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Safety, Security and Emergency Management

Introduction

On July 19, 2018, the Federal Transit Administration (FTA) published the Public Transportation Agency Safety Plan (PTASP) Final Rule that required Section 5307-funded urban transit systems to develop safety plans that include the processes and procedures to implement Safety Management Systems (SMS). Under current rules, Section 5310 and/or 5311 funded agencies are not required at this time to develop an FTA-compliant safety plan.  However, the SMS and safety plan elements presented in this section of the toolkit should be considered as best practices for Section 5310 and/or 5311 funded agencies. Additionally, State DOTs may have established safety program requirements for Section 5310 and/or 5311 subrecipients in the state.

Safety is the Number One priority for a Transit Manager!  A manager is not typically driving a bus, fixing buses or scheduling customer rides, but their responsibility for system safety should guide their decision-making in all aspects of leading and modeling a culture of safety.  The Transit Manager works with the board and leads the employees in the performance of quality service and general morale.  That influence extends to making safety and security the highest priority.

This section of the toolkit is organized into the following subsections:

The Role of the Accountable Executive / Chief Safety Officer

The top executive (usually the Chief Executive Officer or General Manager) of a transit agency shoulders the responsibility, as required by FTA’s Safety Management System (SMS) model, for duties of the Accountable Executive.  The Accountable Executive will be the person who interacts with the board and executive leadership on plans, policies, purchasing decisions and daily operations that impact safety.  The Accountable Executive must also constantly remind employees that safety is the highest priority.  A simple message, Safety Ahead of Schedule, must be the guiding principle articulated to all employees.  

It is a basic management tenet that accountabilities flow from the top down.  While the SMS model requires that safety accountability resides with the Accountable Executive of the transit agency, the agency’s Board of Directors or other governing body must also play an integral role for establishing a foundation for safety management.  The SMS model defines the Accountable Executive as the individual with the ultimate authority and accountability for a transit system’s day to day operations.  The Accountable Executive plays a central role in the development and implementation of safety plan activities consistent with the SMS model.  It is typically at this level that safety objectives, safety performance targets, purchasing decisions and operating budget decisions are made that support safety initiatives.

The Accountable Executive also needs to designate a Chief Safety Officer, who will typically oversee key safety functions.  Depending on the size of the organization, the Chief Safety Officer may be a stand-alone position or additional duties assigned to an individual in another position.  Within the organizational structure, the Chief Safety Officer must report directly to the Accountable Executive for all safety concerns.

As noted in the January/February 2019 FTA Transit Safety and Oversight Spotlight newsletter, the rule also says that a transit agency may allow the Accountable Executive to serve as the Chief Safety Officer.  However, the Chief Safety Officer may not serve in other operational or maintenance capacities unless the agency is a small public transportation provider as defined by the PTASP rule (100 or fewer revenue vehicles in peak service and without rail service).

The Chief Safety Officer may vary from agency to agency, but in general, they manage the transit agency’s safety function such as compliance with federal, state, and local regulations, and overseeing safety requirements for transit projects. Duties might also include hazard management, accident investigation, coordination with the State Safety Oversight Agency, and safety certifications.

Each agency may choose which type of training the Chief Safety Officer will complete to qualify as “adequately trained.” The Community Transportation Association of America (CTAA) offers a Certified Safety and Security Officer (CSSO) program that is geared toward rural transit agencies.

Safety Management System (SMS) Framework

Moving Ahead for Progress in the 21st Century (MAP 21)

Moving Ahead for Progress in the 21st Century (MAP-21) was enacted In July 2012.  The law guided spending and granted FTA authority to establish and enforce a new comprehensive framework to oversee the safety of public transportation throughout the United States.  The authority granted FTA continues in all current and future federal transit funding.

A National Public Transportation Safety Plan was published in January 2017 in the Federal Register.  The NTPSP provides guidance for improving transit safety performance, samples of agency’s safety policy statements, communications tools, and provide updates for standards, best practices, tools, technical assistance, and other trending resources. 

FTA released the final rule in July 2018 on the Public Transportation Agency Safety Plan (PTASP) requirements.

The National Public Transportation Safety Plan (NPTSP)

While the National Public Transportation Safety Plan (NPTSP) does not include any mandatory requirements, it does require performance targets for systems that receive federal financial assistance including:

  • Fatalities – total number of reportable fatalities and rate per total vehicle revenue miles by mode
  • Injuries – total number of reportable injuries and rate per total vehicle revenue miles by mode
  • Safety Events – total number of reportable events and rate per total vehicle revenue miles by mode (typically reported safety violations, customer safety related complaints, employee close call / near miss reporting, etc.)
  • System reliability – total number of reportable events and rate per total vehicle revenue miles by mode (typically road calls and mechanical failures)

Thresholds for reportable fatalities, injuries and events are defined in the National Transit Database (NTD) Safety and Security Reporting Manual (downloadable through the FTA NTD Manuals web page.

