System Safety Program Plan

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DOCUMENT NUMBER: RELEASE/REVISION: RELEASE/REVISION DATE: 02-SMS-PO-A A November 1, 2018 CONTENT OWNER: SAFETY, COMPLIANCE & TRAINING

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Contents System Safety Program Introduction ...... 8 1.0 Safety Policy ...... 9 1.1 System Safety Program Policy Statement ...... 9 1.1.1 Purpose ...... 9 1.1.2 Responsibility ...... 9 1.1.3 Scope ...... 10 1.1.4 Definitions ...... 10 1.1.5 SMS Requirements ...... 11 1.1.5.1 Safety Culture ...... 11 1.1.5.2 Risk-based Hazard Management ...... 11 1.1.5.3 Safety Assurance ...... 11 1.1.5.4 Safety Promotion ...... 12 1.1.6 Safety Policy Review Cycle ...... 12 1.1.7 References ...... 12 1.1.8 Executive Leadership Team Annual Safety Letter ...... 12 1.2 System Safety Program Goals and Objectives ...... 12 1.2.1 Safety Goal #1: Customer Injury Rate ...... 12 1.2.2 Safety Goal #2: Employee Incident Rate ...... 13 1.2.3 Safety Goal #3: Employee Significant Injury and Fatality Potential Rate ...... 13 1.2.4 Safety Goal #4: Train Safety Index Tier 1 Rail Accident/Incident Rate ...... 13 1.2.5 Safety Goal #5: Train Safety Index Tier 2 Major Operating Rule Violation Rate...... 14 1.2.6 Safety Goal #6: Trespasser and Grade Crossing Incident Rate ...... 14 1.3 Railroad System Description ...... 15 1.3.1 Amtrak Owned and Maintained Routes ...... 15 1.3.1.1 Northeast Corridor ...... 16 1.3.1.2 Keystone Corridor ...... 16 1.3.1.3 New Haven-Hartford-Springfield Corridor ...... 17 1.3.1.4 Indiana – Michigan ...... 17 1.3.2 State Supported Routes ...... 17 1.3.3 Long Distance Routes ...... 17 1.3.4 Additional Services ...... 18

1.3.5 Rolling Stock ...... 18 1.3.6 Facilities ...... 18 1.3.6.1 Maintenance of Equipment ...... 19 1.3.6.2 Operations ...... 19 1.3.6.3 Distribution ...... 19 1.3.6.4 Reservation Centers ...... 19 1.3.6.5 Stations ...... 19 1.4 Railroad Management and Organizational Structure ...... 20 1.4.1 Operations ...... 23 1.4.2 Safety ...... 24 1.4.3 Executive Safety Council/System Safety Working Groups/Safety Committees ...... 25 1.5 SMS Implementation Process ...... 26 1.5.1 SMS Implementation Schedule – 2018 ...... 26 1.5.2 SMS Implementation Schedule – 2019 ...... 29 1.5.3 SMS Implementation Schedule – 2020 ...... 31 2.0 Safety Risk Management ...... 34 2.1 Risk-based Hazard Management Program ...... 34 2.1.1 Risk Identification ...... 34 2.1.2 Risk Analysis and Assessment ...... 34 2.1.3 Risk Mitigation ...... 37 2.2 Technology Analysis and Implementation Plan ...... 37 2.2.1 PTC Implementation ...... 38 2.2.2 Non-PTC Risk Assessment and Mitigation ...... 38 2.2.3 T&E Crew Capability Enhancements ...... 38 2.2.4 Training Software and Simulators ...... 38 2.2.5 Ongoing Technology Analysis ...... 38 2.3 Workplace Safety ...... 39 2.3.1 Fitness for Duty ...... 39 2.3.1.1 Medical Clearance ...... 39 2.3.1.2 Control of Drug and Alcohol Use ...... 40 2.3.1.2.1 PIER Program ...... 40 2.3.1.2.2 Drug and Alcohol Policy ...... 40 2.3.1.2.3 Drug and Alcohol Testing ...... 41

2.3.1.2.4 Consequences for Violating the Drug and Alcohol Policy ...... 43 2.3.1.3 Employee Assistance program ...... 43 2.3.1.4 Fatigue Management ...... 44 2.3.1.5 New Hire, Qualification, and Certification Training ...... 44 2.3.2 Occupational Safety and Health...... 44 2.3.2.1 Roadway Worker Protection ...... 44 2.3.2.2 Task-based Risk Assessments ...... 44 2.3.2.3 Safety Committees ...... 45 2.4 Contract Procurement Requirements ...... 45 3.0 Safety Assurance ...... 47 3.1 SMS Infrastructure ...... 47 3.1.1 Process Asset Library ...... 47 3.1.2 Records Information Management ...... 48 3.2 Safety Assurance Oversight ...... 48 3.2.1 Rules Compliance and Procedures Review ...... 48 3.2.1.1 Review of Rules and Procedures ...... 49 3.2.1.1.1 Host Railroad Operations ...... 49 3.2.1.1.2 Canadian Operations ...... 50 3.2.1.1.3 Other Operating Manuals Directly Affecting Railroad Safety ...... 50 3.2.1.2 Techniques for Assessing Compliance ...... 50 3.2.1.3 Techniques for Assessing Effectiveness ...... 51 3.2.2 Maintenance, Repair, and Inspection Program ...... 51 3.2.2.1 Track and Right-of-Way ...... 51 3.2.2.2 Signal and Train Control Systems ...... 51 3.2.2.3 Traction Power ...... 52 3.2.2.4 Rolling Stock ...... 52 3.2.2.5 Fixed Facilities and Equipment ...... 52 3.2.2.5.1 Passenger Station Platform Gaps ...... 52 3.2.3 Internal Evaluation Program ...... 53 3.2.4 Safety Certification ...... 53 3.2.5 Change/Configuration Management ...... 54 3.3 Continuous Improvement ...... 55 3.3.1 Safety Data Acquisition ...... 55

3.3.1.1 Customer Incident Metric ...... 55 3.3.1.2 Employee Incident Metric ...... 55 3.3.1.3 Tier 1 Rail Incident ...... 56 3.3.1.4 Tier 2 Major Operating Rule Violations ...... 57 3.3.1.5 Tier 3 Leading Indicators ...... 59 3.3.1.6 Tier 4 Voluntary Safety Programs ...... 59 3.3.2 Accident/Incident Reporting and Investigation ...... 60 3.3.2.1 Accident/Incident Reporting ...... 60 3.3.2.2 Accident/Incident Investigation ...... 60 3.3.2.3 External Investigations ...... 61 3.3.3 Emergency Management ...... 61 3.3.3.1 Emergency Operations Planning ...... 62 3.3.3.1.1 Preparedness ...... 62 3.3.3.1.2 Response ...... 62 3.3.3.1.3 Recovery ...... 62 3.3.3.1.4 Mitigation ...... 63 3.3.3.2 Emergency Training...... 63 3.3.3.3 Emergency Exercises ...... 63 3.3.3.4 Emergency Equipment ...... 64 4.0 Safety Promotion ...... 65 4.1 Safety Culture ...... 65 4.1.1 Internal Voluntary Reporting System...... 65 4.1.2 Close Call Confidential Reporting System ...... 65 4.1.3 Safety Survey ...... 65 4.1.4 Communication ...... 66 4.1.5 Recognition ...... 67 4.2 System Safety Program Employee/Contractor Training ...... 68 4.2.1 Training Administration and Program Management ...... 68 4.2.1.1 Training Design and Delivery ...... 68 4.2.1.2 Instructor Development ...... 68 4.2.1.3 Records Management ...... 69 4.2.2 SMS Training ...... 69 4.2.3 Qualification and Certification Training ...... 69

4.2.3.1 Track Safety Standards ...... 69 4.2.3.2 Railroad Workplace Safety ...... 70 4.2.3.3 Railroad Operating Rules ...... 70 4.2.3.4 Transportation Department Employees ...... 70 4.2.3.5 Non-T&E Employees ...... 71 4.3 Public Safety Outreach Program ...... 71 4.3.1 Operation Lifesaver ...... 71 4.3.2 Stay Off the Tracks ...... 71 4.3.3 See Something Say Something ...... 72 4.3.4 Additional Public Safety Initiatives...... 72 4.4 Internal System Safety Program Assessment ...... 72 4.4.1 Assessment Schedule ...... 73 4.4.2 Assessment Teams ...... 73 4.4.3 Assessment Criteria...... 73 4.4.4 Assessment Conduct ...... 74 4.4.5 External Reporting and SMS Improvement ...... 74 Revision Record ...... 75 Appendix A – Executive Leadership Team Letter ...... 76 Appendix B – Railroad System Description Specifics ...... 77 B-1 NEC Operators ...... 78 B-2 NEC Grade Crossings ...... 79 B-3 NEC Bridges/Tunnels/Overpasses ...... 79 B-4 State Supported Services ...... 83 B-5 Contract Services ...... 84 B-6 Rolling Stock Inventory ...... 85 Appendix C – Safety Performance Metrics ...... 87 Appendix D – Safety Strategy ...... 88

System Safety Program Introduction On October 30, 1970, Congress passed the Rail Passenger Service Act, which created the National Railroad Passenger Corporation (NRPC), also known as Amtrak. Congress mandated that Amtrak strive for operation on a for profit basis and provide modern, efficient intercity passenger rail service. Amtrak began operations on May 1, 1971, using an assortment of passenger cars acquired from other railroads. As time progressed, Amtrak continued to expand, absorbing personnel, resources, and equipment from contract railroads. Amtrak has become the country’s only inter/city passenger rail provider. The company is composed of approximately 20,000 employees and serves more than 500 destinations in 46 states, the District of Columbia, and three Canadian provinces. Approximately 85,700 customers ride more than 300 Amtrak trains on an average day.

Amtrak’s commitment to safety has evolved along with the company. Amtrak’s CEO and Board of Directors has challenged Amtrak to become the safest passenger railroad in the country. To advance this effort, an Executive Vice President (EVP) and Chief Safety Officer (CSO) was appointed and Safety, Compliance and Training (SC&T) was reorganized, moving the organization out of the Operations Department to create an independent function with a clear line of authority. SC&T is leading the effort to establish the company’s System Safety Program (SSP) based on Safety Management System (SMS) principles. The four pillars of SMS are Safety Policy, Safety Risk Management, Safety Assurance, and Safety Promotion. This System Safety Program Plan (SSPP) is organized based on the SMS pillars and integrates the elements required by 49 CFR 270 System Safety Program.

In an effort to maximize effectiveness, Amtrak is developing and implementing the SMS concurrently. The company adopted a new Safety Policy on April 4, 2018. New metrics are being established that combine historical data and leading indicators. The metrics support data driven risk management resulting in the proactive identification of risks and corresponding mitigations. Safety Assurance techniques have been deployed to determine the root causes and corrective actions required to address known risks. To increase Safety Promotion, the Safety Policy includes a letter signed by the Executive Leadership Team (ELT) that endorses SMS and sets expectations for all employees. Additionally, regular communications have increased in the form of weekly safety focuses, targeted operational advisories, and direct messaging from the ELT and SC&T Department.

The success of Amtrak’s SMS is dependent upon transforming the culture. As part of disciplined, sustained implementation of this SSPP, Amtrak leadership encourages employees to provide feedback regularly. Employees are empowered to stop an operation if an unsafe condition exists. Employees are also encouraged to self-report safety issues, concerns, or provide any other form of feedback. Reinforcing these expectations throughout every phase of SMS implementation is essential to Amtrak’s growth as a learning organization that continuously improves. Specific policies, training, and techniques that are designed to move the company toward a Just Culture will be implemented as the SMS matures.

A lot has changed for Amtrak since May 1, 1971 and while the company’s commitment to safety has never wavered, this SSPP represents an overhaul in how this commitment will be fulfilled going forward. Theoretically, all incidents are preventable. By developing and implementing a robust SMS, Amtrak will systematically advance toward making this theory a reality, setting a new industry standard along the way and becoming the safest railroad in America.

1.0 Safety Policy Safety Policy is the first pillar of the SMS. Amtrak’s Safety Policy establishes the requirement to develop and implement SMS at the company. The following FRA requirements are addressed in this section: 49 CFR 270.103(b) System Safety Program Policy Statement; 270.103(c) System Safety Program Goals; 270.103(d) Railroad System Description; 270.103(e) Railroad Management and Organizational Structure; 270.103(f) System Safety Program (SMS) Implementation Process. 1.1 System Safety Program Policy Statement The Amtrak Safety Policy was signed by CEO Richard Anderson on April 4, 2018 and will be reviewed annually. The Safety Policy establishes the requirement for Amtrak to develop and implement SMS. The accompanying letter has been signed by Amtrak’s Executive Leadership Team and reflects their endorsement of this policy and establishes clear expectations for all employees. 1.1.1 Purpose This System Safety Policy describes Amtrak’s safety program vision and operations. Amtrak’s safety intent is to operate at the highest levels of safety exceeding regulatory requirements which define minimum standards. We will do this through the implementation and operation of a Safety Management System (SMS). The SMS is designed to identify and evaluate hazards and manage risks to reduce accidents and incidents. Amtrak’s SMS will be in full compliance with applicable regulations, including 49 CFR Part 270 System Safety Program requirements and the Transport Canada Safety Management System requirements. 1.1.2 Responsibility The roles and responsibilities associated with development and implementation of the SMS in accordance with Amtrak’s Safety Policy are depicted in Table 1-1.

Table 1-1 SMS Roles and Responsibilities Role Responsibility Responsible for implementation of the SMS throughout Amtrak. This Executive Vice President includes defining the company safety policy; co-chairing the ESC; and Chief Safety Officer overseeing progress as planned in the SSPP; and engaging stakeholders (EVP-CSO) (Amtrak’s Board of Directors, DOT, FRA, etc.). Responsible for partnering with Safety, Compliance and Training to Management and ensure the training, processes, tools, and resources necessary to Employees successfully implement and operate the Amtrak SMS are in place. Responsible for serving as the highest-level safety body at Amtrak and shall address safety problems and manage resources to address safety Executive Safety Council issues. The CSO and the Chief Operating Officer (COO) shall co-chair the (ESC) ESC. Other local and division safety committees throughout Amtrak roll up administratively to the ESC.

Responsible for leading the implementation of the SMS under the direction of the CSO and with the support of the ESC. This will be accomplished by developing, and gaining consensus around, the strategic approach and guidance for implementation. They will work System Safety with Amtrak business partners, and FRA, to ensure approvals for key Department programs as necessary. They will also perform significant accident and incident investigations to further operating safety. Additionally, they will perform safety assurance functions to ensure the efficacy of mitigation and actions as well as critical safety processes. Responsible for owning the implementation of Amtrak’s safety policy. The resulting safety programs must be integral in each business partner’s established processes and procedures. Through these processes and procedures, the business lines are responsible for Management addressing the immediate safety of employees and customers, by identification and mitigation of risks and supporting Amtrak’s safety culture. Management will appropriately prioritize safety when making organizational and operational decisions. Responsible for their personal safety and for the safety of coworkers and customers. Employees always have the right to stop operations if an unsafe condition exists. Employees will understand their role in an Employees SMS which is primarily to identify risks through a variety of means and prevent unsafe operations. Employees will also cooperate with investigations in order to advance the safety of Amtrak.

1.1.3 Scope This System Safety Policy applies to the entire Amtrak organization. Each Amtrak department and facility will maintain a copy of Amtrak’s current System Safety Policy and the processes/procedures necessary for compliance. These documents must be made accessible to all employees. An inventory of the latest version of safety documents, including the Amtrak SSPP, is maintained on Amtrak’s Intranet in the Safety section at http://wiki.corp.nrpc/display/SAFETY/Home.

1.1.4 Definitions The key definitions associated with Amtrak’s SMS are depicted in Table 1-2.

Table 1-2 Definitions Term Definition A systematic approach to safety that is designed to proactively detect and mitigate risk, reducing accidents and incidents. The SMS requires Safety Management process-based performance (employees access and comply with the System (SMS) processes and procedures associated with their job functions) with a framework that includes four components: (1) Safety Policy, (2) Risk Management, (3) Safety Assurance, and (4) Safety Promotion. A structured process designed to proactively identify, analyze, assess, Risk Management and mitigate risk. A structured process designed to oversee process compliance, monitor Safety Assurance risk mitigations, and measure effectiveness.

A deliberate approach designed to foster the desired culture by Safety Promotion continuously communicating, demonstrating, and training the safety values and expectations established by the company. System Safety Program The document that describes the plan for development and Plan (SSPP) implementation of a SMS. The forum where Risk-based Hazard Management occurs and Safety Assurance results are reported. System Safety Working Groups are System Safety Working comprised of front line employees, management employees and Group (SSWG) System Safety personnel. These working groups meet on a regular basis to review safety data and perform hazard management activities. SSWGs are sanctioned by the ESC in the SSWG charter. The highest-level safety body at Amtrak. It supports Executive Safety Council the operation of the Safety Program and the implementation of the (ESC) SMS, sanctions SSWGs, responds to escalated issues/concerns and provides resources when needed.

1.1.5 SMS Requirements Amtrak is committed to becoming the safest passenger railroad in the country. Amtrak will be an industry leader in the implementation of SMS. Achieving this goal demands dedication and involvement from every employee. All employees must proactively identify and take action to resolve hazards and risks to ensure the safety of our operation.

1.1.5.1 Safety Culture We will strive to create a proactive safety environment in which the organization evaluates and mitigates risks to operations before those operations occur. Our culture will encourage and support employee self-reporting of safety errors and will not discipline employees for such reporting. However, intentional disregard for safety and reckless behavior will not be tolerated. 1.1.5.2 Risk-based Hazard Management A risk-based Hazard Management Process shall be implemented to proactively identify, analyze, assess, and mitigate safety risks. SSWGs will be a primary means of identification and prioritization of organizational safety issues. A variety of safety metrics will be established at the corporate level and cascaded throughout the organization. Management will be held accountable for performance to targets established by the metrics. 1.1.5.3 Safety Assurance The Safety Assurance Process shall be implemented to oversee process-based performance, monitor implementation of risk mitigations, and measure safety performance. Management shall proactively support safety assurance oversight, develop and implement corrective and preventive actions in response to findings and take additional action as needed to capitalize on opportunities to continuously improve and increase risk mitigation. Significant accidents and incidents will be thoroughly investigated and acted upon.

1.1.5.4 Safety Promotion We will work to keep safety in the forefront of employees’ minds through routine, helpful, safety communications. As a learning organization, lessons learned from operations incidents and accidents will find their way back into employee training programs to further safety. Management and employees will work collaboratively to promote Amtrak’s achievements toward accomplishing the Safety Goals. 1.1.6 Safety Policy Review Cycle This policy will be reviewed on a regular basis by the CSO. The revision recording documenting the changes that have been made is depicted in Table 1-3.

Table 1-3 Safety Policy Revision Record Revision Date Description Changes May 10, 2017 Update Sec 1.0, 2.0, 3.0, 8.0, Amtrak Safety Statement Sec 1.0 to 7.0 revised to reflect the SMS requirement and April 3, 2018 Annual Update safety goals, ELT letter

1.1.7 References

• Federal Railroad Administration 49 CFR 270 System Safety Program

• Transport Canada SOR/2015-26 Railway Safety Management System 1.1.8 Executive Leadership Team Annual Safety Letter The Executive Leadership Team (ELT) Safety Letter has been included as Appendix A. 1.2 System Safety Program Goals and Objectives The following safety goals and objectives have been established for FY2019. The goals were developed using the SMART methodology (Specific, Measurable, Achievable, Relevant, Time-sensitive). The objectives represent the key milestones that will be accomplished in order to achieve the safety goals. Amtrak’s performance against these goals is measured and reviewed monthly at the ESC. At a minimum, the safety goals and objectives will be refreshed on an annual basis. 1.2.1 Safety Goal #1: Customer Injury Rate The first safety goal is to reduce the FY2019 customer injury rate to 18.8 incidents per 100 million passenger miles (reduction of 10% or more). The following key objectives will be accomplished to support achievement of this goal:

• SC&T will partner with Operations (Transportation, Engineering, and Mechanical) to facilitate Root Cause Analysis and Corrective Actions (RCCAs) targeting the highest risk areas based on historical data.

• SC&T will partner with Operations to proactively assess the risks and determine mitigations associated with operating on routes experiencing a signal suspension and non-PTC routes (e.g., routes with Main Line Track Exclusions or Approved Alternative Timelines).

• SC&T will partner with Operations to perform station assessments designed to proactively identify and mitigate risks in the facilities as well as implement a series of initiatives to improve customer safety on trains (e.g., Get-A-Grip Campaign, additional on-board announcements, and improved signage). 1.2.2 Safety Goal #2: Employee Incident Rate The second safety goal is to reduce the FY2019 FRA reportable employee incident rate to 3.4 incidents per 200,000 employee hours (reduction of 10% or more). The following key objectives will be accomplished to support achievement of this goal:

• SC&T will partner with Operations and Labor to enhance and improve the Voluntary Reporting Program, enabling more efficient and effective response to risks identified and voluntarily reported by employees.

• SC&T will issue an accident/incident investigation process that institutionalizes the initiation of investigations that drive corrective and preventive actions based on the results.

• SC&T will issue a new Personal Protective Equipment (PPE) process and catalog, designed to assist employees identifying and selecting the appropriate PPE. 1.2.3 Safety Goal #3: Employee Significant Injury and Fatality Potential Rate The third safety goal is to reduce the rate of incidents that have the severity potential to cause a Significant Injury (i.e., life altering conditions such as permanent disability) or Fatality (SIF) to 0.34 per 200,000 employee hours (reduction of 5% or more). The following key objectives will be accomplished to support achievement of this goal:

• Operations will partner with SC&T to implement the Corrective Actions Plans (CAPs) resulting from the RCCAs that were initiated in response to fatalities/serious injuries.

• Accidents/Incidents with SIF potential will trigger accident/incident investigations in accordance with the process, driving corrective and preventive actions designed to effectively mitigate the risk or recurrence.

• SC&T will partner with Operations to expand the use of the Job Safety Analysis (JSA) process and Site-Specific Safety Work Plans (SSSWP), driving proactive assessment and mitigation of inherent task and project-based risks. 1.2.4 Safety Goal #4: Train Safety Index Tier 1 Rail Accident/Incident Rate The fourth safety goal is to reduce the Train Safety Index Tier 1 rate to 8.5 incidents per 1,000,000 train miles (reduction of 10% or more, refer to 3.3.1.3 Tier 1 Rail Accidents/Incidents for more detail on this safety performance metric). The following key objectives will be accomplished to support achievement of this goal:

• Operations will complete implementation of PTC on Amtrak routes in accordance with the federally mandated completion date of December 31, 2018.

• SC&T will partner with Operations to engage host railroads, states, and other stakeholders on the implementation of mitigations that reduce risk to an acceptable level on routes and operations where PTC has not been implemented.

• SC&T will partner with Operations to implement additional technologies available in the market that add redundancy and improve situational awareness. 1.2.5 Safety Goal #5: Train Safety Index Tier 2 Major Operating Rule Violation Rate The fifth safety goal is to reduce the Train Safety Index Tier 2 rate to 2.0 incidents per 1,000,000 train miles (reduction of 5% or more, refer to 3.3.1.4 Tier 2 Major Operating Rule Violations for more detail on this safety performance metric). The following key objectives will be accomplished to support achievement of this goal:

• SC&T will implement a tool called SPARTN to improve the data collection and analyses associated with the Total Efficiency and Safety Test System (TESTS) conducted to comply with 49 CFR 217.9 Program of Operational Tests and Inspections; Recordkeeping

• SC&T will increase staff to establish a Railroad Operations Quality Assurance Team to oversee TESTS performance and perform additional oversight.

• SC&T will partner with Operations to initiate RCCA investigations in response to patterns and trends in Major Operating Rule Violations (MORVs). 1.2.6 Safety Goal #6: Trespasser and Grade Crossing Incident Rate The sixth safety goal is to reduce the Trespasser and Grade Crossing Incidents per 1,000,000 train miles (reduction of 10% or more). The following key objectives will be accomplished to support achievement of this goal:

• SC&T will partner with Operation conduct Grade Crossing risk assessments, resulting in the development and implementation of targeted mitigations.

• Amtrak will continue to participate in Operation Life Saver and specifically Operation Clear Track, which is designed to educate, engineering, and enforce compliance at Grade Crossings and the Right-of-Way.

1.3 Railroad System Description A complex railroad system enables Amtrak to function as the nation’s largest inter/city passenger rail provider, serving more than 500 destinations in 46 states, the District of Columbia, and three Canadian provinces. Amtrak operations occur daily with approximately 85,700 passengers riding more than 300 Amtrak trains on an average day. The SMS will be integrated into the railroad system, which is primarily organized based on three types of routes: Northeast Corridor (NEC), State Supported, and Long Distance. The map depicted in Figure 1-1 highlights the routes associated with each category. The following railroad description covers each type of route and includes the facilities, equipment, and additional services that are included in the system. Additionally, refer to Appendix B Railroad System Description Specifics for more detail.

Figure 1-1 Amtrak Operations by Route 1.3.1 Amtrak Owned and Maintained Routes Amtrak owns and maintains track along the Northeast Corridor (NEC) as well as a 97-mile track segment between Porter, IN and Kalamazoo, MI. The NEC serves the northeast’s five major metropolitan regions: Boston, New York, Philadelphia, Baltimore, and Washington, DC. The NEC is composed of 457 mainline miles. Amtrak owns 354 miles and maintains approximately 400 miles. Metro-North owns and maintains approximately 57 miles. Amtrak owns and operates the NEC from Washington, DC to New Rochelle, NY (except for Harold Interlocking in Queens, which is owned by The Long Island Railroad). Amtrak trains travel over Metro-North’s railroad from New Rochelle to New Haven, CT. Amtrak ownership resumes from New Haven to the Rhode Island/Massachusetts state line. Amtrak maintains the NEC in Massachusetts from the state line to Boston’s South Station in accordance with an agreement established with MBTA. Figure 1-2 depicts the NEC based on ownership to include the New Haven-Hartford-Springfield Corridor: A 60.5-mile segment from New Haven to Springfield, MA and the Keystone Corridor: A 104.2-mile segment from Philadelphia to Harrisburg, PA.

