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Classifying Noncompliance 31 overnight split assignment. Due to fatigue, an engineer failed to stop at the stop marker before entering a station. Factor 3. Inadequate Information and Resources A supervisor may also fail to provide the operational information that an employee needs to perform the job (e.g., fail to provide job brief). A supervisor may also fail to provide adequate staffing, thereby stretching the resources of the operational staff. A maintenance supervisor had an inadequate number of personnel assigned to perform the periodic preventive maintenance inspection for a light rail fleet. Trying to adhere to the maintenance schedule and prevent delay in operations, the inspection personnel skipped steps in the inspection checklist. One of the light rail cars had a loose bolt which caused a derailment. Factor 4. Failure to Correct a Known Problem Failing to correct a known problem is a supervisor inaction that may contribute to noncompli- ance. This occurs when a supervisor does not identify and address at-risk employees with remedial or corrective action. An example of this occurred when a bus driver was reported by peers to take risks while operating the bus (e.g., speeding, closing doors before looking to see if a passenger was still in the doorway). While aware of these behaviors, the supervisor did not coach the employee on the risks of these behaviors. The driver was subsequently involved in an intersection accident caused by the driver's failure to properly judge the speed of oncoming vehicles. In a different incident, many operators reported that a signal was difficult to see in bright sunlight but management did not take action to correct the problem until an accident occurred. Factor 5. Supervisor Rule Noncompliance Supervisors may themselves commit errors and violations associated with noncompliance that contribute to their subordinates' lack of compliance. This may include authorizing employees to break the rules and failing to enforce rules or regulations. An incident occurred when a supervisor authorized an employee to break the rules. A bus supervisor emphasized schedule adherence as the most important goal, even at the expense of maintaining a safe operating speed. The bus driver was later involved in an accident where speeding by the bus operator was cited as the probable cause. In another incident, a track maintenance supervisor failed to ensure that the rail was prop- erly secured prior to authorizing a train to travel through the work area. The train passed over the loose rail and derailed. Table 4 lists the factors associated with Level III of the taxonomy. Level IV: Organizational and Regulatory Factors The decisions and policies of upper management and regulatory agencies directly influence public transit supervisor practices. As such, they can directly contribute to incidents or accidents stemming from rules noncompliance. Contributing to these factors are economic challenges that wax and wane over time. During times of economic prosperity, public transit agencies may be able to satisfactorily bal- ance the requirements associated with safe operating practices with the performance goals of the agency (e.g., customer satisfaction and on-time performance). Historically, when economic con- straints come into play, commitment to safety often takes a back seat to performance goals. This has a trickle-down effect to first-line supervisors as well as front-line employees. During times of economic hardship, cutbacks in staffing, training, incentives, and maintenance often lead to

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32 Improving Safety-Related Rules Compliance in the Public Transportation Industry Table 4. Supervisory factors (Level III). Category Examples Inadequate oversight Failed to provide guidance Failed to provide training opportunities Poor leadership Lack of oversight Failed to monitor employee qualifications Failed to track performance Provided inadequate opportunity for Inadequate work schedule employee rest Inadequate information/resources Failed to properly brief employee Failed to give the employee necessary information Provided inadequate staffing Failure to correct known problem Did not call out at-risk employee Did not report unsafe tendencies Did not initiate remedial or corrective action Supervisor rule noncompliance Authorized employee to break the rules Failed to enforce rules or regulations Allowed unqualified employees to perform job an overworked, less motivated, and less qualified staff operating suboptimal equipment. This scenario, when combined with an organization that values performance goals over safety, may lead supervisors and their employees to break safety-related rules, resulting in an accident. The factors in this category include those of resource and acquisition management, organiza- tional climate, an organization's operations, and regulatory influences. Factor 1. Resource and Acquisition Management This factor includes the acquisition and management of public transit employees, equipment, and facilities. Resource management may involve human resources, monetary or budget resources, and equipment and facility resources including maintenance. With respect to the latter two contrib- utors, budget restrictions may prevent a public transit agency from replacing old equipment that require extra maintenance and repairs. As a result, there is more opportunity during the main- tenance process for errors that may lead to equipment failure. Factor 2. Organizational Climate Organizational climate can generally be regarded as the working atmosphere within an organiza- tion. Safety climate is the collective values of management, supervisory staff, and employees as they relate to work safety at a given point in time. Alignment of an organization's formal safety policies, procedures, and rules with the informal values, beliefs, and attitudes of an organization's management and staff is a predictor of a positive safety climate. However, when upper level man- agement claims to embrace an organization's safety policies (i.e., talk the talk) only to overlook those same policies behind the scenes (i.e., failing to walk the walk), erosion of the organization's safety climate occurs. Organizational structure in a public transit agency may contribute to climate erosion when the agency's safety management personnel are not represented at every level of the organization. An agency's safety policies as well as their safety culture may also contribute to noncompliance. In organizations entrenched in a culture of blame, there is often no attempt to identify risks before an incident occurs. Instead of being proactive and preventive, the managers in this type of environ- ment are reactive, looking to blame an employee when there is noncompliance or an accident.