RAILWAY SAFETY ACT REVIEW

Transcription

1 RAILWAY SAFETY ACT REVIEW 2007 Submission for Teamsters Canada Rail Conference Division 320 (CP Rail employees at Vancouver, Port Coquitlam, Mission, Roberts Bank in British Columbia) Submission prepared by Gerry Ranson, Legislative Representative on behalf the membership of TCRC Division 320 Contact: Western Drive Port Coquitlam BC. V3C 2W9 Railway Safety Act Review 2007 Page 1

2 Teamsters Canada Rail Conference Division 320 Submission Regarding the Railway Safety Act Review 2007 This submission is on behalf of members of TCRC Division 320 who are employees of Canadian Pacific Railway and work in the Vancouver Service Area CP Cascade Subdivision and CN Yale Subdivision as Locomotive Engineers, Conductors, Trainpersons and Yardpersons. Any opinions and/or views made in this submission are the views of those members and/or the representative acting on their behalf, they are not intended or should be accepted as views of any other part of the TCRC or any other person outside the jurisdiction of TCRC Division 320. TCRC Division 320 represents some 350 railway operating employees working out of Vancouver, Port Coquitlam, Roberts Bank/Delta Port, and Mission City in British Columbia. We operate freight trains and passenger trains (West Coast Express), road switchers, yard engines, and remote control locomotive systems (RCLS), over the Cascade, New Westminster, Mission Subdivisions as well as the CN Yale Subdivision and BC Rail Port Subdivision. Our submission to the Advisory Panel will deal with railway structures that protect trains and employees, training and qualification of operating employees, conditions employees are required to work in and Transport Canada procedures. We do not intend to criticize any one person by our comments or facts we are providing, but hope to achieve a restructured Act to ensure safety on the railway far into the future. It may also assist the Panel, to understand our comments and the point of view we are trying to make if we explain the operation TCRC Division 320 members work in. The CP Cascade Sub. runs from North Bend BC, through the Fraser Canyon, into the Port of Vancouver, currently ending at Waterfront Station Mile 127. We also operate over the CN and BNSF trackage through the Fraser Canyon and throughout the Greater Vancouver Area. The CN Yale Sub runs, for the most part, on the south side of the Fraser River while the Cascade Sub. runs on the north side. In 1998 CP and CN commenced what was called Pilotless Detouring between Kamloops and Vancouver, whereby in cases of line blockages, trains of both railways could be routed over one line until the blockage was cleared up. Any employees working in unassigned service went through short 2 hour training session, explaining the differences in the rules of each railway. We also familiarized over the other railway s territory. In 2000 the railways agreed to commence a Directional Run Zone (DRZ) operation. The DRZ is from Coho/Nepa, mile 54 CN Ashcroft/CP Thompson Subs, through Boston Bar/North Bend to Matsqui Junction/Mission mile 87 CN Yale/CP Cascade Subs. In 2003 the railways further agreed to enter into an agreement of Co Production (train trades) allowing easier and timelier delivery of traffic to the Vancouver Port. Current operations entail all trains destined for the south side of Vancouver Port to be handled by CP Crews from CN Boston Bar to Vancouver and back to CP North Bend. Likewise CN crews handle all traffic destined to the north side of Vancouver Port. In other words operating employees working in unassigned service for CP Rail run 60% on CP track and 40% on CN track, they operate 70% CP trains and 30% CN trains. This submission is not about statistics or reports; it is made to give the perspective of railway safety from the men and women that work in the railway day in and night out. Railway Safety Act Review 2007 Page 2