Figure 1-2 NEC by Railroad Ownership 1.3.1.1 Northeast Corridor Approximately 260 million passenger trips are made on the NEC annually with 17 million of them made specifically by Amtrak customers. The balance is provided by commuter railroads that share the NEC. In total, over 2,100 passenger and freight trains operate on the NEC every day. NEC infrastructure includes 11 highway-rail grade crossings, over 140 bridges/tunnels/overpasses, and 109 stations (30 of them used by Amtrak). Refer to Appendix B Railroad System Description Specifics, Tables B-1 NEC Operators; B-2 NEC Grade Crossings; B-3 NEC Bridges/Tunnels/Overpasses for more information. The entire route from Washington to Boston is electrified with a catenary power system. Amtrak’s Acela trains operate at top speeds of 135 mph between Washington and New York and 150 mph between New Haven and Boston. Amtrak regional trains operate at top speeds of 125 mph between Washington and Boston. Commuter trains operate in the territory with speeds that are typically 80 to 100 mph and the top speed for freight train operation is 50 mph. Amtrak uses the Advanced Civil Speed Enforcement System (ACSES) and Automatic Train Control (ATC) to meet Positive Train Control (PTC) requirements on the NEC. ACSES is a transponder-based system that provides positive stop enforcement at interlocking home signals, enforcement of permanent civil speed restrictions, and enforcement of temporary speed restrictions through a data radio network and safety server. The ATC system enforces all speeds associated with the signal system. Additionally, freight railroads that operate on the NEC use the Interoperable Electronic Train Management System (I-ETMS) to meet PTC requirements. Amtrak has federated systems with the freight railroads resulting in functional compatibility. 1.3.1.2 Keystone Corridor Amtrak owns and maintains the Keystone Corridor, a 104.2-mile segment from Philadelphia’s 30th Street Station to Harrisburg’s Transportation Center. The corridor is electrified, operating 14 weekday trains each way with top speeds of 110 mph. Amtrak’s Keystone and Pennsylvanian services operate

over the line. South Eastern Pennsylvania Transit Authority (SEPTA) trains also operate over the line and Norfolk Southern maintains trackage rights as well. The Keystone Corridor is Amtrak’s fifth-busiest route and the railroad’s third busiest in the NEC. The service carries and average of 1.47 million customers annually. 1.3.1.3 New Haven-Hartford-Springfield Corridor Amtrak owns and maintains the New Haven-Hartford-Springfield (NHHS) corridor, a 60.5-mile segment from New Haven to Springfield, MA. The service includes four weekday shuttles and five weekend trips with operating speeds up to 110 mph. The service carries an average of 270,353 customers. Additionally, ConnDOT operates a daily commuter train on the corridor known as CTrail resulting in a total of 17 roundtrip trains between New Haven and Hartford that operate each weekday (with 12 of those roundtrip trains continuing to Springfield). On weekends, a total of 13 roundtrip trains operate between New Haven and Hartford, with nine of those trains continuing onto Springfield. 1.3.1.4 Indiana – Michigan Amtrak owns the 97-mile track segment between Porter, IN and Kalamazoo, MI on the Chicago-Detroit route. This is the longest stretch of track that Amtrak owns and maintains outside of the NEC. The track supports the Wolverine service, which provides roundtrips on the Pontiac-Detroit-Ann Arbor-Chicago route and the Blue Water service, which provides roundtrips on the Port Huron-East Lansing-Chicago route. Amtrak has the Incremental Train Control System (ITCS) installed and currently operates under PTC type approval from the FRA at speeds up to 110 mph. ITCS is a communication-based overlay system that uses Global Positioning System (GPS) tracking to monitor train location and speed. Wayside Interface Units (WIU) are installed throughout the track to monitor signal status and highway crossing status. The ITCS/WIU are used in combination to provide redundancy that ensures compliance with all signal and speed requirements. 1.3.2 State Supported Routes Amtrak receives funding from 18 states through 21 agencies for financial support of 26 short-distance routes (less than 750 miles). Section 209 of the Passenger Rail Investment and Improvement Act (PRIIA) requires Amtrak and its state partners to jointly develop a cost-sharing methodology to equitably charge states for intercity passenger rail service. The PRIIA 209 methodology became effective in October 2013. Continued operation of these state-supported routes is subject to annual state operating agreements. Refer to Appendix B Railroad System Description Specifics, Table B-4 State Support Services for more information. 1.3.3 Long Distance Routes Amtrak operates 15 long-distance trains whose routes range in length from 780 to 2,728 miles. These trains provide service at nearly half of the stations in the Amtrak railroad system. Approximately 72% of the miles traveled by Amtrak are on tracks owned by other railroads, referred to as host railroads. Amtrak pays these host railroads for use of the track and services required to support operations. With the exception of Metro-North, the host railroads that support the most Amtrak train miles for long distance operations outside the NEC include: (1) BSNF Railway; (2) Union Pacific Railroad; (3) CSX Transportation; (4) Norfolk Southern; (5) Canadian National Railway; and (6) Metro-North (Hudson Line). The routes associated with each host railroad are depicted in Figure 1-3.

Figure 1-3 Host Railroads used by Amtrak 1.3.4 Additional Services In accordance with Amtrak’s Group Travel, Private Car and Special Movements Standard Operating Practices, the company provides dedicated services to school groups, sports teams, corporations, etc. Amtrak also contracts with outside parties to transport (on its regularly scheduled train service) private rail cars that meet required mechanical and electrical specifications (other services include the Auto Train, which carries customers and their vehicles on a 16½ hour overnight trip from Lorton, Virginia to Sanford, Florida). Amtrak also offers rail service to three Canadian cities (Montreal, Toronto, and Vancouver). Additionally, Amtrak is one of the largest providers of contract services to include Train and Engine (T&E), access, maintenance, and dispatch across 11 states. Refer to Appendix B Railroad System Description Specifics, Table B-5 Contract Services for more information. 1.3.5 Rolling Stock Amtrak’s locomotive and car inventory are composed of approximately 350 locomotives and 1,340 cars for passenger service. Passenger cars include coaches, sleepers, diners, lounges, and cafe cars. A total of 63 baggage cars are also in use. The locomotives are electric or diesel-electric. Additionally, Amtrak rolling stock includes yard and switcher locomotives, work cars and miscellaneous equipment (e.g., ballast hoppers, tampers, undercutters and regulators). Refer to Appendix B Railroad System Description Specifics, Table B-6 Rolling Stock Inventory for more information. 1.3.6 Facilities Amtrak’s corporate headquarters are in Washington, D.C. at One Massachusetts Avenue, N.W., the Railway Express Agency (REA) Building (900 2nd Street, N.E.), and 10 G Street, N.E. Amtrak has additional offices spread throughout the country. The following describes the salient facilities associated with the railroad system.

1.3.6.1 Maintenance of Equipment Amtrak has three heavy-maintenance facilities, located in Wilmington, DE; Bear, DE; and Beech Grove, IN. Employees at these facilities perform maintenance, inspection, repair and overhaul of the company’s rolling stock. The diesel and electric locomotives are maintained at the Wilmington facility. Amfleet I and II, Horizon, Viewliner and Cab Cars are maintained at the Bear facility. Beech Grove maintains Superliner, Horizon, Viewliner and Heritage equipment and performs overhauls on diesel locomotives. Routine and periodic maintenance is performed on passenger cars and locomotives at the following major terminal points: Albany-Rensselaer, NY; Boston, MA (Southampton); New York, NY (Sunnyside); Philadelphia, PA (Penn Coach Yard); Washington, DC (Ivy City); Sanford, FL; Hialeah, FL; Chicago, IL; Brighton Park, IL; New Orleans, LA; Los Angeles, CA (Redondo Junction); Oakland, CA; and Seattle, WA. 1.3.6.2 Operations The Consolidated National Operations Center (CNOC) is located in Wilmington, DE. The 50,000-square- foot facility monitors train operations 24/7, allocates equipment and serves as the response center for incident and emergency reports. Additionally, Amtrak has a Centralized Electrification and Traffic Control (CETC) center located within the same building as CNOC as well as other dispatching and control centers located in New York City and Boston. The CETC focuses on ensuring operational safety through its dispatching system. Wilmington is also home to Amtrak’s largest training facility, where engineers, conductors, and on-board staff are trained. The Joseph C. Szabo Chicago Control Center is Amtrak’s control center at Chicago Union Station. The center manages and dispatches Amtrak and other rail traffic in four geographically separate areas to include Chicago Union Station North, Chicago Union Station South, New Orleans Terminal, and the Amtrak Michigan District. Operations at the center involve interconnections with territories owned by the Metra, Norfolk Southern, BNSF, and Canadian National railroads. 1.3.6.3 Distribution The Indianapolis Distribution Center (IDC) is Amtrak’s largest material and supply facility. The IDC is composed of 180,000 square feet of inside storage space that manages over 16,000 stock-keeping-units (SKUs), which are inventoried electronically to keep the stock instantaneously updated. The IDC is located less than a mile from the Beech Grove shops. Material for all purposes (coach seats, toilet paper, locomotive parts, etc.) are distributed from the IDC to 31 Amtrak terminals nationwide. 1.3.6.4 Reservation Centers Amtrak has two reservation call centers, one in Philadelphia and the other in Riverside, CA (70 miles southeast of Los Angeles). Collectively, over 1000 Amtrak employees work at these two facilities, answering calls to 1-800-USA-RAIL and the Auto Train information line. These facilities also handle responses to website e-mails, provides customer service for the entire country, and process requests for issues ranging from accommodations for customers with disabilities to special food orders. 1.3.6.5 Stations Amtrak serves or operates approximately 691 railroad stations, travel centers, and bus stops. The top 25 stations by ridership are reflected in Table 1-4 (based on FY2017 data).

Table 1-4 Top 25 Amtrak Stations by Ridership Rank Station Ridership 1 New York, NY 10,436,909 2 Washington, DC 5,098,562 3 Philadelphia, PA 4,328,718 4 Chicago, IL 3,247,117 5 Los Angeles, CA 1,635,039 6 Boston - South Station, MA 1,574,450 7 Sacramento, CA 1,051,001 8 Baltimore, MD 1.030,161 9 Albany-Rensselaer, NY 855,176 10 San Diego, CA 777,352 11 Providence, RI 717,537 12 Wilmington, DE 691,694 13 BWI Airport, MD 689,042 14 Newark, NJ 661,344 15 Seattle, WA 649,491 16 New Haven, CT 642,471 17 Boston - Back Bay, MA 611,527 18 Milwaukee, WI 597,134 19 Portland, OR 590,076 20 Emeryville, CA 581,573 21 Lancaster, PA 560,257 22 Harrisburg, PA 508,624 23 Bakersfield, CA 491,824 24 Irvine, CA 450,732 25 Route 128 Station, MA 450,301

1.4 Railroad Management and Organizational Structure Amtrak’s management and organizational structure has been positioned to enable development and implementation of the SMS. In January of 2018, the EVP/CSO was appointed and the SC&T organization was moved out of the Operations Department, creating an independent safety function with a direct line of authority to the CEO. These changes are reflected in the ELT organizational chart, Figure 1-4.

President and CEO

EVP and Chief EVP and Chief EVP and Chief EVP and Chief EVP and Chief EVP and Chief EVP and General EVP and Chief Administrative Commercial Officer Marketing Officer Operating Officer Safety Officer Financial Officer Counsel Information Officer Officer

Figure 1-4 Amtrak ELT Organizational Chart

The President and CEO is ultimately responsible for ensuring Amtrak fulfills its congressional mandate to provide modern, efficient intercity passenger rail service. The EVP and Chief Commercial Officer is responsible for strategically defining the services that Amtrak provides to its customers. The EVP and Chief Marketing Officer is responsible selling those services. The EVP and Chief Operating Officer is responsible for delivering those services. The EVP and Chief Safety Officer is responsible partnering with

these leaders to ensure those services are delivered with minimal risk to customers, employees, equipment and infrastructure. The EVP and Chief Financial Officer is responsible for corporate accounting, budgeting, and financial reporting. The EVP and General Counsel leads Amtrak’s Law Department and serves as Corporate Secretary. The EVP and Chief Administrative Officer is responsible for support functions that include procurement and logistics, human resources, real estate, labor relations, enterprise program management, preparedness, employee assistance, and passenger accessibility. The EVP and Chief Information Officer is responsible for Information Technology (IT) business systems and information security. All members of the ELT signed a letter endorsing the Amtrak Safety Policy and outlining the following expectations:

1. The ELT must create a proactive safety environment in which the organization evaluates and mitigates risks to operations before those operations occur. This culture will encourage and support employee self-reporting of safety errors and we will not discipline for that reporting provided there was no intentional disregard for safety or reckless behavior; neither of which will be tolerated.

2. Amtrak management are responsible for supporting Amtrak’s safety culture by addressing the immediate safety of employees and customers, and proactively identifying and mitigating risks. Management will appropriately build SMS processes into their procedures and prioritize safety when making organization and operational decisions.

3. Employees will take ownership of their personal safety and be responsible for the safety of coworkers and customers. Employees always have the right to stop operations if an unsafe condition exists. Employee will identify risks, through a variety of means, and prevent unsafe operations. Employees will also willingly cooperate with investigations in order to advance the safety of Amtrak.

The SMS Primary (P) and Supporting (S) responsibilities of each ELT member are depicted in Table 1-5.

Table 1-5 ELT Responsibility Matrix

Pillar Element CEO and President EVP & Chief Commercial Officer EVP & Chief Marketing Officer EVP & Chief Operating Officer EVP & Chief Officer Safety EVP & Chief Financial Officer EVP & General Counsel EVP & Chief Administrative Officer VP & Chief Officer Information 270.103(b) Safety Policy PPPPPPPPP Statement 270.103(c) System Safety PSSPPSSSS Program Goals 270.103(d) Railroad System PPSSPSSSS Description

Safety Policy 270.103(e) Railroad Mgmt PPPPPPPPP and Org Structure 270.103(f) Safety Program PSSPPSSSS Implementation Process 270.103(p) Risk-based Hazard PSSPPSSSS Management Program 270.103(q) Risk-based Hazard PSSPPSSSS Analysis 270.103(r) Technology PSSPPSSSS Analysis and Implementation

270.103(k) Workplace Safety PPPPPPPPP Safety Risk Mgmt Risk Safety 270.103(o) Contract PSSSPSSPS Procurement Requirements

270.103(s) Safety Assurance PSSSPSSSS 270.103(n) Safety Data PSSSPSSSS Acquisition 270.103(h) Rules Compliance PSSPSSSSS and Procedures Review 270.103(g) Maintenance, PSSPSSSSS Repair, and Insp Program

Safety Assurance 270.103(j) Emergency PSSPSSSSS Management 270.103(m) Incident/Accident PSSSPSSSS Reporting and Investigation

270.103(t) Safety Culture PPPPPPPPP 270.103(i) Employee / PSSSPSSPS Contractor Training 270.103(l) Public Safety PSSPPSSSS Outreach Program

Safety Promotion Safety 270.303 Internal System PSSSPSSSS Safety Program Assessment

1.4.1 Operations Operations represents where employees and customers experience the company’s service and therefore, this department is a priority focus for SMS. Amtrak’s Operations Department is composed of three primary functions (Transportation, Engineering, and Mechanical) and four support functions (CNOC, APD, Network Support, CNOC, and Station Operations). The Operations Department is depicted in the organizational chart, Figure 1-5.

President and CEO

EVP and Chief Operating Officer

VP Chief VP Chief VP Chief Mechanical AVP Network AVP Station Transportation AVP Operations AVP Chief of Police Engineer Officer Support Operations Officer

Figure 1-5 Amtrak Operations Organizational Chart

The Transportation Department is responsible for directing and controlling all train movement throughout the nationwide system. The Transportation Department is organized into six regional divisions, depicted in Figure 1-6. The region highlighted in blue depicts the Northwest division. The region highlighted in orange depicts the Southwest division. The region highlighted in green depicts the Central division. The region highlighted in pink depicts the Southeast division. The region highlighted in yellow depicts the Empire division. The region highlighted in turquoise depicts the Northeast division.

Figure 1-6 Amtrak Transportation Divisions

The Mechanical Department is composed of the three back-shops located in Beech Grove, Indiana as well as Bear and Wilmington, Delaware. Employees at these facilities carry out component reassembly, modification, repair, and overhaul of rolling stock. Diesel and electric locomotives are maintained at the Wilmington plant. Amfleet I and II, Horizon, Viewliner and Cab Cars are maintained at the Bear facility. Beech Grove maintains Superliner, Horizon, Viewliner, Heritage equipment and diesel locomotives. Additionally, at the following terminal points periodic maintenance, inspection and minor repairs are performed: Albany-Rensselaer, NY; Boston, MA (Southampton); New York, NY (Sunnyside); Philadelphia, PA (Penn Coach Yard); Washington, DC (Ivy City); Sanford, FL; Hialeah, FL; Chicago, IL; Brighton Park, IL; New Orleans, LA; Los Angeles, CA (Redondo Junction); Oakland, CA; and Seattle, WA.

The Engineering Department is primarily composed of four divisions (Electrical Traction, Structures (Buildings and Bridges), Communications and Signals (C&S), and Track) that are collectively responsible for constructing and maintaining the infrastructure associated with the 1,400 miles of routes that Amtrak either owns or maintains through contracted services. This includes approximately 400 of the 457 mainline miles of the NEC. Adjacent to the NEC, Amtrak owns and maintains the New Haven- Hartford-Springfield Corridor, a 60.5-mile segment from New Haven to Springfield, MA as well as the Keystone Corridor, a 104.2-mile segment from Philadelphia to Harrisburg, PA. Additionally, Amtrak owns and maintains a 97-mile track segment between Porter, Indiana and Kalamazoo, Michigan.

Located in Wilmington, Delaware, CNOC is a 24/7 function that monitors daily train operations, coordinates train equipment allocations, and receives, documents, and provides emergency notifications. The APD provides law enforcement and emergency management that serves and protects Amtrak customers, employees, and property. Network Support includes food and beverage services, information management, as well as process and business services. 1.4.2 Safety System Safety represents one part of a triad of standard-bearing organizations (along with Compliance and Training) that come together to form SC&T. Led by the Sr. Director of System Safety, this organization is responsible for the design and development of the SMS to include establishing and maintaining this SSPP. Additionally, System Safety has a team of specialists deployed throughout the railroad system to facilitate and oversee SMS implementation. The Compliance organization includes the Operating Rules and Practices Team as well as the Railroad Operations Quality Assurance Team. Led by the Sr. Director of Compliance, this organization partners with System Safety to perform essential Safety Assurance oversight that is required to verify risk mitigation compliance and measure effectiveness. The Training organization is responsible for technical training and development. Led by the Sr. Director of Training, this organization is responsible for the development and implementation of a robust training program in accordance with 49 CFR 243 Training, Qualification, and Oversight for Safety-Related Railroad Employees. Therefore, System Safety also partners with Training to align this SSPP and the training plan, which is essential for maturing the SMS. In January of 2018, SC&T was separated from Operations and realigned to become part of the newly formed Safety, Health and Environment (SH&E) Department, led by the EVP and CSO. The EVP and CSO reports directly to the CEO, establishing a direct line of authority for the SH&E Department. The VP of SC&T reports to the CSO and the Sr. Directors of System Safety, Compliance and Training report to the VP of SC&T. The SH&E Department is depicted in the organizational chart, Figure 1-7.

President and CEO

EVP and Chief Safety Officer

VP of Safety, Sr. Director of Sr. Director of Compliance and Environment and Public Health Training Sustainability

Sr. Director of Sr. Director of Sr. Director of System Safety Compliance Training

Figure 1-7 Amtrak SH&E Organizational Chart

1.4.3 Executive Safety Council/System Safety Working Groups/Safety Committees Amtrak Operations and System Safety will implement the ESC, SSWGs, and Safety Committees in accordance with 03-SMS-PO-A System Safety Working Groups. The ESC serves as the highest governing body that oversees development and implementation of the SMS and functions as the highest form of SSWG. The ESC is co-chaired by the CSO and COO with additional membership reflected in the ESC charter. The Sr. Director of System Safety administers the meeting, which occurs on a monthly basis. The ESC leads Safety’s strategic direction by actively maintaining and refreshing the safety policy on an annual basis; establishing and disseminating safety goals; and approving this SSPP and overseeing its implementation. The ESC ensures progress by tracking safety performance against metrics; requiring regular status updates on key initiatives; and triggering special investigations, sub-committees, and risk management initiatives designed to reduce the number of incidents and accidents through corrective and preventive action.

The ESC will sanction the SSWGs that will serve as the SMS operating rhythm. The SSWGs will apply risk management processes to conduct assessments and determine mitigations as well as perform safety assurance planning and reporting that is designed to verify compliance and measures effectiveness. Additional activities include change and configuration management, safety certification (as required), continuous improvement initiatives, and training adjustments. SSWGs will be implemented across the Transportation, Engineering, and Mechanical Departments. Regional Safety Committees will also be established as needs dictate with all functions represented. Safety Committees will have the ability to elevate areas where help is needed to the applicable SSWG and ultimately, SSWGs will have the ability to elevate to the ESC for support, funding, resources, direction, etc. The SSWGs will be facilitated by a safety director and led by the corresponding departmental leader. The Chief Transportation Officer will lead the Transportation Department’s SSWG. The Chief Engineer will lead the Engineering Department’s SSWG. The Chief Mechanical Officer will lead the Mechanical Department’s SSWG. The schedule for

activating each of these SSWGs is reflected in the 1.5 SMS Implementation Process. The ESC-SSWG- Safety Committee structure is depicted in Figure 1-7.

Executive Safety Council

Transportation Engineering Mechanical Department Department Department SSWG SSWG SSWG

Regional Safety Regional Safety Regional Safety Regional Safety Regional Safety Regional Safety Committee Committee Committee Committee Committee Committee

Figure 1-7 ESC-SSWG-Safety Committee Structure 1.5 SMS Implementation Process The SMS implementation process is composed of a multi-year approach. The foundational design and development of Amtrak’s SMS has been the focus of FY2018 with baseline metrics established and best practices implemented in reaction to incidents and known risks. The focus of FY2019 is to institutionalize the SMS by maturing best practices into formalized processes, increasing the use of data to address risks, and fostering the Just Culture required for sustained effectiveness. In 2020, the focus will be to advance SMS by capitalizing on technology, expanding the use of data to proactively detect and address risks, and conducting an internal assessment to evaluate the progress made and determine how to improve the SMS going forward. The following section is organized by year with the SMS implementation schedule expanded to depict the specific milestones planned and projected timeline. Given that progress in various areas may shift forward or backward as development and implementation ensues, this SSPP will be updated annually (at a minimum) to track performance against plan. 1.5.1 SMS Implementation Schedule – 2018

Task 18-1 Address Known Risks with RCCA SC&T partnered with the Transportation and Engineering Departments to launch two investigations based on the Root Cause Analysis and Corrective Action (RCCA) technique. The investigation with Transportation was initiated to determine the root cause associated with recurring overspeed conditions and develop a corrective action plan to mitigate the risk of recurrence. The investigation with Engineering was initiated to determine the root cause associated with recurring electrical shock exposure and develop a corrective action plan to mitigate the risk of recurrence. The root cause analyses were completed for both investigations and corrective actions plans have been established.

Task 18-2 Appoint EVP/CSO and Re-organize On January 1, 2018, Amtrak completed the transition to a new President and CEO who established the requirement to develop and implement the company’s SMS. The CEO proceeded to create the requirement for the CSO, an EVP-level position that reports directly to him. The EVP and CSO was appointed on January 22, 2018. When the EVP and CSO was appointed, SC&T was subsequently separated from the Operations Department, creating an independent safety function with a direct line of authority to the CEO. Task 18-3 Increase Safety Promotion Increasing safety promotion started at the beginning of 2018, with improved Weekly Safety Focuses that include the latest safety metrics and SMS Corner, a dedicated section that provides regular messaging on SMS. Amtrak’s first routine leadership summit was held in February of 2018 with SMS at the top of the agenda and presented by the EVP and CSO. SC&T will continue to capitalize on this opportunity to discuss safety with Amtrak leadership. SMS has also become a regular discussion point at the CEO’s and the CSO’s Town Hall events, which compliments the direct messaging issued by both leaders through e-mail and Special Employee Advisories. Safety messaging encourages employees to get involved to share their perspectives and experiences. Those inputs are being published in the newsletter Amtrak This Week. Additional recognition activities include the Safety Video Challenge and President's Service and Safety Award (PSSA). Refer to 4.0 Safety Promotion for more detail. Task 18-4 Publish Safety Policy and Executive Leadership Team Letter The EVP and CSO led an overhaul of the existing safety policy to reflect the SMS requirement. The new safety policy was signed by the CEO on April 4, 2018. In addition to publishing the safety policy, a letter signed by all ELT members was released at the same time. The letter represents the ELT’s endorsement of the new policy and explains the expectations for employees at every level within the company. Additionally, a refreshed ELT Letter will be published to mark the significance of submitting the SSPP, discuss the progress made, and reinforce expectations for employees at every level within the company. Refer to 1.1 System Safety Program Policy Statement for more detail. Task 18-5 Establish Risk Assessment Tools for non-PTC and Signal Suspension Routes SC&T partnered with the Transportation and Engineering Departments to pilot the non-PTC risk assessment process on the non-signaled territory of the Ethan Allen route, which runs from Whitehall, NY to Rutland, VT. Following completion of the Ethan Allen pilot, a Risk Management planning conference was held to prepare for the completion of risks assessments on all routes that are currently not designated for PTC installation (e.g., routes with Main Line Track Exclusions). Concurrently, a Signal Suspension Risk Assessment Template has been established and implemented. This template is designed to proactively identify the risks involved when specific routes experience a signal suspension and to determine the mitigations required to enable continued operations.

