BNSF Contractor Safety + Roadway Worker Protection (RWP)

🏗️ 1. BNSF Safety Foundation

The BNSF Contractor Safety Action Plan is a location-specific plan that carries out the elements of our company's overall Safety Management System on the BNSF site we're working. Every contractor employer has to make sure those plans are communicated, followed, and enforced for every job.

The single most important phone number on BNSF property is the 24-hour BNSF Emergency Number: 1-800-832-5452. That number is the same nationwide. It's posted at every BNSF project location. Memorize it or save it to your phone before you set foot on the property.

If anything goes wrong — incident, injury, near-miss, chemical spill — you call that number AND notify the BNSF Project Representative. Reporting is not optional. It's not something to handle later. It's immediate.

BNSF property is a zero-tolerance zone for drugs, alcohol, and weapons. Show up under the influence, with prohibited substances, or with any weapon, and you're removed from the site. No second chances. This is a federal-railroad-property rule, not a soft policy.

📝 2. Job Safety Briefings

Before ANY work begins each day, the crew holds a Job Safety Briefing. It covers today's work scope, today's hazards, today's controls, today's emergency procedures, and who is responsible for what. The point is: nobody steps onto the site uncertain about what's happening.

The briefing is NOT about scheduling next week's job. It's about today. Anything further out is a separate planning conversation.

For on-track safety briefings specifically, the briefing is only complete when each roadway worker acknowledges they understand the protection in place. Not when the EIC finishes talking. Not when somebody nods. Each worker says back what the protection is — that's when it's done.

🦺 3. PPE & Personal Safety on BNSF Property

The minimum PPE every contractor employee wears on BNSF property is: hard hat, safety boots, safety glasses, and a safety vest. That's the baseline — additional PPE may be required for specific tasks (FR clothing, fall protection harness, hearing protection, respirator), but those four items are non-negotiable just to be there.

Sunglasses are not PPE. They're comfort items. Don't confuse them.

Three-point contact means three of your four limbs are in contact with the equipment at all times when getting on or off. Two hands + one foot, or two feet + one hand. Hop out of a truck cab with both hands occupied? That's how guys break ankles. Three-point, every time.

Seat belts must be worn whenever you're driving OR riding in a moving vehicle on BNSF property. Driver, passenger, hi-rail, pickup — doesn't matter. Belts on.

🔒 4. Housekeeping, Tools, Energy Control (LOTO)

Good housekeeping on a BNSF site means: clean walking paths, proper material storage, no tripping hazards, no debris left where someone could fall. All of it. It's not one thing — it's the whole picture.

Out-of-service tools are off-limits. Doesn't matter how quick the job is. Doesn't matter how simple. If a tool is tagged out of service, it doesn't come back into service until whoever tagged it clears it. "Just this one time" is how people lose fingers.

Slings and rigging are not on a weekly inspection schedule. They get inspected before every use. Every time. A sling that looked fine yesterday could have a cut, kink, or shock-load damage that wasn't there before.

Lockout/Tagout (LOTO) applies when work could expose you to stored or uncontrolled energy — electrical, hydraulic, pneumatic, mechanical, gravity. ALL energy sources must be isolated, locked out, and verified zero-energy before work begins. And the lock goes on by the authorized person performing the work — not the foreman, not a coworker. The person whose hands are at risk owns the lock.

Portable fire extinguishers get visual inspection monthly at a minimum. Look at the gauge, check the pin, check for damage. Annual inspection is the formal one, but monthly is what catches a discharged unit before you need it.

Arc flash can be caused by short circuits, accidental contact with energized parts, equipment failure, dropping tools into live gear — basically any path that lets current arc through air. The energy release is faster than you can react and hot enough to kill. Treat every electrical job as if arc flash is possible until you've proven otherwise.

⚠️ 5. Hazmat, Confined Spaces, Excavation, Electrical Clearance

Every chemical on site must have a Safety Data Sheet (SDS, formerly called MSDS) available with the work group. Not back at the office. Not in a binder somewhere. With the crew that's exposed.

A confined space is defined by all three of: limited or restricted means of entry/exit, large enough for a worker to enter and perform work, AND not designed for continuous human occupancy. All three have to be true. If any one of them isn't, it's not a confined space — but if all three are, treat it with the full permit/atmospheric-testing/rescue-plan protocol.

Overhead power lines of unknown voltage: stay at least 45 feet away from the line — equipment, boom, load, any part of you. If you know the voltage, OSHA tables spell out smaller distances, but if you don't know, 45 feet is the safe default.

Before any digging or excavating on BNSF property, you check with the BNSF Project Representative AND the local one-call utility locate agency. BNSF has signals, fiber, drainage, and signal cable buried in places you wouldn't guess. ND One Call is required by state law for utility locates; the BNSF Project Rep is required by BNSF rules. Both, every time.