3 Mandate of Railway Safety Act Advisory Panel We will try to focus our submission on several of the Panel s mandate. 1.1 Roles and responsibilities: We will address this issue throughout our submission. 1.4 Human factors, safety awareness and public information. training and qualification employee fatigue drug testing, we believe the current law addresses this issue. We are opposed to any form of random testing. This is our position and will not be addressed further. labour relations issues affecting the railway. Most people would like to ignore this issue or not connect safety and labour relations. We intend to explain why poor labour relations or abuse of the collective agreement does affect safety. RSA Part 1 Construction or Alteration of Railway Works And Key Issues to be Explored; Have issues arisen in determining what sound engineering principles are required? Is there a need to define sound engineering principles in the RSA? Is it possible to define sound engineering principles? Portions of the CP and CN track through the Fraser Canyon and Valley are positioned on or near very steep and high embankments and mountain sides. Both railways have a series of signaling and warning devices to alert trains and engineering personal of slides and slip outs. In the last few years there has been a definitive increase in the number and severity of land movements obstructing both railways. In the Panel s Consultation Guidance Document just one of the more dramatic accidents is mentioned. There have been several other situations where trains have been derailed because of land slides or come into contact with such slides. To mention just a few (dates may not be accurate): 1996 Mile 103 CP Cascade Sub, CP Crew on CP Westbound train, 30 mph hits large mudslide, no injuries. (see appendix 01) September 2005 Mile 51 CP Cascade Sub, CN Eastward Train with CN crew enters sharp curve at 45 mph, hits large rocks that have fallen from the bluff next to the track locomotive and tens cars derail, locomotive goes over 30 foot bank to shoreline of Fraser River. Crew had to be rescued, minor injuries sustained. January 23, 2006 Mile 99.8 CP Cascade Sub, CP Westbound train, with CP Crew, 45 mph, hit mud and rock slide, locomotive derailment and minor injuries. (see appendix 02) November 2006 Mile 28 CP Cascade Sub CN Eastward train with CN crew enters sharp curve at 40 mph, hits large rocks and debris that have fallen from the bluff next to the track, locomotive and several cars derail, locomotive goes over 150 foot bank to the edge of the Fraser River. Crew trapped and later rescued, minor injuries sustained. (see appendix 03) March 2007 and prior, Mile 3 CP Cascade Sub. CP crew on CN Eastward train comes upon large landslide, no injuries. Slide occurs after several days of debris and falling rock activity and reports received. Slides have been occurring in this area for many years. (see appendix 04, shows slide in area 2003) Railway Safety Act Review 2007 Page 3

4 March 2007 Mile CP Cascade Sub. CP Crew on CP Westward train, 30 mph, struck by mudslide 30 cars behind locomotive. Train went into emergency, no derailment or injuries. This occurred after several days of minor slide activity (5 6 slides over two weeks). There are many more slides and train contacts with such, as well there have been others on the CN Ashcroft and CP Thompson Subs, (see appendix 05). We will not hazard to guess why we are seeing this increase of slide activity and do not suggest proper engineering work is not taking place. We are cognizant certain geographic anomalies cannot be detected. We do recognize the extreme weather patterns in recent years may have an impact. What needs to be addressed is CP s warning and detection system. Simply stated; compared to CN improvements in recent years, in the same territory, CP s systems are archaic. In fact speaking as a 28 year railroader CP is using the same technology they have since our fathers began railroading; wires on poles, connected to the CTC system. Compare this to CN; they have installed slide fences connected to talker systems that immediately broadcast a radio emergency message if the lines are broken. They have also installed fiber optic land movement detection systems to detect roadbed slip outs. CP has not initiated any new warning systems, even with the increase of mishaps. Our Local Workplace Health and Safety Committee have tried to address this, but only get rebuked with cost restrictive responses. Of particular concern is the area mentioned above; Mile 103 Mile 105 Cascade Sub., the trackage passes below large clay ridden banks and a large plateau known as the Fraser River Escarpment, what is known as the Haney slide and Port Hammond slide areas, municipal engineering studies can be found at; This area has the Fraser River on the south side and a 100+ foot high bank on the north side and residential homes on top. Slides and roadbed slip outs have been occurring in this area for over 100 years. Current engineering studies date back to Not only do all freight train movements to and from the Vancouver Terminal pass through this area, so do West Coast Express trains, carrying about 10,000 passengers five days a week. Yet CP Railway has not installed any semblance of a warning system. Our concern and submission for changes to the Act and in response to the Panel s Consultation Guidance Document; Key Issues Explored, Item 5 Related Railway Safety Issues, 5.3 Advanced Technologies and their use. The Act should contain clear provision to address the requirement for land movement detection systems. Transport Canada s Guideline Engineering Work Relating To Railway Works, is just that, a guide, it does not provide for any mandatory requirement for railway companies to install such warning systems. There should be a clear direction Transport Canada is required to work directly with engineering departments and workplace health and safety committees to address the need to implement any such warning systems. There needs to be clear regulations when a railway has to take the initiative to install warning systems and modernize old systems. Leaving this under the guise of professional engineers who are employed by the railway, does not address the objective of the Act, in part: Railway Safety Act Review 2007 Page 4