Task 18-6 Baseline Safety Metrics Established - Train Safety Index Tiers 1 and 2

To measure the effectiveness of the SMS, new safety metrics have been established. Amtrak is committed to ensuring that all customers have a safe experience. Consequently, the customer incident metric measures the rate for how often customers experience an incident that could erode their trust in Amtrak’s safety. Amtrak is equally committed to employee safety. The employee incident metric measures the rate for how often employees experience an injury or illness. The Tier 1 Train Safety Index is a comRutlpiled metric that measures the rate of rail incidents (derailments, collisions, etc.). The Tier 2 Train Safety Index is a compiled metric that measures the rate of Major Operating Rule Violations (speeding, tampering, etc.). These metrics measure Amtrak’s overall safety performance and will be used to track performance against the established safety goals. The metrics were approved by the ESC and performance is reviewed monthly. Refer to 3.3.1 Safety Data Acquisition for more detail. Task 18-7 Launch SPARTN Oversight Tool As part of advancing the Safety Assurance Program, the SPARTN tool has been launched to support Total Efficiency and Safety Test System (TESTS) conducted to comply with 49 CFR Part 217.9 Program of Operational Tests and Inspections; Recordkeeping. By capturing the TESTS results using SPARTN, the data uploads to Amtrak’s Enterprise Data Warehouse (EDW). Integration through EDW enables improved metrics and analysis that drive the company to proactively identify and act on opportunities to improve before an accident/incident occurs. Additionally, three specialists were added to SC&T as part of the Railroad Operations Quality Assurance Team, which oversees TESTS performance and conducts additional oversight. Refer to 3.0 Safety Assurance Program for more detail. Task 18-8 Establish FY19 Safety Goals To establish FY19 Safety Goals, historical data was used to formulate projections and derive targets. The goals correspond to the new safety metrics established and target a 5-10% performance improvement as detailed in 1.2 System Safety Program Goals and Objectives. The goals were approved by the ESC, CEO and the Amtrak Board’s Safety and Security sub-committee. The goals have been broken down into specific organization-level goals for the Transportation, Engineering, and Mechanical Departments. Provided each department meets or exceeds their specific goals, the overall company will accomplish the safety goals established for FY19. Task 18-9 Obtain Board Approval of Safety Strategy Going Forward The Amtrak Board's Safety and Security Sub-Committee approves the strategic direction of Safety at Amtrak on an annual basis. This SSPP aligns with the strategy and will be updated following the Board's annual approval, accordingly. The FY19 Safety Strategy outlines Amtrak's direction to: 1) Implement an industry-leading SMS using just culture principles; 2) Be a leader in implementation of PTC and assure PTC equivalency in non-PTC territory and; 3) Use data and technology to improve safety, technical training and qualification. The Safety Strategy has been included as Appendix D.

1.5.2 SMS Implementation Schedule – 2019

Task 19-1 Establish Accident/Incident Investigation Process Establishing the Accident/Incident Investigation Process institutionalizes the RCCA methodology, provides guidance to assist in determining when this technique is applied, and provides other tools to perform internal investigations and support external investigations. The process clarifies roles and responsibilities, provides a post-incident review template, and explains the internal coordination required with the ESC. Refer to 3.3.2 Accident/Incident Reporting and Investigation for more detail. Task 19-2 Enhance Voluntary Reporting Program SC&T has engaged Labor leadership to expand use of the Confidential Close Call Reporting System (C3RS) and to establish an internal voluntary reporting system that provides employees with the option to report hazards, near-misses, or any other safety related concern anonymously. Employees that use this option enable SC&T to collect and analyze the data more efficiently, which results in faster development of corrective/preventive actions that further reduce risk. Task 19-3 Obtain ELT Approval of SSPP and submit to FRA This SSPP went through several iterations on a development schedule that included reviews by SC&T leadership, the ESC, Labor, and the ELT. Upon securing approval from the ELT, the SSPP was finalized and submitted to the FRA on November 1, 2018. This SSPP will be update annually at a minimum to align with strategic direction approved by Amtrak's Board and refresh the implementation process to reflect performance against plan. Task 19-4 Launch Just Culture Initiative As FY19 progresses, Amtrak will move toward a Just Culture with the focus on determining how to distinguish between an honest mistake that should be learned from, at risk behavior that should be coached, and intentional disregard for safety or reckless behavior that should be disciplined. This will involve new processes for performing evaluations, training at different levels within the company, and revisiting existing programs. Task 19-5 Establish Risk Management Process Establishing the Risk Management Process institutionalizes the risk management methodology that has been applied in the non-PTC and signal suspension risk assessment tools. Additionally, the process will standardize roles and responsibilities, explain when risk management should be applied, and explain how its used as part of SSWGs. Refer to 2.0 Safety Risk Management for more detail.

Task 19-6 Launch Internal Evaluation Program SC&T is contracting with a third party firm to launch an Internal Evaluation Program. To start, the firm will evaluate Amtrak's compliance to critical safety processes and NTSB recommendations. The results will be used to help mature the SMS by identifying gaps in development and implementation that need to be prioritized and addressed. Task 19-7 Complete non-PTC Risk Assessments

SC&T, Transportation, Engineering and associated labor organizations collaborated to complete the initial non-PTC risk assessments within the June to October timeframe of 2018. Additional non-PTC risk assessments are being conducted in areas where PTC is planned but implementation will be on an FRA approved alternative schedule for compliance. The results are being used to identify and implement mitigations that are comparable to the level of risk mitigation provided by PTC. Task 19-8 Establish the Safety Assurance Process The Safety Assurance Process institutionalizes the oversight required to verify that risk mitigations are properly complied with and to measure their effectiveness. The Safety Assurance Process compliments the risk management process by provided the closed loop feedback required to adjust risk levels and priorities. Additionally, the Safety Assurance Process aligns the Internal Evaluation Program, SPARTN, and oversight performed by System Safety Specialists. Task 19-9 Launch System Safety Working Groups The SSWG provides an organized, systematic approach to SMS implementation. The SSWG process and templates will be established followed by the SSWG pilot conducted in the Transportation Department, which has been a leader in the implementation of SMS Risk Management techniques. The Mechanical SSWG will follow the pilot and then Engineering’s SSWG will be implemented (additional SSWGs may be established as determined by the ESC). Refer to 1.4.3. Executive Safety Council/System Safety Working Groups/Safety Committees for more detail. Task 19-10 Initiate Grade Crossing Risk Assessments As the non-PTC risk assessments and mitigations are implemented, the focus will shift to applying the risk management methodology to high risk grade crossings based on historical data. The initiative will focus on Amtrak owned grade crossings first and then an effort will be made to engage other grade crossing owners to partner on accomplishing risk assessments in their high risk areas.

Task 19-11 Refresh Safety Goals for FY20 In the fourth quarter of FY19, the year’s performance and historical data will be used formulate projections and derive targets for FY20 Safety Goals. The goals will be submitted for SC&T leadership approval, followed by the ESC, ELT, and then submitted to the Board Safety and Security Sub- committee for approval as part of the FY20 Safety Strategy. Upon receiving Board approval, this SSPP will be updated to align with the strategic direction established to include the FY20 Safety Goals.

Task 19-12 Perform annual update of Safety Policy and Executive Leadership Team Letter In line with preparing the FY20 Safety Goals, the Safety Policy will also be refreshed based on lessons learned from SMS development and implementation. Concurrently, the ELT Letter will be updated to endorse the updated Safety Policy, discuss the progress made, challenges ahead, and reinforce expectations for employees at every level within the company.

Task 19-13 Obtain ELT and Board approval of renewed Safety Strategy

The projected FY20 Safety Goals and components of the Safety Policy fold into an overall document that reflects the strategic direction of Safety as the new fiscal year is entered. The Safety Strategy is submitted along with a Board resolution that requires approval on the path forward. Obtaining ELT approval and receiving a passed resolution ensures leadership engagement and support for the resources required to execute. Task 19-14 System Safety Program Plan As FY19 ends, this SSPP will be updated to define the plan going forward to advance SMS development and implementation in alignment with the strategic direction approved by the ELT and Board. This enables the high-level strategy to be planned and operationalized, converting direction into specific initiatives that produce results.

1.5.3 SMS Implementation Schedule – 2020

Task 20-1 Advance Safety Related Training As SMS development and implementation progresses, existing safety training will be improved and new courses developed. Amtrak has established standardized onboarding training for new employees, which includes a module on safety. Safety Starts With Me is an existing training course that is being updated to reflect the SMS approach and expanded to include both non-agreement and agreement employees. SMS has been included as part of a new leadership course (Management 101) that has been developed for existing and recently hired employees that are new to the management ranks. This SMS training effort is part of the overall plan being developed to comply with 49 CFR 243 Training, Qualification, and Oversight for Safety-Related Railroad Employees. Task 20-2 Procure SMS Software Application The initial SMS programs are being designed and developed using the Microsoft Office suite (Word, Excel, PowerPoint, etc.). However, SMS software applications exist that standardize reporting, automate risk management workflows, capture safety assurance results, and integrate with existing technologies to improve metrics and enhance analyses. Therefore, as part of maturing Amtrak’s SMS, an industry leading SMS software application will be procured and integrated. Task 20-3 Expand Train Operations Data Collection and Analysis Data on handling and performance is generated every time a train is placed in operation. By collecting this data from every train, every trip, every day SC&T will be able to analyze and detect trends that provide leading indicators, enabling preventive action to reduce risk before an accident/incident occurs. This will include new data generated from PTC in areas such as alerting and enforcements.

Task 20-4 Launch new Safety website on Intranet Amtrak has contracted with a third party to develop a new intranet that will include a new Safety website. The new website will provide a centralized location for all SMS processes, tools, and materials in a format that is comprehensive and end-user friendly. As the SMS matures, the Safety website will become the source for employees at every level within the company.

Task 20-5 Capitalize on Participation in FRA's RISE Program Amtrak SC&T has actively engaged the FRA as a leading participant in the Rail Information Sharing Environment (RISE) Program. The RISE Program is a Government-Industry collaboration where information is voluntarily shared in an effort to proactively improve safety across the railroad system. As the program matures, Amtrak will capitalize on the benefits from participating in RISE, incorporating the information for use as part of the SMS. Task 20-6 Incorporate Technology-based Enhancements In addition to PTC, Amtrak is evaluating technologies that are available in the marketplace that could either add redundancy or provide further risk mitigation in non-PTC areas (e.g., Main Line Track Exclusions). These technologies include enhanced visual displays and alerting that improves locomotive engineer situational awareness, Global Positioning System (GPS) based tracking, train health monitoring and reporting, upgrades to outward facing video cameras to provide inward/outward capability, and communications with back office systems to provide conditional alerting and analytics to measure compliance with operating rules and related requirements. The evaluation of technology is currently ongoing and implementation is expected to occur as FY20 progresses and possibly earlier. Task 20-7 SPARTN Expansion SPARTN was launched in FY18 as the tool performed to conduct TESTS oversight in accordance with 49 CFR Part 217.9 Program of Operational Tests and Inspections; Recordkeeping. SPARTN expansion is envisioned to enhance this oversight by increasing internal integration with other systems, such as the Enterprise Learning Management Platform (ELMP) and Amtrak Safety Information System (ASIS), enabling oversight results to correlate with training and safety information. Further expansion includes the incorporation of other data sources, such as performance information captured by PTC. Task 20-8 Expand Safety Metrics - Train Safety Index Tiers 3 and 4 With the expansion of SPARTN, implementation of an SMS software application, enhanced voluntary reporting, and PTC activation, the opportunity to capture and analyze additional data exists that will drive the maturation from a reactive safety program to a proactive SMS. Consequently, two additional tiers will be added to the baseline Train Safety Index established in FY18. Tier 3 will be composed of Leading Indicators that enable preventive action that reduces, such as event recorder data from every train and every trip. Tier 4 will be composed of the data generated from voluntary reporting captured by C3RS, the internal voluntary reporting system, RISE, and feedback received by SC&T by phone or email. The data will be examined for confirmed hazardous conditions and analyzed to identify trends or patterns that trigger corrective and preventive actions.

Task 20-9 Refresh Safety Goals for FY21 In the fourth quarter of FY20, the year’s performance and historical data will be used formulate projections and derive targets for FY21 Safety Goals. The goals will be submitted for SC&T leadership approval, followed by the ESC, ELT, and then submitted to the Board Safety and Security Sub- committee for approval as part of the FY21 Safety Strategy. Upon receiving Board approval, this SSPP will be updated to align with the strategic direction established to include the FY21 Safety Goals. Task 20-10 Perform annual update of Safety Policy and Executive Leadership Team Letter

In line with preparing the FY21 Safety Goals, the Safety Policy will also be refreshed based on lessons learned from SMS development and implementation. Concurrently, the ELT Letter will be updated to endorse the updated Safety Policy, discuss the progress made, challenges ahead, and reinforce expectations for employees at every level within the company. Task 20-11 Obtain Board approval of renewed Safety Strategy The projected FY21 Safety Goals and components of the Safety Policy fold into an overall document that reflects the strategic direction of Safety as the new fiscal year is entered. The Safety Strategy is submitted along with a Board resolution that requires approval on the path forward. Obtaining ELT approval and receiving a passed resolution ensures leadership engagement and support for the resources required to execute.

Task 20-12 Update System Safety Program Plan As FY20 ends, this SSPP will be updated to define the plan going forward to advance SMS development and implementation in alignment with the strategic direction approved by the ELT and Board. This enables the high-level strategy to be planned and operationalized, converting direction into specific initiatives that produce results. Task 20-13 Conduct Internal Assessment SC&T will leverage the Internal Evaluation Program to conduct a complete assessment of SMS progress to date. The internal assessment is designed to ensure all of the fundamental components of the SMS are in place and measure their level of development. The results will be used to identify gaps and determine the next steps required to continuously improve the company’s SMS, which will be operationalized through the development and implementation of a Preventive Action Plan. Successful implementation of the Preventive Action Plan supported by SSWGs will signify the shift from a reactive culture that is responding to historical data in 2018 to a proactive culture that actively collects and analyzes data to drive actions that reduce risk before an accident/incident occurs.

2.0 Safety Risk Management Safety Risk Management is the second pillar of the SMS. Amtrak’s dynamic railroad operation comes with inherent risk that drives the need for proactive risk management. The following FRA requirements are addressed in this section: 49 CFR 270.103(p) Risk-based Hazard Management Program; 270.103(q) Risk-based Hazard Analysis; 270.103(r) Technology Analysis and Implementation Plan; 270.103(k) Workplace Safety; 270.103(o) Contract Procurement Requirements. 2.1 Risk-based Hazard Management Program Amtrak’s Operations Department will work with System Safety to implement the company’s Risk-based Hazard Management Program (RHMP) in accordance with 03-SMS-RM-A Risk-based Hazard Management. The purpose of the RHMP is to proactively identify, analyze, assess, and mitigate risks resulting in the prevention of incidents and accidents (risk realization). The RHMP is conducted through targeted risk assessments and action items (mitigations) that are actively managed as part of the SSWGs. The SSWGs are led by the leaders of the organization exposed to the risk (Transportation, Mechanical, and Engineering VPs) and facilitated by subject matter experts on risk management methodology (System Safety Directors or their designees). SSWGs enable the RHMP to continuously examine each area of Amtrak’s operation and account for results from the Safety Assurance Program, which is led by System Safety to track risk mitigations and measures their effectiveness. 2.1.1 Risk Identification As the SMS matures and SSWGs are implemented, the KNOT methodology (Know, Need to Know, Opinion, Think we Know) will be applied to holistically define the system for the applicable area (region/department). At the initial SSWG, the Director of Safety (or designee) will facilitate a brainstorming session using KNOT principles to enable the team to: (a) define what is known (based on experience, performance data, etc.); (b) identify questions or areas that require data review or more research (need to know action items); (c) encourage people to speak freely and share their opinions (rumors, perceptions, etc.); and (d) revisit theories, assumptions, and other notions that need to be verified or validated (think we know). This activity is applied as part of every RHMP session, which allows the team to mature its definition of their system and effective manage change when required. The outcome of using the KNOT methodology results is the proactive identification of risks, which becomes known as the Preliminary Hazards List (PHL). As these risks are analyzed, assessed, and effectively mitigated the process repeats and priorities change. The resulting Hazard List is continuously maintained and reviewed as part of the SSWG. 2.1.2 Risk Analysis and Assessment The identified risks are the subjected to analysis based on the standard probability x severity formula. The probability is measured based on how likely the risk is expected to be realized, which is fundamentally based on how often the activity introducing the risk is performed. The severity is measured based on the potential consequences expected from realizing the risk. A combination of both quantitative and qualitative inputs are used to determine probability and severity. The data used to determine frequency include records of the work performed and event intervals (quantitative) along with feedback from employees, management and safety oversight (qualitative). The data used to determine severity includes any history of risk realization (incidents/accidents) or reported close calls (quantitative) along with brainstorming what-if scenarios, employee experience and feedback from safety oversight (qualitative). Performing this analysis yields a result that enables each risk to be

assessed using two scales and stoplight rating criteria. The scales measure probability and severity, as determined by the risk analysis. The probability scale has a letter-based value range of A to E. The higher the grade, the more likely (probable) the risk is expected to be realized. Th risk management probability scale is depicted in Table 2-1.

Table 2-1 Risk Management Probability Scale Probability Value Meaning Frequent A Opportunity for risk to be realized expected to occur often

Probable B Opportunity for risk to be realized expected on a recurring basis

Occasional C Opportunity for risk to be realized expected to occur

Remote D Opportunity for risk to be realized not expected to occur but possible

Opportunity for risk to be realized not expected to occur and almost Improbable E inconceivable

The severity scale has a number-based value range from 1 to 4. The lower the number value assigned, the more severe the consequence is expected to be if the risk is realized. The risk management severity scale is depicted in Table 2-2.

Table 2-2 Risk Management Severity Scale Severity Value Meaning Risk realization expected to result in one or more of the following: death, permanent total disability, loss of passenger/crew occupied Catastrophic 1 volume with equipment damage causing separations in structure, infrastructure damage that suspends service through the affected area for greater than 24 hours.

Risk realization expected to result in one or more of the following: permanent partial disability, injuries/illness that results in hospitalization, loss of passenger/crew occupied volume with Critical 2 equipment damage that causes openings but no separations in structure, infrastructure damage that suspends service through the affected area for greater than 2 and up to 24 hours.

Risk realization expected to result in one or more of the following: injury or illness resulting in one or more lost work day(s), loss of Marginal 3 passenger/crew occupied volume with equipment damage that causes no openings in structure, infrastructure damage that suspends service through the affected area for more than 30 minutes and up to 2 hours.

Risk realization expected to result in one or more of the following: injury or occupational illness that does not result in a lost work day, no Negligible 4 loss of passenger/crew occupied volume, equipment or infrastructure damage that does not suspend service nor cause a delay through the affected area for more than a maximum of 30 minutes.

The risks are plotted on a risk assessment matrix (or risk profile) as the scales are applied. The risk assessment matrix is embedded with the stoplight criteria, which results in an assessment of each risk as high (red), medium (yellow) or low (green). The matrix includes a risk index that provides definitions associated with the criteria. The risk assessment matrix is depicted in Table 2-3.

Table 2-3 Risk Assessment Matrix Risk Severity Risk Catastrophic Critical Marginal Negligible Probability 1 2 3 4

Frequent – A 1A 2A 3A 4A

Probable – B 1B 2B 3B 4B

Occasional – C 1C 2C 3C 4C

Remote – D 1D 2D 3D 4D

Improbable – E 1E 2E 3E 4E

Risk Index

CEO, COO, and CSO approval 1A, 2A, 3A, 1B, 2B, required to continue activity Red 3B, 1C, 2C, 1D without level-changing mitigations in place.

VP level approval required to 4A, 4B, 3C, 2D, continue activity without Yellow 3D, 1E, 2E, 3E level-changing mitigations in place.

Division VP, AVP, or Gen. Superintendent approval Green 4C, 4D, 4E required. Risk effectively mitigated or considered so unlikely its acceptable as-is.

2.1.3 Risk Mitigation Each risk is examined to determine the action items (mitigations) necessary to reduce the risk to the lowest possible level. The risks assessed as high are prioritized, followed by medium risks and then low risks (as required). The following criteria is based on the Hierarchy of Controls and will be applied when developing risk mitigations:

1. Elimination: Mitigations designed into the operation that completely eliminates the potential for exposure to the risk (e.g., build an over-pass instead of creating a grade crossing as part of establishing a new train route).

2. Substitution: Mitigations designed into the operation that results in avoiding the potential for risk exposure (e.g., avoid a route with a signal suspension by taking an alternate route instead).

3. Engineering: Mitigations designed into the operation that trigger controls when the potential for risk exposure increases (e.g., PTC enforcement when an overspeed condition occurs).

4. Administrative: Mitigations designed to change how the activity is performed (e.g., issuance of a speed restriction through General Order when entering the route with a signal suspension is unavoidable).

5. Personal Protective Equipment (PPE): Mitigations designed to protect from exposure to the risk while an activity is performed (safety eyewear, puncture-resistant gloves, etc.).

At the SSWG meetings, the Operations team applies mitigation criteria in the order specified with most feasible and effective mitigations prioritized accordingly. Each mitigation becomes an action item assigned in the risk management workflow system by System Safety. Depending on how many mitigation actions are assigned to a risk, a dedicated risk mitigation plan may be established. Any risk mitigations that require additional resources (personnel, funding, etc.) to support implementation are elevated to the ESC for review and adjudication. Additionally, the opportunity to capitalize on currently available or new technologies will be considered for each of the steps described above. If a technological mitigation is identified, the proposed solution will be elevated to the ESC, as described in 2.2 Technology Analysis and Implementation Plan. The mitigations for every high and medium risk are also considered for inclusion on the Critical Safety Items List (CSIL). The CSIL is composed of critical elements that are certified by a Lead System Safety Specialist and issued a Certificate of Conformance (COC) as part of the safety certification process. The Safety Assurance Program, administered by System Safety, monitors the implementation and effectiveness of risk mitigation activities and provides the results at the SSWG, enabling the RHMP to continuously improve. 2.2 Technology Analysis and Implementation Plan Amtrak’s Technology Analysis and Implementation Plan is composed of four areas: PTC implementation, risk assessment and mitigation for non-PTC routes (Mainline Track Exclusions, Dark Territories, etc.), Train & Engine (T&E) crew capability enhancements, and training software and simulator upgrades. This plan enables Amtrak to capitalize on technologies available internally within the company and externally in the market to add redundancies and effectively mitigate the risks that are historically associated with

most severe accidents experience. Specifically, (1) Train Collisions; (2) Overspeed Conditions; (3) Open Facing Point Switches; (4) Roadway Worker Protection. 2.2.1 PTC Implementation Amtrak’s Engineering and Mechanical Departments have made implementation of PTC on all company owned and maintained routes a priority and remains on schedule for completion by December 31, 2018 in compliance with FRA requirements. Amtrak has submitted and received the FRA’s approval of the company’s PTC Implementation Plan (PTCIP) in accordance with 49 CFR 236 Rules, Standards, and Instructions Governing the Installation, Inspection, Maintenance, and Repair of Signal and Train Control Systems, Devices, and Appliances Subpart I Positive Train Control Systems. Additionally, Amtrak submits PTC implementation progress reports quarterly in accordance with FRA requirements. 2.2.2 Non-PTC Risk Assessment and Mitigation Concurrent with PTC implementation, Transportation and System Safety are conducting risk assessments on all non-PTC routes as reflected in 1.5 SMS Implementation Process. The results of the non-PTC risk assessments will be used to identify needs and corresponding technologies available in the market to provide robust mitigation that is comparable to PTC. These technologies include enhanced visual displays and alerting that improves locomotive engineer situational awareness, Global Positioning System (GPS) based tracking, train health monitoring and reporting, upgrades to outward facing video cameras to provide inward/outward capability, and communications with back office systems to provide conditional alerting and analytics to measure compliance with operating rules and related requirements. 2.2.3 T&E Crew Capability Enhancements Based on the results of the RCCA conducted to address recurring overspeed conditions, an application (app) is being developed internally that enables conductors to have increased visibility in terms of location by milepost and speed. This provides another human with increased situational awareness, adding redundancy by enabling the conductor to detect and contact the locomotive engineer when a nonconforming condition starts to occur. The app will be integrated into the Conductor’s Enterprise Mobile Device (EMD), which is the same tool used for ticket taking and related job functions. A similar app for use by Locomotive Engineers is being evaluated to include the regulatory implications. This effort is part of completing the Transportation Corrective Action Plan (CAP) reflected in 1.5 SMS Implementation Process. 2.2.4 Training Software and Simulators Based on the results of the RCCA conducted to address recurring overspeed conditions, the simulator portion of Amtrak’s training program is expanding and being upgraded. Amtrak is contracting to have software developed to accurately reflect the routes operated outside of the NEC. The simulator footprint is being re-evaluated to determine infrastructure and capability needs (e.g., full motion vs. stationary) with scenario-based options that disable PTC and other functions as part of verifying skills, knowledge, and proficiency. This effort is part of completing the Transportation Corrective Action Plan (CAP) reflected in 1.5 SMS Implementation Process. 2.2.5 Ongoing Technology Analysis As part of the risk mitigation phase of the RHMP, the opportunity to capitalize on currently available or new technologies will be considered as the mitigation criteria is applied. If a SSWG identifies a potential technological solution, the proposed mitigation will be elevated to the ESC for consideration. As part of

elevating the technology, the identifying team will be required to submit a proposal that explains: (1) the technology and recommendations (2) expected reduction of targeted risk; (3) potential to introduce new or adversely affect other risks; (4) feasibility of implementation based on the operating environment; (5) overall analysis of costs vs. benefits. The ESC will review the proposal and if accepted, an implementation plan will be established. If the proposal is rejected, the rationale will be documented in the ESC minutes and the item closed accordingly. 2.3 Workplace Safety A safe workplace is a fundamental component of Amtrak’s SMS. The initiatives, activities, processes and PPE associated with workplace safety combine to create an environment conducive to effectively mitigating risk and enabling safety performance that continuously improves. Every element of workplace safety is subject to oversight as part of the Safety Assurance Program with the results incorporated as part of RHMP. 2.3.1 Fitness for Duty The effort to minimize risk starts with ensuring that potential and current employees are inherently capable of fulfilling the requirements associated with their positions in the company. Therefore, Amtrak Medical Services has established processes designed to ensure fitness for duty as part of the hiring process and during employment. 2.3.1.1 Medical Clearance Prior to beginning their employment with Amtrak, agreement employees are required to complete a pre-placement physical examination that includes drug testing (non-agreement employees are only required to pass a drug test), which is triggered as part of the application process implemented by Human Resources (HR). The results are evaluated to ensure the employee is medically cleared and capable of performing the work associated with their potential position with the company. In addition, Physical Capacity Evaluations (PCE) are performed to ensure the candidate has the upper and lower body strength required for the position.

