National Academies Press: OpenBook

Improving Safety-Related Rules Compliance in the Public Transportation Industry (2011)

Chapter: Chapter 4 - Best Practices You Can Use

« Previous: Chapter 3 - Classifying Noncompliance
Page 39
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 39
Page 40
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 40
Page 41
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 41
Page 42
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 42
Page 43
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 43
Page 44
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 44
Page 45
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 45
Page 46
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 46
Page 47
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 47
Page 48
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 48
Page 49
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 49
Page 50
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 50
Page 51
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 51
Page 52
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 52
Page 53
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 53
Page 54
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 54
Page 55
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 55
Page 56
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 56
Page 57
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 57
Page 58
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 58
Page 59
Suggested Citation:"Chapter 4 - Best Practices You Can Use." National Academies of Sciences, Engineering, and Medicine. 2011. Improving Safety-Related Rules Compliance in the Public Transportation Industry. Washington, DC: The National Academies Press. doi: 10.17226/14593.
×
Page 59

Below is the uncorrected machine-read text of this chapter, intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text of each book. Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.

This chapter provides specific practices that a transit agency can use to improve safety-related rules compliance. The practices are grouped into six categories: screening and selecting employees, training/testing, communication, monitoring rules compliance, responding to noncompliance, and safety management. Table 10 lists the specific practices in each category. Some of the practices listed in this table are further divided. For example, observational methods for monitoring rules compliance consists of ride-along, mystery rider, observation external to the vehicle, speed monitoring, video data recording, and safety audit. Where appropriate, sample documents illustrate the implementation of the practice. Callout boxes contain examples of how selected practices have been implemented by a transit agency. The suggested effectiveness metric(s) for each best practice follows its description as a bulleted item in a box. A table summarizing the relevant metrics appears in Appendix E. As suggested in the Measuring Compliance with Leading and Lagging Indicators section of Chapter 2, the majority of these metrics are leading indicators. Screening and Selecting Employees DOT regulations require that transit agencies screen for drug- and alcohol-related offenses. In addition, many transit agencies examine a job candidate’s record of moving violations, as well as any history of criminal activity. Within the airline industry, research has demonstrated that previous drug and alcohol offenses (e.g., driving under the influence) were predictive of risky flight maneuvers. While the research has not been extended to apply to the public transportation industry, it is likely an effective practice. 39 C H A P T E R 4 Best Practices You Can Use ✓ % of candidates screened Training and Testing The following highlight best practices for training and testing knowledge of safety-related rules. The reader is encouraged to review the following in the context of the training section of Chapter 2. ✓ % of training programs that measure training effectiveness ✓ Is there a post test for all rules training? (Rating scale that evaluates effectiveness on multiple dimensions) Note: The above metrics apply to all the training and testing best practices.

Effective Training Preparation For training to be effective, trainers must prepare their trainees for the learning experience. A public transit agency’s training curriculum can accomplish this by informing employees about upcoming training opportunities and requirements. The training department may send tradi- tional mail or email announcing any upcoming training. Agencies may also use posters and fly- ers to announce training opportunities. The information about training should include why the transit agency is sponsoring it, the training goals and objectives, and any potential benefits to the employee and the agency. 40 Improving Safety-Related Rules Compliance in the Public Transportation Industry Category Practices Screening and Selecting Employees Screening and Selecting Employees Training/Testing Effective Training Preparation Information Transfer Methods Action-Based Rules Training Assessing Effectiveness of Rules Training Crew Resource Management Communication Proactive Rules Communication Opportunities to Ask Questions Communicating Changes to Rules Positive Safety Language Customer Feedback Monitoring Rules Compliance Operational Testing Observational Methods Automated Methods Responding to Noncompliance See Chapter 3 for investigating and responding to noncompliance Rule Evaluation Task Analysis Improving Training Improving Workspace, Tools and Equipment Improving Safety Culture Behavioral Coaching Discipline Safety Management Assessing the Rules Compliance Program Encouraging Employee Involvement Reporting Near-Misses and Other Safety Risks Incentivizing Rules Compliance Table 10. Best practices by category. Yes/No: ✓ Include staff in design and development of training program ✓ Train the trainer ✓ Prepare trainees for rules training by explaining expectations Information Transfer Methods Information transfer methods typically occur in a classroom setting. However, it is important that the information imparted in this setting has the opportunity to be demonstrated in an action-based learning paradigm (see next subsection). The most effective training will encom- pass a broad cross section of training methods.

