The document discusses a presentation given by Antea Group at a railroad conference about how the Occupational Safety and Health Administration (OSHA) regulates health and safety in the rail industry. Modesto & Empire Traction Company (M&ET) attended the presentation and subsequently hired Antea Group to conduct an OSHA assessment of their programs. The assessment found M&ET was deficient in many areas. With Antea Group's guidance, M&ET developed injury prevention, emergency response, and other health and safety programs to comply with OSHA regulations and protect employees. M&ET has made progress implementing programs but has a few remaining like job safety analyses and working at heights.

1. Antea USA, Inc.
Railroad Environmental Conference
October 23 & 24, 2018
Managing Health and Safety:
Are Your Programs Up to Date?
Jared Martin, Modesto & Empire Traction Company
Matt Carne, Modesto & Empire Traction Company
Peter T. Masson, Consultant, Antea Group

2. Antea USA, Inc.
FRA and OSHA Relationship
FRA regulates matters that relate to operational
safety (i.e. safe movement of equipment over
rails).
All other aspects will be enforced by the
Department of Labor – OSHA, where the
conditions are similar to those in any industry.

3. Antea USA, Inc.
FRA and OSHA MOA – July 16, 2012
Due to the potential overlap of jurisdiction the two agencies
entered into a Memorandum of Agreement to delineate the
areas for which each agency would assume responsibility for
the health and safety of railroad employees.
Under this agreement, each agency will "carry out their
respective statutory responsibilities independently . . . [but
recognize], that administrative efficiency and sound
enforcement policies will be maximized by cooperation and the
timely exchange of information in areas of mutual interest.“
In general, this boundary has generally be accepted to be what
occurs inside a facility, such as a maintenance garage, versus
what occurs on the tracks.

4. Antea USA, Inc.
So what got M&ET started?
In 2016 at an ASLRRA conference in National Harbor,
Maryland, we sat in on a presentation given by Annie
Richardson from Antea Group. She discussed how
OSHA plays a role in the rail industry. We met as a
team after the conference to discuss Annie’s
presentation and how we wanted to address our OSHA
concerns.
We scheduled an OSHA assessment with Antea Group a
few months after the National Harbor Conference.

5. Antea USA, Inc.
And what did we find?
From the assessment that was conducted by Antea
Group we found that we were deficient in many areas.
We simply didn’t know what we didn’t know.
Based on what we had been hearing and what we
found through our assessment, we felt obligated to
protect our employees and our assets.
The state of California typically is the “tip of the spear”
when it comes to regulations and we want to be
prepared if/when OSHA shows up.

6. Antea USA, Inc.
Plans and Programs for the M&ET
• Injury and Illness Prevention Program
• Emergency Action Plan
• HazCom
• Hearing Conservation
• Respiratory Protection (Incl. Silica Sampling)
• Various EHS (Incl. respirator fit testing)

7. Antea USA, Inc.
Lesson Learned
Through this process we have learned the following:
•Fatality can cost up to $9.2 million
•There is always room for improvement (Hazard Assessments)
•Our employees are grateful for the steps we’ve taken to
increase safety and awareness
•Anything and everything must be documented (Training)
•We’re not alone….. Antea Group has been by our side since
2014 offering 24/7 support
We’ve been in business for over 100 years and I have never seen
or heard of OSHA stepping foot on our property; however, one
accident/injury could quickly open up the door.

8. Antea USA, Inc.
Moving forward
There are only a few programs left to wrap up:
•Job safety analyses
•Working at heights
•Bloodborne pathogens
•Hot work permitting
Annual or biannual review, as needed, to ensure
compliance (OSHA and CalOSHA)

9. Antea USA, Inc.
Questions
Matt Carne, Manager of Safety & Training
Modesto & Empire Traction Co.
641 S. McClure Rd.
Modesto, CA 95353
209-576-6714
Peter T Masson, Consultant
Antea Group
505 14th
Street, Suite 900
Oakland, California 94612
Peter.Masson@anteagroup.com

10. Antea USA, Inc.
Questions
Matt Carne, Manager of Safety & Training
Modesto & Empire Traction Co.
641 S. McClure Rd.
Modesto, CA 95353
209-576-6714
Peter T Masson, Consultant
Antea Group
505 14th
Street, Suite 900
Oakland, California 94612
Peter.Masson@anteagroup.com