Employees who are required to hold a locomotive engineer or conductor certification under 49 CFR 240 Qualification and Certification of Locomotive Engineers or 49 CFR 242 Qualification and Certification of Conductors, or a commercial drivers’ license (CDL/CMV) under the FMCSA are required to have periodic examinations. Medical Services evaluates these examinations and makes the fitness for duty determination except in cases of CDL/CMV where the Certified Driver Medical Examiner (CDME) makes this determination. Medical Services also screens these employees for sleep apnea at their periodic examination. Based on the results, Medical Services determines who to refer for diagnostic sleep testing. For employees that did not trigger a referral, Medical Services sends the employee a letter informing them of examination results. Employees are required to notify Medical Services of any sleep disorder diagnosis, which subsequently monitors compliance with the recommended treatment. Absences from work due to medical leave for more than 6 days requires documentation submitted from the applicable physician prior to the return to work date. Medical Services will determine if additional medical documentation or an examination is required in addition to the drug test prior to clearing the employee to return to work, which is determined by the Amtrak Medical Director. Leave for other reasons (personal leave of absence, jury duty, military, etc.) for 30 days or more are required to complete a drug test. For employees who are currently working and exhibiting difficulty performing their job, a manager can make a request for a fitness for duty evaluation to Medical Services who may

request additional medical documentation and potentially an independent physical examination to determine whether the employee is capable of performing in their position. 2.3.1.2 Control of Drug and Alcohol Use Amtrak is committed to establishing and maintaining a drug- and alcohol-free workplace in accordance with company policy 7.3.4 Drug and Alcohol Free Workplace Program. Employees who come to the workplace (on or off duty) intoxicated by or in possession of drugs or alcohol pose an unacceptable risk to themselves, their fellow workers and the traveling public. Therefore, Amtrak requires that all employees report for and remain on duty, alcohol-and drug-free. In October of 2017, Amtrak launched a new drug and alcohol abuse program focused on prevention known as P.I.E.R. (Prevention, Intervention, Education, and Resources). 2.3.1.2.1 PIER Program The Prevention, Intervention, Education, Resources (PIER) program is an Amtrak developed program that emphasizes prevention of drug and alcohol abuse. PIER provides a 24/7 confidential mark-off system for employees impaired due to use of alcohol or drugs. Employees that mark-off are subsequently contacted by volunteer co-workers that serve as counselors. The co-workers help employees determine the education and resources necessary to prevent further instances of drug and alcohol abuse. The employee counselor program is available to every co-worker to provide immediate assistance for referral to a treatment source, and follow-up care for a drug/alcohol problem. The Program’s agreement and non-agreement employees assist co-workers in dealing with substance abuse problems in a confidential manner. Volunteer Counselors are well equipped to perform their role and receive intensive training in the areas of crisis counseling, listening, confidentiality, working with other agreement committees, recognizing signs of problem behaviors, the dynamics of the disease of addiction, locating treatment resources, insurance plans and transportation issues. Counselors maintain close contact with employees returning from treatment, becoming an active part of the continuing care plan and serving as a source of support in the early stages of recovery. The Counselor helps to identify signs of relapse, providing assistance for recovery both on and off the job. After treatment, Counselors facilitate the transition of employees back into the workplace. The PSO program (Police Support Officers) embraces and extends this same level of care to members of the Amtrak Police force, as well as assistance for other problems specific to their profession. The PIER program has been developed by partnering with the Organizational Wellness Learning System (OWLS) group. OWLS is the only program that earned the Surgeon General’s Seal of Approval in 2016 for effectiveness in workplace prevention. 2.3.1.2.2 Drug and Alcohol Policy Amtrak’s policy requires that employees maintain a drug and alcohol-free workplace and therefore, prohibits employees from the following:

• The unlawful manufacture, distribution, dispensing, sale, possession, use or presence in the body of illegal drugs or controlled substances while on or off-duty, while on company premises or vehicles

• The unlawful manufacture, distribution, dispensing, sale or unauthorized use, possession or presence in the body of alcohol or beverage containing alcohol whether on company premises or vehicles, while on or off duty

• Using/consuming alcohol (including beverages or medications that contain alcohol) for whichever is the lesser of the following periods:

o Within eight (8) hours of reporting for work, or

o After receiving notice to report for work

• Violating any Federal regulation or prohibition on controlled substance and alcohol use

• The manufacture, distribution, dispensing, sale, use, possession or presence on or in the body, at any time, of any objects, items, substances or liquids that may be used to alter or substitute a natural body fluid or part (e.g. urine, breath, blood, saliva, hair etc.) that are collected in conjunction with this policy

• Refusing a drug or alcohol testing event

• Prescribed and Over-the-Counter Medications

o Reporting for or remaining on duty when the employee’s alertness, judgment, coordination, physical behavior or mental responsiveness or ability to perform his/her job safely is affected by any prescribed or Over-the-counter (OTC) medication, including products containing alcohol

o It is the responsibility of the employee to submit the Authorization to Work with Medications (Form NRPC 3133) to Health Services for review and concurrence prior to working with medications that may interfere with safe job performance

o It is the employee’s responsibility to consult with a licensed physician or pharmacist, if uncertain whether a medication will adversely affect job performance. When consulting a physician, the employee must describe the specific tasks performed while on duty, not simply state a position title

• Refusing to adhere to the Employee Assistance Program (EAP) counselor or Substance Abuse Professional’s recommended treatment or follow up testing program

• As required by the Federal Drug Free Workplace Act, employees are to notify Amtrak management in writing if they are convicted of violating a criminal drug statute while on company premises no later than five calendar days after such a conviction 2.3.1.2.3 Drug and Alcohol Testing By accepting employment with Amtrak, an employee will be deemed to have consented to alcohol or drug testing under applicable Federal regulations and Amtrak's policy on alcohol and drugs. In certain situations, Amtrak is mandated by FRA 49 CFR Part 219 Control of Alcohol and Drug Use and FMCSA 49

CFR Part 382 Controlled Substances and Alcohol Use and Testing to conduct drug or alcohol testing on employees who perform Hours of Service (HOS) functions or hold a Commercial Drivers License (CDL) respectively. Amtrak also conducts drug or alcohol testing on all employees in situations not mandated by Federal regulation. The following provides a general overview of authorized Federal and company testing events that Amtrak conducts:

• Accident/Injury – Company drug and alcohol test for all employees, unless FMCSA or FRA Post Accident Criteria is met

• Fitness-for-Duty – Company drug and/or alcohol test for all employees, when requested by the Amtrak Medical Director

• Follow-up – Drug or alcohol test for HOS or CDL-CMV employees who violated a Company policy or Federal alcohol/drug regulations

• Periodic Physical – Company drug test for employees required to take a periodic physical

• Post-Accident (FMCSA) – Federal drug and alcohol test for CDL employees who operate a CMV

• Post-Accident Toxicological (FRA) – Federal drug and alcohol test for HOS employees and any fatally injured on-duty employee involved in the event

• Pre-employment – Federal drug test for persons applying for positions that perform HOS or CDL/CMV functions, or a CDL-CMV employee returning from an absence of more than 30 days and has not been in a Federal random testing pool; Company drug test required for all applicants

• Random – Federal drug and/or alcohol test for employees performing HOS and/or CDL-CMV functions employees; Company drug and/or alcohol tests for managers/supervisors of HOS employees

• Reasonable Suspicion – Federal drug and/or alcohol test for employees performing HOS or CDL- CMV functions; Company drug and/or alcohol test for all other employees

• Rule Violation – Company drug and alcohol test for all employees

• Return-to-Duty – Federal drug and/or alcohol test for HOS or CDL-CMV employees who violated a Federal drug and/or alcohol regulation; Company drug or alcohol test for employees who violated Amtrak’s policy; or drug test for employees after an absence of at least 30 days (excluding vacations, jury duty, military leave or furlough)

Once a supervisor informs an employee to undergo a required Federal or Amtrak required alcohol or drug test, the employee cannot mark off under the PIER program in order to avoid testing or disciplinary action. Employees tested in a Federal testing event will have their urine and/or breath specimens collected and tested in accordance with the Federal procedures outlined in 49 CFR Part 40. Blood

specimens will be collected and tested in accordance with procedures outlined in 49 CFR Part 219 Control of Drug and Alcohol Use. Employees tested in a Company testing event will have their urine and/or breath specimen collected and tested using the same standards and procedures for handling and testing of specimens as required under Federal statutes and regulations. If performing an alcohol and drug collection, the on-site testing supervisor is to instruct the testing technician to always perform the breath alcohol collection first (on all employees being tested), then the urine drug collection. A drug and alcohol test record is confidential information. Generally, unless an employee provides written consent, no record of testing will be released to any third party, except to the employee tested, or management employees who have a need to know or a required by law or policy. 2.3.1.2.4 Consequences for Violating the Drug and Alcohol Policy Amtrak encourages employees with alcohol or drug dependencies to voluntarily obtain the earliest possible diagnosis and treatment of their problem. The company supports such efforts through its PIER and Employee Assistance Program (EAP), which provides assessment, short-term counseling and referral services for employees with substance abuse problems. An employee found to be in violation of over-the-counter provision of this policy will be temporarily medically disqualified for the time period necessary for the Amtrak Medical Director to review the employee’s medications history with the employee’s treating physician and make a determination of the employee’s readiness to work. All other violations of the Amtrak policy where an employee had tested positive on a drug or alcohol test event (and it is the employee’s first positive test with Amtrak) will have an opportunity for substance abuse rehabilitation, consistent with PERS-39 (Employee Assistance Program) and any applicable legal requirement. Any subsequent positive drug or alcohol test results in the employee’s termination from Amtrak in all capacities. 2.3.1.3 Employee Assistance program EAP is a program that offers information, initial assessment and referral or short-term counseling for employees and their dependents confronted with the following:

• Stress, anxiety, depression

• Alcoholism or alcohol abuse

• Drug abuse

• Marriage or family problems

• Bereavement or coping with chronic illness

• Job or career concerns

• Behavioral problems

EAP is organized and staffed by licensed/certified counselors. The program is designed to help employees and their dependents identify the root causes of their difficulties and establish a confidential plan of action that is tailored to their specific situations.

2.3.1.4 Fatigue Management The Amtrak Fatigue Management Program is designed to minimize the risk of employee fatigue and meet the requirements of 49 CFR 228 Hours of Service of Railroad Employees; Recordkeeping and Reporting; Sleeping Quarters. Employees with schedule-driven positions have their schedules analyzed every week using the Fatigue Avoidance Scheduling Tool (FAST) or Fatigue Audit InterDyne (FAID). Based on the results, schedules are adjusted and subjected to further analysis until the risk has been reduced to acceptable levels (as indicated by the modelling program). 2.3.1.5 New Hire, Qualification, and Certification Training Amtrak’s HR Training Department is developing and implementing a new hire onboarding program that introduces new employees to the company (past/present/future), explains the strategic plan, provides an SMS overview, explains security requirements, emphasizes customer focus, and outlines expectations associated with financial excellence. Additionally, Amtrak deliver training in various formats to include CBT, simulations, in-class, and on-the-job. Agreement positions have specific qualification and certification requirements (welding, equipment operator, etc.). The company capitalizes on vendor provided training as well (e.g., DOT/Transportation Safety Institute). Training records are maintained electronically in . Based on the function, contractors are required to complete CBT and provide qualification/certification credentials prior to working on Amtrak property. Refer to 4.2 System Safety Program Employee/Contractor Training for more detail. 2.3.2 Occupational Safety and Health The occupational safety and health component of Amtrak’s SMS Risk Management ensures employees are provided with the conditions and protections conducive to a safe working environment. The programs have been designed to meet the requirement of 29 CFR 1910 Occupational Safety and Health Standards and 29 CFR 1926 Safety and Health Regulations for Construction. These programs include Fall Protection, Confined Space Entry, Control of Hazardous Energy (Lock-Out/Tag-Out/Try-Out), Hearing Conservation, PPE, Hazard Communication, Bloodborne Pathogen Exposure, Asbestos Management and Respirable Silica. These programs are maintained on annual basis with new programs added as determined by the SSWG, as part of conducting the RHMP. 2.3.2.1 Roadway Worker Protection The Roadway Worker Protection Manual is developed and maintained by SC&T to minimize the specific risks faced by roadway and bridge workers in accordance with 49 CFR 214 Railroad Workplace Safety. Compliance with the manual minimizes risk by ensuring that mitigations are in place to: render track inaccessible by the movement of trains or equipment, provide roadway workers with enough warning to account for oncoming trains or equipment, and provide bridge workers with the required fall protection. Additionally, compliance with the manual ensures the roadway worker in charge is established, an on- track safety briefing is conducted, a good faith challenge is completed, etc. All roadway workers are required to maintain their qualifications and carry a qualification card at all times while on duty. 2.3.2.2 Task-based Risk Assessments System Safety has partnered with the Engineering and Mechanical Departments to develop standardized templates for assessing risk. These standardized templates include the Job Safety Analysis (JSA) and Site-Specific Work Plan (SSWP). The JSA is used to examine repetitive tasks to identify/assess risk and determine mitigations. The SSWP is applied to identify/assess risk and determine mitigations as part of

preparing for work projects. The standardized SSWP template was established as part of the CAP resulting from the Engineering RCCA investigation and can be customized to support projects of varying size and scope. As the SSWGs are implemented, these activities will be organized and managed as part of conducting the RHMP. 2.3.2.3 Safety Committees Safety Committees are being established throughout Amtrak. The Safety Committees enable mutual collaboration among the organizations that function within a workplace to include labor and management. System Safety collaborates with the committees to provide education on safety standards and requirements, discuss opportunities for improvement, capture feedback, and determine safety activities and initiatives. Risks identified by Safety Committees that are beyond their capability to mitigate are flowed to the SSWG to be included as part of RHMP. In turn, SSWGs may flow mitigations (corrective or preventive actions) to safety committees to manage and implement. The SSWG/Safety Committee relationship is depicted in 1.4.3 Executive Safety Council/System Safety Working Groups/Safety Committees. 2.4 Contract Procurement Requirements The Procurement and Logistics (P&L) Department supports SMS Risk Management by proactively implementing the mitigations required to minimize the level of risk potentially introduced through the process of acquiring products and services. These mitigations include:

• Procurement: Maintaining policies, procedures, acquisition strategies and long-term strategic contracts that will maximize procurement service levels, and at the same time leverage Amtrak’s buying power while limiting business and legal risks.

• Materials Management: Developing and implementing programs and accurate forecasts to ensure material availability necessary to maintain strategic inventories and safe and secure distribution of inventories on a timely basis.

• Automotive: Providing safe, dependable, effective vehicle management administration by implementing cost effective traffic management and efficient repair and replacement methodologies for all customer requirements.

• Planning, Administration and Corporate Services: Providing effective responsiveness, administration and coordination with all user departments for business technology support of AAMPS, Traffic Management, Asset Disposition, and Office and Reprographic Services.

The P&L Department provisions for suppliers and contractors are listed in the General Conditions and Instructions for Bidders, which outlines specific material controls, safety requirements and public safety responsibilities. Also included are requirements for handling hazardous chemicals and wastes, materials disposal and other safety issues. Contractors must comply with all applicable standards, orders or requirements issued under Section 305 of the Clean Air Act, Section 508 of the Clear Water Act, Executive Order 11378, and Environmental Protection Agency regulations which prohibit the use under nonexempt federal contracts, grants, or loans, of facilities included on the EPA List for Violating Facilities. Amtrak has contractual agreements (state and national) for Hazardous Materials/Emergency

Response and Environmental Engineering. These agreements ensure favorable pricing and expedite immediate and effective response due to agreed-upon contractual terms.

The P&L Department uses procedures to control the procurement and use of supplies, materials and equipment, and to ensure that unauthorized hazardous materials and supplies, as well as defective or deficient equipment, are not procured and utilized by Amtrak employees. Procurement of parts, components, supplies and materials is governed by Amtrak Standard Maintenance Procedures (SMP) 25005 - Component, Modification and Test Approvals and Amtrak SMP 31004 – Vendor/Component Approval Procedure. Amtrak’s program for Chemical Product Purchase/Use at Amtrak Facilities contains policies and procedures to assure that Amtrak uses cost-efficient, effective chemicals that are as safe as possible for employees and passengers and do not adversely affect the environment. This program establishes a Chemical Task Force (CTF) to control procurement practices and use of materials, including adhesives, cleaners, deodorants/disinfectants, floor coatings and strippers, welding gases, lubricants, solvents, paint and paint strippers, products for dust/odor/snow/ice control, skin protection, etc. The CTF includes representatives from the Environmental, Public Health, Purchasing, Engineering, Customer Services, Safety, Engineering, and Mechanical Departments. The CTF reviews all chemical submittals, product-testing schedules, process evaluations and test results, and investigates reported chemical- related problems and/or concerns. The group also oversees the development and maintenance of an Approved Chemical Book and develops Chemical Use Manuals and Training Guides. Amtrak Procurement, and the Safety Department, partner on the selection, testing, replacement and ultimate approval of PPE and generic safety products utilized by Amtrak employees. This includes meeting with suppliers to examine product options and current product technology and reviewing current expenditures and product use.

3.0 Safety Assurance Safety Assurance is the third pillar of the SMS. Amtrak System Safety and Compliance will work with the Operations Department to implement the Safety Assurance Program in accordance with 03-SMS-SA-A Safety Assurance. An essential counterpart to Safety Risk Management, the Safety Assurance Program informs the RHMP resulting in a systematic approach that enables Amtrak to become a learning organization that continuously improves. The following FRA requirements are addressed in this section: 49 CFR 270.103(s) Safety Assurance; 49 CFR 270.103(s)(1) Change Management; 49 CFR 270.103(s)(2) Configuration Management; 49 CFR 270.103(s)(3) Safety Certification; 49 CFR 270.103(n) Safety Data Acquisition; 49 CFR 270.103(h) Rules Compliance and Procedures Review; 49 CFR 270.103(g) Maintenance, Repair, and Inspection Program; 49 CFR 270.103(j) Emergency Management; 49 CFR 270.103(m) Incident/Accident Reporting and Investigation. 3.1 SMS Infrastructure The principles of SMS are based on the International Organization for Standardization’s (ISO) 9001:2015 Quality Management System (QMS) standard. Therefore, Amtrak is designing the company’s SMS to be ISO 9001:2015 compliant. The foundational components of an ISO 9001:2015 compliant management system include a Process Asset Library (PAL) and Records Information Management (RIM) Program. 3.1.1 Process Asset Library SC&T is partnering with the Operations Departments and IT to establish a baseline PAL, as reflected in 1.5 SMS Implementation Process. The PAL will serve as the centralized source for the latest information on the company’s assets (policies, processes, procedures, instructions, forms, records, etc.), which are actively maintained and made accessible through the Amtrak intranet. Documentum will be the management tool used to establish the PAL. A graphic depiction of the PAL is reflected in Figure 3-1.

Figure 3-1 Process Asset Library

3.1.2 Records Information Management The information that process owners determine are company records, means this documentation represents evidence of performance that should be retrievable, traceable, and auditable. SC&T works with the Operations Department to implement the company’s RIM program in accordance with 04-SMS- SA-A Records Management, which uses a Records Control Matrix maintained by Quality Assurance to ensure compliance to the following RIM requirements:

• Identification: The applicable leader from each of the Operations Departments (Transportation, Engineering, and Mechanical) will identify the records produced as part of performing their functions and identify the focal assigned the collateral duty of RIM representative, which ensures these records are actively managed in accordance with the RIM program.

• Collection: The RIM representatives proceed to determine how records will be collected, indexed and archived.

• Storage: The RIM representatives specify how their department’s records are stored (electronically or hard copy), where (dedicated location), and keeps the storage organized in a manner that ensures retrievability.

• Protection: The RIM representatives determine what controls will be applied to prevent record loss, damage, or unauthorized use.

• Retention: The RIM representatives specify the retention periods for their records in accordance with company, contractual, or regulatory requirements, as applicable.

• Disposition: The RIM representative specifies how records will be disposed of at the end of their retention period and documents exceptions for any records as applicable (e.g., records stored beyond their retention period to support an ongoing investigation). 3.2 Safety Assurance Oversight Establishing the ISO 9001:2015 infrastructure enables the Operations Department to identify and actively manage their processes and associated information (assets), which is essential to performance that meets or exceeds company expectations and regulatory requirements. To provide assurance of this performance, SC&T will employ oversight techniques that are designed to verify employee compliance and product conformance. 3.2.1 Rules Compliance and Procedures Review Amtrak’s SC&T Department incudes the Operating Practices team, which is responsible for ensuring the company’s operations are in compliance with applicable rules and procedures. Activities of employees in a variety of crafts are governed by operating rules. Employees in the following categories are qualified on Operating Rules and re-qualified annually:

• Train and Engine Service employees and Yardmasters

• Train Dispatchers, Assistant Chief Dispatchers, and Block Operators

• Engineering Department employees that perform duties governed by operating rules

• Mechanical Department employees that perform duties governed by operating rules

• Managers and Supervisors who directly manage any of the above employees

The need for rule development or modification may come from a variety of sources (Acts of Congress, FRA regulation or order, industry best practices, etc.). In locations where operations are governed by the Northeast Operating Rules Advisory Committee (NORAC) or the General Code of Operating Rules (GCOR), Amtrak participates in rule development and rule modifications in accordance with the processes established by each governing committee. 3.2.1.1 Review of Rules and Procedures To manage specific railroad operating considerations (track speed, equipment restrictions, etc.), Amtrak Operating Practices issues railroad employee timetables/special instructions for its owned and operated properties in the northeast, known as the Amtrak NEC Employee Timetable and Timetable Special Instruction. Both the NORAC Operating Rule Book and the Amtrak Timetable/Special Instructions may be modified through a document control system managed by Amtrak’s Operating Practices Division. This system ensures clear communication of operational changes and modifications to effected employees. Amtrak submits any revisions and modifications regarding its operating rules to the FRA in accordance with 49 CFR 217.7 Operating Rules; Filing and Recordkeeping.

Amtrak Operations outside NORAC territory, where Amtrak owns or has operational control, is limited to the following areas: Amtrak owned or operated trackage in Michigan/Indiana and Amtrak terminal operations in Chicago, Illinois and New Orleans, Louisiana. In these locations, railroad operations, including dispatching activities, are conducted in accordance with GCOR rule book. Similar to operations in the Northeast, Amtrak issues employee timetables/special instructions to govern railroad operations on Amtrak owned or operated property. Amtrak has issued three independent employee timetables/special instructions to cover these operational areas, Michigan Line, Chicago Terminal and New Orleans Terminal Employee Timetables/Special Instructions.

Both the GCOR and specific Amtrak timetables/special instructions may be modified through a formal document control system managed by Amtrak’s Operating Practices Division. This document control system ensures clear communication of operational changes and modifications to effected employees. Amtrak submits revisions and modifications regarding its operating rules to the FRA in accordance with 49 CFR 217.7 Operating Rules; Filing and Recordkeeping. 3.2.1.1.1 Host Railroad Operations Amtrak operations over host railroad property, follow their operating rules, timetable/special instruction, and other operational instructions. Annually, Amtrak crews that operate in such areas are trained and qualified on the applicable operating rule books and instructions. This process is documented in Amtrak’s Program of Instruction on Operating Rules submission to FRA in accordance with 49 CFR 217.11 Program of Instruction on Operating Rules; Recordkeeping; Electronic Recordkeeping.

The following operating rules are in effect on Amtrak host railroads:

• Buckingham Branch Railroad Operating Rules (Culpeper – Clifton Forge, VA)

• Central Florida Rail Corridor Operating Rules

• Canadian National U.S. Operating Rules

• CSX Operating Rules

• Norfolk Southern (NS) Operating Rules

• GCOR (BNSF, BRC, CP, TRRA, UP, VRS, SFRTA)

• Metro-North Operating Rules (New York metro area)

• NORAC (Pan AM Railways, MBTA, NECR, ) 3.2.1.1.2 Canadian Operations Amtrak offers rail service to three Canadian cities (Montreal, Toronto, and Vancouver). Trains between Rouses Point, NY and Montreal are operated by Amtrak crews and follow CROR while in Canada. Trains operating between Bellingham, WA and Vancouver are also operated by Amtrak crews and follow CROR while in Canada. Both operations follow Amtrak’s Program of Instruction on Operating Rules regarding the training and qualification of employees operating these trains. Passenger trains operating between Niagara Falls and Toronto are branded as Amtrak trains, but are operated by VIA Rail Canada. 3.2.1.1.3 Other Operating Manuals Directly Affecting Railroad Safety In addition to the operating rule regime noted above, Amtrak maintains additional operating manuals directly affecting railroad safety. These manuals include the RWP Manual, Air Brake and Train Handling Rules and Instructions, Electrical Operating Instruction, and dispatching operations manuals. These manuals have been established to meet or exceed federal regulatory requirements to include 49 CFR 214 Railroad Workplace Safety and 49 CFR 238 Passenger Equipment Safety Standards as well as industry standards and company requirements. 3.2.1.2 Techniques for Assessing Compliance Amtrak’s Quality Assurance (Compliance) Team implements the company’s Total Efficiency and Safety Test System (TESTS) to conduct operational tests and inspections for all employees governed by operating rules in accordance with 49 CFR 217.9 Program of Operational Tests and Inspections; Recordkeeping. TESTS is designed to accomplish the following:

• Reduce the risk of accidents and casualties caused by human error or resulting from impairment of employees by alcohol or drugs.