5 3. The objectives of this Act are to (a) promote and provide for the safety of the public and personnel, and the protection of property and the environment, in the operation of railways; (b) encourage the collaboration and participation of interested parties in improving railway safety; Since the Act may require railways to formulate engineering standards, and those must be approved by the Minister; how can it be that two railways operating in the same territory have been allowed to formulate such differing standards when it comes to protecting the public and personal against geographic terrain mishaps? Who is responsible? The Local Workplace H&S Committee; they have made recommendations for warning systems, to no avail. The professional engineers, they are responsible for providing the necessary information and offering fixes to the situation, not mandating protection systems. The railway; they have the ultimate responsibility to ensure the proper studies and work are carried out and the public and employees are protected. Other than have engineering reports done on the area of mile 103 and others and cleaning up the mess of mud/rock after it comes down, very little is done. Transport Canada, what have they done? Obviously they must be aware of this situation as well as others; however they have yet to issue any type of directive to CP Rail for proper protection/warning systems. Does the RSA have provision for Transport Canada to issue such an initiative, we believe it does, but there is no mechanism for the public or employees to have Transport Canada act on this matter in a formal manner. If this assumption is incorrect, the Act needs to be clearer on how parties can take action to ensure safety is managed correctly. PART II OPERATION AND MAINTENANCE OF RAILWAY WORKS AND EQUIPMENT 18 (c) respecting the following matters, in so far as they relate to safe railway operations, in relation to persons employed in positions referred to in paragraph (b): (i) the training of those persons, both before and after appointment to those positions, and Key Issues to be Explored : Are employees appropriately qualified and trained to carry out their duties safely? To respond effectively to emergencies? Training, we will state from our perspective the training of new employees by CP Rail has improved. This is partly due to the need to employ a large a number of new employees with the on going retirement of baby boomers and through the process of collective bargaining. In this aspect labour relations did have a positive affect on safety. Our point of view comes from subsequent training and qualification years after an employee is initially trained and qualified. Two examples of the current situation. At the out set of CN/CP Co Production agreements that manifested in TCRC Division 320 members being required to operate daily over a foreign railway s route and operate their equipment. Commencing in 1998 we were given a two hour class room instruction on the differences of rules and how rules are applied at CN by fellow employees from the running trades who were not qualified as instructors. There was a 60 page document, timetable and bulletins given to each employee. There was no qualification process. In 2002 and after numerous requests from the Union a new Difference manual was issued to employees. Railway Safety Act Review 2007 Page 5

