-Simon . - Cc: Nadon, Christine; Raitt, Blair Subject: -- Attach me'nts: - 5-04-1 7.docx Hello, . gt had to make some additional changes to the draft report. . i We haveit nowaddressed by havmg them only In the Executive Summary section. 3 also had to combine the ExecutiVe Summary and the Introduction sections as the text p?ri'nted'inthe template is standard for introduction and it cannot be changed. The section is still there. but with the standard text and the information that Was there before was mowed to the Executive Summary (most of it some seemed tobe duplicate so - .it'was removed). I I I No centent offindin'gs 'Was changed. Please review and provide comments. Regards, Bea-ta 000209 I Record released pursuant to the Access to Information Act/ I - . Document divulgue en vertu die Ia oi surl'acces a I'information . . ?Audlt- Report-- - 'f .. - I Railway: - I .CP Rail I Railway'SMs - - Keith Shearer - Representative: GM Regulatory Operating Practices Audit Dates: I - . January 5, 2015 to March 6, 2015 Converting Authority: I Stephanie Lines,-Director, Operations Management Audit Team Leader: - Beata Hart, Safety Oversight and Audit Of?Cer - Report date: . - 2015 Executive Summary . . . An audit of the CP Rail (CPR) fatigue management plans (FMP), considering Safety Management System Regulations (SMS), Transport Canada Work Rest Rules for Railway Operating Employees (WRR) and Fatigue _Management Pians, Requirements and Assessment Guidelines? was conducted by Transport Canada (TC) from . January 5, 2015 to March 6, 2015. The objective of the audit was to evaluate and verify implementation of - the Fatigue Management Plan, as required by the WRR, and as de?ned by CP and submitted to Transport Canada. This was accomplished through a systematic, detailed assessment of railWay company FMP to ensure compliance to the WRR as Weli as their implementation as de?ned by the RaiIWay..This- assessment was carried out through record reviews, observations andinterviews with personnel. he initial audit noti?cation and the documentation request Were sent to CPR on November 28, '2014 1' eting was held atCPR?s corporate 3 of?ces in Calgary. During that meeting, the audit team con?rmed the scope-of the audit and the proposed schedule. The audit team then proceeded to review the records provided and interviewed selected members of the- management team. Subsequently, TC visited CP corporate of?ces the Week of January 26th and on March 6 to further verify records and to interview personnel. - - Regional veri?cation activities took place the week of January 19- (Vancouver) and March 3 (Calgary,'Toronto and - Vancouver). The purpose of these visits were tointerview local Management and Operating employees to verify implementation of the MP. TC recognizes the special circumstances that developed due to the work stoppage caused'by the union strike activity the week of February 16. The auditing activities scheduled for that week were postponed and the audit commenced the week of March 2, 2015. . . . A closing meeting summarizing the audit activities was conducted as part of the wrap~up meeting on March 5 at the Calgary Alyth facility. Next steps Were presented but, due to audit activities still being performed at other - facilities at the same time, no potential ?ndings were conununicated. I. I The" audit team reviewed the following policies, precesses and procedures," which Were provided by CPR: 0 General Fatigue Management'Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating - Employees (November 2011); - Work/rest Rules for Railway Operating Employees, as published by the Railway Association of Canada and provided by CPR (February 201 0' Speci?c Fatigue Management Plan, Emergency Situations (March 17,2003); 0 Speci?c Fatigue Management Plan, 64 hours in 7 days (March 17 2003); Page 1 of 15 - 000210 . Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'acces a I'information 0 Speci?c Fatigue Management Plan, Work Train Service over 12 hours (March 17, 2003), and; RAC Work/Rest Rules, Interpretation Document (Effective June 29, 2005) rt fth' (H d' 771571 Details are pr0v1ded 1n the section or this report. Detailed descriptions of those are prov1ded m-the Findings section of this report. The Railway is encouraged to demonstrate how they intend to enhance railway Safety by" providing a corrective . action plan to each of ?ndings of de?ciency, Within 30 days of the issues of this audit report. The Corrective Action Plan shouid reference the Transport Canada audit ?ndings and detail the Railway?s proposed corrective actions to address them. Each corrective action shouId describe activities to be completed, identify personnel responsible, and outiine timelines for implementation. An example Corrective Action Plan tempiate is attached to this report and it may be used. Introduction Pursuant to the Railway Safety Act, Transport canada has conducted a systematic, detaiied assessment of railway company policies, processes and procedures to evaluate them against the documentation requirements of the RSMS Regulations; and verify the implementation and effectiveness of said policies, processes and procedures. . Audit Scope The scope of this audit Was to verify the implementation of the Fatigue Management Plans as de?ned by CF, I considering the requirements rules for raiiway operating employees? and ?Fatigue Management