• Improve and maintain employee alertness.

• Provide supervisors with an immediate evaluation of an employee’s application, understanding and compliance with the rules.

• Assist supervisors in educating employees on the correct way to apply the rules in actual operating situations.

• Enable the company to measure general and specific areas of rules compliance, so that overall rules compliance can be maintained or improved. 3.2.1.3 Techniques for Assessing Effectiveness Amtrak conducts a formal six-month review of the efficiency test program. The review compares supervisor’s testing results to various data available to Amtrak for analysis, which includes past incident/accident reports, operating rule violation reports, FRA inspection reports and other operational information. Based on the results, Quality Assurance makes adjustments to supervisors testing requirements or directs supervisors to focus testing on a particular location or activity to verify compliance levels and reduce incident rates. In addition to six-month reviews process, Quality Assurance also produces an annual summary of operational tests. This summary documents the number, type and result of each test conducted on Amtrak during the year. A copy of each annual report is retained and made available to the FRA in accordance with 49 CFR 217 Railroad Operating Rules. 3.2.2 Maintenance, Repair, and Inspection Program A properly maintained railroad system systematically minimizes risk. Therefore, compliance with maintenance, repair, and inspection processes and procedures is a fundamental component of the Amtrak SMS. These programs are in place in both the Mechanical and Engineering organizations. The Mechanical Department is responsible for maintenance, inspection and repair of rolling stock. The Engineering Department is responsible for the maintenance, repair, and inspection of track, right-of- way, as well as signal and train control systems. 3.2.2.1 Track and Right-of-Way Engineering maintains and implements MW1000 Limits and Specification for the Safety, Maintenance, and Construction of Track to maintain the track that Amtrak is responsible for in accordance with 49 CFR 213 Track Safety Standards. MW1000 is composed of three parts. The first part defines the limits and specification for track safety, maintenance and construction. The second part defines the limits and specifications for turnout (and other trackwork) safety, maintenance and construction (to include slips, crossing diamonds, and other special trackwork). The third part defines limits and specifications for the miter rail and expansion joint safety, maintenance and construction. Additionally, Engineering’s System Structures Department maintains and implements the company’s Bridge Management Program (BMP), which outlines the inspection requirements for all bridges along Amtrak’s right-of-way in accordance with 49 CFR 237 Bridge Safety Standards. 3.2.2.2 Signal and Train Control Systems Operating Practices and Engineering maintains and implements a series of processes and procedures designed to maintain the C&S (communication and signal) systems in accordance 49 CFR 236 Rules, Standards, and Instructions Governing the Installation, Inspection, Maintenance, and Repair of Signal

and Train Control Systems, Devices, and Appliances. Specifically, AMT-4 Special Instructions Governing Operation of Signals and Interlockings, AMT-23 Special Instructions Governing Construction and Maintenance of Signals and Interlockings, and AMT-27 Instructions for Testing Signal Apparatus and Signal Systems are used to maintain the C&S system. 3.2.2.3 Traction Power The NEC (from Washington, D.C. to Boston) is electrified. Amtrak Engineering maintains and implements a series of processes and procedures designed to maintain the Electric Traction (ET) system. Specifically, AMT-2 Electrical Operating Instructions for Construction, Maintenance, Operation and Testing of Equipment is used to maintain the company’s ET system. 3.2.2.4 Rolling Stock Amtrak rolling stock has been organized into three tiers. The Mechanical Department maintains and implements the company’s Tier 1 Operations Part 238 Maintenance Plan to maintain Tier I rolling stock (operating speeds of 125 mph or less) in accordance with 49 CFR 238 Passenger Equipment Safety Standards Subpart C Specific Requirements for Tier I Passenger Equipment. Similarly, the Mechanical Department maintains and implements the company’s High-Speed Trainset Inspection, Maintenance and Testing (ITM) Plan to maintain Tier II rolling stock (operating speeds of exceeding 125 mph) in accordance with 49 CFR 238 Passenger Equipment Safety Standards Subpart F Inspection, Testing, and Maintenance Requirements for Tier II Passenger Equipment. The Tier III category has been reserved for next generation equipment that will operate at speeds exceeding 160 mph. The plans for maintaining this equipment will be developed in coordination with the company’s strategic plans accordingly. Additionally, the Mechanical Quality Assurance (QA) performs oversight and inspections to ensure rolling stock is properly maintained, which in turn supports the overall Safety Assurance program, particularly in the areas of configuration and change management. 3.2.2.5 Fixed Facilities and Equipment Amtrak fixed facilities and related equipment receive periodic inspections in accordance with 29 CFR 1910 Occupational Safety and Health Standards. The inspections focus on the safe maintenance, inspection, and use of these facilities to include fire protection, emergency communications, walking surfaces, ventilation, etc. Ownership of these systems may belong to the building’s owner, a building management company, or other entity. However, Amtrak conducts oversight to ensure that system activation, certification, alteration or remediation are conducted as necessary to maintain employee and passenger safety. Additionally, the Environmental Audit Program measures performance of Amtrak facilities against Environmental Protection Agency (EPA) and internal procedures. The program includes 32 large and medium facilities that are audited on a biennial basis. Smaller facilities that have fewer environmental risks are subject to Small Facility Assessments (SFA) conducted by in-house environmental personnel on a triennial basis. 3.2.2.5.1 Passenger Station Platform Gaps Amtrak maintains passenger gaps in accordance with the Amtrak Station Program and Planning Guidelines manual, which has been developed in accordance with 49 CFR 37.42 Service in an Integrated Setting to Passengers at Intercity, Commuter, and High-Speed Rail Station Platforms Constructed or Altered After February 1, 2012. Adherence to these requirements ensures:

• Safe Passage (Total Dynamic Envelope) of all Amtrak and non-Amtrak trains

• Normal passenger loading and unloading at Amtrak utilized platforms

• Access to at least one side of a rail car at an Amtrak utilized platform

• Compliance with Americans with Disabilities Act

The Amtrak Engineering Station & Facilities Standard Design Practices (SDP) defines the standard requirements for station and platform conditions. Assessments that include regular inspections of platform gaps are conducted every two years to ensure stations and platforms are maintained in a State-of-Good-Repair (SOGR) and conforms to form/fit/function requirements. This ensures rail clearances and platform gaps are consistent across Amtrak stations. 3.2.3 Internal Evaluation Program Safety Assurance Program will include two levels of internal evaluation, a company-level function and a SSWG-level function, which will be established and implemented in accordance with 03-SMS-SA-A Safety Assurance. The company-level function is designed to holistically evaluate the company’s overall compliance to the SMS to include implementation of this SSPP and response to feedback outside agencies (NTSB, FRA, OSHA, etc.). The findings from the evaluation will be reviewed and accepted by the ESC with corrective actions assigned and tracked accordingly. At the SSWG-level, System Safety’s role is to serve as the subject matter expert in the risk management methodology, facilitating the RHMP in an effort to support Operations, which is responsible for leading the RHMP to effectively manage their risks. As Operations identifies risks and corresponding mitigations, System Safety Specialists perform an internal evaluation function to verify that mitigations were implemented in accordance with estimated completion dates and determine whether the mitigations are effectively reducing the risk as expected. The findings are recorded in the risk management workflow system and assigned to applicable owner for corrective action. The results are reported and managed at the SSWG and used as part of RHMP to make adjustments by adding new or re-defining existing risks and doing the same for mitigations, which creates a systematic approach designed to enable continuous improvement. 3.2.4 Safety Certification The Safety Assurance Program will include a Safety Certification function that will be established and implemented in accordance with 05-SMS-SA-A Safety Certification. A major change to the railroad system, such as installing a new tunnel or bridge, triggers safety certification requirements that will be embedded throughout the project’s lifecycle (e.g., Concept Planning, Preliminary Engineering, Final Design, Construction, and Testing). As part of these projects, a Certifiable Elements List (CEL) will be established to identify the items requiring safety certification (train control enforcement, emergency egress, fire protection, etc.) along with the form/fit/function success criteria that will be applied, and how the element will be verified (analysis, testing, review, etc.). System Safety will partner with the applicable subject matter experts to perform the safety certification function. Upon completing a successful verification, a Certificate of Conformance (COC) will be issued that is signed by the System Safety Specialist and subject matter expert. If an element fails certification, a COC will not be issued until corrective action has been taken and verified as effective. If a waiver is sought for any certifiable element, a risk assessment will be required with the ESC serving as the approving authority.

How safety certification requirements are applied to existing railroad operations will be determined by the SSWG as part of conducting RHMP. For example, if a particular maintenance action is deemed high risk, that activity would be considered for inclusion on the Critical Safety Item List (CSIL). Items added to the CSIL require safety certification. Similar to the project-based approach, System Safety will partner with the applicable subject matter experts, certifiable elements will be identified, form/fit/function success criteria defined, and the techniques that will be used for verification specified (analysis, testing, review, etc.). Upon completing a successful verification, a COC will be issued that is signed by the System Safety Specialist and subject matter expert. If an element fails certification, a COC will not be issued until corrective action has been taken and verified as effective. If a waiver is sought, a risk assessment will be required with the SSWG serving as the approving authority (with escalation to the ESC utilized, as required). 3.2.5 Change/Configuration Management As the SMS matures, change becomes the primary instigator for introducing new risks or changing existing risk levels. The SSWGs will provide the forum to effectively manage change, as reflected in 03- SMS-RM-A Risk-based Hazard Management. During the Risk Identification segment of the RHMP, applying the KNOT methodology involves determining if any new changes have been identified or if any are anticipated. The change could be under any context to include changes within existing activities or introduction of new activities (projects, services, etc.). When a change is reported, the applicable Operations employee partners with System Safety to perform a Change Risk Assessment (CRA), which is a form designed to perform a targeted evaluation of the change. The CRA is submitted at the SSWG with a proposed classification. Class I changes are considered to have a major impact to the existing railroad system (e.g., introduction of a new route). Class I changes require vetting through the ESC, which evaluates the results of the CRA and either accepts the risks based on the mitigations planned or requires additional action (to assess, mitigate, etc.). ESC approval is required prior to implementation (e.g., starting service on the new route). Class II changes are considered minor (e.g., changes to a station as part of ADA compliance). The Class II changes are managed by the SSWGs to ensure the risks are effectively mitigated based on the results of the CRA with no ESC involvement required. The activities that introduce extensive change to the railroad system (e.g., NY/NJ Gateway Project) may have their own dedicated safety working groups (councils, committees, etc.) that include their own change management function, as determined and sanctioned by the ESC.

Configuration Management will fold into the same process used to manage any other change, as reflected in 03-SMS-RM-A Risk-based Hazard Management. The focus of configuration management is to ensure that physical characteristics and conditions of the railroad system are maintained to conform with the as-designed form/fit/function. Similar to change management, the SSWG provides the forum to effectively manage configuration with a CRA used to evaluate configuration changes and corresponding risks as a result. Additionally, targeted assessments are performed on critical safety configurations, such as the assessment of stations to verify platform gaps and clearances every two years. If the RHMP identifies additional critical safety configurations that should have their form/fit/function verified, those items are added to the CSIL for inclusion as part of the Safety Certification Program in accordance with 05-SMS-SA-A Safety Certification.

3.3 Continuous Improvement The Safety Assurance Program provides an oversight function that verifies employee compliance and product conformance but also determines if the mitigations (to include processes, rules, specifications, etc.) are effectively mitigating risks as intended. By measuring effectiveness, deficiencies are detected that trigger corrective action, opportunities for improvement are revealed that enable preventive action, and changes that potentially introduce risk are captured. This provides the fuel for an RHMP that is continuously adjusting, learning, and adapting to become more effective. 3.3.1 Safety Data Acquisition The Safety Data and Analytics Team is responsible for collecting, analyzing, and generating the Amtrak safety performance metrics, which are composed of the following: customer incident metric, employee incident metric, grade crossing and trespasser event metric, Tier 1 Rail Incidents, Tier 2 Major Operating Rule Violations (MORV), Tier 3 Leading Indicators. The data to support the majority of these metrics is acquired by complying with company policy 3.11 Internal Control Plan. Additionally, data is collected through systems that feed Amtrak’s EDW, such as SPARTN. The Safety Data and Analytics Team works with other SC&T divisions (e.g., Central Reporting and Operating Practices) to perform analyses used to establish the goals reflected in 1.2 System Safety Program Goals and Objectives. Those company-level goals will be deconstructed to cascade specific goals at the department-level. The safety data will be reviewed monthly by the ESC and SSWGs, driving adjustments to the RHMP and Safety Assurance, which supports continuous improvement of the SMS and enables safety goals to be reached and exceeded. 3.3.1.1 Customer Incident Metric Amtrak is committed to providing the safe experience expected every time a customer chooses to reward the company with their business. Consequently, the customer incident metric is the highest priority because the rate includes the FRA reportable incidents that have occurred where a customer experienced either an injury, illness or event that made them feel unsafe. The data is primarily collected from a customer or employee reporting that an injury was experienced to customer service, who in turn ensures the NRPC 7000 Passenger/Guest Injury/Illness form is completed and submitted to Central Reporting fax or scan (e-mail) in accordance with company policy 3.11 Internal Control Plan. The data is normalized based on incidents per 100 million passenger miles resulting in a rate for incidents experienced on trains and a rate for incidents experienced in facilities. Refer to Appendix C Safety Metrics to review an example of the customer incident metric. 3.3.1.2 Employee Incident Metric Amtrak is committed to ensuring that employees have the safe experience expected while at work. The employee incident metric includes the FRA reportable incidents where an employee experienced either an injury, illness or SIF, which is an event that either resulted in a significant injury or fatality or had the potential. The data is primarily collected from the affected employee or their supervisor, who reports the injury through the hotline (800-505-5549) and completes the NRPC 5000 Employee Injury/Illness form, which is submitted to Central Reporting by fax or scan (e-mail) in accordance with company policy 3.11 Internal Control Plan. The data is normalized based on incidents per 200,000 man-hours resulting in a rate for employee incidents and a rate for SIF potential. Refer to Appendix C Safety Performance Metrics to review an example of the employee incident metric.

3.3.1.3 Tier 1 Rail Incident Tier 1 Rail Incident represent operational risks that were realized, which adversely affects both customers and employees as well as Amtrak property. The Tier 1 Rail Incident metric compiles the accidents/incidents involving Rail Equipment and Grade Crossings (REGC), which are reported by employees using the NRPC 7000 Rail Incident Report form and sent to Central Reporting by fax or scan (e-mail) in accordance with company policy 3.11 Internal Control Plan. The rate is determined by dividing the total amount of REGC FRA reportable incidents by one million train miles. The incidents that are included in the Tier 1 Index are defined in Table 3-1. Refer to Appendix C Safety Performance Metrics to review an example of the Tier 1 Rail Incident metric.

Table 3-1 Tier 1 REGC Incident/Accident Definitions Type Definition A derailment occurs when on-track equipment leaves the rail for Derailment a reason other than a collision, explosion, highway-rail grade crossing impact, etc.

A collision in which the trains or locomotives, or electric multiple unit (EMU) or diesel multiple-unit (DMU) trains, involved are Head on Collision traveling in opposite directions on the same track, provided that both consists have a locomotive (or EMU or DMU trains).

An accident/incident in which a consist strikes: 1) a bumping post or a foreign object on the track right-of-way; 2) a highway vehicle at a location other than a highway-rail grade Obstruction crossing site; 3) derailed equipment; or 4) a track motorcar or similar work equipment not equipped with AAR couplers and not operating under train rules.

An accident/incident, not classified as a collision, that involves contact between on-track equipment. Generally, these involve single cars or cuts of cars that are damaged during switching, Other Impacts train makeup, setting out, etc., operations. If both consists contain a locomotive, an EMU locomotive, or a DMU locomotive, the event should be classified as a collision between trains.

Broken pantograph or wire issues resulting in prolonged outage Pantograph/Wire of Head-end Power (HEP).

A collision between parts or lading of a consist on an adjacent Raking Collision track or with a structure such as a bridge.

Separation Separation of moving and loaded passenger cars.

A collision at a turnout where one consist strikes the side of Side Collision another consist.

A collision in which the trains or locomotives (or EMU or DMU Rear-end trains) involved are traveling in the same direction on the same Collision track, provided that both consists have a locomotive (or EMU or DMU trains).

A collision in which a moving train breaks into parts and an Broken Train impact occurs between these parts, or when a portion of the Collision broken train collides with another consist.

An accident/incident caused by the detonation of material carried or transported by rail. A detonation occurs when a shock wave Explosion – exceeds the speed of sound. Explosions-detonations resulting Detonation from mishaps during loading or unloading operations, and those caused by fire aboard on-track equipment, are included in this definition.

An accident/incident caused by combustion or violent release of material carried by or transported by rail. Examples of this type Fire/Violent include fuel and electrical equipment fires, crankcase explosions, Rupture and violent releases of liquefied petroleum gas or anhydrous ammonia.

RR Grade A collision between on-track railroad equipment at a point where Crossing tracks intersect with a roadway.

Other Events not classified as one of the preceding types.

3.3.1.4 Tier 2 Major Operating Rule Violations Tier 2 MORVs represent a failure to comply with rules that are designed to effectively mitigate risk. The risk may not have been realized (i.e., an actual accident/incident may not have occurred) but the MORV resulted in a level of exposure to that potential that was unnecessary and avoidable. MORVs are reported by employees using the NRPC 7000 Rail Incident Report and tracked by the Compliance branch of SC&T. The Tier 2 rate compiles all of the MORV types defined in Table 3-2. The rate is determined by dividing total amount of MORVs by one million train miles. Refer to Appendix C Safety Performance Metrics to review an example of the Tier 2 Major Operating Rule Violations metric.

Table 3-2 Tier 2 MORV Definitions Type Definition Speeding Exceeding maximum authorized speed by 10 MPH or more.

Tampering Tampering with a safety device. Failing to stop for a signal that requires a complete stop or Stop Signal passing a Stop Signal without proper authority.

Colliding with equipment or a deliberately placed obstruction, such as a bumping post or barricade, resulting in a derailment or Collision FRA Reportable Accident or Incident. Exception: Collision at a public highway grade crossing where the employee does not contribute to the cause or severity of the incident.

Secure Failing to properly secure equipment left unattended. Equipment

Foul Leaving equipment in the foul of a connecting track.

Air Brake Test Failing to perform an air brake test required by 49 CFR 232/238.

Main Track Failing to restore and properly secure a main track, hand- Hand-Operated operated switch to normal position, when required. Switch

Main Track Switch without Operating a main track switch without proper authority. Authority

Run Through Running through an improperly lined main track switch.

Derail Device Failing to apply or stop short of a derail, when required.

Fouling without Occupying or fouling a segment of track without proper authority Authority or protection.

Blue Signal Failing to comply with blue signal protection requirements.

Deliver/Comply Failing to issue, deliver or comply with a written or oral directive with Directive required to ensure safety.

Directive Issuing a written or oral directive that creates an unsafe Creating Unsafe condition. Condition

Protect Failing to protect a train or track car, when required. Equipment

Failing to apply or maintain blocking device protection, when Blocking Device required.

Required Establishing a route that fails to provide required protection.

Switch Under Operating a switch under a train or track car. Train

RWP Failure to provide proper roadway worker protection.

Failure to comply with one of the following which results in a derailment or an FRA Reportable Accident or Incident. Operating Rule or Special Instruction; Causing FRA Rpt. AMT-2, AMT-3, AMT-4, or AMT-23 instruction; Incident SMP, RWP, Control Center instruction (e.g. Dispatchers’ Manual), Safety Rules (AMT-5, NRPC 1095, etc.), or lockout / tag out procedure; Track standards, MW 1000 or other MW instructions.

Negligently operating an Amtrak owned or leased vehicle or Vehicle equipment, other than on-track equipment, resulting in damage Negligence to property, equipment, or injury.

3.3.1.5 Tier 3 Leading Indicators Tier 3 Leading Indicators will be composed of event recorder data from every train and every trip, enforcement and alerting data captured from PTC, trains-in-emergency events, and results from external oversight (FRA, OSHA, FDA, etc). The metric will be used to identify trends and patterns that reveal opportunities for improvement, triggering preventive action. As the SMS matures, preventive actions taken based on Tier 3 data is expected to have a positive impact on the rates associated with the rest of the Train Safety Index, enabling the company to meet and exceed safety goals that become more ambitious year over year. 3.3.1.6 Tier 4 Voluntary Safety Programs Text Tier 4 Voluntary Safety Programs will be composed of reports received from: the external Confidential Close Call Reporting System (C3RS) and the internal Voluntary Reporting System as well as general feedback received by SC&T by phone or email. The data will be examined for confirmed hazardous conditions and analyzed to identify trends or patterns that suggest systemic performance risks exist. A dedicated page on the company intranet will display the hazards identified, trending feedback, and status of corrective and preventive actions being taken in response.

3.3.2 Accident/Incident Reporting and Investigation The following sub-sections reflect Amtrak’s reporting and investigative approach for accidents/incidents that do not meet 49 CFR 225.9 Telephonic Reports of Certain Accidents/Incidents and Other Events. In the event an accident/incident that does meet this criterion, the conductor or supervisor on duty will immediately call Amtrak’s CNOC, which is operational 24/7. CNOC immediately provides notification to the National Response Center (NRC), in accordance with 49 CFR 840 Rules Pertaining to Notification of Railroad Accidents. APD will proceed to respond in accordance with the company’s Emergency Operations Plan. Refer to 3.3.3 Emergency Management for more detail. 3.3.2.1 Accident/Incident Reporting Safety Data and Analytics maintains and implements company policy 3.11 Internal Control Plan in accordance with 49 CFR 225 Railroad Accidents/Incidents: Reports Classification, and Investigations. This includes internal reporting requirements, incident review procedures, and external (FRA) reporting procedures. The FRA reporting officer ensures that accidents/incidents that are identified as reportable are reported within 30 days after the close of that specific month. Additionally, accurate internal reporting of accidents/incidents enables analyses that will be used by the ESC and SSWGs to determine when investigations are triggered, corrective actions implemented, and preventive actions taken. 3.3.2.2 Accident/Incident Investigation Investigations of accidents/incidents will be conducted by Operations and SC&T in accordance with 01- SMS-SA-A Accident/Incident Investigation. The accidents/incidents that meet the criteria outlined in 49 CFR 225.9 automatically trigger an internal investigation, which is managed by the SSWG with oversight from the ESC. Additionally, the ESC and SSWGs initiate investigations based on trends detected in the performance metrics, feedback from internal/external reporting systems, and the results of Safety Assurance oversight. The accident/incident investigations apply the following RCCA methodology:

• Problem Statement: Defines the current state (as-is) compared to expectations (should be). The problem statement also includes where the accident/incident occurred, when (day/time), and explains the significance (property damage, fatality, injury, illness, etc.).

• Team: The problem statement is defined with initial/obvious stakeholders, which allows the needs of the investigation to become clear. Then additional team members are identified and their roles defined.

• Background: Captures the facts, conditions, circumstances, and related events associated with the accident/incident.

• Immediate/Containment Actions: The team identifies the actions that need to be taken immediately to include notifications, documentation, and any other actions that can help ensure the same or similar accident/incident does not occur while the investigation is in progress (advisories, restrictions, etc.).

• Root Cause Analysis: A root cause analysis is performed to reveal the root cause(s) for why the accident/incident occurred. There are a variety of techniques used to perform root cause

analysis (5-Why, Fishbone, Fault Tree, etc.). The Safety and Regulatory Compliance Manager works with the RCCA lead to determine the appropriate technique.

• Corrective Actions and Preventive Actions: After the root cause analysis has been completed, a Corrective Action Plan (CAP) composed of corrective actions and preventive actions are developed to address the root cause and key contributing factors. The CAP is expected to effectively mitigate the risk of the same or similar accident/incident from re-occurring.

• Verification of Effectiveness: The Safety and Regulatory Compliance Manager performs oversight as part of the Safety Assurance and Certification program to ensure the corrective actions and preventive actions are implemented and the risk is mitigated as intended. The results are reported to the SSWG for incorporation as part of risk-based hazard management, which may result in adjustments or new mitigations, as required.

The SSWG is responsible for assigning a lead to investigate (the ESC will perform this task as deemed necessary). A System Safety subject matter expert facilitates the RCCA to ensure the methodology is followed properly. The RCCA lead is responsible for providing the ESC/SSWG with regular updates on the investigation’s progress until the CAP is completed. Upon completion of the CAP, System Safety performs an audit to verify the corrective and preventive actions taken effectively mitigate the risk or recurrence as intended. The findings of the audit are reviewed by the ESC/SSWG to determine if the investigation needs to be re-opened, additional corrective or preventive actions taken, or the investigation can be closed. 3.3.2.3 External Investigations If CNOC determines the reported incident/accident meets the requirements of 49 CFR 225.9 and proceeds to follow NRC reporting in accordance with 49 CFR 840 Rules Pertaining to Notification of Railroad Accidents. The nature of the accident/incident experienced may trigger an external investigation by the FRA, OSHA, or NTSB. If an external investigation is initiated, Amtrak will support and concurrently perform an internal investigation. The results of the external investigation will be reported by the Sr. Director of System Safety to the ESC for review and adjudication (a decision on whether to implement recommendations). Results from the ESC review will be flowed to the applicable SSWG for incorporation, accordingly. 3.3.3 Emergency Management If a risk is realized (an incident or accident occurs), the severity may result in an emergency. How Amtrak responds to an emergency is critical to minimizing the consequences experienced by customers, employees, and assets. APD leads an integrated enterprise-wide emergency management and corporate security system designed to prepare and protect employees, customers and assets. The system is based on a security risk management strategy that addresses: emergency preparedness planning; incident management coordination; security awareness, training and exercises for employees and external stakeholders; security of critical rail and key assets through video surveillance and access control solutions.

