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Best Practices You Can Use 47 Figure 9. BART reporting form for unanticipated occurrences. 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. 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.
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48 Improving Safety-Related Rules Compliance in the Public Transportation Industry Figure 10. Customer comment form for Mountain Line Transit Authority. 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-
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Best Practices You Can Use 49 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 lNoncompliance: instruction provided; level 2Noncompliance: written/follow-up action; level 3Noncompliance: 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.
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50 Improving Safety-Related Rules Compliance in the Public Transportation Industry Figure 11. Log used by MBTA observers for heavy rail testing. 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. Number and types of tests % passing Number of major rule violations
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Best Practices You Can Use 51 Observational Methods The most common technique for monitoring safety-related MBTA Safety Rules Compliance Program rules compliance involves the use of observational methods. The NTSB's report on a collision between two These may be done with or without advance notice to the MBTA light rail trains in May 2008 pointed to the employee. Some believe that if employees know they are being lack of an established formal testing program that observed, they will be extra vigilant in observing rules and there- would provide a comprehensive evaluation of fore there should be no advance warning of who will be observed employee rule compliance. In February 2009, rec- on a given day. The observation may be part of a formal rules test ognizing the need for such a program, the MBTA or it may be for employee evaluation and coaching or part of a established its Safety Rules Compliance Program training experience. The ride-along, mystery rider, and observer (SRCP). The agency stated in its Standard Operat- in a separate vehicle should all have a checklist to guide their ing Procedure that the goals of the program are to observations. · Reduce accidents caused by human error. · Improve and enhance the vigilance of employees Number and types of observations % and number in compliance with rules 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, Ride-Along training, and skill level. A ride-along involves a supervisor or training officer accom- · Incorporate lessons learned into existing training panying the vehicle operator on a daily run to observe how the programs. operator handles the vehicle and possible passenger interactions. If the ride-along is part of a training experience, the observer will A Safety Rules Compliance Steering Committee coach the operator as appropriate. governs and oversees the SRCP. It is co-chaired by the Director of Safety and the Deputy Chief Oper- Mystery Rider ating Officer. This oversight committee has repre- A mystery rider is an individual who poses as a patron and sentatives from the operating bus and subway rides the transit vehicle to observe the operator. It is usually an departments as well as the Director of the Opera- experienced transit operator whom the transit agency hires for tions Control Center and Training. The committee this purpose. If the vehicle operator or other attendant handles established the procedures for the operational cash, a mystery rider may be engaged to ensure that all cash tests. Each inspection procedure covers the ele- received is properly handled and delivered to the agency. In this ments of a testing program as described above. situation, the mystery rider may also observe selected operator The committee meets monthly to review test behavior such as improper use of an electronic device or the results and make changes as necessary. Approxi- presence of unauthorized people in the cab compartment. mately 1,000 tests are performed monthly. Since the start of the testing program, there has been a Observation Exterior to Vehicle decline in the number of safety rule violations. 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.
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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.
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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.). 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.
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54 Improving Safety-Related Rules Compliance in the Public Transportation Industry The following are guidelines for implementing a safety Metrolink Locomotive Digital Video audit process. Recorder System · Develop a checklist for the audits. · Select and train the individuals on the audit team. After the Chatsworth, California, incident between · Design a process for recording the results of audits so that a Metrolink and Union Pacific train in September 2008, the Board of Directors for the Southern Cali- problems or trends can be identified. · Communicate with employees who will be audited regard- fornia Regional Rail Authority (Metrolink) approved the procurement and use of cameras in ing the purpose and scope of the audits, what to expect their locomotive cabs. Following the Board's when the audit occurs, and how it can benefit them. action, and as a result of the NTSB's investigation · Design and monitor a process for following up on defi- of the Chatsworth incident, the NTSB also recom- ciencies. mended the use of in-cab audio and image record- ing systems that would discourage the type of Number of safety audits noncompliant behavior that caused this incident. In Number and types of problems observed and coached 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 Review Radio Transmissions activity in front of the locomotive and two inward- If radio transmissions are recorded, reviewing them pro- facing cameras to record the control panels and vides a means to check proper radio procedure. A field human activities inside the locomotive cab. The sys- observer can complement visual observations with the tem records both audio and video data to an exter- operator's communication with the dispatcher or opera- nal hard drive. New cab cars will also have LDVRs. tions center during the operational test thus providing a Metrolink may use the data for the investigation of more complete picture of rules compliance. specific incidents such as an impact between a Metrolink train and a highway vehicle, a derail- % and number of communications in compliance with rules 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 Automated Methods · Prohibition of sleeping while on duty · Presence of unauthorized persons in the cab A number of automated methods for monitoring safety- related rules compliance exist. Not all automated methods Stringent procedures govern the authorized usage, are suitable for all modes. retrieval, preservation, and disclosure of the recordings to ensure that they are used only for the purposes permitted in the agency's policy. % and number of people in compliance with rules % and number of operations in compliance with rules 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.
