NRM Internal Compliance Audit
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The document provides information about Nevada Railroad Materials Inc. and conducting internal compliance audits of railroad track inspection processes. It discusses evaluating track inspection qualification and frequency, speed of inspections, audit of inspection records, rail flaw detection processes, rail joint inspections, heat monitoring of continuous welded rail, and ensuring compliance with FRA regulations. The goal is to thoroughly review inspection and maintenance processes to identify any issues before the FRA conducts an audit, in order to maintain a safe infrastructure for passengers, employees and nearby communities. Additional inspection and consulting services are also described.
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NRM Internal Compliance Audit
- 4. Is Our Track Inspection Process Sound? We start by performing a full evaluation of your Track Inspection Process which includes but is not limited to the following: ◦ Part 213.7 Qualification – How are your Inspectors qualified? Who qualified them? Will your process meet Part 243 requirements? Do you have a list of qualified employees? ◦ Speed analysis – How long does it take to inspect your railroad? How much track authority is used to perform the inspection? Can an inspector really perform a quality inspection at 42 MPH? ◦ Audit track inspection records for frequency requirements and compare to field assessments. If no defects are being reported, why am I finding defects in the field? ◦ Track Inspection Process – Evaluate how the inspection is planned, conducted, documented, and followed up on. Recommendations will be provided after including industry best practices.
- 5. Do you run a rail flaw detector? Ever wonder if your rail detection process is sound? Here are some things to consider: ◦ What frequency are you running your rail detector? Was this frequency submitted to the FRA as required in the last regulation change? Is it still accurate? Are you updating it as required? ◦ Are your rail flaw detector operators qualified as required by the regulation? Do you have their training records? Where are they? ◦ Are the defects protected correctly? What about the first train over the defect before it is repaired? Did your track department issue a slow order properly and within the required class of track? Where is this documented? ◦ Was the defect repaired properly? What about the rail joint that was added when the defect was repaired? Is there a plan to weld it? If so, when? What if rail was added? ◦ We can look at each of these situations and make a determination as to if the process is sound, and being followed.
- 8. Regulations we focus on during this audit Part 213.7 – Designation of qualified persons to supervise certain renewals and inspect track Part 213.110 – Gage restraint measurement systems Part 213.113 – Defective Rails Part 213.118 and 119 – CWR Plan review, approval, and contents. Part 213.121 – Rail Joints Part 213.233 – Track Inspections Part 213.234 – Automated Inspection of Track Constructed with Concrete Crossties. Part 213.235 – Inspection of switches, track crossings, and lift rail assemblies or other transition devices on moveable bridges Part 213.237 – Inspection of Rail Part 213.238 – Qualified Operator Part 213.241 – Inspection Records
- 9. Internal Compliance Audits Summary Our job is not to disqualify an inspector or provide information to help terminate some ones employment. We are focused on providing a quality audit of the track maintenance, inspection, repair, and oversight process to ensure a safe infrastructure for our clients passengers, employees, and residents paralleling the ROW. ◦ Operations compliance audits typically are not focused on the infrastructure and how it is inspected, maintained, and repaired. ◦ We conduct a Deep Dive Type audit intended to provide answers to a lot of the questions our clients may have about either their own employees or the contract operator they provide oversight to. ◦ We aim to find problems before the problems find you. Let us help with a comprehensive internal audit before the FRA conducts one and imposes penalties. ◦ We are here to help.
- 10. Additional Services NRM provided inspector to conduct a full Part 213 inspection of the entire track structure. (An internal inspection BEFORE the FRA inspection) ◦ This could take a week, or four weeks depending on multiple variables which should be discussed prior to scheduling the inspection. State of Good Repair Assessment ◦ NRM can provide an inspector who will conduct a full or sample SOGR assessment. SOGR assessments are ideal when an agency wants to keep track of the condition of the track structure prior to, during, and after the term of a contract has ended or is ending in the near future. This allows the agency to make a determination as to the condition of the track before, and after the term of the contract. NRM can also make recommendations after the inspection in order to help make decisions to extend the life of the physical plant. Ratings are typically between 1 and 5, and color coded. A baseline inspection should be performed, and periodic inspections to assess if the condition has improved, or degraded. Capital Tie Maintenance Program ◦ NRM utilizes state of the art systems which allow our inspectors to grade each and every railroad tie between MP locations. The condition is logged into a ruggedized palm top pilot. The inspection data is uploaded into a software program provided by Zeta-Tech. From this software system, NRM is able to make a recommendation on tie replacement using a number of variables such as: ◦ Replace every 2, 3, 4, 5 tie clusters ◦ Build a capital tie replacement program to bring class up to a higher class for speed increases. ◦ Build a capital tie replacement program for minor maintenance. Part 214 – On Track Safety Program ◦ Is your Part 214 program in full compliance with the new regulations? Part 213.7 Training and Qualification ◦ Includes OJT Training Program, Classroom Training, and hands on application in the field.