3.3.3.1 Emergency Operations Planning The Emergency Operations Plan (EOP) provides the overarching guidance for a suite of plans, processes, and procedures that come together to form the emergency management and corporate security system. The EOP addresses all four phases of the emergency management continuum (preparedness, response, recovery, and mitigation) and specifies the interfaces with other departments and functions that have critical roles within the company. 3.3.3.1.1 Preparedness The plans associated with ensuring effective emergency preparedness include the Passenger Train Emergency Preparedness Plans (PTEPP), Multi-year Training and Exercise Plan (TEP), Security and Public Awareness Overview (SAPO). The PTEPP and associated training programs are developed in collaboration with each of Amtrak’s host railroads as well as railroads that operate on Amtrak owned territory in accordance with 49 CFR 239 Passenger Train Emergency Preparedness. The purpose of the PTEPP plans is to address communication and training protocols in order to prepare for on board emergencies and mitigate the loss of life and injury. The Multi-year Training and Exercise Plan (TEP) specifies the plan for implementation of training and exercise programs across the company. The SAPO specifies the plan for training and educating the traveling public about safety and security hazards to include the actions in the event of suspicious behavior or packages are identified on an Amtrak property. 3.3.3.1.2 Response The plans, processes and procedures associated with ensuring effective emergency response include the Incident Response Team (IRT) Framework Annex, Incident Hotline Standard Operating Procedures (SOPs), Crisis Communication Plan (CCP), Annex A Emergency Communications Plan (ECP), and Annex B Sit-U Annex. The IRT Framework Annex provides information and procedures regarding the IRT including its goals and objectives, organizational structure, concept of operations, descriptions of relationships between Amtrak and external agencies, details the roles and responsibilities of IRT members, and provides specific checklists and guidance for IRT members. Incident Hotline SOPs describe the procedures that the Mid-Atlantic Reservation Sales Contact Center (MARSCC) and the Western Reservation Sales Contact Center (WRSCC) implement for the Amtrak Incident Hotline to assist people who may have had family or friends affected an Amtrak incident and to fulfill assurances required by the Rail Passenger Disaster Family Assistance Act. The CCP defines how Amtrak manage communications effectively in times of crisis. The CCP assigns specific roles and responsibilities to individuals, establishes a method of notification, and provides a framework for how public information will be managed during an incident. Amtrak ECP Annex addresses system interoperability, system redundancy, and the use, maintenance, and equipment augmentation necessary to support the preparation, response, and recovery associated with an Amtrak incident. The Situation Unit (Sit-U Annex) defines how APD Sit-U distills internal and external information sources into usable information for decision makers. The APD Sit-U also serves as the lead integrator for the National Incident Management System (NIMS) and defines how the CNOC supports railroad operations. 3.3.3.1.3 Recovery The plans associated with ensuring effective emergency recovery include the Continuity of Operations Plans (COOP), Continuity of Business (COB) Program Overview, Facility Emergency Plans (FEPs), and Annex C Recovery Plan. The COOP describes how Amtrak’s mission essential functions (MEFs) are performed, or rapidly and efficiently resumed, during a disruption event or emergency. The COB

describes the continuity of Amtrak as a business by identifying orders of succession, delegation of emergency authority and command, and control for Deputy Chiefs and Senior Managers at Amtrak. The FEPs establishes policy and guidance for executing emergency action, including evacuation, shelter-in- place procedures, or other protective actions at an Amtrak facility or station. The EOP Recovery Plan Annex describes how Amtrak addresses short- and long-term recovery priorities and provides guidance for restoration of critical corporate functions, services, vital resources, facilities, programs, and infrastructure to any area affected by a disruptive incident or event. 3.3.3.1.4 Mitigation The plans associated with ensuring effective emergency mitigation include the System Security and Emergency Preparedness Plan (SSEPP) and Risk Management Framework (RMF). The SSEPP specifies Amtrak’s security and preparedness processes and procedures, with an emphasis on activities that take place prior to an incident occurring. The RMF defines the process used by APD to actively identify, mitigate, and manage risks. 3.3.3.2 Emergency Training APD develops and administers training designed to ensure passengers and employees are prepared for an emergency in accordance with 49 CFR 239. The training program is composed of the following courses with training records tracked using the Amtrak learning management system for employees and Quickbase system for external participants:

• Passenger Train Emergency Response (PTER): Training conducted with external first responders across the United States and Canada. PTER builds on the adult education pedagogy to ensure police, fire, emergency medical technicians and first responders know how to operate safely in the railroad environment.

• Passenger Railroad Emergency Preparedness and Response Education (PREPARE): Training conducted with Train and Engine (T&E), On-board Services (OBS) and dispatch center employees. PREPARE in increases employees understanding of roles and responsibilities during train emergencies and explains the ability to integrate with external partners to include host railroads, state, and local responders.

• IRT training educates employees on procedures for responding to emergencies in compliance with federal investigation requirements.

• FEP training provides employees an opportunity to refresh their awareness of response actions to take during an emergency at an Amtrak facility (Evacuate, Shelter-in-Place, and Stay-in-Place).

• Just-In-Time (JIT) training refreshes employees’ knowledge related to specific response protocols (e.g., tunnel evacuation or family assistance). JIT is conducted prior to each exercise to strengthen employees ‘ability to practice during the simulation. 3.3.3.3 Emergency Exercises Exercises compliment emergency planning and training to maximize readiness. APD conducts full scale emergency exercises with first responders and all 31 different host railroads. Additional emergency exercises include:

• Emergency preparedness drills are conducted with T&E and OBS crews to practice and apply employees understanding of roles and responsibilities to include coordination with first responders.

• IRT exercises are conducted biennially allowing management employees to practice and validate the understanding of their roles and responsibilities to include coordination activities performed at the incident site to comply with federal investigation requirements, specifically the Rail Passenger Disaster Family Assistance Act.

• Transportation and Customer Service exercises with station and front-line employees practice the coordination and response protocols for employees providing for customers impacted by a serious incident on a train or being received at a station.

• Unified incident management exercises focus on coordinated emergency response activities between Amtrak and external partners to increase the understanding of key decision points, information needs, and resource requirements.

• Special event exercises are conducted to prepare for courses of action that encompass a range of potential transportation and station-related incidents, such as station overcrowding and active threats in preparation of a presidential inauguration. Special event exercises also include examining the impact of severe weather to the Amtrak network.

APD manages the Amtrak Corrective Action Program as a mechanism for continuous reporting and analysis of each training and exercise event resulting in an ongoing view of progress. Following each exercise, after action reports are written to summarize the corrective actions and recommendations that were identified, which are tracked using the Quickbase system. Records are tracked using the Amtrak learning management system for employees and Quickbase system for external participants. 3.3.3.4 Emergency Equipment Amtrak trains are configured to meet the requirements associated with 49 CFR 238 Passenger Equipment Safety Standards. This emergency equipment includes: Emergency Communication Systems; Emergency Signage and Instructions; Low-level Path Markings; Emergency Lighting; Emergency Windows; and Roof Access. Amtrak’s Mechanical Division inspects and maintains all emergency equipment in accordance with 49 CFR 238 requirements. Additionally, Amtrak Facilities, Stations and Tunnels are designed and maintained in accordance with 29 CFR 1910 Occupational Safety and Health Standards and Nation Fire Protection Association of Standards (NFPA) 130 Standard for Fixed Guideway Transit and Passenger Rail Systems, which provides fire protection and life-safety requirements for underground, surface and elevated fixed guideway transit and passenger rail systems to include storage facilities, train ways, stations, emergency ventilation systems, and communications and control systems.

4.0 Safety Promotion Safety Promotion is the fourth pillar of the SMS. Safety Promotion is focused on the culture of Amtrak, which will ultimately determine the effectiveness of the company’s SMS. The following FRA requirements are addressed in this section: 49 CFR 270.103(t) Safety Culture; 49 CFR 270.103(i) System Safety Program Employee/Contractor Training; 49 CFR 270.103(l) Public Safety Outreach Program; 49 CFR 270.303 Internal System Safety Program Assessment. 4.1 Safety Culture While the SMS is composed of a policy, processes, tools, and templates, a robust safety culture brings them all together in a manner that is reflected in the decisions and actions taken by employees on a day-to-day basis. Amtrak strives for a culture that is proactive, where safety is self-motivated and defined by a sense of duty to others. The desired culture creates an environment conducive to learning from mistakes while at the same time, having no tolerance for reckless behaviors that reflect an intentional disregard for safety. A series of initiatives have been designed to help make this vision for the company’s safety culture a reality. 4.1.1 Internal Voluntary Reporting System Among the most powerful ways to develop a culture is by listening to the employees and then taking action that can be linked clearly to their feedback. By implementing an internal voluntary reporting system, employees will have the opportunity to report hazards, near-misses, or any other safety concern to the company while remaining anonymous. This capability will provide an online interface for reporting and upon receipt, the data will be collected and analyzed. As part of the Amtrak’s safety intranet, a dedicated web-page will show the results of the analysis in terms of the hazards identified, feedback trending, and the status of corrective and preventive actions being taken in response. 4.1.2 Close Call Confidential Reporting System The Close Call Confidential Reporting System (C3RS) is an FRA-funded initiative that provide employees with the opportunity to anonymously report close calls outside of the company. The industry-wide initiative has been adopted by Amtrak and the company provides the ability to access the system through safety web-page of the company intranet. System Safety will obtain the feedback provided by the FRA and include that data with the information received from the voluntary reporting system and includes the results on the internal web-page that shows hazards identified, trending items, and the corrective actions and preventive actions taken in response. 4.1.3 Safety Survey The safety survey is a tool that will be used to understand the current state of the Amtrak’s safety culture and measure progress toward the company’s vision. Sponsored by the ESC, the survey will be conducted annually with support from a third party. The initial survey will be used to baseline the current state. Subsequent survey’s will compare year over year results, enabling leadership to determine if the safety culture is progressing as intended. The survey will use an approach based on the Likert Scale, which is the most commonly used technique for scaling responses in survey research. The survey will invite all employees to express how much they agree or disagree with specific statements designed to solicit feedback associated with the safety culture at Amtrak. A statistical analysis will be performed on the results to reveal positive and negative trends. The ESC will use these results to

determine focus areas, priorities, corresponding action items, and responsibilities, which becomes the company’s preventive action plan. Figure 4-1 depicts an example of safety survey results.

Figure 4-1 Example of Safety Survey Results 4.1.4 Communication Effective communication is central to safety promotion and employee engagement. Therefore, Safety, Compliance and Training implements a deliberate approach to communication in accordance with 03- SMS-PR-A Safety Communication Plan. The communication plan includes:

• CEO and CSO safety messaging as part of events (leadership summits, quarterly reviews, town halls, all-hands, etc.) and special employee advisories sent by corporate communications.

• ELT letter address to all employees, endorsing the safety policy and explaining the roles and responsibilities that each of share in supporting the SMS

• Weekly Safety Focuses that are specific to Transportation, Engineering, Mechanical, and non- Operations employees that address relevant safety topics and include the SMS corner, which explains the principles behind this approach to safety.

• Safety Alerts that bring immediate attention and awareness to an emerging safety issue.

• Safety Bulletins the provide general information on safety changes, improvements, etc.

• A safety email address ([email protected]), which provides employees with the ability to contact safety with questions, feedback, or requests for assistance. Employees can also submit topics for the Weekly Safety Focuses and share their own safety stories.

• The Amtrak Safety Intranet, which provides the sources for all of the processes, tools, templates, and materials associated with the SMS as well as providing the ability to access the internal voluntary reporting system or C3RS.

• Operating Practices Advisories (OPAs) designed to increase awareness through targeted messaging related to subjects such as situation awareness, decision making, etc.

• Employee safety stories shared in the company’s weekly newsletter, Amtrak This Week.

4.1.5 Recognition Recognizing employees that exemplify the culture that Amtrak envisions is critical to its development. The President's Service and Safety Award (PSSA) is an annual recognition initiative designed to acknowledge those who embody this safety culture. Employees are allowed to nominate themselves or fellow coworkers. The award includes a trip to Washington, D.C. for a recognition event with the CEO and a commemorative plaque. A poster promoting the PSSA is depicted in Figure 4-2.

Figure 4-2 PSSA Poster

The safety video challenge is another recognition initiative that invites employees to make a short video (no more than three minutes), demonstrating how they live Amtrak’s safety culture in their day-to-day activities. As Amtrak’s SMS progresses, employees that are embracing the approach and driving its implementation will have additional opportunities to receive recognition at quarterly leadership summits, town hall meetings, and other company events.

4.2 System Safety Program Employee/Contractor Training An effective training program supports both implementation of SMS processes and helps shape the safety culture necessary to ensure its success. Therefore, a Training Plan will be developed and implemented by the Amtrak’s Training Department to establish a structured approach that encompasses the design, delivery, and administrative functions in accordance with 49 CFR 243 Training, Qualification, and Oversight for Safety-Related Railroad Employees. The training plan will ensure that any employee who is authorized, certified, qualified, etc. to perform a specific task is competent and capable of performing that task effectively in the field, per established safety, quality and operational requirements. Additionally, the plan includes a defined process composed of feedback loops that assure the desired employee performance criteria is met and that when failures or near misses occur the systemic, curricula, or human error is identified and corrected resulting in systematic continuous improvement, robust regulatory compliance, and overall risk reduction. 4.2.1 Training Administration and Program Management The Operations Training and Development Department leads the administration and program management of Amtrak’s safety training programs, which uses the ADDIE (Analysis, Design, Development, Implementation, Evaluation) program management model to provide effective and efficient training. The foundation of the training program starts with the learning path matrix, which shows how all job functions at Amtrak map to an inventory of the knowledge and skills (proficiency) necessary for that position and associated training courses required. The learning path matrix, which is actively maintained and adjusted to account for additional duties and tasks, ensures that every employee has been trained to the appropriate level. 4.2.1.1 Training Design and Delivery All curriculum will be designed based upon measurable results following the ADDIE program management model as outlined within 0X-SMS-PR-A Training Plan. The SMS requirements outlined in the SSPP (reflected in 1.5 SMS Implementation Process), regulatory requirements, and the mitigations identified by SSWGs will drive training performance criteria, which forms the basis for learning objectives. Instructional System Designers (ISD) will be teamed with subject matter experts in creation of the coursework. The ISDs will provide the instructional strategies for how the training will be delivered and structured while the subject matter experts provide current processes, procedures and best practices, and experience to define what will be trained. At certain stages throughout course development, approval points for subject matter experts and management will be embedded to ensure the courses meet the defined learning objectives.

Multiple data points will be collected throughout the system such as Efficiency Testing, employee exams, internal/external audits, etc., which will then be used to analyze and identify employee performance weaknesses in terms of leading and lagging indicators related to safety, quality and operational performance. Then a determination will be made as to whether adjustments to the training components of the program are the appropriate approach to close any identified gaps or otherwise improve safety performance effectiveness. 4.2.1.2 Instructor Development Instructor competency is critical to ensuring that training is properly delivered, and subsequent assessment of trainees reflects an accurate evaluation. Therefore, instructors receive training in course

facilitation as well as course-specific training as part of the Train-the-Trainer (TTT) program. Depending on the discipline they are assigned, instructors may be required to have earned the specific qualification associated with their assigned discipline (e.g., qualification training for Locomotive Engineers). 4.2.1.3 Records Management The documentation associated with the training program will be managed in accordance with the company’s RIM program as reflected in 0X-SMS-SA-A Records Management. These records include facilitator guides, participant guides, PowerPoints, handouts, syllabi, evidence of completion, etc. These records will be maintained for both employees and contractors. 4.2.2 SMS Training To advance implementation of the SMS, a multi-faceted approach will be taken to update existing safety training, integrate safety into other training courses, and develop new training courses. Additionally, the following courses are being developed specific to Amtrak’s SMS, as reflected in 1.5 SMS Implementation Process:

• Accident/Incident Investigation

• SMS Fundamentals

• Risk-based Hazard Management

• Safety Assurance

• System Safety Working Group

• Injury, Illness, and Rail Incident Reporting

• Records Management 4.2.3 Qualification and Certification Training In addition to training developed to enable SMS implement and safety culture development, specific qualification and certification requirements ensure that employees have the knowledge, skills and abilities necessary to perform their jobs safely. These requirements are associated with track safety standards, railroad workplace safety, and railroad operating rules. 4.2.3.1 Track Safety Standards Amtrak’s MW1000 governs maintenance-of-way forces in the inspection, maintenance and construction of track in accordance with CFR 49 213 Track Safety Standards. The MW1000 addresses the following subject areas:

• Part I Limits and Specifications for Track Safety, Maintenance and Construction

• Part II Limits and specifications for Turnout (and other track work) Safety, Maintenance and Construction

• Part III Limits and Specifications for Miter Rail and Expansion Joint Safety, Maintenance and Construction

Amtrak conducts two separate initial qualification programs: Track Classes 1-5 and Track Classes 1-9 (includes High Speed track). Both programs include classroom instruction and field training. Subject areas include track materials and components, inspection/geometry requirements and string-lining techniques. Written examinations are administered during each program. Program attendance and results are entered into Amtrak’s learning management system. Employees failing to achieve the minimum score can be retested within 30 days. Those failing on the second attempt can make a 3rd attempt within 30 days of the 2nd attempt. Failure to obtain qualification on the third attempt will restrict an employee from attending a new training program for a period of two years. Requalification, which includes a period of instruction and a written examination, is required annually.

4.2.3.2 Railroad Workplace Safety The roadway worker protection manual defines the procedures designed to protect roadway workers in accordance with 49 CFR 214 Railroad Workplace Safety. Additionally, affected craft employees (Track, Structures, and Electric Traction) also receive bridge worker training. This training applies to employees working on bridges that are twelve feet or more above ground or water surfaces and includes the requirement to demonstrate how to properly use fall protection equipment. All RWP trained employees are required to maintain their qualification status by completing annual training and carrying a valid qualification card on their person when on duty. To successfully complete RWP training, employees are required to pass an exam with a score of 80% or higher. Employee training dates are maintained in the company’s human resource database. 4.2.3.3 Railroad Operating Rules In accordance with 49 CFR Part 217.11, employees whose duties require them to be qualified on the Operating Rules and Timetable/Special Instructions must successfully complete initial qualification and periodic requalification programs. While each program involves instruction on critical job responsibilities relative to operating practice requirements and a formal assessment, the content of each program and the performance requirements are craft specific. When reporting for the examination, employees present their Operating Rules book, Timetable/Special Instructions and other instructions for inspection. Employees who fail this examination are eligible for re-examination in accordance with their applicable collective bargaining agreement. 4.2.3.4 Transportation Department Employees To remain qualified, employees are personally responsible for ensuring they attend an annual Operating Rules class. Employees in the following categories require initial qualification on operating rules and annual requalification:

• Train Dispatchers, Assistant Chief Dispatchers, and Block Operators

• Train and Engine Service employees and Yardmasters

• Employees who move or assist in the movement of trains or engines

• Employees who request foul time or take tracks out of service for maintenance

• Employees who operate on track equipment

• C&S Maintainers

• Supervisors and Managers who directly supervise any of the above employees 4.2.3.5 Non-T&E Employees Three qualification levels exist for non-T&E (i.e., Engineering and Mechanical) employees. Qualified employees are required to requalify every year. Attendance rosters for each qualification class are maintained by SC&T, which includes the results for each attendee.

• Class A – Authorizes drivers to operated Specialized MW equipment (equipment that reliably shunts track circuits)

• Class B – Authorizes employees to take tracks out of service for maintenance and to move or pilot track cars when properly qualified on physical characteristics

• Class C – Authorizes employees to obtain foul time when properly qualified on physical characteristics.

4.3 Public Safety Outreach Program Due to Amtrak’s unique standing as the only the only inter/city passenger rail provider in the United States, the public is constantly interaction with the company’s railroad system. Therefore, public safety outreach is a fundamental component of safety promotion. The Amtrak Police Department (APD) managed program is composed of a series of features and initiatives designed to proactively engage the public and capture their feedback, which is used to continuously improve the campaign toward minimizing the public’s exposure to unnecessary and avoidable risk. 4.3.1 Operation Lifesaver Amtrak is an active member and supporting partner of Operation Lifesaver, Inc. (OLI). This national, non-profit organization is dedicated to reducing collisions, fatalities and injuries along the nation’s railroad. OLI has 50 offices (one in each state) to include a state coordinator and volunteers that administer public railroad safety campaign initiatives annually. OLI and Amtrak have conducted a series of joint campaigns such as Operation Clear Track and National Rail Safety Week. Amtrak provides OLI with the resources (law enforcement officers, volunteers, safety videos, railroad safety pocket cards, etc.) that enable railway safety to reach millions. 4.3.2 Stay Off the Tracks Amtrak is creating the website called www.stayoffthetracks.org, which will be dedicated to making the public aware of the dangers associated with grade crossings and trespassing along the railroad right-of- way. The website will include articles, videos, and related information on what the public can do to stay safe and keep others safe. Additionally, the website will cover the Emergency Notification System (ENS), safety laws, and contact information to report a violation, incident, or emergency.

4.3.3 See Something Say Something Amtrak’s ongoing See Something Say Something campaign provides an easy method for customers, employees, and the public to make a report through the Text-A-Tip feature on the Amtrak app. This method provides a discrete way for anyone to report a safety or security concern and communicate live with a dispatcher from the National Communications Center (NCC). The NCC subsequently disseminates the report to the APD or the local police that serves the community where the report originated. Additionally, Amtrak provides several standard methods for the public to engage. The public can Text-A- Tip to Amtrak without the app by using APD11 (27311) or call Amtrak toll-free at 1-800-331-0008. Signage posted throughout Amtrak’s infrastructure to include every grade crossing and station provides the public with contact information. The public can also report concerns to uniformed personnel present on board trains or inside stations. 4.3.4 Additional Public Safety Initiatives In addition to the larger public safety campaigns, Amtrak has been and will continue to launch a series of initiatives designed to improve public safety and help the company’s customer become a part of the safety culture envisioned. These initiatives include:

• Ambassadors: Amtrak’s Ambassador Program invites all employees to volunteer during anticipated surge periods (holidays, sporting events, etc.). The Ambassadors help fulfill a critical function by helping customers safety complete their travels.

• PASS: Amtrak’s Partner’s for Safety and Security (PASS) program is based on the neighborhood watch philosophy. Customers are invited to actively enroll in the program and receive information through https://pass.amtrak.com/

• Driver’s Ed / CDL Training: Amtrak sends free safety videos to driver’s education and CDL schools across the country for inclusion in their training programs. The videos (one on Operation Lifesaver and the other on ENS) have now been delivered to more than 165,000 students.

• Operation RAILSAFE: A combination of online and in-person training for the purpose of strengthening coordination and integration among Amtrak’s stakeholders (emergency responders, host railroads, transit agencies, law enforcement officials, municipalities, etc.) in an effort to improve the security of the public and infrastructure from acts of terrorism.

• Suicide Prevention: Amtrak has joined a task force with the FRA on to study suicide by train. To increase awareness, Amtrak is placing 110 suicide hotline signs along the right-of-way.

• Social Media Monitoring: Amtrak Legal reaches out (over 200 letters have been sent) to individuals who have been detected on social media trespassing on company property. 4.4 Internal System Safety Program Assessment Sponsored by the ESC, the System Safety Program assessment will be conducted. The assessment will provide leadership with an indicator of how effective the SMS has been and include recommendations that fuel continuous improvement. The fundamental components of the internal assessment include

establishing a schedule, assembling teams, baselining evaluation criteria, recording the results, internal and external reporting, and implementing corrective actions and preventive actions. 4.4.1 Assessment Schedule After baseline implementation of the SMS has been completed as reflected in 1.5 SMS Implementation Process, the first internal assessment will be activated. To ensure the internal assessment methodically encompasses all SMS pillars, a formalized schedule will be established by the Sr. Director of System Safety and approved by the ESC. The baseline assessment will be conducted over the six-month period that follows two years of SMS implementation. This initial assessment includes all pillars in an effort to assess their level of development and provide input to the company’s preventive action plan, which will be designed to advance SMS development and implementation. Subsequent assessments will be based on cycle that systematically encompasses all SMS pillars over the course of a three-year period. 4.4.2 Assessment Teams To support the baseline assessment schedule, assessment teams will be established. The ESC will identify the assessment team leads. The team leads are responsible for assembling assessment teams. The assessment teams will be composed of at least two assessors with more added as needed, depending on the scope and complexity of the pillar under review. The purpose of having at least two assessors is to provide checks and balances that promote critical thinking and objectivity. The team leads will solicit volunteers from Amtrak employees, which provides another opportunity to encourage them to take an active role in the SMS. Additionally, third party support may be utilized to lead or participate on assessment teams. 4.4.3 Assessment Criteria To conduct the assessment, checklists will be established. The checklists will be based on the SMS pillar under review and will include the applicable processes, procedures, templates, etc. Every checklist starts with a reference that refers to the requirement under assessment, followed by the question to ask, evaluation criteria to measure against, and a place to record the results. The assessment team leads are responsible for establishing the checklists and submitting them for review and approval by the ESC prior to implementation. A notional assessment checklist is depicted in Figure 4-3.

