The North County Transit District (NCTD) has teamed up with the National Aeronautics and Space Administration (NASA) and the Federal Railroad Administration (FRA) to add an extra level of safety for its staff, contractors and the public. On August 1, 2019, NCTD entered into a partnership with NASA, the FRA, Bombardier Transportation USA, Inc., and the International Association of Sheet Metal, Air, Rail and Transportation Workers (SMART) to participate in the Confidential Close Call Reporting System (C3RS) program.
C3RS is designed to improve railroad safety by collecting and analyzing reports that describe unsafe conditions or events in the railroad industry. Staff and contractors can report safety issues or “close calls” voluntarily and confidentially. A close call is any condition or event that may have the potential for more serious safety consequences such as a blue flag not removed after releasing railway construction equipment or failing to provide proper track protection during track maintenance. By analyzing these events, potential life-saving information can be obtained to help prevent more serious incidents in the future.
NASA took the lead on this program after developing and managing the highly successful Aviation Safety Reporting System (ASRS) which began in 1976. ASRS has received over 1.2 million confidential reports from the aviation community resulting in numerous contributions to aviation safety. As an independent and respected research organization that does not have regulatory or enforcement interests, NASA serves as an objective and trustworthy recipient of reports submitted by railroad professionals.
By identifying close calls on or around the railroad tracks, participating agencies can identify why close calls may occur, recommend and implement corrective actions, and evaluate the effectiveness of any such action that was implemented.
C3RS is in addition and complementary to the many existing safety programs that NCTD currently has in place such as Positive Train Control, which is designed to prevent train-to-train collisions, derailments caused by excessive train speed, train movements through misaligned track switches and unauthorized train entry into work zones.
“Safety at NCTD is our top priority,” explains Matthew Tucker, NCTD Executive Director. “Having the opportunity to partner with a highly successful organization such as NASA to enhance our safety protocols was an easy decision for NCTD.”
Confidentiality is a key element of the C3RS program. Railroad personnel can submit reports when they are involved in or observe an incident or situation in which railroad safety might be compromised. All report submissions are voluntary. Reports sent to C3RS are held in strict confidence, and individuals who report are provided waivers from carrier discipline and FRA enforcement of qualifying events.
“Because of NASA’s strict confidentiality policy for these reports, it’s more likely that we’ll get accurate details about the incident,” says NCTD’s Chief Operations Officer-Rail Eric Roe. “Those details can lead to new safety measures that make the tracks safer for everyone on and around the rails.”
C3RS includes partners Bombardier Transportation and SMART. Bombardier Transportation is NCTD’s rail operations and maintenance contractor. SMART is the union that represents the conductors and engineers on NCTD’s San Diego Subdivision.
NCTD has become the ninth railroad carrier to participate in the C3RS program since its 2007 inception. Other participants include Amtrak, Long Island Rail Road, MBTA/Keolis, Metra, Metro-North, New Jersey Transit, SEPTA, Strasburg Rail Road, Denton County Transportation Authority, North Shore Railroad Group, Belt Railway of Chicago – Operations and Belt Railway of Chicago Non-Ops. FRA is currently accepting new carriers into the program.
In a press release, Southeastern Pennsylvania Transportation Authority (SEPTA) signed an Implementing Memorandum of Understanding (IMOU) with SMART TD Local 61, BLET and the Federal Railroad Administration (FRA) for the Confidential Close Call Reporting System (C3RS). Below is SEPTA’s press release:
PHILADELPHIA (December 12, 2016) – SEPTA, the Brotherhood of Locomotive Engineers and Trainmen (BLET), SMART United Transportation Union-Local 61 (SMART-UTU) and the Federal Railroad Administration (FRA) today signed an Implementing Memorandum of Understanding (IMOU) for the Confidential Close Call Reporting System (C3RS).
As a C3RS site, SEPTA’s railroad conductors and engineers will be able to anonymously report near misses and unsafe conditions without fear of repercussion. SEPTA joins Amtrak, New Jersey Transit, Metra (Chicago), MBTA/Keolis (Boston), Long Island Railroad, Metro North and Strasburg Railroad (Strasburg, Pa) as carriers with C3RS IMOUs.
“Building a strong safety culture is a key organizational goal for SEPTA. We are always exploring ways to expand and enhance our programs,” said SEPTA General Manager Jeffrey Knueppel. “As a C3RS site, we will be made aware of situations that we might not have been previously alerted to so that we can take action to prevent accidents and protect our employees and passengers.”
Under the C3RS system, SEPTA’s engineers and conductors will be able to submit a safety problem or close call online or through U.S. mail to the National Aeronautics and Space Administration (NASA). NASA, acting as an independent third party federal agency, gathers and analyzes all data for C3RS, removes employees’ names and contact information (these are required for the NASA portion of the investigation) and then returns the reports to a peer review team comprised of SEPTA managers, the unions and FRA for review and action.
“We are looking for conditions or close calls other than accidents or injuries that might not otherwise be reported to the FRA,” said SEPTA Assistant General Manager of System Safety Scott Sauer. “We are asking employees to report events that we might not otherwise know about, the warning signs and precursors that could lead to major safety risks and accidents.”
“C3RS, along with PTC [Positive Train Control] implementation, which is nearly complete on SEPTA territory, will greatly improve the safety of our system,” Knueppel said.
“Previously, employees may have been hesitant to report a close call, fearing disciplinary action for themselves or colleagues,” said Sauer. “When NASA returns the report to the peer review team, it is completely scrubbed of any employee information. We never know who submitted the information to NASA.”
And the result, according to the Federal Railroad Administration, is a significant reduction in rail workplace derailments that too often lead to serious injury and death — plus, as a bonus, better labor/management relationships and improved operational performance.
We’re talking about four pilot projects called Confidential Close Call Reporting System (C3RS), whose core value is that railroaders don’t intentionally make mistakes, and the most effective means of correcting workplace errors that have the potential to cause death, injury and accidents is to investigate the cause in a non-judgmental environment.
In a review of C3RS pilot projects on Amtrak, Canadian Pacific, New Jersey Transit and Union Pacific, the FRA also determined they result in supervisors becoming “more fair and cooperative” and placing a greater value on safety relative to productivity, fewer discipline cases, and workers more willing to raise safety concerns with management.
C3RS is a collaborative effort involving the FRA, carriers, the UTU and the Brotherhood of Locomotive Engineers and Trainmen.
The pilot projects encourage engineers, conductors, trainmen and yardmasters to report — without fear of discipline or FRA enforcement action, even if rules violations are involved — close calls that may have resulted in accidents or injuries.
All C3RS reports by employees are collected anonymously and kept confidential. With names and locations masked, a C3RS peer review team recommends corrective action, such as improved training, changes in physical plant, changes in existing federal safety laws or regulations, changes in carrier operating rules, and improved training and/or education.
Examples of close calls include varying levels of risk, such as leaving pieces of equipment unsecured, improper blocking, operating trains beyond track authority, or violating operating rules.
UTU International Vice President John Previsich spearheads the UTU involvement in the four C3RS pilot projects – systemwide on Amtrak and New Jersey Transit, and at CP’s Portage, Wis., yard, and UP’s North Platte, Neb., yard.
At UP, which has the most experience with C3RS, the pilot project has led to reformatting track warrants so they are easier to read, and with a UP officer observing that C3RS “is helping UP move from a blame culture to one that bridges communication gaps between employees and management.”