Roger Ernest Toussaint - Comments

Safety Culture is mentioned once at 55374. Anything that could be done to help the focus on this as a big picture issue should be helpful. Beyond timely consultation towards reaching an agreement between employees and employer on an SSP, it would be helpful to script some more detailed recommendations, such as visibly post notice on the requirement to submit an SSP and its components in advance of SSP being drawn up, as parties tend to get "dug in" once they have developed and made known their position. Require biannual or quarterly meetings between parties (employer/employee) on safety concerns, report minutes to the FRA. Require an orderly challenge system for unsafe work orders, within a time definite following the SSP being put in place. Require that an in place SSP not be altered to reduce safety protection without FRA approval. Review the Executive Order establishing the NY State Track Safety Task Force for advances in the track safety process at the nations largest system. Set up a committee to make recommendations on uniform minimum standards for working on the RIGHT of Way, including inner city rail.