The Final Rule on the PTASP includes the following definitions:

  • Accident - an event that involves any of the following:
    • loss of life
    • report of a serious injury to a person
    • collision of public transportation vehicles
    • runaway train
    • evacuation for life safety reasons
    • derailment of a rail transit vehicle, at any location, at any time, whatever the cause
  • Incident - an event that involves any of the following:
    • personal injury that is not a serious injury
    • one or more injuries requiring medical transport
    • damage to facilities, equipment, rolling stock, or infrastructure that disrupts the operations of a transit agency
  • Event – an accident, incident or occurrence

The Public Transportation Agency Safety Plan (PTASP)

The July 2018 Public Transportation Agency Safety Plan (PTASP) Final Rule (49 CFR Part 673) applies to recipients or sub-recipients of funding under 49 U.S.C. 5307 that operates a public transportation system.

  • Section 5307 funded agencies operating 100 or fewer revenue service vehicles in peak service (small urban transit systems) are required to develop an FTA compliant agency safety plan.
  • Small urban systems may use their State DOT to draft and certify their plan or may develop and certify their own plan.
  • Section 5307 funded agencies operating more than 100 revenue service vehicles in peak service (large transit systems) are required to develop their own FTA compliant agency safety plan

The PTASP must:

  • Be approved by the agency board of directors or equivalent authority by July 19, 2020 
  • Be based on the Safety Management System (SMS) approach
  • Contain performance targets based on safety criteria established under the National Public Transportation Safety Plan
  • Establish a process for annual review

Section 5310 and/or 5311 funded agencies are not required AT THIS TIME to develop an FTA compliant safety plan. The safety plan requirements for 5307 systems should be considered as best practices for 5310 and/or 5311 funded agencies.

FTA has developed a Public Transportation Agency Safety Plan for Bus Transit Template, which outlines the requirement of an FTA compliant plan.

The Safety Management System (SMS) – A Brief Overview

SMS is about strategically applying resources to risk.  To do this effectively, the organizational structure includes these elements:

  • Defined roles and responsibilities
  • Strong executive safety leadership
  • Formal safety accountabilities and communication
  • Effective policies and procedures
  • Active employee involvement
  • Scalable to the size of the transit agency and complexity of the service delivery model

Key SMS activities:

  • Collecting and analyzing safety data to proactively identify hazards
  • Taking actions to mitigate the risk associated with the potential consequences of hazards
  • Ongoing monitoring of risk through a system of safety controls
  • Using data to support allocation of resources that promote and support safety performance

Key features of SMS:

  • Accountability for the management of safety at the highest level of the transit agency
  • Collaboration between management and labor to ensure agreement on safety risk priorities
  • Structure and strategic decision making for safety resource allocation
  • Enhanced service safety performance through proactive safety risk analyses
  • Increased confidence in safety risk controls through safety assurance
  • Partnership and knowledge sharing between public transportation agencies, state agencies and FTA
  • A positive safety culture that supports safety communication and hazard reporting

The role of senior management in SMS:

  • Senior management understands and accepts its role of accountability in promoting safety and managing the transit agency safety program
  • Senior management ensures employee partnership and participation on all safety matters
  • Safety Officer / Manager provides ongoing communication about the SMS to all employees

SMS and the current safety structure:

  • Builds on existing transit agency resources, both human and technical, and refocuses activities to more effectively use these resources
  • Ensures that safety decision-making is integrated into the management processes that drive the organization

Working with public safety and emergency preparedness, SMS:

  • Integrates public safety and emergency preparedness information into the assessment of risk
  • Helps management and employees understand their total safety risk exposure and allows for resources to be applied strategically and effectively

SMS and safety culture:

  • Facilitates a shift in attitudes for both management and employees concerning the importance of safety in day-to-day activities
  • Emphasizes safety training and communication throughout the entire transit agency to ensure safety policies and procedures and hazard reporting needs are understood and
  • Encourages management and employees to work together to identify and mitigate safety risk
  • Encourages employees to routinely report close calls and near misses with the understanding that positive actions will be taken by the agency to reduce potential negative outcomes
  • Prioritizes safety related complaints by passengers and those in the community with the understanding that positive actions will be taken by the agency to reduce potential negative outcomes

Safety Management System Overview – 4 Pillars

SMS is composed of four functional components:

  1. Safety Policy
  • The foundation of a safety management system
  • Clear objectives and procedures to accomplish objectives
  • Defines roles of management and employees
  1. Safety Risk Management
  • Processes and procedures for identifying hazards or potential hazards
  • Collection, analysis and assessment of risks for hazards
  • Measures to reduce or eliminate risks
  1. Safety Assurance
  • Ensures performance and effectiveness of safety risk measures developed under safety risk management
  • Ensures continuous collection, analysis and assessment of performance data to meet or exceed safety objectives
  • Monitors and inspects activities to support oversight and performance
  1. Safety Promotion
  • Includes training and communication of safety information
  • Allows a process for employees to communicate safety concerns without fear of retribution

Safety & Overarching Theme

Throughout all phases of SMS, there are four important questions that should be driving your process.