Plans, Requirements and Assessment Guidelines?. - The follOwing components of the Safety Management Systems Regulations were also applicable: 2(b) Safety authorities, responsibilities and accountabilities; Compliance with applicable regulations, rules, standards and orders; 2(e) Risk management process; I 2(b) Skills, training and supervision, and; 2(i) Collection and analysis of safety performance data (since fatigue is safety?related) All records providing evidence of compiiance with the above processes and all policies processes and procedures developed in support of fatigue management, dating back to January 2010 to present. Other IsSues 000211 Page 3 of1'5 I Record released pursuant to the Access to Information Act Document divulgue en vertu ole Ia sur I'aooes a I'information 000212 . Record released pursuant to the Access to Information Act/ - . . . . DoCument div_u gu? en vertu de la oi sur I'acces a I'information . -. . A railway company shall implement and maintain a safety management system that includes, ata minimum, the following component: 2(d) systems for identifying applicable: railway safety regulatiOns, rules, standards and orders, and the p'rocedores for demonstrating compliance With them; and; (ii) exemptions and the'pr'ocedures for demonstrating compliance with the terms or Conditions speci?ed in the notice of exemption - Work/rest rules for railway operating employees TC 0 0-140 February 2011 'Page'4of15 - - - 000213 5,20? I Record released pursuant to the Access to Information Act/ . Document divulgue en vertu de la oi sur I'acces? I'information - .- - . I A railway company shall implement and maintain a safety management system that includes, at a minimum, the foliowing component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance-with them, and; (ii) exemptions and the procedures for demonstrating compliance with the terms or conditiOns speci?ed in the notice of exemption; . Work/rest rules for railway Operating employees, TC 0 0140, February 201 I 'Page50f515' . 000214 Record released pursuant to the Access to Information Act/ - . Document divulgue en vertu de la oi sur I'aoces a I'informatiOn . I 4 railway company Shall implement and maintain a safety management system that includes, at a minimum, the foilowing component: 2(b) clear authorities; responsibilities and accountabilities for safety at all levels in-the railway cempany General Fatlgue Managemen Canada Rail Conference Operating (N oVember 201 1 - Page 6 Of 15 .000215 Record released pursuant to the Access to Information Act/ . Document divulgue en vertu de la oi sur I'aoces a I'information Page 7 of 15 000216 'Record released pursuant to the Access to Information Act Document divulgue en vertu de la sur I'acces a 'in_formation I 261) 771781 A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component; 2 2(h) systems for ensuring that employees and any other persons to Whom the railway Company grants access to its property, have appropriate skills and training and adequate supervision to ensure that they comply with all safety requirements; General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail. Conference Operating Employees (November 201 Page 8 of 15 -. 000217 .20 1 - - Record released pursuant to the Access to Information Act/ 5- . Document divulgu? en vertu de la oi sur I'aoces a I'information I 2w) A railway company Shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable: railway safety regulations, rules, standards and Orders,- and the procedures for demonstrating compliance with them, and; . (ii) exemptions and the procedures for demonstrating compliance'with the terms or conditions speci?ed in the notice of exemption. General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 2011) Page 9 of 15 000218 Record released pursuant to the Access to Information Act/ Document divulgue en Vertu de la oi sur I'aoces a I'information 7 . sQ20(1)(c) - Pagetoof15 000219 5120(1 Record released pursuant to the Access to Information Act/ . Document divulgue en vertu de la sur I'aoces a I'information Page11 of15 000220 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la - oi sur I'acces a I'information 771831 2(i) A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: - 2(i) procedures for the collection-and analysis of data for assessing the safety performance of'the railway company. General Fatigue Management Plan for Can dia nd the Tea Employees (November 2011) Page12 of15 000221 's.20(1_ - I Page130f15 Record released pursuant to the Access to Information Act/ Document divulgue en vertu de la oi sur I'aoces a I'information ;'000222 - - . Record released pursuantto the Access to Information ActDocument divulgue en vertu de la sur Iaoces a IInformatIon 3 Page14of15' - . . 