49CFR236 SUBPART H

HCRQ has provided:

• system safety consulting services,
  
• software safety consulting services, and
  
• training
  

with respect to compliance with this regulation.  In fact we were the first to do so.

Subpart H requires a Railroad Safety Program Plan (RSPP), and a 20-section Product Safety Plan (PSP) including:

• risk assessment, and
  
• safety assessment.
  

Some of the appendices of 49CFR236 underwent revision coincident with the creation of Subpart I.  In addition, Appendix F was added.

Within Appendix B (risk assessment), one addition is "Software fault/failure analysis must be based on the assessment of the design and implementation of all safety-related software including the application code, its operating/ executive program, COTS software, and associated device drivers, as well as historical performance data, analytical methods and experimental safety-critical performance testing performed on the subsystem or component. The software assessment process must demonstrate through repeatable predictive results that all software defects have been identified and corrected by process with a high degree of confidence."  Another is "The railroad shall document any assumptions regarding software defects.  These assumptions shall be in a form that permit the railroad to project the likelihood of detecting an in-service software defect.  These assumptions shall be documented in such a form as to permit later comparisons with in-service experience."  Ask HCRQ for help in these areas.

We analyzed the modifications proposed by the RSAC PTC Working Group, from the standpoint of safety assessment and risk assessment, and identified a significant number of areas that would be subject to interpretation or would result in increased cost. 

We are used to performing roles such as this.  We step up to the plate while other system safety consultants sit in the stands.  Perhaps it is not in their best interest to save you money!

HCRQ submitted comments to the FRA, and attended the last meeting of the RSAC PTC Working Group to defend them.  Our comments, and the net results, are documented in the PTC System Final Rule. On September 27, 2010, the FRA published the PTC Systems Final Rule Amendments.

Coincident with the new 49CFR236 Appendix F (Minimum Requirements of FRA Directed Independent Third-Party Assessment of PTC System Safety Verification and Validation).  HCRQ offers this service.


By the way, did you know that we developed a system safety course based on 49CFR236 Subpart H?   Contact us if you are interested.