Instructor-led training. This is the most typical form of classroom training. The instructor will preside over a class explaining the content via lecture, hand- outs, static visual presentation (e.g., slides), and other audio-visual teaching aids. Instructor-led training is most effective when the leader provides students with real-world exemplary material that demonstrates the following: • Necessity for a rule • Proper execution of the rule in the operational environment • Potential outcomes if the rule is not followed • Skill does not protect an employee from the safety risks associated with rule noncompliance • Actual examples of incidents or accidents stemming from rule non- compliance Instructor-led training should also provide the employee with the oppor- tunity to ask questions in a non-evaluative manner, that is, instructors should encourage their students to ask questions without placing value on the qual- ity of questions. Video presentation. Videos are an effective way to bring a lecture and static course materials to life. Instructors can use video to present the positive image of employees following the rules thereby modeling the expected behav- ior and proper execution. Alternatively, video may also be used to present the negative consequences of employees who failed to comply with rules. The latter may include video of actual accident scenes and/or scenario-based re-enactment. Computer-based training (CBT). Many organizations are migrating toward this type of training either by supplementing classroom training or replacing it altogether. The disadvantage to replacing classroom training altogether with CBT is that employees lose the ability to ask questions and they may not learn from comments from their peers. As a supplementary form of training, CBT has advantages. It is less costly than traditional classroom train- ing; therefore, transit agencies can conduct CBT throughout the year to rein- force less frequent classroom training. CBT offers employees the flexibility to complete the training at their own convenience outside of work hours. Refresher training. Transit agencies as well as organizations in other safety- critical industries provide periodic training throughout the year to reinforce initial rules training. Refresher training may be classroom-based, via CBT or through action-based training described in the next subsection. Action-Based Rules Training Action-based or experiential training focuses on educating the employee about how to execute the rule in an operational setting. This can occur when the employee is on-the-job or in a simulated scenario. Action-based training is most effective when combined with information transfer methods. Best Practices You Can Use 41 ✓ Pre/post tests that evaluate understanding the purpose of rules ✓ % of rules with explanations Virginia Regional Transit Authority (VRTA) has a multi-method training system for relating safety-related rules. Employees are notified of safety rules beginning the first day of employment. Throughout the year, VRTA provides monthly and approximately 40 hours of safety- and security-related training to employees via Saturday training meetings. This includes an inten- sive 8-hour boot camp typically held in early Spring. All employee meetings include video training that may cover specific incidents. The Accident Review Committee complements VRTA’s training program by conducting monthly incident and accident briefings with employees as needed. Mountain Line Transit Authority uses an effective video program from the trucking industry to inform its drivers of safety-critical scenarios. The video shows scenarios from the perspective of someone behind the wheel of a transit vehicle. The program is reportedly successful for initial driver training as well as for periodic refresher training.

Simulator training. Other industries, particularly aviation, make simulation a central com- ponent of rules and competency training. Many bus and rail operators make use of simulator training. While the disadvantage of simulator training is the cost of high-fidelity simulators, smaller operators should consider lower cost alternatives. Low-fidelity simulators may not pro- vide the vehicle operator with the tactile and motion feedback that more expensive simulators provide; however, they still provide the opportunity to place the vehicle operator in situations they may not frequently encounter in passenger operations. This better prepares the operator for un- expected situations that may arise, which may call for the execution of less frequently used rules. Simulator training also provides a means to train an operator to respond to high-risk scenarios without putting the individual at risk of experiencing negative consequences. On-the-job training (OJT). All transit agencies use OJT as a form of training. Effective OJT guidelines are discussed in the training section of Understanding Rules Noncompliance. Practice in nonpassenger operation. Transit agencies, particularly bus operators, provide their employees with the opportunity to learn to operate transit vehicles without passengers on board. This is particularly useful for novice employees as they are not distracted by persons on board. Defensive driving course. Many bus transit agencies, as well as other commercial driving organizations, require their employees to complete a defensive driving course. This type of instruction teaches employees to be proactive on the roadways considering ways to prevent acci- dents due to the poor driving choices of other drivers on the road. To maximize the effectiveness of defensive driving, the skills learned should be periodically reviewed with the employee. Crew Resource Management Background. Crew Resource Management (CRM) has been an extremely successful training program in the aviation industry. Although this training program was initially directed toward air- line crews, it has been expanded over the years to include such employees as dispatchers and main- tenance personnel. In addition, it is a program that can include employees who work alone but have a direct working relationship with other related employees, such as transit vehicle operators and dispatchers. Further, CRM training addresses many of the topics covered in this report includ- ing perceptual errors, distraction, fatigue, workload, risk taking, and safety culture. History. CRM was established within the airline industry in the early 1980s, in response to a series of aviation accidents caused solely by human factors and not mechanical failures. It has been so successful that this training is now mandated by the Federal Aviation Administration for all passenger airlines, and will soon be expanded to include all cargo operations as well. Purpose. The CRM training program recognizes that human error will occur, and develops techniques and strategies to deal with such errors. It promotes a working environment that encourages all employees to speak up and assert their views, thus preventing small errors from being magnified and ultimately affecting the safety of flight. It is sometimes defined as “the man- agement of errors.” 42 Improving Safety-Related Rules Compliance in the Public Transportation Industry ✓ Pre/Post tests that evaluate understanding how a rule is applied ✓ % of rules with examples ✓ % of rules with practice opportunities ✓ Annual opportunities for refresher training ✓ % of scheduled refresher training completed ✓ % of action-based training that incorporates positive feedback during training ✓ Course evaluation containing questions about frequency and quality of feedback during training

