Oversight of Critical Infrastructure – Lessons from Transport Canada

Readers may recall the derailment which occurred in the Quebec town of Lac-Mégantic in July 2013.

An unattended 74-car freight train carrying crude oil ran away and derailed, resulting in the fire and explosion of multiple tank cars.  Forty-two people were confirmed dead.  More than 30 buildings in the town’s centre – roughly half of the downtown area – were destroyed.

It is within this context – although audit work was completed at the end of June – that the Auditor General of Canada has recently released a report on rail safety in Canada.

The report presents an excellent framework to consider for any organisation – public or private sector – that manages critical infrastructure.

The report noted:

  • Transport Canada has implemented a regulatory framework for rail transportation that includes a safety management system approach to identify, analyze, and respond to rail safety risks.
  • Transport Canada has conducted many inspections and some audits to identify non-compliance with rail safety regulations, rules, and engineering standards. However, the Department does not systematically collect and use important and relevant railway safety performance and risk data to ensure that its oversight activities are targeting the higher-risk railways and the most significant safety risks.
  • Despite the fact that federal railways were required 12 years ago to implement safety management systems for managing their safety risks and complying with safety requirements, Transport Canada has yet to establish an audit approach that provides a minimum level of assurance that federal railways have done so.
  • The guidance and tools provided to inspectors for assessing federal railways’ safety management systems are missing many key elements. For example, they contain few requirements to help inspectors plan, conduct, and conclude on audits and inspections, and for following up on findings. This makes it difficult for Transport Canada to ensure that its inspections and audits are effective in determining whether railways are taking corrective actions where necessary. Lastly, Transport Canada does not have a quality assurance plan to continuously improve its oversight of rail safety.
  • Transport Canada has defined the skills its inspectors need to conduct inspections and  audits. However, the Department has not assessed whether its current workforce has the required skills.

We can sit in perverse judgement on the failings of Transport Canada and speculate as to the consequences that such failings may bring.

To do so would however miss the opportunity that this report presents.

This report should be used as a checklist by those who oversee and are required to maintain infrastructure either on behalf of a state or for the benefit of an organisation.


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