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WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION RAILROAD WALKWAY INSPECTION PROCEDURES

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Page 1: Walkway Inspection Procedures · Web viewInspectors will perform a follow-up inspection at locations where a defect was issued to ensure it has been remedied and that the walkway

WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION

RAILROAD WALKWAY INSPECTION PROCEDURES

Revised – June 2019

Page 2: Walkway Inspection Procedures · Web viewInspectors will perform a follow-up inspection at locations where a defect was issued to ensure it has been remedied and that the walkway

Railroad Walkway Inspection ProceduresRevised June 2019

TABLE OF CONTENTS

Section Page

Application of Procedures ...…………………………………………………………………….. 3Assignments …………………………………………………………………………………….... 4Inspection Process ………………………………………………………………………………. 5Time Frames and Enforcement ………………………………………………………………....7Appendix 1 – UTC Walkway Rules ……………………………………………………………. 8Appendix 2 – Walkway Inspection Form ……………………………………………………… 10Appendix 3 – Walkway Defect Notice …………………………………………………………. 13Appendix 4 – Sample Defect Photo .…………………………………………………………... 15

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Page 3: Walkway Inspection Procedures · Web viewInspectors will perform a follow-up inspection at locations where a defect was issued to ensure it has been remedied and that the walkway

Railroad Walkway Inspection ProceduresRevised June 2019

APPLICATION OF PROCEDURES

Walkway rules in WAC 480-60-035 (see Appendix 1) and these procedures do not apply to areas outside of a rail yard. Utlities and Transportation Commission (UTC) jurisdiction is limited to walkways within rail yards.

Definitions:

Yard – A system of tracks, other than main tracks and sidings, used for making up trains, storing cars, and other purposes. Under this definition the UTC considers a yard to be two or more tracks not including mainline(s) and siding(s).

Walkway – A walkway is defined as any area that meets any of the four following criteria:

a. An area measuring four feet around switch stands within a rail yard along a switching lead. For the purpose of these procedures, a fixed derail is considered a switch.

b. The area between tracks, excluding between the rail, from the switch to the clearance point of the connecting track.

c. An area measuring five feet from the outside edge of the rail between switches, along a switching lead, or other area within a yard that a walkway is traversed over multiple times within a shift to perform switching or similar work related tasks, if the area is such that an employee is required to walk between switches several times in a single day to perform duties associated with the track.

d. Any other area where an employee is required to perform duties associated with a track, trestle or bridge several times in a single day.

Walkway rules in WAC 480-60-035 and these procedures do not apply to the ground between the rails of each track beyond the clearance points. They also do not apply to the ground alongside tracks, even within a rail yard, at locations where railroad workers may be required to walk, but are not required to perform switching activities.

Reasonably Smooth Surface – A walkway that has an elevation approximately level with the tops of the ties, but not above the rail. Elevation must not exceed two inches between the tops of the ties and the walkway material. A reasonably smooth walkway is free of holes, debris, and other slip, trip, and fall hazards that pose a risk to a railroad employee or anyone that may be traversing over the walkway.

Sufficiently Wide – A walkway is considered sufficiently wide if it measures four feet in any direction around a switch stand and five feet from the outside edge of the rail along the area between multiple switches (e.g. on a switching lead) if the geography of the area allows.

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Railroad Walkway Inspection ProceduresRevised June 2019

ASSIGNMENTS

Walkway inspections will be assigned to UTC rail safety inspectors (Inspectors) as follows:

Routine Inspections – Inspectors will inspect walkways within each yard at least once every three years.

Complaints – When a complaint is received, the Rail Safety Supervisor (Supervisor) will issue an inspection assignment to an Inspector to determine if walkway defects exist.

Follow-up Inspections – Inspectors will perform a follow-up inspection at locations where a defect was issued to ensure it has been remedied and that the walkway is in compliance with WAC 480-60-035. The railroad must provide a photograph of a remedied defect to UTC. The Inspector may waive a follow-up inspection if he or she determines the photograph sufficiently reflects the defect is corrected.

Locations found to contain an abundance of defects or serious defects that pose an immediate risk to employees will require a follow-up inspection.

Follow-up inspections may also be performed on known problem areas. A ‘known problem area’ is a walkway or series of walkways that Inspectors have identified as out of compliance with the regulations without a subsequent correction, or a yard that has previously contained multiple violations of the walkway regulations. Known problem areas will require additional emphasis and inspections until the yard comes into full compliance with the regulations.

Random Inspections – Inspectors may inspect walkways at random or while conducting other rail safety business. Random inspections are designed to prevent railroads from expecting a defined inspection pattern and are performed in addition to routine inspections.

Notification Procedure

Inspectors will contact the railroad seven calendar days prior to a routine or follow-up inspection to advise the railroad that an Inspector will be on the property to perform a walkway inspection. Prior to a random inspection, Inspectors will attempt to locate and contact local railroad staff or management to accompany them.