How it works. The CRM training program emphasizes human factors. All new employees working in operational areas requiring this training receive their introductory information during the orientation process. To reinforce this initial training, annual recurrent training is also provided. In addition, to be successful, the program must receive the full support from the company’s exec- utive management as well as from the operational managers. A successful CRM program is one that becomes an integral part of the corporate culture. Again, CRM training goes beyond crew interaction, and encourages all employees to use all available resources to complete the tasks safely. The operating mantra becomes “what is right” and not “who is right.” Results. Through emphasis on resource management and human factors, CRM programs have been a highly successful strategy in substantially reducing accidents through the management of errors. Much of the training could also be applied to the public transportation industry, particularly with those employees who work together as a crew (train operations, track crew) or those who work directly with other employees such as operators and dispatchers (bus operations or light rail). For more information. Additional information regarding crew resource management is available from the following resources: U.S. Department of Transportation. (1992). Crew Resource Management: An Introductory Handbook. Report No. DOT/FAA/RD-92/26, DOT/VNTSC-FAA-92-8. Washington, DC: Research and Development Services. Kern, Tony. (2001). Controlling Pilot Error: Culture, Environment, and CRM. New York: McGraw Hill. Beaty, David. (1995). The Naked Pilot: The Human Factor in Aircraft Accidents. Shrewsbury, England. Airlife Publishing Company. Best Practices You Can Use 43 ✓ Number of teams trained Communication Communication plays a key role in a safety-related rules compliance program. A number of techniques exist for informing employees of new rules as well as encouraging compliance. The techniques described in this section supplement any training that occurs. Proactive Rules Communication Communicating the purpose of a safety-related rule and the consequences of noncompliance helps to reinforce compliance with the rule. Posters are an effective means for doing this. Figure 5 contains a poster designed to communicate Los Angeles County Metropolitan Transportation Authority’s (LACMTA) cell phone policy. Posters such as this one may be placed in the operator/crew reporting area or any other location where the target group of employees frequently passes. Safety or training bulletins are another method for proactively communicating with employees. These bulletins might provide an actual example of the conse- quences of a rule violation at the transit agency or at another transit agency. The bulletin might be in the form of a poster or a more detailed document that is posted on a bulletin board. Figure 6 contains a safety bulletin from Orange County Transportation Authority (OCTA) in the form of a poster. This bulletin is an example of how an incident that occurred at the transit agency can become a learning experience for others. Figure 5. Example of poster from LACMTA.

Opportunities to Ask Questions Rules training classes provide an opportunity for employees to ask questions about the intent or application of a rule, but the employee needs a means to resolve issues after the class ends and he or she is back on duty. Some transit agen- cies encourage trainees to contact their instructor with questions that arise on the job. A daily job or safety briefing is another means for doing this. The rule of the day/week may be discussed at this time. SDTI provides guidance to its supervisors for these types of discussions (see Figure 8). Some public transit agencies also con- duct periodic safety meetings with their employees. These meetings provide an opportunity to review recent rules changes and to allow employees to ask ques- tions. Safety meetings are longer than daily job briefings. Conducting them may require removing employees from their job or paying them overtime to partici- pate after their normal work period. Unfortunately, budgetary and logistical con- siderations may prevent a transit agency from doing this. There must also be an opportunity for employees to ask questions and voice their concerns outside of the formal meetings. Having an open door policy where supervisors and managers make themselves available encourages employees to seek help or raise issues. Having a blame-free safety culture in the organization assures employees that there will be no retribution for asking questions. 44 Improving Safety-Related Rules Compliance in the Public Transportation Industry Figure 6. OCTA safety bulletin for posting. Metro-North Crew Debriefing Metro-North Railroad (MNR) found that conducting 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 con- ductor(s) spend a few minutes with their supervisor talking about what happened that day. They focus on any unanti- cipated occurrences, such as a crossing gate being out of service, and how they handled them, mentioning the rules that they applied. This is now standard practice at MNR. Many transit agencies have a rule of the day/week as a means to proactively maintain employee knowledge of the rules. San Diego Trolley, Inc. (SDTI) publishes Rule of the Week for posting in crew areas (see Figure 7). Many transit agencies discuss the rule of the day at a daily job briefing. ✓ % of crew reporting locations with bulletin boards or variable message signs ✓ % of rule changes posted ✓ Number of safety meetings or other discussion opportunities

Communicating Changes to Rules When there is a change in safety-related rules, there are a variety of methods available to com- municate a new or modified rule. If the new rule is intended to eliminate a serious safety risk, then a Meet and Greet strategy may be used in addition to a printed notice that is mailed to each affected employee. Meet and Greet involves the supervisor explaining the new rule to each employee on a one-on-one basis. The advantage of this approach is that it provides the employee an opportunity to task questions and the transit agency is certain that each employee knows about and understands the rule change. Another strategy, which may be used in conjunction with Meet and Greet, is having the employee sign that he or she has received and read the new rule. The new rule may be distributed via mail or email. A periodic newsletter may also reinforce the nature and importance of the new rule. Best Practices You Can Use 45 Figure 7. Rule of the Week publication from San Diego Trolley, Inc. ✓ % of employees who participated in “meet and greet” ✓ % of employees who acknowledge receipt of new rule in writing

46 Improving Safety-Related Rules Compliance in the Public Transportation Industry Figure 8. Super Vision guidance document for San Diego Trolley, Inc., supervisors.

Positive Safety Language The term “incident” implies an event that has negative consequences. “Unanticipated or unusual occurrence” implies simply an event that was not expected (see Figure 9). In addition, the results of operational testing should be reported in terms of % passing rather than % failing. This conveys the positive message that the goal is for everyone to pass rather than a focus on those who do not. Best Practices You Can Use 47 Figure 9. BART reporting form for unanticipated occurrences. ✓ Number or % of safety communications containing positive safety language Customer Feedback Patron feedback can be a source of reports of noncompliant safety behavior. Today, even the smaller paratransit agencies provide a means for their patrons to submit their concerns by email, paper form submittal, telephone, or through the transit agency’s website (see Figure 10). Paratran- sit agencies provide service under contract to social service agencies in the community. Soliciting feedback from these agencies is another means of evaluating driver compliance with safety-related rules. The existence of these communication channels may serve to motivate employees to comply with the rules. ✓ Number of reports regarding operator behavior ✓ Average follow-up time Monitoring Rules Compliance A formal operational testing program is one method for monitoring compliance with safety- related rules. Monitoring may involve observational and/or automated data collection methods. The following sections describe the elements of an operational testing program as well as the various methods for monitoring.

