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56 Improving Safety-Related Rules Compliance in the Public Transportation Industry Responding to Noncompliance For one major railroad, a typi- When a transit agency determines that an employee has been noncompliant with cal month resulted in 4,269 dif- a safety-related rule, the first response should be to determine why the employee ferent items examined on the failed to comply. For each instance of noncompliance, the agency should use the event recorder downloads. Of taxonomy and questions designed to determine root cause presented in Chapter 3. these, there were 142 excep- Once the agency determines root cause, it can work to remediate the underlying tions of which 30 were found to cause(s) and contributing factors. Remedial efforts may be in conjunction with or be significant. Decertification in addition to the following methods. of the engineer resulted for 13 of these incidents. Without the Rule evaluation. The evaluation should consider safety-related rules in the analysis of the event recorder context of the work environment. At a minimum, the agency should determine data, management would not the answers to the following questions. have identified these events. 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.