  1. What are your agency’s most serious safety concerns?  (Risk)
  1. How do you know this?  (Data)
  1. What is your agency doing about it?  (Resources)
  1. Is what your agency doing working?  (Trending)

As you review, revise and develop your internal safety policies and procedures, you need to ensure that whatever you have in place effectively leads you to the answers of these questions.

Manager’s Role in Overseeing Daily Vehicle Operations

While a Transit Manager may not directly supervise daily vehicle operations, they lead the management and operations team in its commitment to safety, security and the agency’s role in emergency management.  The Manager influences and guides the transit system’s employee relations, safety plans and policies, safety committees and meetings, and customer service. The management team shows commitment to safety by example and innovative initiatives to encourage safety procedures and implementation.

The Transit Manager will monitor daily operations through the managers and supervisors in each department of the agency.  The Manager’s role is to ensure that policies, procedures, training, recordkeeping and monitoring is in place in four critical areas:

  1. Vehicle safety –

The Transit Manager

  • Ensures regular vehicle maintenance
  • Ensures preventive vehicle maintenance is following bus manufacturers recommendations  
  • Oversees the on-sight maintenance shop, sub-contracted vehicle maintenance at independent garages, and/or vehicle maintenance performed by any sub-contractors
  1. Driving safety –

The Transit Manager

  • Ensures that hiring managers conduct appropriate background checks and ongoing Motor Vehicle Report monitoring of all bus operators
  • Ensure that training is in place for new hires as well as veteran bus operators
  • Ensure that all policies and procedures are being followed on a daily basis
  • Ensures that bus operators receive initial and ongoing training to include, at a minimum:
  • Pre-trip inspection
  • Defensive driver training
  • Drug and alcohol awareness
  • Responding to onboard emergencies, including safe evacuation
  • All policies, procedures and practices of the agency

*There are many training programs available through local and national organizations and private companies.  The National RTAP START safety training module and 2 the Point Training Cards provide high quality training material that can assist in the recommended training.

  1. Passenger safety –

The Transit Manager

  • Ensures that all bus operators receive training in:
    • Customer service
    • Safe boarding and de-boarding of ambulatory passengers
    • Passenger assistance training including safe boarding, de-boarding and onboard securement of passengers who use mobility devices
    • Ensures that there is a method to mitigate hazards that could impact passenger safety
    • Ensures that there is a method to deal with passenger incidents or accidents
    • Ensures all public health concerns involving passengers are addressed
  1. Emergency procedures –

The Transit Manager

  • Ensures the development and review of documents, protocols and procedures as well as proper training and practice for emergency situations including:
  • Hazardous weather
  • Onboard accidents and incidents
  • Vehicle evacuation
  • Facility evacuation
  • Onboard conflict
  • Vehicle accidents
  • Vehicle or facility fire
  • Community evacuation
  • Ensures that communications and are open and there is cooperation between the transit agency and emergency personnel (local, county and state)
  • Is knowledgeable of the National Incident Management System (NIMS). The website offers free, online training courses.

Manager’s Role in Security Awareness

The Transit Manager needs to ensure during this era of increased criminal activity and drug use, heightened national security, and greater technical piracy, that all employees are trained to be the eyes and ears in the community.  A system for “if you see something, say something” should be in place for employees and passengers to report suspicious people, activities, vehicles, packages, objects, and behaviors that could pose a potential security risk or incident.  All employees should be trained in BOLO (Be On the Lookout) and know who to tell when identifying someone or something suspicious.  In addition, with the advent of smart phones, applications have been created for the public to photograph and report anything suspicious.

Manager’s Role in Emergency Management

The Transit Manager needs to be aware that the transit system will work with the community first responders in the event of a local, state or national crisis.  This could include evacuating residents during events ranging from severe weather to criminal or terrorism activities within their community.  The agency must have in place protocols to deal with accidents, evacuation, relocating vehicles, body fluid spills, sick or ill passengers, smoke or fire incidents both onboard the buses or any facilities owned by the transit system.  One of the key steps to ensure that the transit system is working in harmony with local emergency management is active participation in the Local Emergency Planning Committee (LEPC).  This group, typically under the authority of the county Emergency Manager, meets regularly to plan and practice emergency response.  The Manager should also ensure that a relationship is established with local police and fire personnel who should be familiar with the transit agency’s facilities and vehicles to allow for quicker action in the event of emergencies.

Section Sources

Updated May 1, 2019