If the inspection originates from a complaint, Inspectors may contact the party who complained and invite them to attend the inspection if appropriate. The railroad will be notified at least one day in advance that an Inspector will be on site and all complaints will be investigated within seven business days from the day the complaint is received.

Inspectors are encouraged to perform walkway inspections accompanied by a railroad representative to allow for a mutually beneficial relationship with the railroad to promote compliance and understanding. If the railroad fails to respond or does not wish to participate, the inspection will proceed as planned.

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Railroad Walkway Inspection ProceduresRevised June 2019

INSPECTION PROCESS

1. Prior to a walkway inspection, Inspectors will:

a. Gather appropriate information before conducting the inspection, such as:i. Review previous inspection reports.ii. Review previous or current complaint information; gather additional

information if needed.iii. Obtain information from Inspectors who previously inspected the walkway.iv. Discuss unusual situations with the Supervisor.

b. If the assignment originates from a complaint, contact the complainant and the railroad representative. Provide a courtesy notification that an inspection will take place and invite both parties to attend. Each may or may not attend.

2. Upon arrival, Inspectors will:

a. Park clear of the railroad tracks at a safe location. Use safety skills during each inspection.

b. Use appropriate personal protective equipment.

c. Gather all necessary inspection materials and equipment.

d. Always expect train movement on nearby tracks.

e. Stay clear of tracks whenever possible.

f. Check in with the railroad representative in person or by phone if he or she is available. This could include the yardmaster, roadmaster, trainmaster, supervisor, manager, or other official.

g. Perform a briefing with any railroad employees working in the area to include the work being performed and any potential hazards or conflicts.

3. During a walkway inspection, Inspectors will:

a. Fill out the Walkway Inspection Form for each yard inspected (see Walkway Inspection Form at Appendix 2), to ensure the walkway is in compliance with WAC 480-60-035.

b. Take photos of any defective walkway conditions. Inspectors will use identifying markers to pinpoint the location of a defect, a sieve to show the size of the ballast or walkway material, and a ruler or tape measure to show where measurements are out of compliance.

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Railroad Walkway Inspection ProceduresRevised June 2019

c. Take notes and document information about the walkways and other surroundings that are relevant to the inspection.

d. Discuss findings with railroad representative if available.

4. After a walkway inspection, Inspectors will:

a. Record the inspection in UTC’s rail database to include a copy of the Walkway Inspection Form and photos of defects identified, if any.

b. Distribute the Railroad Walkway Inspection Form Defect Notice (see Appendix 3), the completed Walkway Inspection Form, a copy of WAC 480-60-35, and supporting photos to the appropriate railroad contacts by email. If an email address is not available, the documents will be sent by mail.

c. If no defects exist, notify the railroad and record the contact in the database in the “Assignment Comment” box on the first screen of the assignment.

d. If the inspection resulted from a complaint, notify the party that submitted the complaint and report findings.

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Railroad Walkway Inspection ProceduresRevised June 2019

TIME FRAMES AND ENFORCEMENT

All Inspections

Within seven calendar days of the inspection date, Inspectors must record the results of the inspection in UTC’s Rail Database and officially notify the railroad of any defects.

Complaint Inspection

If the inspection originates from a complaint, Inspectors must complete the inspection within seven calendar days from the date of issuance of the assignment. If there is an imminent safety issue, the Supervisor may require Inspectors to perform an inspection immediately.

Enforcement

Inspectors will adhere to UTC’s rail safety enforcement policy for all issued defects. To promote compliance, Inspector discretion allows technical assistance to be provided for educational purposes in lieu of a defect notice. If a defect is issued, the railroad contact will be notified of the defect. The railroad has 30 days to respond with actions or planned actions to correct the defect. This response must include the date the corrections were made or are planned to be made, and photos of the corrected defects.

If a response is not received from the railroad, the Inspector will send a second notification after 30 days. The railroad will have an additional five business days from the second notification to respond. If a response is not received, the matter will be referred for enforcement. A compliance letter will be issued, which may lead to administrative penalities if the defect is not corrected.

In the event that a defect poses an immediate threat to employee or public safety, a seven-day notice may be issued in lieu of the 30-day notice described above.

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Railroad Walkway Inspection ProceduresRevised June 2019

APPENDIX 1 – UTC Walkway Rules

WAC 480-60-035 - Walkways.1. Walkways must be provided in yards where employees regularly work on the ground.

2. Ease and safety of walking are the primary considerations for providing walkways. Ease and safety of walking and adequate track drainage are the primary considerations for selecting surface materials. Accordingly, walkways required by this rule must have a reasonably smooth surface and be maintained in a safe condition, without compromising track drainage. Any of the following are suitable surface materials:

a. Crushed material may be used for walkways. The material must not exceed one and one-half inches in size. The term "one and one-half inches in size" has a specialized meaning. That meaning can vary from company to company within the industry. For purposes of this rule, the term will have the following meaning (note: Percentages refer to weight measurements):

100 percent of the material will pass through a one and one-half inch square sieve opening.    

90 to 100 percent of the material will pass through a one inch square sieve opening.