Operational Testing The Federal Railroad Administration (FRA) requires that all railroads, including commuter rail operators, have a program of operational testing to ensure rules compliance. Many public transit agencies have adopted this model and created operational testing programs for light rail, subway, and bus operations. The elements of an operational testing program are the following: • Organizational responsibility • Employees covered • Rules covered and testing methods for conducting tests • Frequency of testing and number of tests • Employee notification and recordkeeping • Corrective action Organizational Responsibility Transit agencies use a variety of organizational structures to administer their safety-related rules compliance programs. Some appoint a Director of Rules or Rules Compliance Program Administrator who reports to the transit agency’s safety officer or training manager. Alterna- tively, the agency may constitute a committee to define and oversee the testing program. The committee would have representatives from the various operating departments as well as the Safety Director and others that the agency deems appropriate. If a committee has responsibility, then this committee establishes the scope of the program as well as all the testing and notifica- 48 Improving Safety-Related Rules Compliance in the Public Transportation Industry Figure 10. Customer comment form for Mountain Line Transit Authority.

tion procedures. The agency must also decide who conducts the tests and what qualifications they must have. Employees Covered In accordance with FRA regulations, all locomotive engineers and conductors must have peri- odic operational tests. Transit agencies with heavy or light rail systems should have an operational testing program for their vehicle operators as part of their system safety plan. At some transit agen- cies, such as the MBTA, the testing program also includes bus operators. Rules and Testing Methods At a minimum, commuter rail operators must have tests that cover all the FRA prescribed rules in 49 C.F.R. that deal with the movement of trains. Some transit agencies, such as South- eastern Pennsylvania Transportation Authority (SEPTA), are expanding their testing program to cover all rules in their rulebook. Test coverage for heavy and light rail operations will likely differ somewhat from commuter rail operations. One reason for this difference is that some heavy rail lines have trip stops that prevent speeding so a speed test would not be meaningful. Also, on a rail transit system that operates in automatic mode, the vehicle operator has less con- trol of the train and hence less opportunity for rule noncompliance. For each rule, the testing program must specify how the rule is tested. For example: • Speed may be tested with a properly calibrated radar gun or analysis of event recorder data, if available. • Visual observation is suitable to check for unauthorized personnel in the cab but a video recording system may be the preferred method if more frequent observation is necessary. • Use monitoring of live or recorded radio transmissions to check for proper radio protocol to authorize train movement. • Use event recorder data to determine if the engineer/operator sounded the whistle at a high- way-rail crossing. Test Coverage The program should define the frequency of testing and the number and types of tests. Tests for critical safety-related rules, such as speed and compliance with signal indications, may occur monthly while other rules, such as those involving shove moves in a yard, may occur less frequently. Alternatively, the transit agency may have a more limited set of rules to test and all rules may be tested monthly. For example, a bus operator may test every month for speed, intersection maneuvers, and pre-trip inspections. The agency may set up the testing program so that every operator is tested at least once annually. Any vehicle operator who has had a pre- ventable accident may be subject to additional testing. The transit agency should constantly review its test results and accident experience and adjust the rules testing program to focus on any problematic rules. Employee Notification and Recordkeeping The result of a test may be a simple pass or fail. SEPTA’s commuter rail testing program includes three levels of noncompliance: level l–Noncompliance: instruction provided; level 2–Noncompliance: written/follow-up action; level 3–Noncompliance: withheld/remove from service. The importance of the rule determines the level of noncompliance. For example, run- ning a red signal is a serious level 3 violation so a vehicle operator who ran thru a red signal would be removed from service. SEPTA is in the process of applying these levels of noncompliance to the testing program for its suburban rail, heavy rail, and light rail operations. Best Practices You Can Use 49

The employee needs to know the outcome of any test, regardless of whether the employee passed or failed. Ideally, the notification should occur immediately following the test regardless of the outcome. If the employee fails a test and there is any possibility of an accident or injury, then immediate action must be taken by the supervisor. Sometimes immediate notification may not be possible without interruption of transit operations. It is important to commend the employee on passing. Employees need reassurance and commendation for performing their jobs in accordance with the transit agency’s expectations. Most transit agencies have a computer-based system for maintaining test results. Testers record their observations on a paper log which is then entered into the database (see Figure 11). Electronic recording is also possible if a tablet PC or other similar device is available. Peri- odic reports are prepared to monitor the frequency and types of tests as well as the success/ failure rates. Corrective Action The severity of the rule violation will determine the appropriate corrective action. (See the Responding to Noncompliance section.) For example, transit agency policy may stipulate imme- diate dismissal from the agency for certain failures such as use or possession of a personal elec- tronic device while on duty. 50 Improving Safety-Related Rules Compliance in the Public Transportation Industry Figure 11. Log used by MBTA observers for heavy rail testing. ✓ Number and types of tests ✓ % passing ✓ Number of major rule violations

