FRA Rule 236.18:  Software Management Control Plan

On the 7th of March, 2005, rule 236.18 requiring the development of a software
management control plan became part of the mandate for roads under the jurisdiction
of the FRA.  In brief, the rule requires that a software management control plan that
ensures the 'proper and intended software version for each specific site and location is
documented and maintained through the life-cycle of the system' is developed and
maintained by every road.  The plan must further describe the means of assuring
configuration management in the event of replacement, modification or disarrangement
of the signal system.

Rule 234.275 states that processor controlled grade crossing warning systems also fall
under the rule provided that they provide information to signal or train control systems.

Important features of the rule are:
  • A software management plan must be in place by the 6th of December, 2005.
  • The plan must be fully implemented within 30 months of its adoption.

Roads should be sure that the plan that they adopt provides for easy maintenance and
also assures that processor controlled devices are correctly configured.  The plan
should assure:
  • that all supplier service bulletins and warnings issued against processor
    controlled devices have been identified and corrected.
  • that the proper version of all applications software is installed.
  • and that the plan provides an easy means of comparing installed software
    against future service bulletins and warnings.

These rules, 236.18 and 234.275, are requirements in addition to the new sub-part H
of rule 236.  Sub-part H deals with 'new and novel' technology.  236.18 and 234.275
deal with existing systems, that is, systems that were in production prior to June 6th,
2005.

Appendix A of Rule 236 sets out the penalties associated with 236.18:
  • Failure to develop and adopt a plan; $5000 for a violation, $10,000 for a willful
    violation.
  • Failure to fully implement a plan; $5000 for a violation, $10,000 for a willful
    violation.
  • Inadequate plan; $5000 for a violation, $10,000 for a willful violation.

Appendix A of Rule 234 sets out the penalties associated with 234.275:
  • Processor-based systems; $5000 for a violation, $7500 for a willful violation.

The Isis Solution

Isis can provide a software management control plan tailored to your operation, from a
signal department with hundreds of processor-based installations to a shortline with
one or two blocks of coded track.  

Our team can quickly identify the locations that require documentation in the plan, can
then assure that the minimum modification level of executive software is identified, and
can then help implement the plan, including options for maintaining documentation
online in an easily accessed web room.  For more information, or to discuss your
exposure under this rule, please contact us using the link below.

                                               FRA 236.18
ISIS, LLC
FRA Rule 236.18 Software Management Control Plans