6 CP Rail set an open box of these manuals in the reporting locations of employees and issued a bulletin we were required to have this document in our possession while at work. This was similar to the issuance of new CROR and General Operating Instruction manuals around the same time. The Union took issue, and demanded proper instruction and qualification take place but no resolve was achieved. Railway Employee Qualification Standards Regulations SOR/ mandates: 10. (1) A railway company shall, at intervals of not more than three years, have each employee in an occupational category re examined on the required subjects. The period of 1998 to 2007, since employees began working in the Directional Run Zone, we have never been qualified on CN rules application and have never been re examined for rules differences between CN and CP or CN operating procedures and equipment. Most recently, latter part of 2006 Transport Canada through a routine inspection, it was noted the CN/CP Differences package was out of date, both railways were formally requested to address the issue. A new differences manual was issued, yet there was no training or examination of this material. During the current round of RQ training and exams, commencing in November 2006, there was not one issue presented during class or on the tests about CN rules and operations, yet we are required to operate at least 40% our working time within CN territory and on CN equipment. We have addressed this matter formally to Transport Canada, only to be told they do not have jurisdiction on how or what training must take place. REQS Regulation Section 14 clearly establishes what material employees are to be trained on and qualified under. We are required to have in our possession many CN documents and manuals that deal with the subject matter listed in Section 14. Many CN rules and applications are significantly different than CP s, yet we have received no training or qualification. We do not agree Transport Canada does not have jurisdiction over this matter, yet there is no avenue to dispute their position. Currently REQS Regulations fall under the jurisdiction of the Canada Transportation Act, this may be the reason for the position they are taking. Discussing this matter with the Canada Transportation Agency, they have informed us the regulation is not their jurisdiction. It is our position Railway Employee Qualification Standards Regulations SOR/ should rightfully fall within the jurisdiction of the RSA, if it does not already. Section 18 of the Act needs to clearly state what government body has jurisdiction to determine if proper training is taking place. Training is an integral part of any safety program in any workplace, because of the regulatory nature of the railway industry, proper training is a must. Another example of the need for a third party to oversee training in the railway industry is the area in which TCRC Division 320 members work. This area consists of two main marshalling yards. All the yards that do the switching are Remote Control Locomotive System (RCLS) equipped. Initial RCLS training is provided; current employees receive a two week course, new employees receive a four week course. There is no subsequent training regarding RCLS operations. REQS Regulations Section 14 requires training and re examination every three years on Locomotive Operations by Locomotive Engineers and Transfer Hostlers. The regulations do not include the provision for RCLS Operator (Yard Service Employee), nor does CP Rail include any subsequent training on locomotive operations to yard service employees who operate RCLS. Railway Safety Act Review 2007 Page 6

7 Who is responsible: The onus has to be placed on the railway to ensure training and qualification takes place, the REQS Regulations do state this but there is no provision who is going to watch over this regulation. Transport Canada (Minister of Transport) does have a say over rules implementation, Section 19 and 20 of the Act, why would they not have jurisdiction over the training of those rules? We offer Section 18 should state training will be subject to approval of the Minister or other such wording to ensure the correct government body who is going to police this Act and regulations is identified. How do we know if employees are appropriately qualified and trained to carry out their duties safely and/or to respond effectively to emergencies if there is no training and qualification of the rules and operation with a particular workplace? Obviously the Act does not address this issue, but it should. (ii) hours of work and rest periods to be observed by those persons, and; Key Issues to be Explored Are employee fatigue, hours of service and overtime concerns for railway safety? In regard to Hours of Work and Mandatory Time off Duty regulations imposed by Transport Canada and general fatigue in the railway industry. It is our position the current regulations do little to address fatigue. There is no semblance of fatigue management within the territory we work in. The current regulation restricts how often we can go to work, which restricts our earning capacity, this then causes people to be subjected to take work outside the hours of normal sleep patterns or when no sleep has been obtained. There is no doubt labour relations plays a large part in any fatigue management plan or other matters dealing with managing fatigue. Our collective agreement does contain provision for train crews to have rest and to book rest while on duty (after 10 hours) yet that provision is violated on a daily basis, with very little repercussions. We offer evidence of this to the Panel, not to address the collective agreement violation, which is being handled through the grievance procedure, but to emphasize the point the Railway is not addressing fatigue and how that affects safety. (Refer to Appendix 06 Crew time on duty times.) Fatigue Countermeasures have been implemented at many railways in North America; in fact CP Rail instituted Time Pools on the Laggan Sub. subsequent to the Canalert 95 project, yet no real efforts have been made or implemented since then. We offer since 2002 BNSF has established many such programs through out its network covering 50% of its unassigned operating employees; such as: Assigned days off, seven on/three off, five on/two off work rest schedules. Union Pacific since 2002 has had specialized groups working on train line up accuracy, providing more precise line up to it s operating personal. This is probably the number one complaint from operating employees represented by TCRC Division 320. Line ups and work information has never been worse in the current workforce s history. Line ups and crewing manifests are not accurate and are not updated to reflect the true standing of train to crew requirements. CP Rail has instituted strict Attendance Management Policies that do little to achieve any positive affect on fatigue in the railway workplace. We accept employers have the right to address absenteeism, yet they have to realize people operating trains need to have time off to ensure they are alert and fit. Collective Agreements or Hours of Railway Safety Act Review 2007 Page 7