Ride-Along A ride-along involves a supervisor or training officer accom- panying the vehicle operator on a daily run to observe how the operator handles the vehicle and possible passenger interactions. If the ride-along is part of a training experience, the observer will coach the operator as appropriate. Mystery Rider A mystery rider is an individual who poses as a patron and rides the transit vehicle to observe the operator. It is usually an experienced transit operator whom the transit agency hires for this purpose. If the vehicle operator or other attendant handles cash, a mystery rider may be engaged to ensure that all cash received is properly handled and delivered to the agency. In this situation, the mystery rider may also observe selected operator behavior such as improper use of an electronic device or the presence of unauthorized people in the cab compartment. Observation Exterior to Vehicle If there is a location where transit vehicles pass frequently, an observer stationed at that location can observe multiple vehicle operators. This may occur at a busy intersection or an overpass. Alternatively, an observer may follow a transit or paratransit vehicle in another vehicle. Speed Monitoring with Radar Gun Monitoring bus speed is most easily done with a radar gun by a trained observer. Radar guns may be used with heavy or light rail if the vehicle does not have a data recorder that captures speed. Radar guns require periodic calibration. (See Figure 12.) Video Data Recording Systems Recent improvements in video data recording systems make them a viable option for moni- toring transit operator performance. Observational Methods The most common technique for monitoring safety-related rules compliance involves the use of observational methods. These may be done with or without advance notice to the employee. Some believe that if employees know they are being observed, they will be extra vigilant in observing rules and there- fore there should be no advance warning of who will be observed on a given day. The observation may be part of a formal rules test or it may be for employee evaluation and coaching or part of a training experience. The ride-along, mystery rider, and observer in a separate vehicle should all have a checklist to guide their observations. Best Practices You Can Use 51 MBTA Safety Rules Compliance Program The NTSB’s report on a collision between two MBTA light rail trains in May 2008 pointed to the lack of an established formal testing program that would provide a comprehensive evaluation of employee rule compliance. In February 2009, rec- ognizing the need for such a program, the MBTA established its Safety Rules Compliance Program (SRCP). The agency stated in its Standard Operat- ing Procedure that the goals of the program are to • Reduce accidents caused by human error. • Improve and enhance the vigilance of employees to comply with established rules and procedures. • Determine the degree of compliance with established rules to improve compliance. • Focus attention on rules and areas where there is a need to improve employees’ knowledge, training, and skill level. • Incorporate lessons learned into existing training programs. A Safety Rules Compliance Steering Committee governs and oversees the SRCP. It is co-chaired by the Director of Safety and the Deputy Chief Oper- ating Officer. This oversight committee has repre- sentatives from the operating bus and subway departments as well as the Director of the Opera- tions Control Center and Training. The committee established the procedures for the operational tests. Each inspection procedure covers the ele- ments of a testing program as described above. The committee meets monthly to review test results and make changes as necessary. Approxi- mately 1,000 tests are performed monthly. Since the start of the testing program, there has been a decline in the number of safety rule violations. ✓ Number and types of observations ✓ % and number in compliance with rules

52 Improving Safety-Related Rules Compliance in the Public Transportation Industry Figure 12. MBTA inspection procedure for radar speed observation. Purpose. Systems that provide video recordings and vehicle performance data in the event of safety-related rule noncompliance are a means to document errors and violations. Beyond that, the data from these systems can be incorporated into training and coaching with the employee involved. Video clips may also become case examples for future operator training classes. Public transit bus and paratransit operators as well as private motorcoach operators report success with this type of system. How they work. A series of small video cameras are installed on the interior of the bus. Some record interior views and others record the roadway ahead. A data logger mounted on the interior of the vehicle records exceptional forces such as hard braking, swerving or a collision. When an event triggers the data logger, the data describing the event along with related video data is either saved on the data logger for later download or transmitted wirelessly to a central location. Figure 13 shows a video camera mounted behind the rear view mirror of a transit bus.

How to use them. Supervisors receive a report for each event that the system logs. It is the supervisor’s responsibility to respond appropriately. If the event is a minor error, coaching is appropriate. A more serious violation will likely result in discipline and retraining. The following are guidelines for implementing a video data recording system. • Train supervisors on effective use of the video system. • Notify your labor organization about plans for the system (training and rules compliance monitoring) and how the transit agency plans to use it to benefit their members. Share experiences with labor from the motorcoach and other transit agencies. (See the Motorcoach section of Appendix A.) Labor acceptance can be enhanced when the tool is primarily used for training. The system is also useful for documenting accidents caused by other vehicle operators. • Establish guidelines for supervisors regarding how quickly to deal with a reported event. • Communicate with vehicle operators regarding why the system is being implemented and how it can benefit them. • Incorporate the system into any transit agency reward program. For example, acknowledge miles or hours of incident free driving. • Use video clips of near-miss incidents at safety meetings and training sessions to reinforce the need for safe driving practices and rules. Safety Audit Purpose. A safety audit is a process for observing activities in the workplace. The objective is to identify safe and unsafe work behaviors and to acknowledge safe behavior while correcting any deficiencies. The audit is a non-punitive process. An audit team with representatives from both labor and management, and possibly an official from the safety department, conducts the audit using a checklist. The auditing process should be interactive with auditors talking with workers about their tasks. If the auditor observes an unsafe behavior, the auditor should discuss the consequences of the unsafe act and suggest a safer way to perform the task. In the transit envi- ronment, safety audits are most suitable for use with track gangs and employees at equipment repair facilities. Best Practices You Can Use 53 Figure 13. Video data recording system installed behind rearview mirror in a transit bus (photo courtesy of DriveCam, Inc.).

