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Pulse Point Newsletter for April 16, 2001
Published by Alliance Consulting International
Partners in Environmental and Occupational Health and Safety
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PROPOSED STANDARD ON HEALTH AND SAFETY IN RAILROAD OPERATIONS AND MAINTENANCE

By Enrique Medina, MS, CIH

This is the fourth review of recently released proposed Official Mexican Standards (NOMs in Spanish) issued by Mexico's Ministry of Labor and Social Security (STPS). These standards are currently undergoing revisions prior to publication as final rules.

This month's issue features Proposed Official Mexican Standard PROY-NOM-032-STPS-2000, Operations and maintenance of railroads- safety and health conditions. It was published on January 12, 2001 in the Official Journal of the Federation.

This proposed standard is intended to establish the minimum safety conditions to protect railroad workers from occupational hazards stemming from the operation, maintenance, repair and emergency response activities in rail yards and rail rights-of-way.

A key provision of the proposed standard is the employer's responsibility to conduct a hazard assessment of railroad operations, which will serve as a basis for establishing a written health and safety program for protection of workers and the work place. As part of its obligations, the employer must:

Notify workers of the risks related to railroad operation, maintenance and repair activities, and document compliance with this requirement.
Comply with the required health and safety conditions described in the standard.
Develop written procedures in Spanish for railroad operations.
Train workers based on established procedures from the health and safety program. The training program must document at a minimum the instructional topics presented, the training dates, personnel to be trained, and actual attendance at training sessions.
Document medical surveillance of workers through initial, regular and specific medical examinations, in accordance with standards issued by the Health Ministry. In the absence of specific regulatory requirements, the employer's physician shall determine the scheduling and content of periodic and specific medical examinations. Medical surveillance activities must be recorded in the employee's medical records. A non-mandatory guideline for medical examinations is provided in the standard to assist employers in meeting this obligation.
Have a trained emergency response team and train in emergency response, fire fighting including the use of fire extinguishers, and rescue activities. Fire, evacuation and injured worker rescue drills must be conducted at least every six months. Assigned workers must be trained in the use of first aid kits, which must be stocked according to the activities at the work site.
Provide workers with personal protection equipment according to NOM-017-STPS-1993, and train them on the proper use and maintenance of such equipment.
Establish a Worker-Management Health and Safety Commission according to NOM-019-STPS-1993. Workers in right-of-way assignments may be part of the commission even if their work area encompasses two or more states.

The hazard assessment must be conducted at the start of operations and whenever work conditions change the potential risks of the operation. A number of specific operations that are considered hazardous must be evaluated. These include fluid transfer of hazardous substances, locomotive fueling and maintenance, movement of cars with hazardous materials or waste, handling or storage of explosives, and welding and hot work on trains.

The assessment must describe the processes involved in the operation, identify potential health and safety hazards and their responsible agents, and describe the exposure period and hazard characteristics. The probability of a particular hazard must be evaluated based on prior events. A hazard classification must be assigned based on experience with the process. For new operations, the hazard classification may be estimated from experiences in similar operations. The assessment must also describe the specific safety measures adopted to eliminate or control hazards, including personal protection equipment and emergency procedures.

The proposed standard provides specific health and safety procedures that must be followed for a number of railroad operations, based on the result of the hazard assessment. It requires compliance with a number of other standards as they apply to railroad work sites, including machine guarding and safety devices, according to NOM-004-STPS-1999; safety conditions in buildings, as per NOM-001-STPS-1999; safety signage and piping color codes, in keeping with NOM-026-STPS-1998; and fire prevention and protection (NOM-002-STPS-2000). A hazard ranking of hazardous materials must be implemented as per NOM-018-STPS-2000 and safe handling and storage of hazardous chemicals must follow NOM-005-STPS-1998 to control spills and releases.

The proposed standard lists a number of job-specific safety procedures that must be developed for crews working in trains, rail yards, warehouses and rail rights-of-way. These should address communication devices and signals, car coupling and uncoupling, boarding and disembarking from trains, work on scaffolds and elevated surfaces, and electrical safety, among others.

Section 10 of the proposed standard deals with emergency response. It requires employers to have a written emergency response plan available to all workers and internal responders. It must include periodic drills for all personnel, alarms and codes for different types of emergencies, responsibilities of emergency brigades for fire, spills, search and rescue, and first aid, according to the hazard assessment.

The proposed standard includes a non-mandatory guidance checklist for medical evaluations of railroad personnel. It details the scope of such evaluations for train engineers, brakemen, and conductors.

As in all new STPS standards, the proposed NOM provides employers the option to contract with an accredited Verification Unit to verify or evaluate compliance with the standard. Verification Unit assessments will be valid for a two-year period. The proposed standard is subject to a 60-day comment period from the date of publication. Following the normal rule-making process, a revised proposed standard will be published after the comments received have been reviewed. The proposed NOM is slated to become a final standard 60-day period following its publication in the Official Journal of the Federation.

If you have questions about how the new environmental impact regulations may affect your current or future projects, please contact us at (619) 297-1469 or send us an email at emedina@pulse-point.com.

Alliance Consulting International
Partners in Environmental and Occupational Health and Safety
3361 28th St.
San Diego, California 92104
(619)297-1469
(fax (619)297-1023
emedina@pulse-point.com
www.pulse-point.com/alliance

For articles in previous issues of Pulse Point visit our web site's "archive" section at: www.pulse-point.com/
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All material Copyright © 2001 Pulse Point.
Pulse Point is written for the benefit of our readers with the sole intent to provide general information. The articles are not intended as specific opinions or as a substitute for professional advice in individual cases.