8 Service rest has not addressed the main point of fatigue in the rail industry. Strict adherence to absenteeism only adds to these concerns; employees that should not be accepting calls for work, are doing so out fear of reprisal and discipline. We have seen no action from Transport Canada on this matter. Hours of Service issues are not addressed by them. The information provided in appendix 06 indicates crews being on duty well in excess of 12 hours and up to 24 hours, this type of action was permitted by Transport Canada under emergent circumstances, when in fact it was because of inclement weather and poor planning. What is needed is a more proactive mandatory approach from Transport Canada. They cannot simply sit on the sidelines and wait for infractions or mishaps to happen. Since the parties affected by fatigue have not been able to achieve any progress, TC needs to have a more hands on approach. It is our suggestion the Panel examines the FRA s Safety Assurance Compliance Program (SACP). On each major railroad under FRA jurisdiction SACP teams are set up, they include FRA inspectors and managers, railroad officials, and employee representatives. The point here is the FRA is directly involved in the safety problems and resolution of those problems. Since American Railroads seem to be further advanced than us in Canada, we believe direct government involvement on this issue has helped achieve some fatigue counter measures that we have not been able to. We emphasize more blanket restrictive regulations on hours of work will not fix the problem. Railway Safety Act 47.1 (1) The Governor in Council may make regulations respecting the development and implementation of safety management systems by railway companies, including the criteria to which the safety management systems must conform. "safety management system" means a formal framework for integrating safety into day-to-day railway operations and includes safety goals and performance targets, risk assessments, responsibilities and authorities, rules and procedures, and monitoring and evaluation processes; Key Issues to be Explored Safety Management Systems has the formal framework for integrating safety into day to day railway operations SMS been put in place at all railway companies and how is working Are the roles, responsibilities and the authorities for SMS clear of railway companies, of Transport Canada? Of others who are part of the railway safety system. We do not have much to say on this issue; simply put we were not aware of this provision of the Act until researching for this submission. In speaking to our H&S Committee Representatives, most did not know what a SMS was. A member who had been on our Local H&S Committee for some 12 years had heard about it but was not sure what it entailed or does for safety. Last year Transport Canada auditors interviewed two of our H&S Committee reps; they did not clearly explain what they were doing or about SMS. Most recently and because this term has come to our attention, the matter was raised at the monthly H&S Committee meeting April 24/07. Managers gave an overview of the SMS. They explained the Committee s Safety Framework was part of the SMS. Railway Safety Act Review 2007 Page 8

