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Understanding Rules Noncompliance 17 Measuring Compliance with Leading and Lagging Indicators Continuous improvement in safety-related rules compliance requires ways to monitor and measure practices that public transit agencies use to encourage safe behavior. Safety profession- als advocate that "You can't improve what you don't measure." Many safety systems, including those focused on rules compliance, focus on lagging indicators. Lagging indicators are measures of undesirable outcomes that have already occurred (Blair and O'Toole 2010). The numbers of rule violations, vehicle accidents, and injuries are examples. In contrast, leading indicators focus on activities or conditions that, if completed, will prevent or reduce the risk of lagging indicators. They help improve future performance by promoting action to correct the latent factors that cre- ate safety risks. Leading indicators focus on process and are achievement-oriented while lagging indicators are avoidance-oriented. Leading indicators include measures such as number of indi- viduals trained, number of safety meetings, number of safety-related communications, and number of reports to a safety reporting system. Safety Culture, Management, and Rules Compliance While the academic literature does not share a single standard definition regarding safety culture, researchers as well as practitioners agree that safety culture is a subset of organizational culture (see Figure 2). As such, safety culture represents that part of an organization's culture that relates to safety. Therefore, safety culture encompasses organizational structure as it pertains to safety as well as the way people think, feel, and behave with respect to safety practices (Cooper 2002). Related to the notion of safety culture is safety climate. While these two terms have sometimes been used interchangeably, they are different constructs. According to Flin, Mearns, O'Connor, and Bryden (2000), "safety climate can be regarded as the surface features of the safety culture discerned from the workforce's attitudes and perceptions at a given point in time." Given this definition, assessing safety climate provides a "snapshot" of an organization's safety culture. Safety climate assessment tools provide a way for transit agencies to measure their organizational commitment to safety. A review of the relevant safety culture and climate literature suggests that rules compliance is optimal when an organization addresses the following dimensions of safety culture (Antonsen 2009; Cooper 2002; Flin, Mearns, O'Connor, and Bryden 2000): Culture Organizational structure, Situational factors policies, procedures and ...what the organization has management systems Behavioral Management, supervisory Behavioral factors Cognitive ...what people do and employee decisions, communication and actions Situational Cognitive factors Management, supervisory and employee values, ...what people think & feel attitudes and beliefs Figure 2. Organizational culture.

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18 Improving Safety-Related Rules Compliance in the Public Transportation Industry Management and Supervision When assessing safety culture, one of the most important factors to consider is the level of com- mitment of management and supervisors to encouraging safe operations. This must be a genuine effort so that employees are able to perceive organizational commitment and internalize this atti- tude into their own set of personal values. Also, leadership style of both upper management and first-line supervisors is an important impetus for worker safety. The types of questions that formal assessment tools must answer include the following: When it comes to safe operations, do management and supervisors "walk the walk" or just "talk the talk?" Is there a consistent message regarding safety from top-level management as well as at the level of first-line supervisors? Do workers perceive that management is specifically committed to safety and in general concerned with their overall well-being? Safety System Safety culture assessments usually involve characterizing the makeup and functionality of an organization's safety system. Elements of a safety system include a safety management system (SMS), the presence and hierarchical position of safety officials, safety committees, policies, and equipment. Fernndez-Muiz, Montes-Pen, and Vsquez-Ords (2007) define an SMS as "a set of policies and practices aimed at positively impacting on the employees' attitudes and behav- iors with regard to risk." The aim of an SMS is to intervene on the circumstances that result in risks and accidents. This involves identifying and analyzing both latent and visible hazards. Bottani, Monica, and Vignali (2009) surveyed 400 manufacturing firms, some with and some without formal SMSs. The results demonstrated that the attitudes regarding several safety- related variables were better for safety officials from the companies that had formal SMSs. Further research is needed that uses process measures in addition to attitudinal ones. There have been guidelines set forth for conducting a hazard analysis for transit projects (Adduci, Hathaway, and Meadow 2000). Recently, the FTA released a guidebook describing how to implement a transit SMS (Ahmed 2011). The guidebook is an excellent source of informa- tion for public transit agencies interested in adopting a transit SMS including information regarding safety performance measurement. Many safety systems include a program for rewarding safe work practices as a means to encour- age safe behavior. Behavior-based safety (BBS) programs focus on the interaction between people and their working environment. There are functional variations of these programs with the most common using members to monitor the behavior of a workgroup and managers to monitor their own safety-related leadership behavior. The most common employee protocol involves peer obser- vation with on-the-spot feedback. However, there are reports of self-observation approaches where single operators perform their own checklists. The data is compiled over a number of self- observations and the results are used to inform training needs and other remedial action (Cooper, 2007). Self-observations are most appropriate for transit operators. However, there is no empiri- cal data to support the efficacy of the self-observation approach. Cooper (2007) presents the IDEAL components of a BBS program. They include the following: Identify unsafe behaviors Develop appropriate observation lists Educate everyone and train observers Assess ongoing safety behaviors Limitless feedback

