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APPENDIX D Rules Compliance Program Success Stories Continental Airlines Continental Airlines entered into the Aviation Safety Action Program (ASAP) in 2001. The establishment of this voluntary reporting system has proven to be a genuine success, and is fully supported by the Federal Aviation Administration (FAA), Continental Flight Operations Management, and the pilots as represented by the Airline Pilots Association. Credit should be given to all of the above participants, who established the system, as it involved a substantial amount of effort on everyone's part. The concept of a voluntary reporting system within the company's frame- work was indeed a new concept. Because of the unfamiliarity with a nonpunitive safety reporting system and the departure from a culture of blame, the involved parties had to work through their concerns to establish a high level of trust, a requisite basis of any voluntary reporting system. The operation of the ASAP system at Continental Airlines has been extremely successful, and there is no doubt that this system has made the aviation operating environment a much safer place. The system generates from 130 to 160 reports per month, and there are now over 8,600 reports in the database, arranged according to a specific taxonomy. Continental has also developed a distribution system that sends the de-identified reports to upper management and the training department. Pilots have access to the last 12 months of reporting data. Continental management personnel believe that over 95% of the data uncovered through this program would never have been reported without a voluntary safety reporting system in place. In addition, this system is responsible for analyzing why certain events take place, rather than just the documentation of a safety breach. Further, the system mandates some type of corrective action in each case. Finally, corrections to the overall airline system based on preventive actions addressing small incidents may prevent major incidents or accidents. The system has been successful because of the trust and mutual respect established among the FAA, Continental management, and the pilot's union. This has superseded the older mentality of punishment for any perceived violation of the operating rules. The employees now feel empowered to report any perceived degradation of safety without fear of reprisal, and as a result this has substantially raised the level of safety. As of August 2010, Continental also has an ASAP system with their dispatchers, maintenance personnel, and their load planners. Other employee groups will be added in the future. (Note: Continental Airlines has agreed to a merger with United Airlines, and this union is estimated to be completed during 2011.) Union Pacific Railroad and Brotherhood of Maintenance of Way Employees Division Background In May 2009, the Brotherhood of Maintenance of Way Employees Division of the International Brotherhood of Teamsters (BMWED) and the Union Pacific Railroad (UP) signed an agreement 109

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110 Improving Safety-Related Rules Compliance in the Public Transportation Industry to establish a pilot program designed to encourage employees to report rule violations and personal injuries without fear of reprisal from UP. The initiation of this program came about due to concerns from labor that employees were being pressured to not report injuries. This program has two elements: the Safety Analysis Process (SAP) and Close Call Reporting. The pilot began in December 2009 and will run for 2 years. It involves about a quarter of the BMWED-represented employees on the UP system. Based on the pilot experience, BMWED and UP will decide whether or not to continue the program and if so, whether it should be extended to all BMWED employees on the UP. David Connell, UP's Vice President-Engineering said, "Although rule compliance is the foundation of workplace safety, we believe this pilot program will take us beyond rule compliance to more of a team approach to identify and eliminate risk." (BMWED Journal, July/August 2009, Volume 118, Number 4, p. 19.) Program Operation As part of this program, UP established seven full-time safety coach positions to serve as a liaison between 2000 BMWED represented employees and UP management. Coaches listen to and convey safety concerns of covered employees to management. Organizationally, they report to a safety manager at corporate headquarters in Omaha. They attempt to resolve questions or concerns on safety-related matters and provide advice regarding improving safety performance, as appropriate. The safety coaches do not participate in any disciplinary procedures. UP appointed and trained the safety coaches prior to the start of the pilot program in December 2009. The goal of SAP is the identification and elimination of factors that lead to an incident or accident. SAP provides employees with an alternative to the discipline process. At the employee's discretion, the employee may opt for SAP, except for certain egregious violations such as use of drugs or alcohol and actions that involve willful and wanton behavior. Multiple violations of the same rule that occur within one year and result in an accident or injury are not candidates for the SAP process. When an employee chooses SAP, a labor/management team (LMT) consisting of a safety coach and a management representative meets with the employee to gather information concerning the incident. The LMT formulates a corrective action plan (CAP). The CAP may include recom- mended changes to work processes or the work environment, skills training for the employee, recommendations for rule or policy development, hazard correction, counseling of the employee, and use of the incident with others as a learning experience. The LMT must schedule a follow-up review within 90 days to ensure that the CAP has the intended impact. All SAP-related information is confidential and may not be used in conjunction with any litigation. An advisory board consisting of three BMWED officials and three UP management officials oversees the SAP. At the end of the two-year pilot period, this group will determine whether or not the program continues. Separately, covered employees may report close call incidents. Experience to Date The BMWED employees have embraced the safety coaches as indicated by a June 2010 survey designed to measure their effectiveness. Employees were unanimous in their positive ratings of the impact of the safety coaches in creating a safer workplace in the track department. BMWED officials report that letting go of the punishment mentality is key to the success of the SAP and close call reporting. Based on the survey results, the safety coaches are playing a critical role in changing this mindset. Overall SAP is working as intended. The only issue to date has been the need for a clearer definition of what constitutes willful and wanton behavior. BMWED and UP are currently