The following are guidelines for implementing a safety audit process. • Develop a checklist for the audits. • Select and train the individuals on the audit team. • Design a process for recording the results of audits so that problems or trends can be identified. • Communicate with employees who will be audited regard- ing the purpose and scope of the audits, what to expect when the audit occurs, and how it can benefit them. • Design and monitor a process for following up on defi- ciencies. 54 Improving Safety-Related Rules Compliance in the Public Transportation Industry Metrolink Locomotive Digital Video Recorder System After the Chatsworth, California, incident between a Metrolink and Union Pacific train in September 2008, the Board of Directors for the Southern Cali- fornia Regional Rail Authority (Metrolink) approved the procurement and use of cameras in their locomotive cabs. Following the Board’s action, and as a result of the NTSB’s investigation of the Chatsworth incident, the NTSB also recom- mended the use of in-cab audio and image record- ing systems that would discourage the type of noncompliant behavior that caused this incident. In October 2009, Metrolink introduced its Locomotive Digital Video Recorder (LDVR) system in all of its locomotives. The system has three cameras per locomotive: an outward-facing camera to record activity in front of the locomotive and two inward- facing cameras to record the control panels and human activities inside the locomotive cab. The sys- tem records both audio and video data to an exter- nal hard drive. New cab cars will also have LDVRs. Metrolink may use the data for the investigation of specific incidents such as an impact between a Metrolink train and a highway vehicle, a derail- ment, or an alleged block signal rules violation. Metrolink’s policy also limits the use of this video and audio data to random testing for compliance with three specific rules: • Prohibition on use of electronic devices • Prohibition of sleeping while on duty • Presence of unauthorized persons in the cab Stringent procedures govern the authorized usage, retrieval, preservation, and disclosure of the recordings to ensure that they are used only for the purposes permitted in the agency’s policy. ✓ Number of safety audits ✓ Number and types of problems observed and coached Review Radio Transmissions If radio transmissions are recorded, reviewing them pro- vides a means to check proper radio procedure. A field observer can complement visual observations with the operator’s communication with the dispatcher or opera- tions center during the operational test thus providing a more complete picture of rules compliance. ✓ % and number of communications in compliance with rules ✓ % and number of people in compliance with rules ✓ % and number of operations in compliance with rules Automated Methods A number of automated methods for monitoring safety- related rules compliance exist. Not all automated methods are suitable for all modes. Onboard Event Recorder Onboard event recorders for locomotives record train speed, direction of movement, time, dis- tance, throttle position, and application and operation of the braking systems. In other words, the onboard data logger records what the engineer is doing with the locomotive. These systems include software for automatically downloading event recorder information and scanning the data for exceptions. This software applies criteria to identify two types of exceptions: those with a safety implication and those related to proper train handling. The primary safety-related excep- tion is the engineer- or conductor-induced emergency brake application. Train handling excep- tions arise when the train is not operated in accordance with company policies intended to reduce wear on the equipment or achieve optimal fuel economy.

The Class I railroads have specific trackside locations where data auto- matically downloads when a train passes. For example, when a locomo- tive is within 1 mile of a download loca- tion, the event recorder information is automatically downloaded to the base station. Every hour a server at a central location receives all downloads for all base stations. (Download of the data may occur at a yard or other central location if field locations do not exist.) At a designated time, the server auto- matically scans the previous day’s downloads for exceptions. This infor- mation is forwarded to a database to match the train, engineer, and location. A central group or an individual super- visor may review the exceptions identi- fied by the system. Each exception usually receives addi- tional scrutiny. For example, assume the data indicates that the engineer induced an emergency brake application. Upon investigating further, the supervisor dis- covers that the engineer put the train into emergency because of a car stopped on the tracks at that location. This is an appropriate use of emergency braking. If, however, no such circumstance existed, then the emergency braking may have been due to human error. Data from Signal System A signal system that controls rail oper- ations provides the capability to identify rule violations such as passing a red signal. These data should be reviewed periodically to determine whether or not there are problem locations. Frequent red signal violations at a specific location necessitate a closer examination of the situation. Management will likely want to determine how the problem signal dif- fers from others and whether there are unique characteristics that are causing the signal overruns. Is it on a curve? Is the signal obscured by signal or foliage? What is the distance from the previous signal? Best Practices You Can Use 55 NYCT Safety Audit Teams As a result of two fatalities involving track workers in April 2007, New York City Transit’s (NYCT) Office of System Safety (OSS), Bus and Rail Field Operations Division began a safety audit program in mid-May 2007 designed to observe on-track work and correct any unsafe work practices or safety rule noncompliance. There are two audit teams working 4 nights per week. The team usually consists of two Trans- portation Workers Union (TWU) representatives, one or two staff from OSS, and two flaggers. The audit team uses a 21-question checklist that was developed by NYCT OSS. The checklist includes items such as the following: • Flagging procedures • Implementation of General Orders with regard to protecting out of service track • Use of the third-rail alarm devices • Proper lighting • Use of PPE • Toolbox safety talk • Identification of job hazards • Knowledge of egress from the site • Pre-site inspection before starting work • Inspection of tools and equipment • Training and qualifications of the workers engaged in on-track work Most noncompliance is corrected with re-instruction onsite. If neces- sary, the gang will be removed from the tracks until the problem is cor- rected. The audit goal is to correct at-risk behaviors or conditions so that the work is completed safely and without harm to any of the workers. The inspection teams recently moved to using a triplicate form in which the OSS representative, TWU representative, and the job site supervisor sign to acknowledge that notification of noncompliance was made. A weekly report of the inspections is sent to the executive leadership of the Departments of Subways and Capital Program Management for response. OSS monitors the number of deficiencies per site. On a quarterly basis, OSS issues a report on the average number of deficiencies per site as well as the types of deficiencies. The number of deficiencies has declined substantially since initiation of the program in 2007. Two key factors are responsible for the success of NYCT’s Safety Audit Teams: management support and adequate resources. The transit agency’s CEO has supported this effort since its inception. His endorse- ment of the program plus the willingness of NYCT’s managers to support the findings of the safety audits have made the program a meaningful component of the agency’s overall safety program.