🪢 6. Fall Protection

Personal fall arrest systems get inspected before each use. Not quarterly. Not monthly. Every single time you put it on. Look at the harness webbing, the D-rings, the buckles, the lanyard, the shock absorber, and the connector. Any cut, fray, burn, chemical exposure, deformed hardware, or activated shock pack? It's out of service. Tag it and replace it.

Body belts cannot be used as part of a personal fall arrest system. Period. A body belt distributes fall forces to the abdomen and lower back, which causes internal injuries on arrest. Personal fall arrest requires a full-body harness with the D-ring between the shoulder blades.

Railroad bridge fall protection requirements vary by BNSF Department. Some departments require fall arrest above a certain height; others have different controls. Don't assume — confirm the specific requirement with BNSF for your project.

If you're working over or adjacent to water deeper than 4 feet (or where drowning is a risk) without fall arrest gear, you need a Coast Guard-approved life vest, a lifesaving skiff nearby, and a Coast Guard-approved life ring within reach. All three, not one of three.

🚂 7. RWP Foundation — On-Track Safety Basics

Roadway Worker Protection (RWP) training must be renewed annually. It's not a one-and-done card. Every year, every covered worker re-certifies.

The cardinal rule of railroading — say it out loud, then again: "Always expect a train or equipment to move on any track in either direction at any time." Any track. Either direction. Any time. Even tracks that "haven't had a train through in years." Even on a Sunday at 3am. The moment you stop expecting a train is the moment one is on top of you.

"Fouling" the track means being within 4 feet of the field side of the nearest rail. That's the danger zone. Anyone in that zone — person, tool, equipment, vehicle — is "in the foul" and at risk of being struck.

Working within 25 feet of the centerline of a track requires you to have completed RWP training. Doesn't matter what you're doing — if you're in that 25-foot zone, RWP applies.

Per the FRA, when you're in the foul, the immediate hazard is: a person or equipment could be struck by a train or on-track equipment. That's why RWP exists — to keep that from happening.

Who is a roadway worker? Any contractor employee whose duties for a railroad client may require them to foul a track. That includes the people doing the actual rail work, AND the survey crews, equipment operators, and anyone else whose work scope can put them in the foul zone.

Roadway workers must verify on-track safety is provided BEFORE they foul the track — not after, not during. Before.

A roadway worker only fouls a track when necessary for the performance of duty. Not to take a shortcut, not to grab a tool, not because it's closer. Only when the work itself requires it.

👷 8. EIC, On-Track Briefings, Right to Challenge

The EIC (Employee In Charge) is the qualified person responsible for on-track safety on a given job. They must be trained in the General Code of Operating Rules (GCOR) — the rulebook for railroad operations. The EIC owns the on-track safety briefing, the establishment of working limits, and the method of protection chosen.

Every roadway worker working in the fouling space must: know the type of on-track safety provided, avoid fouling unless safety is in place, participate in the daily on-track safety job briefing, and know who the EIC is. They are NOT required to be trained in the GCOR themselves — that's on the EIC.

Every roadway worker has the Right to Challenge. If you believe the on-track safety in place is wrong, unsafe, or being violated, you stop work and report it. You report it to the EIC first — that's who controls on-track safety on the job. If the EIC won't resolve it, escalate up the chain — but the first stop is the EIC.

The method of on-track safety chosen depends on: the work being performed, the type of track, the weather, and the physical characteristics of the track. All of the above — no single factor decides. The EIC picks the right method for the specific job.

🛤️ 9. On-Track Safety Methods

There are several methods to keep roadway workers safe from trains. The most relevant ones to know:

• Train Approach Warning (TAW) — a watchman/lookout watches for trains and gives the crew enough warning to clear to a place of safety. Requires a dedicated lookout whose only job is watching.
• Working Limits — the EIC takes control of a segment of track so trains can't enter. On controlled track, this requires physically preventing trains/equipment from entering (installing a derail, opening a switch, creating a discontinuity in the rail).
• Foul Time — track is granted to the EIC by the dispatcher for a specific time window.
• Exclusive Track Occupancy — the EIC is the only one allowed to occupy the track segment.
• Individual Train Detection (ITD) — used in limited circumstances; the worker watches for trains themselves while working alone.

When the Train Approach Warning method is used, every roadway worker must be able to clear the track and reach a predetermined place of safety at least 15 seconds before the train arrives. That's the regulatory minimum — practically, you want more.

Working limits are required any time work may delay or stop rail movements, any time workers or equipment can't immediately get clear, OR any time physical conditions compromise sightlines or the ability to clear. All the above — they're overlapping conditions.

If a project involves equipment working in the foul, you can't rely on TAW or ITD — you must use working limits on controlled and non-controlled track. Equipment is too big and too slow to clear; you have to keep trains out instead.