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Best Practices You Can Use 55 The Class I railroads have specific trackside locations where data auto- NYCT Safety Audit Teams matically downloads when a train passes. For example, when a locomo- As a result of two fatalities involving track workers in April 2007, New tive is within 1 mile of a download loca- York City Transit's (NYCT) Office of System Safety (OSS), Bus and Rail tion, the event recorder information is Field Operations Division began a safety audit program in mid-May automatically downloaded to the base 2007 designed to observe on-track work and correct any unsafe work station. Every hour a server at a central practices or safety rule noncompliance. There are two audit teams location receives all downloads for all working 4 nights per week. The team usually consists of two Trans- base stations. (Download of the data portation Workers Union (TWU) representatives, one or two staff may occur at a yard or other central from OSS, and two flaggers. location if field locations do not exist.) The audit team uses a 21-question checklist that was developed by At a designated time, the server auto- NYCT OSS. The checklist includes items such as the following: matically scans the previous day's downloads for exceptions. This infor- · Flagging procedures mation is forwarded to a database to · Implementation of General Orders with regard to protecting out of match the train, engineer, and location. service track A central group or an individual super- · Use of the third-rail alarm devices visor may review the exceptions identi- · Proper lighting fied by the system. · Use of PPE · Toolbox safety talk Each exception usually receives addi- · Identification of job hazards tional scrutiny. For example, assume the · Knowledge of egress from the site data indicates that the engineer induced · Pre-site inspection before starting work an emergency brake application. Upon · Inspection of tools and equipment investigating further, the supervisor dis- · Training and qualifications of the workers engaged in on-track work covers that the engineer put the train into emergency because of a car stopped Most noncompliance is corrected with re-instruction onsite. If neces- on the tracks at that location. This is an sary, the gang will be removed from the tracks until the problem is cor- appropriate use of emergency braking. rected. The audit goal is to correct at-risk behaviors or conditions so If, however, no such circumstance that the work is completed safely and without harm to any of existed, then the emergency braking the workers. may have been due to human error. The inspection teams recently moved to using a triplicate form in Data from Signal System which the OSS representative, TWU representative, and the job site supervisor sign to acknowledge that notification of noncompliance A signal system that controls rail oper- was made. A weekly report of the inspections is sent to the executive ations provides the capability to identify leadership of the Departments of Subways and Capital Program rule violations such as passing a red Management for response. signal. These data should be reviewed periodically to determine whether or not OSS monitors the number of deficiencies per site. On a quarterly basis, there are problem locations. Frequent OSS issues a report on the average number of deficiencies per site as red signal violations at a specific location well as the types of deficiencies. The number of deficiencies has necessitate a closer examination of the declined substantially since initiation of the program in 2007. situation. Management will likely want to determine how the problem signal dif- Two key factors are responsible for the success of NYCT's Safety Audit fers from others and whether there are Teams: management support and adequate resources. The transit unique characteristics that are causing agency's CEO has supported this effort since its inception. His endorse- the signal overruns. Is it on a curve? Is the ment of the program plus the willingness of NYCT's managers to signal obscured by signal or foliage? support the findings of the safety audits have made the program a What is the distance from the previous meaningful component of the agency's overall safety program. signal?