Responding to Noncompliance When a transit agency determines that an employee has been noncompliant with a safety-related rule, the first response should be to determine why the employee failed to comply. For each instance of noncompliance, the agency should use the taxonomy and questions designed to determine root cause presented in Chapter 3. Once the agency determines root cause, it can work to remediate the underlying cause(s) and contributing factors. Remedial efforts may be in conjunction with or in addition to the following methods. Rule evaluation. The evaluation should consider safety-related rules in the context of the work environment. At a minimum, the agency should determine the answers to the following questions. • Is the rule’s noncompliance rate high? • Is the rule easily comprehended? • Has it been explained well both verbally and in written form? • Has the rule been demonstrated to the employee in classroom, computer- based, and/or on-the-job training? • Have you queried employees or labor representatives regarding the relevance of the rule? • Do employees report that it is difficult to comply with a rule and if so, why? Task analysis. Conducting a job or cognitive task analysis may help the transit agency evalu- ate the job’s task demands to make sure an employee is able to comply with the rules. The purpose of task analysis is to clearly define what thoughts, actions, and tasks are necessary to successfully perform one’s job. Task analysis may help the agency understand that an existing rule might con- flict with how a person is expected to do the job. The results may help the agency to improve its safety-related practices, procedures, rule books, manuals, written instructions/materials and other written job aids. The premise behind task analysis is to fit the task or rule to the human, not vice versa. Making it easier for an employee to comply with safety-related rules will reduce the rate of noncompliance. The following is an excellent resource that describes these methods: Kirwan, B., and Ainsworth, L. K. (1992). A Guide to Task Analysis. CRC Press: Boca Raton, FL. Improve training. The agency may find that employees had insufficient training regarding rules. See the training section in Chapter 2 to identify ways to improve the training process. Improve workspace, tools, and equipment. In the same way that it is important to fit the rule to the employee, it is also imperative that the working environment be tailored to the user. When regular noncompliance occurs with a particular rule, the workspace, including tools and equipment, should be evaluated to ensure employees are able to comply with their expected workspace interactions. Improve safety culture. Safety culture is the focus of TCRP Project A-35, “Improving Safety Culture in Public Transportation.” The reader is encouraged to review the information con- tained within the TCRP Project A-35 final report as well as the information regarding safety cul- ture in Chapter 2 of this report. As previously discussed, adopting a no-blame policy will greatly improve the safety culture of an organization. The transit agency’s top-level management must embrace this policy and communicate through the ranks of the organization. Implementing a safety reporting system as suggested in Chapter 5 is an important step in improving safety cul- ture. Making safety a higher priority than the agency’s performance goals is also an imperative component of safety culture. The agency should not tolerate supervisory or management accep- tance of noncompliance to meet performance goals. 56 Improving Safety-Related Rules Compliance in the Public Transportation Industry For one major railroad, a typi- cal month resulted in 4,269 dif- ferent items examined on the event recorder downloads. Of these, there were 142 excep- tions of which 30 were found to be significant. Decertification of the engineer resulted for 13 of these incidents. Without the analysis of the event recorder data, management would not have identified these events.

Behavioral coaching. Many transit agencies provide remedial coaching and/or training for their employees when they are found to be noncompliant. This may occur during ride- alongs in passenger operations, during action-based training exercises, or after noncompli- ance has been found to occur during operational testing or some other monitoring exercise. Behavioral coaching is most effective when positive reinforcement is used in conjunction with non-evaluative identification of the incorrect behavior. For example, first the coach should comment on the correct actions of the employee providing praise for a job well done. Then the coach should identify ways to improve performance or safety- related rule compliance. Coaching should occur as soon as pos- sible after noncompliance occurs. Discipline. This topic, including best practices, is reviewed in greater detail in Chapter 2. A majority of transit agencies sub- scribe to some form of a progressive discipline program with a no tolerance policy for egregious and criminal acts. This generally entails verbal warning/reprimand for the first offense, written rep- rimand with or without remedial training efforts, and then dis- missal as a last resort. Best Practices You Can Use 57 ✓ % and number of discipline cases ✓ % and number of dismissals ✓ % and number of coaching cases ✓ % and number of remedial training cases Safety Management Assessing the Safety-Related Rules Compliance Program Since the overall goal of a safety-related rules compliance program is to reduce the risk of a low-probability, high-consequence event, the evaluation process for that program should include leading as well as lagging indicators. Leading indicators focus on process and are achievement- oriented while lagging indicators are avoidance-oriented. Complacency can occur if only lagging indicators are used, especially if they focus on an infrequently occurring undesirable outcome. If the focus is on lagging indicators, there may be a tendency to manage the numbers rather than to improve or manage the factors leading to the undesirable result, in this case, a safety-related rule violation. There is no prescribed mix of measures that a transit agency should use. Rather it depends on the nature and size of the operation and the agency’s experience with safety-related rules compliance. Ideally, there should be a mix of leading and lagging indicators with more leading than lagging met- rics. Each agency must pick the set of metrics that is appropriate for its situation. It is important to limit the number of metrics. If there are too many measures, it is possible that the burden of the recordkeeping will result in the organization abandoning the leading indicators and only using lag- ging indicators such as the number of test failures and the number of preventable accidents. The description in this chapter for each practice includes suggested metrics for monitoring the effectiveness of that practice. Since the goal of the majority of the best practices is to reduce risk, the suggested metrics are primarily leading indicators. For any practices that already exist to encourage safety-related rule compliance, the transit agency may want to adopt one of the sug- gested metrics or consider developing their own leading indicator. The Burlington Northern Santa Fe (BNSF) Rail- way has an Alternative Handling Agreement with the United Transportation Union and the Brotherhood of Locomotive Engineers and Trainmen. They use the term alternative handling in lieu of alternative discipline because the infraction does not go on the employee’s permanent record. The employee has a choice between using the traditional progressive discipline program and alternative handling. Certain infractions are not eligible for the program including decertification violations specified by federal regulation and other high-risk incidents. The employee may be disqualified for alternative handling if repeated noncompliance occurs in a 12-month period.