Assessor: Bob Smith Site: WAS Employee ID: 0012345 Date of Audit: XX/XX/XXXX

Internal Assessment of SMS Element 1 System Safety Program Policy Statement

Question Reference Assessment Question Evaluation Criteria N/A Results ACCEPTREJECT

The Amtrak Policy and Instruction Manual (APIM) SSPP Section 1 System System Safety Policy exists Could you please provide the includes 3.4.5 System Safety Policy, which is current in 1-1 Safety Program Policy Is actively maintained and reviewed System Safety Policy statement?  accordance with the stated annual review requirement Statement Has been signed by the Amtrak CEO and has been signed by CEO Richard Anderson.

Figure 4-3 Internal Assessment Checklist Example

4.4.4 Assessment Conduct Before starting the assessment, the team lead will be required to provide a commencement briefing to the ESC and leadership from the site/division/region expected to participate. The commencement briefing covers the pillars/sub-elements under assessment, planned locations and personnel involved, day-to-day schedule and a question/answer period. When the assessment is complete, an out-briefing is provided to the same audience and additional personnel as required. The out-briefing recaps the assessment and presents preliminary findings in terms of (a) observations (noted behaviors witnessed that are not necessarily actionable); (b) recommendations (opportunities for improvement that are not related to a deficiency); and (c) deficiencies (areas that are not in compliance with the SMS). The deficiencies will be categorized as red/yellow/green based on application of Amtrak’s risk management methodology. The out-brief also provides the ESC and assessment participants with the opportunity to provide feedback to the assessment team, which is taken under consideration as part of establishing the final report. The assessment team submits the final report to the ESC for approval within 10 business days of completing the assessment. The ESC has the authority to approve or reject the report (with feedback). However, once the report is accepted, System Safety will partner with Operations to develop a Preventive Action Plan. The Preventive Action Plan will be based on the ESC’s decisions on what observations to address, recommendations to incorporate, and the actions that will be taken to address the identified deficiencies. The Preventive Action Plan will become the fundamental vehicle used to advance the company’s SMS after baseline implementation is completed. 4.4.5 External Reporting and SMS Improvement After the final internal assessment report is approved by the ESC, Amtrak System Safety will ensure that a copy is submitted to the FRA in accordance with 49 CFR 270.303 Internal System Safety Program Assessment. As part of the Safety Assurance Program, Amtrak System Safety will ensure that all deficiencies are properly addressed in accordance with the Preventive Action Plan approved by the ESC. Additionally, System Safety is responsible for maintaining the SSPP. Any updates that are identified as a result of the internal assessment will be incorporated at the next revision cycle unless needs (such as a high-risk deficiency, ESC request, etc.) dictate an out-of-cycle update. As the SMS matures, the SSPP will evolve to become a manual that reflects the SMS established at Amtrak.

Revision Record Rev Reference Summary of Changes A Entire Document Baseline version established.

Appendix A – Executive Leadership Team Letter

Appendix B – Railroad System Description Specifics

B-1 NEC Operators Approximately 260 million passenger trips are made on the NEC annually, 17 million of them are made specifically by Amtrak customers. The balance is provided by commuter railroads that share the NEC. In total, over 2,100 passenger and freight trains operate on the NEC every day. Table B-1 provides more detail on the railroads that use the NEC most frequently.

Table B-1 NEC Operators Railroad Type Route/Frequency VRE operates commuter trains to and Virginia Railway Passenger from Washington DC’s Union Station Express (VRE) every weekday (Monday-Friday) MARC operates commuter trains Maryland Area between Baltimore and DC as well as Regional Commuter Passenger Baltimore and Perryville, MD every (MARC) weekday (Monday-Friday) SEPTA operates commuter trains Southeastern between: Newark, DE and Wilmington, Pennsylvania DE; Wilmington and Philadelphia; Passenger Transportation Philadelphia and Authority (SEPTA) Thorndale/Harrisburg/Trenton, NJ daily (Monday-Sunday) NJ Transit operates commuter trains New Jersey (NJ) between Atlantic City and Philadelphia as Passenger Transit well as Trenton and NYC daily (Monday- Sunday) LIRR operates commuter trains to and Long Island Rail Passenger from NYC’s Penn Station daily (Monday- Road (LIRR) Sunday) Metro-North operates commuter trains Metro-North Passenger between NYC and New Haven, CT daily Commuter Railroad (Monday-Sunday) SLE (Connecticut) operates commuter trains between New Haven and New CDOT Passenger London, CT daily (Monday-Sunday) as well as daily commuter service from New Haven to Hartford to Springfield (MA) Massachusetts Bay MBTA owns and operates commuter Transportation Passenger trains between Wickford Junction, RI and Authority (MBTA) Boston daily (Monday-Sunday) Norfolk Southern NS maintains trackage rights between Freight (NS) Washington, DC and Newark, NJ CSX maintains trackage rights between CSX Freight Washington, DC and Newark, NJ and portions of the NEC mainline in MA. Conrail maintains trackage rights Conrail Freight between Philadelphia and Newark, NJ

Providence and P&W maintains trackage rights between Worcester (P&W) Freight New Haven and the RI/MA state line Railroad

B-2 NEC Grade Crossings The NEC includes 11 highway-rail grade crossings. All 11 grade crossings are in Connecticut. Except for three grade crossings near New London Union Station, all have four-quadrant gates with induction loop sensors, which allow vehicles stopped on the tracks to be detected in time for an oncoming train to stop. The NEC grade crossings are listed in Table B-2.

Table B-2 NEC Grade Crossings City Street DOT/AAR No. Description Connects the Pawcatuck residential area to the Palmer Street 500263U Mechanic Street arterial. Provides sole access to Elihu Island. Private Elihu Island Road 500267W crossing. Provides sole access to a small marina. Private Walker's Dock 500269K Stonington crossing. Wamphassuc Road 500272T Provides sole access to a residential area. Latimer Point Road 500275N Provides sole access to a residential area. Next to Mystic station. Provides sole access to Broadway Avenue 500277C a residential and industrial area, several marinas, and the northbound platform. Provides sole access to the Willow Point Groton School Street 500278J residential area and marina. Provides sole access to Block Island Ferry and Ferry Street 500294T Cross Sound Ferry docks and marine facilities. Next to New London Union Station. Provides New access to the Fisher's Island Ferry, City Pier, London State Street 500295A Waterfront Park, and the northbound platform. Bank Street 500297N Provides access to Waterfront Park. Provides sole access to a residential and Waterford Miner Lane 500307S industrial area. B-3 NEC Bridges/Tunnels/Overpasses The NEC’s more than 140 bridges/tunnels/overpasses are embedded throughout the corridor. Table B-3 lists each of them in order starting from the Washington, DC area heading northward to Massachusetts.

Table B-3 NEC Bridges/Tunnels/Overpasses State Name Location DC Anacostia Railroad Bridge Southeast Washington MD Baltimore and Potomac (B&P) Tunnels Baltimore County MD Union Tunnel Baltimore County MD Gunpowder River Bridge Baltimore County MD Gwynn Falls Viaduct Baltimore County MD Bush River Bridge Harford County MD Susquehanna River Bridge Hartford County

DE Brandywine River Bridge New Castle County DE Naaman Creek Stone Arch New Castle County DE Steel Mill Road Arch New Castle County DE Brick Arch Viaduct New Castle County DE US13 Overpass New Castle County PA Darby Creek Bridge Delaware County PA Cobbs Creek Bridge Delaware County PA Pennypack Creek Bridge Philadelphia County PA Island Road Overpass Philadelphia County PA B&O - Amtrak Overpass Philadelphia County PA Connecting Railway Bridge Philadelphia County PA Washington Street Overpass Bucks County NJ Belleville Turnpike Overpass Hudson County NJ Newark Turnpike Overpass Hudson County NJ Northeast Corridor Bridge Hudson County NJ Portal Bridge Hudson County NJ Frank E Rodgers Boulevard Overpass Hudson County NJ South Clinton Avenue Bridge Mercer County NJ Delaware River Bridge Mercer County NJ Route 29 Overpass Mercer County NJ Dock Bridge Essex County NJ East Kinney Overpass Essex County NJ Green Street Overpass Essex County NJ Tichenor Street Overpass Essex County NJ Wright Street Overpass Essex County NJ CRCX - Northeast Corridor Overpass Essex County NJ South Street Overpass Union County NJ Garden State Parkway Overpass Middlesex County NJ Raritan River Bridge Middlesex County NJ Route 35 Overpass #2 Middlesex County NJ New Brunswick Avenue Overpass Union County NJ North Avenue Overpass Union County NJ North Broad Street Arch Overpass Union County NJ Rahway Avenue Overpass Union County NJ Rahway River Bridge Union County NJ South Elmora Avenue Overpass Union County NJ South Wood Avenue Overpass Union County NJ ME/Amtrak Overpass Union County NY 174th Street Bridge Bronx County NY Hutchinson River Bridge Bronx County NY White Plains Road Bridge Bronx County NY Union Port Road Bridge Bronx County NY Bronx River Bridge Bronx County NY William Street Bridge Westchester County NY West Street Bridge Westchester County NY Rockland Avenue Bridge Westchester County NY North Barry Avenue Bridge Westchester County NY Willet Avenue Overpass Westchester County NY US1 Overpass Westchester County

NY Mamaroneck River Bridge Westchester County NY Mamaroneck Avenue Overpass Westchester County NY Macy Road Overpass Westchester County NY King Street Overpass Westchester County NY Jefferson Street Overpass Westchester County NY Blind Brook Bridge Westchester County NY Beaver Swamp Brook Bridge Westchester County NY Hillside Avenue Bridge Westchester County NY Centre Avenue Bridge Westchester County NY Webster Avenue Overpass Westchester County NY Broadway Bridge Westchester County NY US 1 Overpass Westchester County NY Pelhamdale Avenue Overpass Westchester County NY Kings Highway Overpass Westchester County NY Bronx Kill Bridge New York County NY East River Tunnels New York County NY North River Tunnels New York County NY Hell Gate Bridge New York County CT Byram River Bridge Fairfield County CT Barnum Avenue Cutoff Bridge Fairfield County CT Drinkwater Place Bridge Fairfield County CT CT110 Bridge Fairfield County CT CT136 Overpass Fairfield County CT Courtland Avenue Overpass Fairfield County CT Byram Road Bridge Fairfield County CT Fivemile River Bridge Fairfield County CT Field Point Road Overpass Fairfield County CT Norwalk River Bridge Fairfield County CT Rippowam River Bridge Fairfield County CT Pequonnock River Bridge Fairfield County CT Saugatuck River Bridge Fairfield County CT Mianus River Bridge Fairfield County CT Arch Street Overpass Fairfield County CT Riverside Avenue Bridge Fairfield County CT Jenkins Curve Overpass Fairfield County CT Main/Washington Street Overpass Fairfield County CT CT81 Overpass Middlesex County CT Patchogue River Bridge Middlesex County CT North High Street Overpass Middlesex County CT Walkway Overpass Middlesex County CT Indian River Arch Bridge Middlesex County CT Connecticut River Bridge Middlesex County CT East Haven Tunnels New Haven County CT Hammonasset River Bridge New Haven County CT James Street Overpass New Haven County CT Leetes Island Arch New Haven County CT Mill River Bridge New Haven County CT Humphrey Street Overpass New Haven County CT Wepawaug River Bridge New Haven County

CT Montowese Street Amtrak Bridge New Haven County CT US1 Overpass New Haven County CT Devon bridge New Haven County CT Quinnipiac Avenue Overpass New Haven County CT Groton Bridge New London County CT Mystic River Bridge New London County CT Niantic River Bridge New London County CT Pawcatuck River Bridge #1 New London County CT Shaw's Cove Bridge New London County CT Mosher Street Bridge New London County CT Rocky Neck State Park Footbridge New London County CT State Pier Road Overpass New London County CT Amtrak/NECR Overpass New London County RI Blackstone River Bridge Providence County RI High Street Overpass Providence County RI Branch Avenue Bridge Providence County RI Charles Street Overpass Providence County RI Smithfield Avenue Bridge Providence County RI Park Avenue Bridge Providence County RI Lonsdale Avenue Bridge Providence County RI King Street Overpass Kent County RI Maskerchugg River Bridge Kent County RI Shore Access Road Arch Kent County RI Pawtuxet River Bridge Kent County RI Pawcatuck River Bridge #3 Washington County RI Pawcatuck River Bridge #4 Washington County RI Pawcatuck River Bridge #5 Washington County RI Pawcatuck River Bridge #6 Washington County RI High Street Bridge Washington County RI South County Trail Bridge Washington County MA Mill Street Bridge Bristol County MA Park Street Bridge Bristol County MA Peck Street Bridge Bristol County MA South Main Street Bridge Bristol County MA Seven Mile River Railroad Bridge Bristol County MA South Main Street Bridge Bristol County MA Ten Mile River Bridge No. 32.50 Bristol County MA Ten Mile River Bridge No. 33.51 Bristol County MA Wading River Railroad Bridge No. 28.43 Bristol County MA Arborway Arch Bridge Suffolk County MA Shore Line Bridge Suffolk County MA River Street Bridge Suffolk County MA Canton Viaduct Norfolk County

B-4 State Supported Services Amtrak receives funding from 18 states through 21 agencies for financial support of 26 short-distance routes (less than 750 miles). These state supported services are depicted in Table B-4.

Table B-4 State Supported Amtrak Operations State Service Route MA-CT Springfield Shuttle Springfield-New Haven MA-CT-VT Vermonter New Haven-St. Albans ME Downeaster Brunswick-Portland-Boston Empire New York-Albany-Buffalo-Niagara Falls NY Maple Leaf New York-Niagara Falls-Toronto Adirondack New York-Montreal NY-VT Ethan Allen Express New York-Rutland Keystone Harrisburg-Philadelphia PA Pennsylvanian Philadelphia-Pittsburgh Washington-Lynchburg-Richmond-Newport VA Virginia Regional News-Norfolk Carolinian Charlotte-Raleigh-Washington NC Piedmont Raleigh-Charlotte IL-WI Hiawatha Chicago-Milwaukee Lincoln Chicago-St. Louis IL Illini & Saluki Chicago-Carbondale Carl Sandburg Chicago-Quincy IN Hoosier State Indianapolis-Chicago Wolverine Pontiac-Detroit-Chicago MI Blue Water Port Huron-East Lansing-Chicago Pere Marquette Grand Rapids-Chicago MO Missouri River Runner Kansas City-St. Louis WA-OR Cascades Eugene-Portland-Seattle-Vancouver, B.C. TX-OK Heartland Flyer Oklahoma City-Fort Worth Capitol Corridor San Jose-Sacramento-Auburn CA Pacific Surfliner San Luis Obispo-Los Angeles-San Diego San Joaquins Sacramento-Oakland-Bakersfield

B-5 Contract Services Amtrak is one of the largest providers of contract services (commuter, maintenance, etc.). The contract services provided are depicted in Table B-5.

Table B-5 Contract Services State Commuter Service Amtrak operates an average of 57 MARC Penn Line commuter trains MD MARC every weekday (Washington-Baltimore-Perryville) under a contract with the Maryland Transit Administration (MTA) Amtrak operates the daily Shore Line East commuter service, which CT CDOT consists of 20 trains between New Haven and Old Saybrook and 13 between New Haven and New London. Amtrak operates the Metrolink commuter service, which serves a five-county area in the Los Angeles Basin, with seven lines, 55 stations, and 40,000 weekday passengers. Amtrak provides all train CA Metrolink and engine crews and management services. Besides the regularly scheduled trains, Amtrak operates special trains for summer beach travelers, for county fairs, and for sports and other special events. Amtrak operates approximately 56 trains daily in MA, including Acela Express and Northeast Regional trains on the NEC and State MA MBTA Supported Downeaster and Vermonter services. Amtrak also operates the National Network Lake Shore Limited (daily Boston- Springfield-Albany-Cleveland-Chicago route). Amtrak maintains Sounder commuter rail equipment under a WA Sound Transit contract with Sound Transit. This service operates between Everett- Seattle and between Seattle-Tacoma. Amtrak and Florida DOT entered into an agreement for periodic and FL SunRail heavy maintenance of SunRail equipment. NJ Transit operates more than weekday 400 trains (about 200 on NJ NJ Transit weekends) on the NEC with access provided by Amtrak. Amtrak provides SEPTA with access and electric traction power to PA SEPTA enable their commuter services to operate over the NEC. Amtrak provides the Delaware Transit Corporation (DTC) with access DE DTC to NEC tracks for their Philadelphia-Wilmington-Newark commuter operations (operated by SEPTA). Amtrak works with Key Holidays, a tour operator, to operate “Fun Trains” and “Snow Trains,” which are special trains that carry thousands of passengers from the Bay Area to Reno. Many of these NV Key Holidays passengers go on to visit ski resorts and other recreational areas near Lake Tahoe during winter months when airports and highways are often disabled or shut down. Amtrak provides seasonal service between Denver and Winter Park Resort, known as the Winter Park Express. This seasonal, Winter Park CO weekend service provides a car-free transportation alternative to the Resort ski resort. Approximately 26 round trips are made from January through March.

B-6 Rolling Stock Inventory Table B-6a depicts Amtrak’s passenger car fleet and Table B-6b outlines Amtrak’s locomotives and state-owned equipment.

Table B-6a Amtrak Passenger Car Fleet Heritage Hep Total: 17 Amfleet I Total: 454 Type Series Active Type Series Active Diner 8502 - 8532 9 Club Dinette 48140 - 48196 44 Diner Grill 8550 - 8559 2 All Table Dinette 43345 - 43397 46 Dome Lounge 10031 1 Capst. Bus. CL (ADA) 81501 - 81551 39 High Level Lounge 39970 - 39975 5 Capstone Co. (ADA) 82500 - 82999 325 Viewliner Total: 51 Amfleet II Total: 145 Type Series Active Type Series Active Diner 8400 1 Coach (ADA) 25000 - 25124 120 Sleeper 62000 - 62049 50 Lounge 28000 - 28024 25 Viewliner II Total: 71 Horizon Total: 92 Type Series Active Type Series Active Baggage 61000 - 61069 70 Full Dinette (ADA) 53501 - 53511 5 Sleeper 62500 - 62524 0 Coach 54000 1 Diner 68000 - 68024 1 Coach (ADA) 54500 - 54584 76 Baggage-Dorm 69000 - 69009 0 Club Dinette (ADA) 58000 - 58106 10 Superliner I Total: 240 Inspection / Training Cars Total: 10 Type Series Active Type Series Active Coach/Baggage 31000 - 31047 42 Amfleet I Inspection 10001 1 Coach (CalTrans Svc) 31934 1 Amfleet I Track Geometry 10002 1 Sleeper 32000 - 32069 60 Viewliner I Theatre Car 10004 1 Lounge 33000 - 33024 20 Catenary Geometry Car 10005 1 Lounge (Diner conv) 33100 - 33104 5 Exhibit Cars 10093 - 10095 4 Coach (ADA) 34000 - 34101 70 Company Service Cars 10020 - 10021 2 Coach (CalTrans Svc) 34900 - 34999 6 Former Metroliner Cars Total: 17 Snack Coach 35001 - 35010 9 Type Series Active Diner-Lounge 37000 - 37016 15 Cab Control Coach 9632 - 9651 16 Diner 38000 - 38034 12 Cab Conference Coach 9800 1 Superliner II Total: 184 Bag/NPCU/Auto Carrier Total: 118 Type Series Active Type Series Active Sleeper 32070 - 32115 47 Baggage (Heritage) 1159 - 1260 1 Deluxe Sleeper 32500 - 32505 6 Baggage (Heritage) 1701 - 1763 12 Lounge 33025 - 33049 23 Baggage/Bicycle 1855 - 1857 0 Coach (ADA) 34102 - 34139 31 Wheel/Buffer Cars 10404 - 10405 2 "Arcade" Co (Mod) (ADA) 34504 - 34515 5 Cab/Baggage 90200 - 90413 22 Diner 38039 - 38068 30 Exhibit Train NPCU 405 1 Trans. Dorm 39000 - 39011 11 Auto Carrier Multi-Purp. 9200 - 9279 80 Trans. Sleeper 39012 - 39046 31

Table B-6b Amtrak Locomotives and State-0wned Equipment Road Diesel Locomotives Total: 259 Diesel Switchers Total: 50 Type Series Active Type Series Active P-42 1 - 207 189 GP38H-3 520 - 527 8 F59PHI 450 - 470 21 MP15 530 - 539 10 P32-8 500 - 519 18 SW1500, SW1001 540 - 541, 569 2 P32AC-DM 700 - 717 18 GP15D 570 - 579 10 P-40 800 - 843 13 MP14, MP21 590 - 599 6 NEC High Speed Equipment (Acela Express) Total: 161 GP38 720 - 724 5 Type Series Active SW1 737 1 Power Car 2000 - 2039 40 80-Ton 1000, 1100 2 First Class 3200 - 3219 20 SW1000 790 - 799 6 Café 3300 - 3319 20 California-Owned Locomotives Total: 17 End Bus Class 3400 - 3419 20 Type Series Active Mid Bus Class 3500 - 3559 60 F59PHI C2001 - C2015 15 Inspection Car 10003 1 P32-8 C2051 - C2052 2 Talgo Equipment (Cascades) Total: 90 Other California-Owned Cars Total: 91 Type Series Active Type Series Active Bike/Baggage 7100 - 7105, 7110 - 7111 7 Single-level C5001 - C5014 14 Bistro Car 7300 - 7305, 7310 - 7311 7 Car Coach C8001 - C8032 32 Standard Coach 7400 - 7425 26 Car Baggage Co. C8201 - C8206 6 Business Class 7450 - 7454 5 Car Cab Coach C8301 - C8314 14 ADA Coach 7500 - 7504 5 Car Dining C8801 - C8814 13 ADA Coach 7200 - 7205, 7520 - 7522 9 Car II Coach/Café C6361 - C6362 2 ADA Bus Class 7550 - 7554, 7560 - 7563 9 Car II Coach C6461 - C6465 5 ADA Co w/o Toilet 7700 - 7707 8 Car II Coach Bag C6961 - C6965 5 Dining (Table) Car 7800 - 7804, 7810 - 7811 7 Pacific Surferliner Bi-level Equip Total: 49 End Power/Cab Car 7900 - 7905, 7910 - 7911 7 Type Series Active Electric Locomotives Total: 68 Coach/Café 6300 - 6352 10 Type Series Active Coach 6400 - 6453 18 ACS-64 600 - 670 68 Business Class Car 6800 - 6852 10 HHP8 680 - 694 0 Cab/Coach Baggage 6900 - 6953 11 AEM7 901 - 953 0 North Carolina-Owned Cars Total: 20 North Carolina-Owned Locomotives Total: 6 Type Series Active Type Series Active Coach 400001-012 14 F59PHI NC1755, NC1797 2 Coach-Baggage 400101 1 F59PH NC1810 - NC1893 4 Lounge 400201-204 5

Appendix C – Safety Performance Metrics

Safety & Security Committee (Sept. 2018) (Copy) - Safety Topics*

® FOR APPROVAL ˛ FOR INFORMATION 4.1 SAFETY TOPICS FY 2019 Safety Metrics

Customer Incidents 28.00

26.00

24.00

22.00

20.00

18.00

16.00

14.00 Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep

Lower CL Upper CL FY2018 (Actual) FY2018 (Forecast) FY2019 (Goal)

Figure 1 – Customer Incidents

Table 1. Customer Safety Metric Table 2. Customer Safety Score FY FY FY 2018 Score Customer Injury Rate Metric 2018 2019 Prediction 3 <=18.8 YtD Goal <=19.8 Customer Injury Rate 2 20.8 20.8 18.8 >18.8 (Excluding 188, 501, 91) 1 >19.8 Notes: • Goal is based on a 10% reduction of FY 2018 predicted value. This excludes major incidents. The goal represents a 30% reduction including major incidents. • Rates over past five years have generally increased, causing the goal to at the higher end of the control limits. • Rates are normalized per 100 million passenger miles.

FY 2019 Customer Programs • Station Assessment – Review of conditions at all Amtrak stations to identify potential safety issues. • Get-a-Grip Campaign – On-board campaign for employees and customers to better educate people about moving on the train. • On Board Announcements and Signage – Unified messaging and announcements providing safety information to customers. • Investigations – Performed using the Root Cause Analysis and Corrective Action (RCCA) methodology to target known risk areas based on historical data.

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Employee Incidents - FRA Rate 5.00 4.1

4.50

4.00

3.50

3.00

2.50

2.00 Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep

Lower CL Upper CL FY2018 (Actual) FY2018 (Forecast) FY2019 (Goal)

Figure 2 – Employee Incidents- FRA Rate

Table 3. Employee Safety Metric- FRA Reportable Table 4: Employee Safety Score- FRA Incident Rate Reportable Incident Rate Employee FRA FY FY Score FY 2018 Reportable Incident Rate Metric 2018 2019 Prediction YtD Goal 3 <=3.4 <=3.6 Employee FRA 2 3.7 3.8 3.4 >3.4 Reportable Incident Rate 1 >3.6

Notes: • Goal is based on 10% reduction from FY 2018 predicted value. • Rates are normalized based on 200,000 man-hours.

FY 2019 Programs: • MoveSmart – Review of potential programs to address strains and sprains. • PPE Program – New PPE process and catalog, designed to assist employees with selecting and obtaining the correct PPE. • Ergonomics Analysis – Conduct ergonomic assessments of work areas and tasks to identify opportunities to improve safety and efficiency. • Fit for Duty / Physical Capacity Assessment Program – Conduct assessments of potential candidates to validate their physical ability to perform required tasks and duties.