9 We refer to the Railway Safety Management System Regulations; (c) a system for involving employees and their representatives in the development and implementation of the railway company's safety management system; Transport Canada Auditors comes into the workplace to review the safety system, yet they do not take the time to explain to the H&S Committee what they are doing, nor have they informed the Committee of the results of any such audits. The employer implements a SMS but does not educate H&S Committee members about this. RSA SMS should not override the provisions of the Canada Labour Code, it should be there to enhance it. The Safety Management System cannot be considered a valid system for dealing with safety in the railway industry if Local Workplace H&S Committees are not aware of the company s SMS and/or have not been fully apprised and educated on it. H&S Committees have the responsibility, as provided for in the Canada Labour Code, for safety in the workplace. The evidence indicates, at least in our location, the Committees have not been informed about the SMS. If in fact it is the purpose of the Act, for employees to be involved in the day to day application of the SMS, it should be incumbent upon the Act to stipulate who is responsible for informing and educating employees and H&S Committees about the safety system in place for that workplace. Conclusion and Overview: We submit, the Railway Safety Act needs to provide for a clear and quantitative approach to safety on the railway. There should be concise direction and parameters dealing with regulations on training and who polices such. The regulations emanating from the Act must be brought up to date and kept up to date with new approaches to safety and consideration of current technologies. The Act provides for grants for upgrading railway crossings, why is a similar provision not provided to hazard warning systems, which not only protect railway property but the public as well. The authority that monitors and has jurisdiction over the Act and its regulations have to be clearly stipulated. There needs to be a laypersons dispute resolution process for day to day dealings of the Act. We are aware the Act does provide for appeals when directives or orders are issued, yet there is no real guide how this takes place. There is no process for disputing decisions made from complaints by the public or employees about contraventions of the Act. Most enactments of legislative controlling workplaces have dispute resolution processes; some examples would be Workers Compensation, Employment Insurance, and the Canada Labour Code. Yet we could not find any type of dispute process for when a railway safety officer issues a decision ruling on infractions that may have occurred. All too often we have submitted complaints and concerns to Transport Canada, only to be told we have discussed this with the railway and no violation occurred. Transport Canada s investigation procedures need to be clearly defined. Investigating an issue and making a decision based on one side of the story does not give balance to the system of safety in the railways. Transport Canada has to be more forthcoming with the results of their investigations and audits. Looking at the FRA website many reports are readily available; Most agents of the government who have been given jurisdiction over Acts and/or regulations provide this type of information (similar to above). Railway Safety Act Review 2007 Page 9

10 Transport Canada should be mandated to have a proactive, hands on approach in dealing with the Act and the workplace. For us in the operating side of the railway, TC also oversees Part II of the Canada Labour Code, yet rarely are they involved with Local H&S Committees. They do inspections but do not get involved in any training or programs to promote safety. They need to be directly involved to provide guidance and ensure the Acts/Codes are being complied with, similar to provincial worker's compensation boards. Instituting something like the Hours of Service Regulations and then leaving it to the parties to make it work is not sufficient to deal with the issues it is intended to address. Fatigue is the number one concern of train crews, yet no progress is being made to solve the concerns. TCRC Division 320 is only a small component of the Union, and is not empowered to enact fatigue counter measures on its own, nor is local managers, yet nationally very little has been done on this issue. If Transport Canada was directly involved and found that a particular area of the railway was required to have certain measures taken to address fatigue, it could empower the parties to act. Since safety is the main component of this review, we urge the Panel to visit Local Workplace H&S Committees to get a clear picture what is taking place in the railways today. We thank the Panel for this opportunity and reserve the right to present further material at the consultation hearings. Respectf Ily submitted Gerry Rans for TCRC 320 Railway Safety Act Review Page 10 TCRC Division 320 Submission - April 27, 2007

11 APPENDIX 01 Mile 103 CP Cascade Subdivision Locomotive after hitting slide. Railway Safety Act Review 2007 Page 11

12 APPENDIX 02 Mile 99.8 CP Cascade Subdivision January 2006 Railway Safety Act Review 2007 Page 12

13 APPENDIX 03 MILE 28 CP Cascade Sub. November 2005, unprotected area, crew trapped and minor injuries Railway Safety Act Review 2007 Page 13

14 APPENDIX 04 Mile 3.7 CP Cascade Subdivision, January 2003, slide fences installed since this slide, slide occurring March 2007 was similar in size and location. Railway Safety Act Review 2007 Page 14