In establishing a way to measure the effectiveness of a safety-related rules compliance program, there are three key factors: • Select the appropriate set of metrics for the transit agency. • Limit the number of metrics that are tracked. • Monitor and acknowledge progress over time (see Schneider National Trucking Company in Appendix D). In addition, a transit agency may want to benchmark its rules compliance experience with peer agencies. Encouraging Employee Involvement Transit agencies can employ a number of strategies to encourage employee commitment to safety-related rules compliance. A joint labor/management safety committee that meets on a reg- ular basis may solicit suggestions from employees. Posters or other notices may inform employ- ees of the existence of the safety committee and how to offer suggestions to either the committee or the safety department. 58 Improving Safety-Related Rules Compliance in the Public Transportation Industry ✓ Number of management/labor committees ✓ Number of posters/notices inviting employees to express concerns Reporting Near-Misses and Other Safety Risks Safety reporting system. Chapter 5 provides an in-depth description of best practices for implementing a safety reporting system. The chapter reviews how to implement a full-scale sys- tem; it also describes how to adopt interim safety reporting mechanisms prior to adopting a full- scale system—a lengthy process requiring significant commitment from stakeholders as well as budgetary considerations. Safety hotline. Many transit agencies also have a safety hotline whereby employees can anony- mously report general safety concerns. This type of system presents an opportunity for employees to report safety-related rules noncompliance. However, employees may be reluctant to report each other’s noncompliance, because it is seen as “ratting out” one’s fellow coworkers. Creating a no- blame work culture will help to encourage employees to report noncompliance. A transit agency can also encourage employees to use the hotline to report ineffective or confusing rules. Employ- ees can use the hotline to report incidents stemming not only from safety-related rules non- compliance, but also incidents stemming from poorly defined rules or situational variables (e.g., workspace design) that prevent employees from successfully executing safety-related rules. ✓ Number of reports per month ✓ Average time to respond to reporting employee ✓ Number of recommendations implemented Incentivizing Safety-Related Rules Compliance Chapter 2 presents many best practices for incentivizing rules compliance. If the incentive pro- gram rewards the types of behaviors that relate to the transit agency’s leading indicators, it should encourage compliance. A safety point system is one approach. The system would award points for

activities such as attending a voluntary rules or safety training class, coaching another employee, making a presentation at a department safety meeting, or suggesting a change in procedure that improves safety-related rules compliance. This type of system makes it possible for every employee to receive an incentive in recognition of accumulating a set point level. There might be different levels that the employee could achieve over his or her career. Best Practices You Can Use 59 ✓ Number of annual awards per 100 employees

Next: Chapter 5 - Safety Reporting System Best Practices »
Improving Safety-Related Rules Compliance in the Public Transportation Industry Get This Book
×
MyNAP members save 10% online.
Login or Register to save!
Download Free PDF

TRB’s Transit Cooperative Research Program (TCRP) Report 149: Improving Safety-Related Rules Compliance in the Public Transportation Industry identifies potential best practices for all of the elements of a comprehensive approach to safety-related rules compliance.

The categories of best practices, which correspond to the elements of a safety-related rules compliance program, include screening and selecting employees, training and testing, communication, monitoring rules compliance, responding to noncompliance, and safety management.

The report also outlines the features of a prototype safety reporting system for public transportation.

  1. ×

    Welcome to OpenBook!

    You're looking at OpenBook, NAP.edu's online reading room since 1999. Based on feedback from you, our users, we've made some improvements that make it easier than ever to read thousands of publications on our website.

    Do you want to take a quick tour of the OpenBook's features?

    No Thanks Take a Tour »
  2. ×

    Show this book's table of contents, where you can jump to any chapter by name.

    « Back Next »
  3. ×

    ...or use these buttons to go back to the previous chapter or skip to the next one.

    « Back Next »
  4. ×

    Jump up to the previous page or down to the next one. Also, you can type in a page number and press Enter to go directly to that page in the book.

    « Back Next »
  5. ×

    To search the entire text of this book, type in your search term here and press Enter.

    « Back Next »
  6. ×

    Share a link to this book page on your preferred social network or via email.

    « Back Next »
  7. ×

    View our suggested citation for this chapter.

    « Back Next »
  8. ×

    Ready to take your reading offline? Click here to buy this book in print or download it as a free PDF, if available.

    « Back Next »
Stay Connected!