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Rules Compliance Program Success Stories 111 working on this. Through the end of October 2010, a total of 26 employees requested the SAP; four were denied as involving willful and wanton behavior. The close call hotline has had fewer reports, but this is changing as the employees develop more trust in the safety coaches. Minnesota Valley Transit Authority Minnesota Valley Transit Authority (MVTA) is a small bus operator that provides over 2 million passenger trips annually. The agency reports that it has worked very hard to create a safety-focused culture by developing a comprehensive safety program that requires each employee to put safety first. The agency constantly seeks ways to further reduce the number of safety-related incidents. A safety review in 2007 indicated that the majority of safety-related incidents occurred within three months of new bus operator training. In an effort to reduce these incidents involving recent hires, MVTA made changes to its hiring and training practices. Prior to 2008, operator candidates could have no more than three traffic citations or moving violations in the prior three years. Once employed, operators were removed from service if they received more than three moving violations or preventable accidents in a 12-month period. Beginning in 2008, candidates may have no more than three citations or moving vio- lations in the prior five years. In addition, MVTA will remove from service any operator who receives more than one moving violation or preventable accident in a 12-month period. While these changes reduced the applicant pool, MVTA found that it improved the quality of the applicants. In addition to changing hiring and retention criteria, MVTA made changes to its operator training program. Prior to 2008, the training was 62 to 70 hours. Beginning in 2008, all new hires must participate in 96 hours of training, regardless of prior experience. Included in the 96-hour training period is 5 days of cadetting. Previously only two days of cadetting occurred. During cadetting, an experienced trainer accompanies the new hire when first operating in revenue service. The trainer observes and coaches the operator and helps the new operator to deal with any problems or questions that arise. These changes in hiring and training policies have brought results. MVTA experienced a 30 percent drop in the number of safety-related incidents between 2007 and 2009 while the number of trips increased. Specifically, safety-related incidents decreased from once every 83,000 miles to once in 179,000 miles in 2009. While training costs did increase, as operator retention increased due to the higher quality hires, the annual investment in training has now leveled out. Another indicator of the success of these changes has been an increase in the number of commendations that MVTA received from patrons. MVTA recognizes employees for safe driving behavior. The agency documents a commendation from a patron with a Letter of Commendation that is placed in the employees file. Every year the agency identifies those operators who qualify for Driver of the Year. Qualification is based on a number of factors but number of patron commendations is a key factor. The drivers vote to select one full-time and one part-time Driver of the Year. The selected drivers are honored at an annual dinner. MVTA's service is through a contract provider. The contract with the service provider is lengthy because it contains extensive detail with regard to both the hiring and training standards (described above) as well as other performance standards. MVTA's staff is co-located with the contractor so they are able to oversee the contractor's operation on a daily basis and ensure that contractual standards are met. The contract also includes provision for incentive and penalty payments to the contractor based on overall performance and the contractor must use any incen- tive payments for the benefit of the drivers. For this reason, the drivers have an incentive to work

