Under its current status as a railcar leasing company, BRL has presented plans to address these issues to ensure that they comply with applicable Russian laws and regulations, including the technical standards of the Ministry of Railways (MPS, the railway regulatory authority), the separate, state-owned Russian Railways (RZD, the day-to-day manager of the Russian railway infrastructure) and the All Russia Railway Research Institute (VNIIZHT), environmental and health and safety laws and rules and World Bank requirements. The detail about how these issues are addressed by the Company or other responsible parties is summarized in the paragraphs that follow.
- Hazardous Materials Management
Some of the company’s customers may transport chemicals and substances defined by MPS rules as hazardous, and as dangerous goods by the UN (United Nations, Transport of Dangerous Goods – Model Regulations. 12th Revised Edition. 2001). Transportation of hazardous liquids present risks during loading and loading activities, where overfilling and spillage are the largest hazards. Hazards also arise from the risk of accidents during transport of hazardous substances.
Cars and wagons are designed to meet MPS and RZD standards for the materials and chemical products to be carried. In addition, BRL’s railcar designs will be generally consistent with the UN Model Regulations. Each car will be fabricated by a government licensed manufacturer, and will have a passport, or vehicle registration certificate, confirming that the car meets all required design specifications, such as material of construction, thickness, coatings and linings, etc. In addition, cars will be equipped with appropriate safety features, such as additional safety valves, automatic coupler restraining arms, shelf couplers (to prevent separation in an accident) and end shields, and appropriate top hatch seals and bottom valve controls. As appropriate, railcars will display labels describing the dangerous properties of the goods being carried (MPS hazardous index and UN hazardous class) to allow proper handling by transport personnel or emergency services in the event of an accident. Moreover, Russian regulations require railcars to undergo regular, frequent maintenance and repair at licensed maintenance depots where the entire wagon is disassembled and worn components are replaced or brought to standard.
As a railcar leasing company, BRL currently has, and will continue to have, limited or no responsibility for managing the hazardous materials in transport. Instead, this responsibility lies with the actual carrier or operator of the railcar, from loading through transportation to unloading. The carrier will be responsible for monitoring the material during transport, such as inspecting for leaking valves in transit. Notwithstanding, BRL will ensure that the wagons it leases -- both older and newer models -- are well-maintained and meet equipment operating standards.
- Emergency Preparedness and Response
Again, owing to its limited responsibility, BRL will depend on its customers and government authorities for accident planning and response. In this capacity, the authorities will provide emergency planning and response coordination, emergency response equipment, and appropriate training of its employees. In the event of an accident, customer personnel or on-the-scene MPS staff will immediately notify MPS emergency management who in turn inform the impacted community in coordination with the Ministry of Emergency Situations (MChS). At the same time, MPS and MChS damage assessment and response teams will mobilize and respond to the damage and to eliminate risks posed within a matter of hours. MPS’ procedures also include extensive incident investigation protocols that establish the cause of the accident, impose penalties, if applicable, and identify the steps needed to prevent reoccurrence.
- Maintenance-Related Effluents and Wastes Management
BRL will outsource all applicable railcar maintenance activities at selected RZD workshops or at licensed facilities owned and operated by private contractors. The insides of the cars will be steam cleaned with aqueous-based cleaning solutions. At RZD cleaning stations, washwaters will be collected and treated in holding lagoons prior to surface water discharge in compliance with national and local environmental requirements. In some cases, railcar cleaning contractors employ more sophisticated wastewater management systems, whereby both oils and wastewaters are recycled, with zero discharge to the environment.
- Employee Health and Safety
As a railcar leasing company, BRL currently will have no employees involved in workplaces where occupational health and safety pose significant risks or concerns. Instead, such activities will be conducted by employees of responsible railcar operators and RZD or private contractor workshops, as appropriate. These parties are responsible for providing the necessary programs and protections for employees in their respective workplaces.