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Employee Incidents - SIF Rate 0.80

0.70 4.1

0.60

0.50

0.40

0.30

0.20

0.10

0.00 Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep

Lower CL Upper CL FY2018 (Actual) FY2018 (Forecast) FY2019 (Goal)

Figure 3- Employee Incidents- SIF Rate

Table 5. Employee Safety Metric- SIF Incident Rate Table 6. Employee Safety Score- SIF Incident Rate FY FY FY 2018 Metric 2018 2019 Employee SIF Prediction Score YtD Goal Incident Rate Employee SIF 0.35 0.36 0.34 3 <=0.34 Incident Rate <=0.36 2 >0.34 Notes: 1 >0.36 • Goal is based on a 5% reduction from FY 2018 predicted value • Rates are normalized based on 200,000 man-hours

FY 2019 Programs: • Accident/Incident Investigation Process – Standardized process that triggers Post-Incident Reviews that drive implementation of corrective and preventive actions. • Conflict resolution training – Conduct training in techniques for de-escalation of conflict • Job Safety Analysis (JSA) – Expand use of the Job Safety Analysis process, driving proactive assessment and mitigation of inherent task-based risks. • Safety Training – Update enterprise wide training to incorporate SMS lessons and expand to include both agreement and non-agreement employees.

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Table 7. Cascaded Employee Safety Metric- FRA Reportable Incident Rate 4.1 FY 2018 FY 2018 FY 2019 Metric YtD Prediction Goal FRA Reportable Rate (Company Wide) 3.71 3.79 3.41 APD 9.99 9.77 8.79 Engineering 4.17 4.31 3.88 Mechanical 3.59 3.68 3.31 Transportation 3.91 4.01 3.61 Other 1.05 1.08 0.97

Table 8. Cascaded Employee Safety Metric- SIF Incident Rate

FY 2018 FY 2018 FY 2019 Metric YtD Prediction Goal SIF Rate (Company Wide) 0.35 0.36 0.34 APD 0.86 0.91 0.86 Engineering 0.42 0.43 0.41 Mechanical 0.37 0.42 0.40 Transportation 0.36 0.37 0.35 Other 0.06 0.04 0.04

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Tier 1 Rate 12.00 4.1

11.00

10.00

9.00

8.00

7.00

6.00

5.00

4.00 Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep

Lower CL Upper CL FY2018 (Actual) FY2018 (Forecast) FY2019 (Goal)

Figure 4- Train Safety Index Tier 1 Rate

Table 10. Train Safety Table 9. Train Safety Index Tier 1 Rate Index Tier 1 Score FY FY FY 2018 Score Tier 1 Rate Metric 2018 2019 Prediction YtD Goal 3 <=8.5 <=8.9 Tier 1 Rate 9.4 9.4 8.5 2 >8.5 1 Notes: >8.9 • Goal is based on a 10% reduction from FY 2018 predicted value. • Includes both reportable and non-reportable incidents. • In general, more events have been captured in recent years (non-reportable) which has pushed FY 2018 higher than past years. • Rates are normalized based on 1 million train miles.

FY 2019 Programs: • Implement PTC – Complete implementation of PTC on Amtrak routes in accordance with the federally mandated completion date of December 31, 2018. • Non-PTC Mitigation – Engage host railroads, states, and other stakeholders on the implementation of mitigations that reduce risk to an acceptable level on routes and operations where PTC has not been implemented. • AWARE Program – Implement Apps that add redundancy and increase situational awareness. • Route Qualification Program – Increase training requirements for Locomotive Engineers to qualify when changing routes and maintain proficiency. • Obstructions – To be determined.

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Tier 2 Rate 6.00 4.1 5.00

4.00

3.00

2.00

1.00

0.00 Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep

2017 FY2018 (Actual) FY2018 (Forecast) FY2019 (Goal)

Figure 5- Train Safety Index Tier 2 Rate

Table 12. Train Table 11. Train Safety Index Tier 2 Rate Safety Index Tier 2 Score FY FY FY 2018 Metric 2018 2019 Score Tier 2 Rate Prediction YtD Goal 3 <=2.0 Tier 2 Rate 2.1 2.1 2.0 <=2.1 2 >2.0 1 >2.1 Notes: • Goal is based on a 5% reduction from FY 2018 predicted value. • Control lines not shown because 5 years of Tier 2 data is available. • Tier 2 incidents do not include incidents that were also reported as close calls as part of C3RS. • Rates are normalized based on 1 million train miles.

FY 2019 Programs: • RCCA on Stop Signals – Initiate RCCA investigations in response to patterns and trends in Major Operating Rule Violations. • QA Group Establishment – Establish a Railroad Operations Quality Assurance Team to oversee performance and perform additional oversight. • SPARTN – Improve the data collection and analyses associated with 49 CFR 217.9 . • Voluntary Reporting Systems – addition of new voluntary reporting systems.

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Table 13. Cascaded Train Safety Index Tier 2 Rate 4.1 FY 2018 FY 2018 FY 2019 Metric YtD Prediction Goal Tier 2 Incidents (Company Wide) 2.1 2.1 2.0 Tier 2 Incident Threshold 70 86 79 Engineering 13 17 16 Mechanical 17 20 18 Transportation 40 49 45

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Trespasser and Grade Crossing Rate 14.00 4.1

13.00

12.00

11.00

10.00

9.00

8.00

7.00

6.00 Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep

Lower CL Upper CL FY2018 (Actual) FY2018 (Forecast) FY2019 (Goal)

Figure 6- Trespasser and Grade Crossing Incident Rate

Table 14. Trespasser and Grade Crossing Safety Table 15. Trespasser and Grade Metric Crossing Safety Score Trespasser and Grade FY FY Score FY 2018 Crossing Incident Rate Metric 2018 2019 Prediction YtD Goal 3 <=9.0 <=9.5 Trespasser and 2 Grade Crossing 10.0 10.0 9.0 >9.0 Incident Rate 1 >9.5

Notes: • Goal is based on a 10% reduction from FY 2018 predicted value. • Rates are normalized based on 1 million train miles.

FY 2019 Programs: • Operation Life Saver – continued participation in OLS and operation clear track, an effort to educate, engineer, and enforce grade crossing and railroad ROW. • Grade Crossing Risk Management – Conduct Grade Crossing risk assessments and implement mitigation plans.

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Appendix D – Safety Strategy

Safety & Security Committee (Sept. 2018) (Copy) - Safety Topics*

˛ FOR APPROVAL ® FOR INFORMATION 4.3 BOARD OF DIRECTORS FY 2019 SAFETY STRATEGY

A string of five major accidents, customer and employee fatalities, and serious injuries resulted in the Amtrak leadership decision that a different approach was needed to address safety at the railroad. Train accidents 188 (May 2015), 89 (April 2016), 506 (July 2017), 501 (December 2017) and 91 (February 2018) all pointed to systemic failures and opportunities within our systems to improve safety. Since May 2015 we have incurred 11 customer and seven employee fatalities related to railroad operations. Additionally, on average, about 1,200 customers and 850 employees per year are injured across the Amtrak system. In November 2017, the National Transportation Safety Board issued an accident report for Train 89 that was very critical of the safety culture at Amtrak stating, in part, that:

“The 29 active failures and latent conditions indicate a systemic problem with Amtrak’s safety culture” “Amtrak’s safety programs were deficient and failed to provide effective first-line safety oversight” “The lack of consistent knowledge and vision for safety across Amtrak’s management created a culture that facilitated and enabled unsafe work practices by employees” “Amtrak did not have an effective safety management system program”

In addition to the human loss and personal suffering that results from the accidents, Amtrak has suffered damage to brand reputation as well as exposure to significant financial claims and revenue loss.

Amtrak executive leadership, with the support of the Board of Directors, has endorsed a change in approach to managing safety. A review of the current situation has identified numerous opportunities to improve safety at Amtrak including: advancing on-board safety technology, addressing human performance and safety culture, improving management and employee relationships related to safety, and enhancing organizational interfaces and coordination. During 2017 and early 2018, organizational changes were made to create a Safety, Health and Environment team whose major purpose is to support a renewed organizational focus on safety. Since the beginning of 2018, the forward-looking safety strategy has been evolving. The safety strategy can be described by three groups of activities:

Amtrak 2019 Safety Strategy

Implement an industry-leading Safety Management System (SMS) using just culture principles

Be a leader in implementation of PTC and assure PTC equivalency in non-PTC territory

Use data and technology to improve safety, technical training and qualification

During FY 2019 we will continue our journey toward improved safety performance. We will focus on expanding the influence of our safety programs to employees through implementation and enhancement of voluntary safety reporting, implementing just culture practices, maturing our SMS safety processes, increasing safety of operations in non-PTC territory, and improving our employee technical training programs. We will restructure our employee training programs to match the latest industry standards and increase the use of Confidential & Proprietary Page 1 of 8

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simulations to provide enhanced and more efficient training. We will maximize the data available to us from safety programs, train operations, field observations, and employee voluntary safety reports to better connect this data with the training we conduct. 4.3 Implement an industry leading Safety Management System (SMS) using just culture principles There are four key pillars of Safety Management Systems; Safety Policy, Hazard Identification and Risk Mitigation, Safety Assurance and Safety Promotion. The chart below describes the functions of each element.

• Objectives / metrics Training • Safety statement Communication • Program manuals Culture reinforcement • Procedures SAFETY POLICY PROMOTION

• Safety reporting RISK SAFETY • Safety investigation • Hazard identification MANAGEMENT ASSURANCE • Audit of actual • Risk mitigation operation • Evaluation of safety program • Program adjustments

A dual path SMS implementation strategy was briefed to the Board in March 2018. One path would lead to the submittal of a detailed and comprehensive SMS plan to the FRA by November 1, 2018 in accordance with our desire to be industry leading and to also be in support of our upcoming Tier III High Speed train set (Acela 21) operations. The second path was to begin implementation of critical elements of SMS to gain operational and safety benefits immediately. Over the past six months we have made progress on both paths.

The FRA rule, 49 CFR Part 270, requiring implementation of Safety Management Systems is currently stayed and our submittal of a plan will be a first by any railroad. We are working with the FRA to reach agreement on exactly what they expect to receive and are on target to submit our SMS plan by November 1. Initial reviews of the plan are complete, and we are now engaged in Amtrak stakeholder review and plan adjustment based on comments received. Stakeholders reviewing the plan include operations and labor organization leadership.

Our 2019 strategy for SMS implementation is to build upon work accomplished so far and to mature the components of each pillar. Realistically this will also be our 2020 SMS strategy. Other industry experience suggests full SMS implementation, with mature processes, is a multi-year effort. A brief description of our current progress, and key focus areas for 2019, in each pillar follows.

Safety Policy In March, the Board of Directors issued a SMS/PTC Resolution, setting the expectations of Management to achieve industry-leading performance in both areas. This resolution clearly set the expectations for our safety program and has been foundational in our activities.

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The Executive Leadership Team (ELT) revised the existing Safety Policy to reflect the principles of SMS. This policy was socialized, released, and communicated to all employees. The ELT issued its first annual safety letter which not only addressed the Safety Policy but also clarified expectations around roles of senior leadership, management, and employees in a safety management system. Going forward this letter will be 4.3 updated at the start of each calendar year to make safety an integral part of the Amtrak strategy as laid out in the Annual Operating Plan. The key principles of the Safety Policy are:

• We must be America’s safest passenger railroad. • All employees are empowered to stop an operation if an unsafe condition exists. • We will operate at the highest level of safety – by exceeding regulatory standards. • We will proactively identify and mitigate risk, based on data. • We will become a learning organization where safety self-reporting is encouraged. • We must not tolerate intentional disregard for safety or reckless behavior.

We have refocused our suite of safety metrics around Customer Injury, Employee Injury, Train Safety Index, and Trespasser/Grade Crossing Incidents. As a transportation company, Customer Injury must be the first metric we always discuss. In the last 12 months over 1,100 customers reported injuries on Amtrak and we need to redouble our efforts to reduce these injuries. Our Employee Injury metric will also include a Significant Injury Fatality (SIF) measure to focus us on those injuries with known potential to be serious.

The Train Safety Index is a new metric for Amtrak and will focus attention on safe operations of our trains. The Tier 1 metric is designed to capture events that a customer riding on the train would observe and cause them to question Amtrak’s safety. These events include fires, train separations, derailments, hitting obstructions, and other similar incidents. The Train Safety Index Tier 2 events are currently referred to as Major Operating Rule Violations (MORV). MORV is a precursor metric designed to identify and highlight issues before they become significant operating safety issues. The purpose of renaming this metric is to move away from the focus on discipline for violations and instead move toward a culture of safety, learning, and proactive continuous improvement.

Trespasser/Grade Crossing Incidents remain an important metric because, except for a major rail accident, these are the most serious and frequent incidents we encounter on the railroad. Trespasser and Grade Crossing Incidents cause numerous fatalities and serious injuries annually. Additionally, these types of incidents are highly disruptive to operations and take a significant emotional toll on our employees.

The 2019 safety metrics have been socialized and accepted by the Executive Safety Council and the ELT for inclusion in the 2019 Annual Operating Plan. In general, improvement targets of 10% over 2018 expected performance have been set for each metric.

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Table 1. FY 2019 Safety Metrics Metric FY 2018 FY 2019 Prediction Goal 4.3 Customer Injuries 20.8 18.8 Employee Injuries / Illnesses 3.8 3.4 SIF Rate 0.36 0.34 Tier 1 Train Safety Index 9.4 8.5 Tier 2 Train Safety Index 2.1 2.0 Trespasser and Grade Crossing 10.0 9.0 Incidents

In 2019 our strategy will be to mature these metrics and the business processes around them to increase visibility and focus on corrective actions. We will also expand the Train Safety Index to include more information from our voluntary safety programs and train operating data analysis.

Hazard Identification and Risk Mitigation This pillar is the engine of a SMS. It is where the primary work of identifying and correcting safety issues occurs. In 2018 we began to formalize several hazard identification processes and expanded the scope of others. Processes that gather and provide critical safety data from the operation, allowing analysis and corrective actions to occur, are essential to any safety system. A few examples of established processes are noted below.

On account of certain serious incidents, formal risk assessments were established to better understand known issues. For example, an assessment of operation in signal suspension areas was completed. We also institutionalized a new risk assessment process for significant changes in operations and for routes running over new territory. In 2019 we will continue to utilize this risk methodology as we consider the introduction of Acela 21 and additional methods to protect our maintenance of way workforce. We will also perform risk assessments as operational situations occur that demand a disciplined review.

Additionally in 2018, we added a new technique to the suite of Amtrak’s risk mitigation tools: Root Cause Corrective Action (RCCA). RCCA is a process to comprehensively determine corrective actions of known risks. Three RCCAs currently underway address train over speed, stop signal violations and electric shock issues. These will be completed in early 2019.

Today there are disparate groups throughout the company that meet routinely to address local and company safety issues. Numerous safety committees meet in the field and an Executive Safety Council meets monthly. Absent is a firm connection between these committees and an oversight and support structure to ensure safety issues are adequately dealt with or elevated for resolution with effective and prompt corrective actions. In 2019 we will be addressing this issue through establishment of management oversight tools and a System Safety Working Group process.

Safety information from employees is widely considered one of the most important tools for a company to utilize to truly understand its safety risks. To receive this information in a meaningful and timely manner requires some form of Voluntary Safety Program. In exchange for receiving the unvarnished observations from employees regarding operational safety, these programs typically offer some form of immunity from discipline for self-reported rule violations.

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Amtrak has a mixed bag of these programs. Where we have formal programs in place we have begun the effort to enhance them to receive more timely and comprehensive safety information. Amtrak’s locomotive engineer, conductor and train dispatcher labor groups have programs in place and we are working with labor leaders on determining what program enhancements are possible. Amtrak’s maintenance of way labor groups have not had 4.3 these programs in place for the last several years but we have recently reached agreement on instituting such a program. In 2019 we will focus on enhancing existing programs and starting programs where they do not exist today. Securing labor engagement is a critical component for success in this area.

Safety Assurance The safety assurance pillar of SMS provides the oversight that our safety programs are functioning as intended and serve as a check and balance function. Data and observations from operations are reviewed and checked against process expectations. We have begun to expand the way these checks are accomplished. In addition to routine safety performance reviews at the Board level and at the Executive Safety Council, we have converted our systems to reflect the new safety metrics. We have also instituted a new monthly Chief Safety Officer Safety Performance Report which includes a more comprehensive view of many measures related to safety across Amtrak. This is a work in progress and will continue to mature in 2019.

The national railroad system is a complicated system where safety infractions may occur. We have instituted a formal Accident and Incident Investigation process and have begun to use it with the more significant events we have experienced. This tool allows us to document investigation results, make recommendations for corrective actions, and then follow progress on the implementation of the corrective actions. This activity will continue to grow in 2019.

Data from observations is essential to assess effectiveness of Amtrak procedures and training. Amtrak has a sophisticated system of railroad observations called Efficiency Testing. Data is collected from thousands of observations captured each year. Unfortunately, the system to manage that data was not helpful in assessing the volume of data gathered. We recently rolled out a new system designed to better handle data management, reporting and connectivity to our training. This system, called SPARTN, went live in July and we are already seeing results that point toward where we should revise our testing program. In 2019 we will roll out further functionality and expand SPARTN to additional employees outside the population where testing is a regulatory requirement.

Today Amtrak has the capability to download operational train data from event recorders on demand. This is a critical tool in understanding what happened during an event. We can also perform these downloads in support of the efficiency testing. Other railroads, and industries, have instituted processes to automatically download operating data and perform proactive data analysis to address emerging safety issues. By aggregating and understanding common operating issues, such as speed violations at FAST Act identified speed restriction locations, we can build mitigation strategies to eliminate the number of speeding events. Other train handling issues can be analyzed in a similar manner.

Amtrak is behind in this critical process and we are working a multi-part strategy to address this issue. We are currently coding critical speed locations into our database and establishing the capabilities to get real time alerts for speed – first in the office and ultimately in the locomotive. This coded track data is critical information to assist in the analysis of operating data downloaded from the trains. We will need to build processes, and infrastructure, to analyze the large quantities of operational data in an efficient manner. We will also need to collaborate with labor and the FRA to ensure data protection and employee confidentiality are maintained.

Ultimately these processes will enable integration with other available data from voluntary safety programs, inward and outward facing cameras, dispatch, and weather to tell a more complete safety story. The aviation

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industry has even fused data from multiple carriers together to gain a more complete picture. Working with the FRA, Amtrak has volunteered to lead a pilot data sharing program on the Northeast corridor.

During 2019 we will create an Internal Evaluation Program. This is a self-assessment of critical safety programs 4.3 and an important element of any SMS. Examples of critical safety programs are: student engineer certification; dispatching; safety training programs; compliance with hours of service regulations; and rolling stock maintenance programs.

We would anticipate there being 20-30 of these programs and that they would be reviewed on a three to four year rotating cycle. Reviewing these highest-level safety programs to identify whether they are in place and functioning as intended ensures that the programs are institutionalized, consistently applied, and not dependent upon any one individual. Amtrak has no such evaluation program in place today.

Safety Promotion The purpose of safety promotion is to reinforce our desired culture. Communications and training help define how the company will execute its safety programs. A company’s culture is not what the documentation says but rather how management and employees behave as they implement and execute programs. In late 2017 the NTSB described Amtrak’s safety culture as “deficient” given the recent accidents and their root causes. They noted a lack of meaningful collaboration between management and employees as it related to safety.

The railroad industry has historically had a culture that is discipline focused. It is sometimes referred to as a “name and blame” culture. Modern safety programs recognize that this culture is not effective at reducing incidents. Often employees are reluctant to volunteer critical safety information for fear of discipline and refuse to help determine root cause and corrective actions in a collaborative manner.

At Amtrak we have identified the need to move towards a culture that recognizes that we operate a complex system and that humans are fallible and will make mistakes. Amtrak needs to become a learning organization that works to revise processes and procedures and retrain where necessary to minimize the chance of issues repeating. Employees need to be effectively coached after mistakes are made, not disciplined. It is important to note, intentional disregard for safety and reckless behavior must not be tolerated.

During 2019 we will move towards this “Just Culture.” The challenge to implementation is learning how to distinguish between an honest mistake, at risk behavior, and intentional disregard for safety or reckless behavior. Management will also need to learn and implement new business processes that will apply when evaluating errors made in operations. This will involve training at all levels of Amtrak and revisiting some existing programs such as the Cardinal Rules.

Technical training at Amtrak needs a review and refresh to ensure our programs are current with the latest industry principles. We also need to implement more business metrics and management aids to efficiently run the business.

The FRA has mandated a new regulation, Part 243, which requires safety related training courses be developed in alignment with best practices for instructional design of learning materials. In 2019 we will revamp over 100 safety related classes in concert with this requirement. We will also incorporate feedback from field data (efficiency testing and train operations) into training materials simultaneously ensuring that just culture concepts are being incorporated into all learning opportunities.

Ongoing routine communications going out through a variety of channels to reinforce Safety messages is an important feature of our SMS program. We have focused on maximizing opportunities for safety awareness Confidential & Proprietary

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communications on many fronts such as: Department bulletins and alerts, Corporate Communications (Amtrak This Week, Ink, etc.), senior leader meetings, conferences, and new ideas including a safety video contest. These activities will continue during 2019. 4.3 Be a leader in PTC implementation and assure PTC Equivalency in non-PTC territory Amtrak has been a vocal supporter of Positive Train Control for passenger operations. Amtrak’s five recent major accidents would have been prevented with functioning PTC. There is a significant Company effort to achieve compliance by the 2018 deadline; however, there will be well over 1,400 miles of track on which Amtrak operates that will not have PTC. This is track that is exempted from the PTC regulation typically due to low rail traffic volumes, but risk remains in operations without PTC.

Amtrak’s internal requirement, as outlined in the Board resolution issued earlier in the year, is to drive toward PTC or PTC equivalency in these areas. We have created, and are implementing, a risk assessment and mitigation process that will ultimately chart a path toward PTC equivalency over time. The Safety and Transportation departments, along with labor, have been performing risk assessments on every mile of track that we expect to operate on which will not have PTC. These risk assessments will outline the inherent risks on these track segments and provide the foundation for understanding the levels of risk mitigation that will be required for Amtrak’s continued operations on these non-PTC territories.

The ultimate solution for Amtrak is 100% full PTC investment across our system. Continuing into 2019 we will define and implement the specific mitigation paths towards PTC equivalency with immediate, intermediate, and long-term time frame solutions for each track segment as required. This will take time to identify, fund and implement.

Mitigations need to be developed to prevent over speed derailment protection, incursion into work zones, operation through misaligned switches, and train to train collisions. Mitigations are expected to cover a range of solutions from additional personnel in the locomotive to added signage to speed alerting to full PTC implementation.

Use data and technology to improve safety, technical training and qualification The expanding use of technology has been proven to advance safety and efficiency in operations. Advancements in materials science, computing power, real time data analytics, simulation and automation have advanced safety in automobiles, aviation, and the marine and trucking industries. Railroad safety has also benefited with PTC being the most recent example. Amtrak, however, has not kept pace with recent developments in on-board sensor technology, locomotive engineer situational awareness tools, use of simulation in training, and employing technology for advanced inspection techniques.

In 2018 we began to address this technological lag through requirements in new equipment purchases. We requested advanced sensors for determining track and catenary condition be included on the Acela 21 product. Similarly, we specified increased situational awareness capabilities on our new locomotive Request for Proposals. As these projects progress we will continue to press for inclusion of advanced technology at every opportunity.

Training, Qualification and Testing Program Modernization Technical training at Amtrak relies on a historical model of classroom training supplemented by on the job experience. While this approach certainly has a place at the railroad, we have not kept pace with technological applications in the training environment.

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The increased use of simulation for the training of locomotive engineers and conductors represents an opportunity to enhance experiences and preparedness for real world operations. This is achieved by presenting students with a variety of scenarios in a learning environment that they will not routinely experience during on the job training. In addition to enhancing initial and recurrent training, we must also improve our route 4.3 qualification training experiences.

It is imperative that we make progress toward elimination of disruptive qualification runs and regulatory efficiency testing during revenue train operations. Our ultimate objective is 100% testing and qualification through simulation, as has been accomplished in other industries. We must make an investment in more simulation tools and improve the quality, fidelity and reliability of existing simulators to achieve this objective.

Our first stumbling block is the lack of actual route software in our simulators – except for the Northeast Corridor. In 2018 we began to correct this through purchase of route software for the Pacific Northwest operations. In 2019 we have budgeted to expand this software purchase to the rest of the system as well as the necessary computing operating host software. Our goal is for all Amtrak routes to have accurate route details reflected in the simulation software. We must then build acceptable training profiles to require comprehensive simulation usage in the qualification process. Initial discussions with employees, management and FRA suggest that we will need to do considerable work to achieve cultural acceptance of this move toward more aggressive use of simulation.

Additional training simulation for Mechanical and Engineering employee training has also been built into the 2019 capital plan. This includes additional brake test simulators and maintenance of way equipment renderings for development of virtual reality and 360-degree training tools.

Implementing Amtrak’s Safety Strategy in 2019 As we work toward execution of the 2019 Amtrak Safety Strategy we will continue to make safety an ever present core value. One way to achieve this is continual visibility of progress and ensuring employee involvement at all levels.

This means daily significant safety events are reviewed by the operations leadership team; we have weekly updates on performance to both the President/CEO and the ELT and monthly updates with the Executive Safety Council. We will continue to engage labor at all levels and ensure they have input into our safety objectives. Reporting our safety performance to the Board and the Safety and Security Committee will continue to occur at each meeting.

Additionally, we are now providing regular updates to both the FRA and the NTSB. These updates are intended to not only brief on the status of our efforts but also to solicit additional input from their respective areas of expertise. We will use this opportunity with the FRA to press for a change in their compliance philosophy, moving away from a discipline centered approach to one more supportive of our just culture efforts.

Winning the hearts and minds of employees on safety will be critical to our success. In addition to training and communications, this will require a change by management in daily behavior, focus, and beliefs. To support this change, safety performance will be more strongly reflected in the compensation system reflecting industry best practice. At the enterprise level, Amtrak’s short-term incentive program will include a safety performance provision. At the management level, annual performance reviews will include a safety metric performance component.

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