15 APPENDIX 05 Drynoc. Mile 79 CP Thompson Subdivsion March 12, 2007 Railway Safety Act Review 2007 Page 15

16 APPENDIX 06a Coquitlam/Roberts Bank Crews Over 12 Hours November 27 December 28, 2006 DATE ON DUTY TIME EMPLOYEE NAME TRAIN ARRIVAL OR RELIEVED OFF DUTY TIME HOURS ON DUTY 20-Nov-06 23: :20 23-Nov-06 19: (RLVD) :15 24-Nov-06 21: :22 27-Nov C (RLVD) :10 27-Nov-06 16: (RLVD) :05 27-Nov-06 17: (RLVD) :15 27-Nov-06 17:35 C (RLVD) :40 27-Nov-06 17: (RLVD) :45 27-Nov (RLVD) :30 27-Nov (RLVD) :30 27-Nov VDP 0825(RLVD) :45 27-Nov-06 22: (RLVD) :05 27-Nov-06 23: (RLVD) :16 28-Nov (RLVD) :20 28-Nov-06 1: (RLVD) :30 28-Nov-06 3: (RLVD) :10 28-Nov C (RLVD) :15 29-Nov-06 12: (RLVD) :00 29-Nov-06 17: :05 4-Dec-06 21: :15 4-Dec-06 21: (RLVD) :19 7-Dec-06 23: :15 9-Dec C (RLVD) :00 9-Dec (RLVD) :59 11-Dec :29 12-Dec C :25 13-Dec C :05 13-Dec :10 14-Dec :30 14-Dec (RLVD) :25 14-Dec :15 14-Dec C (RLVD) :15 14-Dec C (RLVD) :25 14-Dec (RLVD) :15 15-Dec :17 16-Dec (RLVD) :00 18-Dec :15 21-Dec :15 Railway Safety Act Review

17 APPENDIX 06b Coquitlam/Roberts Bank Crews Over 10 Hours November 27 December 28, 2006 DATE ON DUTY TIME Railway Safety Act Review 2007 EMPLOYEE NAME TRAIN ARRIVAL OR RELIEVED OFF DUTY TIME HOURS ON DUTY 27-Nov :25 27-Nov RC 1505(RLVD) :00 27-Nov-06 6: :15 27-Nov-06 7: :35 27-Nov C :30 27-Nov-06 11:25 VDP :05 28-Nov C102-27RC :15 28-Nov RC 1505(RLVD) :59 28-Nov-06 7: :15 28-Nov-06 9: :09 28-Nov-06 9: (RLVD) :10 28-Nov-06 9: (RLVD) :45 28-Nov-06 12:00 C :40 29-Nov-06 6: :15 29-Nov :05 29-Nov :55 30-Nov (RLVD) :30 30-Nov-06 8:00 C :30 1-Dec V (RLVD) :45 06-Dec C :45 09-Dec :40 10-Dec C :09 10-Dec (RLVD) :15 10-Dec :20 10-Dec :25 13-Dec C (RLVD) :15 13-Dec (RLVD) :00 14-Dec :05 14-Dec :15 14-Dec :50 14-Dec SRS :15 14-Dec C :30 14-Dec :25 15-Dec :05 15-Dec DH/Train :00 15-Dec :45 16-Dec (RLVD) :07 16-Dec (RLVD) :00 16-Dec DHCombo :00 16-Dec DHCombo :05 16-Dec DHCombo :19 18-Dec C :10 18-Dec C :25 18-Dec :45 17

18 20-Dec C :15 20-Dec (RLDV) :40 22-Dec C :15 22-Dec :20 23-Dec C :10 24-Dec :05 28-Dec (RLVD) :20 Railway Safety Act Review

19 APPENDIX 06c Coquitlam/Roberts Bank Crews Over Hours January February Date Crew Train Time Called RLVD/ARR Off Duty Total Hours 07/01/ A '15" R '06" 07/01/ R '15" R '05" ???? '10" A '40" A '25" R '45" A '30" 07/01/ A '10" 07/01/ R '45" 07/01/ Turned 1715R '45" Turned 1805R '50" C A '45" 07/01/ A '20" 07/01/ Turned 0901R '50" 07/01/ R '45" A ' A '30" 07/01/ A '35" A '10" 07/01/21 C A '25" 07/01/ R '15" 07/02/01 C HO/1722A '05" 07/02/ Turned 2130R '15" 07/02/ A '10" 07/02/18 C A '30" C Turned 0945R '30" 07/02/20 C A '10" 07/02/ A '35" 07/02/ A '20" 07/02/ A '45" C A '30" Railway Safety Act Review