Adjacent tracks are tracks with track centers spaced less than 25 feet apart. If the centers are within 25 feet, anything you do on one track can affect the other. Treat them as one safety zone.

To initially report a severe hazard over the radio, the call begins with: "Emergency, emergency, emergency." Three times. That phrasing clears the channel and signals to everyone listening that this is an emergency call, not routine traffic. Same urgency function as "Mayday" in marine — different word in rail.

Walking around on the track surface? The safest path is on the ties between the rails when you have safe sight distance. Don't walk or step on the rail itself (slippery, can twist an ankle). Be aware ballast is uneven and can hide sharp objects. Cross tracks quickly and perpendicular — don't linger in the foul.

📏 10. Work Zones, Markings, Equipment Spacing

A work zone isn't just the immediate spot you're working — it extends 25 feet longitudinally past the front and rear of any on-track equipment. So if you have a hi-rail and a piece of equipment on the rail, the zone is the length of both plus 25 feet on each end.

Orange safety fence on a BNSF site marks the work zone boundary. Minimum distance from the nearest rail: 10 feet. Closer than that and the fence itself can foul the track or be struck.

On-track work equipment traveling under their own power — there is NOT a flat 50-foot spacing requirement between units when traveling. Spacing depends on conditions, visibility, and the controls set by the EIC and dispatcher. The myth that it's always 50 feet is wrong.

When passing in front of standing on-track equipment, maintain at least 25 feet of clearance. The equipment may move with little or no warning — you don't want to be in its path.

📦 11. Intermodal & Automotive Facility Safety

BNSF's intermodal (container) and automotive (vehicle haul) facilities have specific safety rules in addition to the general BNSF Employee Safety Rules. They're a high-traffic, high-equipment environment. Different hazards than open-track work.

Anyone pulling an oversize, high, wide, or specialized load through a BNSF facility must follow all applicable rules — permits, escorts, route confirmation, clearance measurements. All the above. Skipping any one is how loads catch on bridges or wires.

If a load shifts while pulling a unit: gradually slow down, lower the fifth wheel, stop your tractor, and call a supervisor. Don't try to muscle through it. Don't make sudden moves that could turn a shift into a rollover.

No container, chassis, or trailer movement is worth rushing if rushing it could cause injury. The clock will wait. The injury won't un-happen.

Lift operators must stop all movement immediately if they lose visual contact with the ground person. The ground person is the second set of eyes. Lose them, and the operator is operating blind to half their hazards.

If you accidentally lift a railcar off its center pin, notify your supervisor immediately. Do NOT keep moving or try to set it back yourself. A railcar off its pin is unsafe until it's been re-set by qualified personnel.

On an ALI (Automotive Loading Indicator), a green light means all bridge plates have been placed, verified, and vehicle movement on the railcar is safe. Red or no light, you don't move.

Workers may NEVER occupy a loading/unloading ramp while it's being moved. Only the operator is allowed on the ramp while it's in operation.

Before moving a no-start vehicle (won't crank, dead, broken-down) on a facility, all workers must hold a Job Safety Briefing with the supervisor to determine what will be done and who will do it. No-start moves are deceptively risky — the vehicle has no brake assist, no power steering, and the people pushing/winching it are exposed.

Only ONE vehicle is allowed on a loading/unloading ramp at a time. Not two, not "just for a second." One.

⚖️ 12. Authority & Responsibility

When you're a contractor working for a railroad client like BNSF, you have three overlapping sets of rules to meet: FRA (Federal Railroad Administration — the federal rail regulator), the Railroad Client (BNSF's own rules layered on top of FRA), and OSHA (federal workplace safety). All three apply at the same time. When they conflict, the strictest rule wins.

Ultimately, the person responsible for following client-specific safety requirements is the employee. Not the EIC. Not the supervisor. Not the Project Manager. The individual employee owns their own safety conduct on site. Supervisors enforce, train, and correct — but the person who has to follow the rule is the person standing there. Knowing the rules is part of being a professional.

🎯 Bottom line

BNSF property is one of the highest-stakes work environments we send crews to. The rules feel like a lot because they are — but every single one of them exists because somebody got hurt or killed not following it. Every. Single. One.

Three things to take home from this meeting:

1. Always expect a train. Any track, either direction, any time. The day you stop expecting one is the day one is coming.
2. 4 feet is the foul. 25 feet is RWP. 10 feet is the fence. 45 feet is the unknown power line. Memorize those four numbers.
3. You have the Right to Challenge. If something looks wrong on a job, stop. Report to the EIC. Don't go along because everyone else is going along. That's how serious incidents happen — people staying quiet when their gut says no.

Sign the sheet on the way out. Get home tonight.