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112 Improving Safety-Related Rules Compliance in the Public Transportation Industry together to operate safely and to monitor one another for safe driving practices. MVTA feels that a detailed contract combined with intensive oversight of the contractor are key elements in achieving safety-related rule compliance when a contractor is the service provider. Schneider National Trucking Company Schneider National, employing approximately 15,000 drivers, is committed to ensuring its drivers adhere to safe operating practices. Schneider realizes it can either pay up front for proactive safety measures, or pay later (most likely at greater loss to the company) for accidents resulting in injury and claims. Therefore, Schneider considers safety to be an investment. Schneider hires inexperienced as well as experienced drivers and uses various employee screening methods. During the hiring process employees are screened for drug and alcohol offenses and their records are reviewed for moving violations. Safety-rules training for new hires is based on their previous professional driving experience. Experienced drivers receive a four- day orientation. Inexperienced drivers receive two weeks of classroom training and two weeks on-the-road training. Schneider keeps its employees informed about changes to rules during periodic safety briefings. The company takes the opportunity during these briefings to explain the safety policies it has as well as their purpose. A safety official at the company stated that people are more likely to adhere to a rule when they know the risky maneuvers the rules are designed to prevent can have dire consequences. As such, it is not enough to inform employees of safety rules, but educate them about the risk associated with precarious driving behavior. Many drivers, not just those in commercial operations, believe their driving skills are better than average so they are unlikely to be involved in accidents. Schneider tries to reinforce that accidents can happen to anyone. To reinforce safety rules retention, Schneider provides periodic refresher training. It reported providing traditional types of training, e.g., biennial spring/winter training. In the winter, specific types of safety rules can be revisited such as driving in icy weather, whereas spring training will highlight different driving challenges, e.g., fatigue resulting from the driver pushing him- or herself beyond performance limits because of the extra daylight hours. Schneider reported it is moving from these traditional types of training to more frequent CBT (as much as five times a year) along with an annual rules recertification and in-truck assessment. Schneider employs two types of drivers. Some have dedicated routine assignments while others are long-haul operators. A distributed workforce presents a unique challenge to management. It is particularly difficult to manage long-haul truck drivers and create a sense of cohesiveness among the employees. Schneider encourages individual responsibility in the form of self- monitoring. In addition, Schneider conducts periodic ride-alongs, monitor motorist reports, as well as review automated truck-handling reports. It investigates vehicle incidents and conduct root cause analysis. Schneider uses onboard monitors to measure hard braking. It calculates the average number of hard brakes per x number of operations and compares that to the average hard braking for the employee population. Schneider determines the cause of excessive hard braking when an individual's average is significantly greater than that of the employee population. Schneider has an onboard fatigue counter that measures how long a driver has been operating since the employee's last break. It also uses an onboard collision/lane departure automation tool. Schneider has an internal system for tracking incidents that involve rules noncompliance. The results are sent to the fleet manager who intervenes. Accident information is also sent to a centralized database that uses the information as risk data. Schneider conducts monthly risk assessments. It assigns severity points to at-risk individuals. It will identify 3 to 6 of these individuals and provide a group intervention including counseling and a remedial training

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Rules Compliance Program Success Stories 113 session. Then Schneider monitors these individuals to make sure they do not revert to risky behavior. Schneider engages its employees with incentive programs. There is a traditional monetary bonus program linked to safe driving, but also use non-monetary rewards like safety recognition, e.g., the CEO of the company might send a personalized letter to a valued employee. One of Schneider's most progressive philosophies is its organizational approach to safety. When asked what advice to offer the transit industry, a safety official at the company stated that rules compliance "must start with a foundation of safety culture." Management commit- ment from the top level down is the only way this can be accomplished and this is evident at this company. Metro-North Railroad FRA requirements for operational or efficiency testing apply to Metro-North Railroad (MNR) but MNR's rules compliance program far exceeds what FRA requires. MNR's rules compliance program is part of the agency's comprehensive Priority One safety program that has evolved over the past 15 years. MNR conducts operations tests in accordance with FRA regulations. The agency developed a computerized system to record test results and to identify those subject to testing. The com- puterized system not only provides the means for management to be certain of meeting min- imum testing requirements but it also provides the data for identification of rules subject to noncompliance. The railroad's Priority One program has been a work in progress. The underlying philosophy is continuous improvement, not constant change. Data, such as that generated by the operational testing program, is used to assess status, measure progress, and identify areas in need of improve- ment. There is a focus on leading indicators to identify safety risks before problems occur. Operating departments review all incidents along with test results to determine if there are any patterns to these events. There is a Priority One comprehensive communication strategy that is evident in the rules compliance program as well. MNR uses Red Alerts, such as the one shown in Figure 15, to inform employees of new rules and to use rules noncompliance incidents as a learning experience for others. The agency has also developed a series of posters to heighten awareness of rules compliance issues. Because it is difficult to determine which strategies work and which do not, MNR has tried multiple approaches to encourage rules compliance. Railroad management found that conduct- ing a crew debriefing at the end of the day's runs is an effective way to reinforce knowledge and application of its operating rules. The engineer and conductor(s) spend a few minutes with their supervisor talking about what happened that day. They focus on any unanticipated occurrences, such as a failure of in-cab signals, and how they handled them, mentioning the rules that they applied. This is now standard practice at MNR. When the agency adopts new rules that every operating employee must understand, such as the cell phone ban, the "meet and greet" method is used. Every supervisor talks with each of his/her direct reports to notify the employee and to explain the application of the new or modified rule. MNR does not have a formal safety incentive program because it believes it does not neces- sarily reinforce safety as a core value. Instead line management has the discretion to give safety recognition within the group by sponsoring a lunch or giving out caps if the group has achieved a safety milestone such as 1 year without an injury or rule violation.

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114 Improving Safety-Related Rules Compliance in the Public Transportation Industry Figure 15. Sample MNR red alert. Today MNR experiences few serious violations. The agency has worked hard to achieve this level of performance. MNR safety and rules officials attribute this success to their comprehen- sive approach to safety and rules compliance that is supported by a safety culture that comes from the top of the organization.