40 to 80 percent of the material will pass through a three-quarter inch square sieve opening.

15 to 60 percent of the material will pass through a one-half inch square sieve opening.

0 to 30 percent of the material will pass through a three-eighths inch square sieve opening.

0 to 10 percent of the material will pass through a #4 sieve (standard nomenclature in the industry).

0 to 5 percent of the material will pass through a #8 sieve. 0 to 0.5 percent of the material will pass through a #200 sieve.

Note: Smaller crushed material is preferable. It should be used where drainage and durability issues do not arise. Material that is three-quarter inch or less in size is recommended for switching leads in yards.

b. Walkway surfaces may also be made of asphalt, concrete, planking, grating, or other similar material suitable for walking.

c. Native materials may be used for a walkway surface if the materials provide a surface that is reasonably smooth and safe.

3. Walkways must not have a grade or slope in excess of one inch of elevation for each eight inches of horizontal length in any direction, unless the geography of the area makes this impracticable.

4. Walkways must be kept clear of vegetation, debris, mud, and other obstructions that constitute a hazard to railroad employees working on the ground. Standing water must be removed from walkways as soon as reasonably possible.

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Railroad Walkway Inspection ProceduresRevised June 2019

5. When walkways are removed or damaged due to construction or emergencies, they must be restored within thirty days after construction is completed or the emergency ends.

6. Walkways must be sufficiently wide to allow employees to safely perform all duties associated with the use of the walkways.

7. Walkways on bridges and trestles existing on (effective date of this rule), must not be permanently removed without approval from the commission. Permission must be obtained by the process set forth in WAC 480-60-020. Walkways on bridges or trestles that are temporarily removed or damaged due to construction or emergencies must be restored within thirty days after construction is completed or the emergency ends.

8. (8)(a) Unless the commission identifies a serious safety condition on a walkway, Class I railroads must bring their walkways into compliance with this section within one year of the effective date of these rules, and Class II and Class III railroads must bring their walkways into compliance within five years of the effective date of these rules.

a. If a railroad believes it will experience a serious financial hardship in bringing its walkways into compliance within the time allowed, it must submit to the commission in writing, an alternate proposal for bringing its walkways into compliance. The commission may grant an extension of time following a review of the railroad's alternate walkway compliance proposal.

[Statutory Authority: RCW 81.04.160 and 80.01.040. 00-04-011 (Order No. R-469, Docket No. TR-981101), § 480-60-035, filed 1/21/00, effective 2/21/00.]

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Railroad Walkway Inspection ProceduresRevised June 2019

APPENDIX 2Walkway Inspection Form

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Railroad Walkway Inspection ProceduresRevised June 2019

APPENDIX 3Walkway Defect Notice

Railroad Walkway InspectionDefect Notice

A recent inspection of the walkways in your railroad yard found defect(s) that need to be corrected. Please review this Railroad Walkway Inspection Defect Notice (Notice) and respond within 30 days with the date the defects were corrected, as provided beginning on page 2 of this Notice.If corrections cannot be made within 30 days, you must contact inspector (inspector name) (UTC) by email or telephone with an explanation and commitment date for future corrections, as follows: Email (email address), Phone (phone number). If you fail to respond within 30 days or to correct the defects within a reasonable time, commission staff may recommend that the commission take enforcement action which may include monetary penalties for violation of commission rules.If you have comments, you may enter them here

Date Signature and Title

Assignment #: (Assignment #) Railroad Yard: (Name of Yard)Date of Inspection

(Date)

Inspector: (Inspector Name) (UTC)

Railroad Contact: (RR Contact Name)

Railroad Company:

(Name of Railroad)

Please see next page for defect details.

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Railroad Walkway Inspection ProceduresRevised June 2019

Questions? Contact (Inspector Name) (UTC) at phone: 360-(Tel #) or email: (Inspector email address).

DEFECT(S) TO BE CORRECTEDRail Yard Name: (Name of Yard) Walkway Location: (Location of Defect)RCW/WAC: WAC 480-60-035Inspection Date: (Date) Notification Date: (Date)

Defect Type: (Desciption)Defect Detail:(e.g. Walkway has a slope in excess of 1” in elevation for each 8” of horizontal length).Defect Comments:(e.g. Slope is too steep. It should be no more than one inch per foot.

Correction was completed on:(Date)

Comments:

Return all pages to the address listed below.

(Please Fold and Staple)Rail SafetyWashington Utilities and Transportation Commission

P.O. Box 47250

Olympia, WA 98504-7250

(Please Fold and Staple)Assignment #: (Assignment #)Staff Assigned: (Staff Name) (UTC)Responsible Party:

(Railroad Name)

Contact Name: (Contact Name)

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Railroad Walkway Inspection ProceduresRevised June 2019

APPENDIX 4 Sample Defect Photo

The following photo represents a walkway that is out of compliance per WAC 480-60-035(2) because it does not provide a reasonably smooth surface as defined in these procedures. The elevation between the tops of the tie and the walkway material exceeds 2 inches creating a potential tripping hazard for railroad employees.

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