000223 I Record released pursuant to the Access to Information Act] I Document divulgue en vertu de la oi sur I'acces a I'information . A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demenstrating complianCe With them; and (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions speci?ed in the notice of exemption. General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (N ovember 201 Page1'5bf15 . _000224 I .to -the.WRR as "weil as their impiementation as de?ned by the Railway. This assessment was carried out through Record released pursuant to the Access to Information Act/ . Document divulgu? en vertu de la sur I'acc?s a I'information Audit Report Railway; CP Rail Railway Keith Shearer Representative: GM Regulatory Operating Practices Audit Dates: . January 5, 2015 to March 6 2015 I Ctmvening Authority: I Stephanie Lines, Director, Operations Management - - Audit Team Leader: Beata Hart, Safety Oversight and Audit-Of?cer RepOrt date: . Executive Summary . - - - . An audit of the CP Rail (CPR) fatigue'management plans (FMP) and in light of Safety Management System Regulations (SMS) was conducted-by Transport Canada (TC) from January 5, 2015 to March 6, 2015. The objective of the audit was to evaluate and verify implementation of the Fatigue Management Plan, as de?ned by GP and submitted to Transport Canada. - Thiswas accomplished through a systematic, detailed assessment of raiiway company FMP to ensure compliance I The following provides an overview of the ?ndings. Each one requires a corrective action: Page?t of 13 000225 - Record released pursuant to the Access to Information Act/ 5-20? . Document divulgue en vertu de la oi_sur I'acces a I'information 5.21 (1 Introdu?ctiOn . Pursuant to the Railway Safety Act, TC has conducted a systematic, detailed assesSment of CPS policies, I processes and procedures to evaluate and verify their implementation of the Fatigue Management Plans, as de?ned by CP and Submitted to Transport Canada, and to-v'erify development, implementation and monitoring of fatigue management methodologies as required by ?Work/rest rules for railway operating employees? and ?Fatigue 7Management Plans Requirements and Assessment Guidelines?. In addition to above mentioned requirements, following components of the SMS Regulations were also used as- basis of the audit: I 2(b) Safety authorities, responsibilities and account-abilities 2(d) Compliance with applicable regulations, mics, standards and orders I 2(e) Risk management process 2(h) Skills, training and supervision 2(i) Collection and analysis of safety performance data . The initial audit noti?cation and the documentation request were sent to Not/ember 28, 2014. The on?site auditing activities began on January 5, 2015 and the opening meeting was held at corporate of?cesin Calgary. During that meeting, the audit team confirmed the scope of the audit and the proposed schedule. The audit-team proceeded to review the records provided and interviewed selected members of CP Page 2 of 13' 000226 Audit Scope . . I The scope of this audit was the implementation of the Fatigue Management Plans as de?ned by GP and in light of .the requirements of ?I?Work/restrules for railway operating employees? and ?Fatigue Management Plans, Requirements and Assessment Guidelines?. . Other I.s_sues Record released pursuant to the Access to Information Act Document divulgu? en vertu de la sur I'acces a I'information management team. Subsequently, TC visited CP corporate of?ces the week of Ianuary .26?11 and on March 6 to further verify records and to interview personnel. - Regional veri?cation activities took placethe week of January 19 (Vancouver) and March 3 (Calgary, Toronto?and Vancouver). The purpose of these visits was to interview local Management and'Operating employees to verify implementation of the FMP. - TC recognize-Is special circumstances that developed due to the work stoppage caused by the union strike activity the week'of February 16. The auditing activities scheduled for that week were postponed and the audit Commenced . the week ofMarch 2, 2015. - Closing meeting summarizing the audit activities was conducted as: part of the wrap-up meeting on March 5 at" the Calgary Agincourt facility. Next steps were presented but, due to the activities being performed at other facilities atthe same time, no potential ?ndings were communicated. The audit team reviewed the following policies, processes and procedures, which Were provided by CPR: .0 General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 2011); - Work/rest Rules for RaiIWay Operating Employees, as published by Railway Association of Canada and I provided by CPR. Speci?c Fatigue Management Plan, "Emergency Situations (March 17, 2003) 0 Speci?c Fatigue Management Plan, 64 hours in 7 days (March 17, 2003) Speci?c Fatigue Management Plan, Work Train Service over 12 hours (March 17, 2003) '0 RAC Work/Rest Rules, Interpretation Document (Effective June 29, 2005) A response to this audit is required within 30 days from the issue of this report, and must include a corrective action plan to address each of the ?ndings from this audit. The corrective action plan shouid describe activities to be completed, identify. personnel responsible, and outline timelines for implementation. CPR will be responsible for submitting evidence of implementatiOn of planned corrective actions-per the timelines outlined in their corrective action plan. must be noti?ed of any changes to the corrective action plan. - Following components of the safety Management Systems Regulations were also applicable: Safety authorities, responsibilities and accountabilities 2(d) Compliance with applicable regulations, ruies, standards and orders . Risk management process training and supervision . I collection and analysis of safety performance data (since fatigue is safetyeirelated)? _'All records-previding evidenCe of compliance with the above processes and all. poiicies processes and - procedures developed in supportof fatigue management, dating back to January 2010 to present. Page 3.0f13 _000227 . - Record released pursuant to the Access to Information Act/ . - I Document divulgue en \(ertu de la oi sur I'acces a I'information - . - - 7 Audit Findings . . The audit findings listed below require corrective actions. he Railway is required to provide a corrective action plan in response to each audit ?nding. 