The Federal Railroad Administration (FRA) recently issued its final rule on the establishment of System Safety Programs (SSPs). According to FRA sources, this rule has been a long time in the making — the Federal Aviation Administration has had such rules for almost two decades.

The rule primarily seeks to address defined methods of identifying potential safety hazards in the passenger railroad environment, clear ways of defining progress toward eliminating those hazards, and a paper trail that will demonstrate how the railroads are moving toward compliance with all FRA regulations.

To the uninitiated, railroad safety like all industrial safety programs looks like a simple matter of training. You either have safety or you don't, and the outcome in terms of both employee and public accidents is a clear indicator of which is which.

But it's not that simple.

When I became a transportation specialist in the insurance business, I had to deal with all kinds of safety programs created by all manner of executives, managers, middle managers, and simply by workers who held meetings and reached a consensus on what is and is not safe.

It may be cynical to say so, but those businesses transportation among them that had the most exposure to public liability for their unsafe actions, also had, by far, the best safety programs. It seems that exposure to public liability and the "bad press" that goes with it often provided the incentive for serious consideration of safety. This is my experience and not supported by any studies of which I am aware.

Often, the simplest of businesses small manufacturing plants with under 50 workers, for example had the worst safety programs. On the other end of the spectrum, railroads are complex entities that operate some of the heaviest of imaginable machinery outdoors and under unpredictable and widely variable conditions. I should expect them to have among the best of safety programs, and they often do. But is it enough?

Though most railroads would like to be fenced off or hidden away from general public access and should be if they could manage all risk most are not.

The average customer for passenger rail service does not have a safety background and assumes his safety is taken care of no matter where he or she is in the train or on the railroad's property. The general public that does not ride the train is even less predictable, often never having had even the brief physical taste enjoyed by the railroad passenger of what immense forces are in play when a train has to go into emergency braking.

Which brings me to SSPs. System safety as a discipline had its early roots in the military management of safe ordinance systems and in nuclear power and other complex systems with high risk potential. In other words, they grew from environments where accidents can result in catastrophe. SSPs have been refined over the years to ultimately become a subdiscipline of systems engineering.

Here's what there is to like about SSPs and their offshoots, System Safety Program Plans (SSPPs): SSPs say we don't have to wait to plan for safety until something unsafe happens. In the passenger railroading business, this means all personnel without exception should be engaged in identifying hazards. A dining car chef, for example, might see a hazard in the way that frozen foods are loaded into the train.

For another example, take a car inspector, a key safety player who you would expect to focus on defects and hazards in the passenger carrying equipment. But he might also see a hazard in the way the train is spotted for inspection, or in the way his inspections are digested and made manifest to repair and maintenance personnel.

In a system safety environment, identifying hazards takes on equal importance to implementing solutions, defining progress and documenting the success of the system. Although nobody can ignore when things go wrong, system safety is not as focused on what went wrong and why as it is on what can go wrong and how to stop it.

SSPs are ongoing, interrelated and virtually as complex as the railroad environment itself. Under the perfectly functioning SSP, no railroad accident should ever happen. In theory, if SSPs work, the National Transportation Safety Board would become unnecessary. The only thing different about an FRA-mandated approach to SSP is that the FRA takes it for granted that regulatory compliance is equivalent to a perfectly functioning program.

Whether that is true or not, this is a bold step in the right direction for safety on all passenger railroads. Those that don't have SSPs have the opportunity to learn, and those that do have the incentive to bring them up to standard. Here's hoping the opportunities are well taken.

For an excellent example of an SSPP for passenger rail, see the American Public Transportation Association's manual for development.