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Understanding Rules Noncompliance 19 A safety reporting system, such as those in aviation and the railroad industry, is a proactive element of any safety system. Formalizing the safety system within an organization by means of the aforementioned elements provides protective barriers against unexpected occurrences related to safety-related rule noncompliance. These systems are reviewed in Appendix C. Work Pressure Safety-critical service industries such as public transportation must effectively balance the need for on-time performance with the need to perform safely. Assessing the tension between these two often competing goals provides a way to determine if the effects of top-level manage- ment commitment have "trickled down" to the supervisory and employee level. Sometimes supervisors and top-level management establish safety goals without consulting the workforce to determine if the goals are practical and attainable. When safety and performance compete at the level of the operator, supervisors may choose to look the other way when safety violations occur to maintain on-time performance or keep equipment in service. This in turn sends the message to employees that safety is not truly valued and sacrificing safe operations to stay on schedule is acceptable. Procedures and Rules While not traditionally part of most formal safety culture and climate assessments, the per- ceptions of and attitudes toward safety rules and procedures provide an indicator of whether or not individuals within an organization accept and value them. Rules and procedural adherence can be improved when management partners with labor to create safety rules and procedures. In essence, this process empowers individuals by giving them input to the safety system. Labor feels management respects their opinions as expert operators and they feel ownership of the rules and policies. Therefore, employees are more likely to comply. The rules and procedures in a truly resilient organization empower the employees to deal with unanticipated events. From a behavioral economics perspective, Battmann and Klumb (1993) suggested that procedural and rules violations originate primarily from the following: Unclear or conflicting rules or constraints Delayed, ambiguous, or missing feedback Absence of clear priority rules in cases of conflicts between high-level and low-level safety commitments Dekker (2003) comments that operators fail to adapt procedures when adapting is necessary, or alternatively they attempt procedural adaptations that ultimately prove futile. To improve rules compliance, organizations should avoid increasing pressure to comply. Rather, they should invest in their understanding of the gap between procedures and practice, and help develop operators' skill at adapting. Employees There are many factors related to the workforce that provide an indicator of safety culture and climate including employee competence, safety training, safety attitudes and risk-taking behavior, and job satisfaction and security. Organizations committed to safety adhere to rigorous screen- ing procedures when hiring to ensure that their employees have the required knowledge, skills, and abilities to perform their jobs. They provide exemplary training to ensure the workforce understands how to operate under both typical and atypical operating circumstances. They train the workforce to recover from unexpected occurrences as well. Finally, employees are more likely

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20 Improving Safety-Related Rules Compliance in the Public Transportation Industry to be committed to their organization's safety goals if they are satisfied with and feel secure in their jobs. Genuine management commitment to the employee fosters employee commitment to the organization. Summary Points There must be a top-level management commitment to safety that permeates the public transit agency from the top level all the way down to the employees. Safety reporting systems, hazard analyses, and safety management systems are all effective ways to improve a public transit agency's safety culture thereby improving rules compliance. Safety must be a higher priority than on-time performance at all levels of a public transit agency. The safety-related rule-making process must involve the employees who are required to follow the rules. Safety-related rules must be clear, concise, and easily understood by employees. Genuine management commitment to the employee fosters employee commitment to the public transit agency.