771571 A railway company Shall implement and maintain .a safety management system that'includes, at. a minim In, the . following component: 2(d) systems for identifying applicable . . . . railway safety regulations, rules, standards and orders,- and the'procedures for demonstrating compliance with theth and .. (ii) eXefnpt'ions and the prooednres for demonSn?ating compliance With the terms or conditions speci?ed in the netice?of exemption - Work/rest rules for railway operating employees, TC 0 0-1'40, Febi'uary 2011 Page 4 of 13 000228 . - - - - . - Record released pursuant to the Access to Information Act/ . 520(1 . - . Document divulgue en vertu de la sur I'acces a ?information . I 771601 A railway company shall implement and maintain a safety management system that includes, at a minimum, the following component: 4 2(d) systems for identifying applicable railway safety regulations, rules, *standarcis and orders, and the'procedure's fer demonstrating cempliance'with them,and - - (ii) exemptions and the procedures for demonstrating compliance with the terms or conditions specified in the notiCe 3 of exemption; - . Work/rest rules for railway operating employees TC 0 0-140 February 2011 Pagesofis - .. 000229 . Record released pursuant to the Access to Information Act/ 5-20? . . a Document divulgue en vertu de la oi sur I'acces a I'information A railway company shall implement and maintain a safety management system that includes, at a minimum the - foliOwing compenent: clear authorities,- reSponsibilities and accOuntab?ilities for Safety at all levels in the railway cempany General Fatigue Management 1? amstersCanada Rail Conference Operating Employees (November 2011) Page6 000230 I Record" released pursuant to the Access to Information Act/ . Document divulgu? en vertu de la sur I'aco?s a I'information' Page 7 of '1 3 000231 3 - Record released pursuant to the Access to Information Act . .3520? I - - Document divulgue en vertu de la sur l'acces a I'information I Tsa21(1xb)" 771781 . Training . A railway company shall implement and maintain .a safety management system that includes, atta minimum, the following component; . 2(h) systems "for enSuring that employees and any other persons to'whom the railway company grants access to I its property, have appropriate skills and trainingand adequate supervision to ensure that they comply with all safety requirements; - - General Fatigue Management Plan for Canadian Paci?c and the feamsters Cainada Rail Conference Operating -: Employees (November 2011), Page 8 Of. 1 3 -- - 000232 . . - - . - Record released pursuant to the Access to Information Act/ 5120(1 Documentdivulgue en vertu de la sur I'acces-a l'information I . railWa'y companyshall implement and maintain a safety management system that includes, at-a minimum, the follOWing component: for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demons-Hating. compliance With them, and (ii) exemptions and the precedures for demonstrating compliance with the terms or canditions speci?ed in'the notice . - of exemption; General _-Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 2011) - __Page 9 of.13 "3000233 . Record released pursuant to the Access to Information Act 3-20? . - - Document divulgue en vertu de la oi sur I'aoces a I'information {Page 10 of 13 000234 . Record released pursuant to the Access to Information Act/ -s.20(1 - I . I Document divulgue en vertu de la sur I'acces a I'information . . is.? 771831 A railway company shall implement and maintain a safety management system that includes, at a minimum, the - following component: 2(1) procedures for the collection and analys' of data for assessing the safety performance of the railway company General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 2011) Page11 of13 .000235 .- . - Record released pursuant to the Access to Information Act/ 320(1 Document divulgue en vertu de la oi sur I'aoces a I'information I Page 12 of13 000236 2 -- Record released pursuant to the Access to Information Act/ . . .. I 5.20Document drvulgue en vertu de la sur Iacces a [Information I . 771875 2(a) i A railway company shall implement and maintain a safety management system that inleudes,- at minimum, the following component: 2(d) systems for identifying applicable railway safety regulations, rules, standards and orders, and the procedures for demonstrating compliance with them, and . (ii) exemptions and the procedures for demonstrating Compliance with the terms or Conditions speci?ed in the notice of exemption; General Fatigue Management Plan for Canadian Paci?c and the Teamsters Canada Rail Conference Operating Employees (November 201 . Page 1.3 of13 - 000237 Page 238 is withheld pursuant to sections est retenue en vertu des articles of the Access to Information Act de la Loi sur l?acces a l?information Pages 239 to I a 240 are withheld pursuant to sections sont retenues en vertu des articles of the Access to Information Act de la Loi sur l?acces a l?information