Locomotive Emissions Monitoring Program - Railway Association of ...

Appendix G
Railway Association of Canada Management Plan for Responding to Audit of
the 2007 Locomotive Emissions Monitoring Program Report
Listed below are the recommendations extracted from the Audit report of the 2007 Locomotive Emissions Monitoring
(LEM) Program report. Corresponding to each recommendation is the action that the Railway Association of Canada
(RAC) will take.
Non-Conformities
NC-01
Recommendation:
Supporting documentation for these data must be retained by the RAC members submitting data for inclusion in
the LEM Reports and internal controls for the documentation must be strengthened to allow for the records to be
readily identifiable, traceable and retrievable. Records of the original data used for the LEM Reports must be legible,
adequately protected, retained for a suitable period of time and disposed of in an appropriate manner.
RAC consultants should cross-reference the accuracy and completeness of the locomotive retirement data
submitted for the LEM Reports against other relevant sources.
Management Plan:
The RAC will request the following actions of RAC member railways:
• Retain supporting documentation of the data they submit for inclusion in the LEM Reports;
• Strengthen internal controls for the documentation to allow for the records to be readily identifiable, traceable
and retrievable.
• Records, of the original data used for the LEM Reports, be legible, adequately protected, retained for a suitable
period of time (five years) and disposed of in an appropriate manner.
• Request data, such as the year end locomotive inventory, prior to sending out the full RAC Trends Survey in order
to give the consultants, who prepare the LEM report, additional time to review, analyze, and organize the data.
The RAC will direct its consultants to take the following action:
• Cross reference the accuracy and completeness of the locomotive retirement data submitted for LEM Reports
against other relevant sources.
Opportunities for Improvement:
OFI-01
Recommendation:
RAC should establish a firm cut-off date for receipt of data from RAC members and include a note
in the corresponding LEM Report that missing data were not received by the cut-off date.
RAC should strengthen communication of expected timelines for the project and expectations to RAC members,
prior to sending out the surveys. RAC MOU Management Committee as well as RAC MOU Technical Review Committee
meetings may be an opportunity to address this.
59 LEM 2008