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Best Practices You Can Use 57 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 The Burlington Northern Santa Fe (BNSF) Rail- coach should identify ways to improve performance or safety- way has an Alternative Handling Agreement related rule compliance. Coaching should occur as soon as pos- with the United Transportation Union and sible after noncompliance occurs. the Brotherhood of Locomotive Engineers and Trainmen. They use the term alternative handling in lieu of alternative discipline Discipline. This topic, including best practices, is reviewed in because the infraction does not go on the greater detail in Chapter 2. A majority of transit agencies sub- employee's permanent record. The employee scribe to some form of a progressive discipline program with a no has a choice between using the traditional tolerance policy for egregious and criminal acts. This generally progressive discipline program and alternative entails verbal warning/reprimand for the first offense, written rep- handling. Certain infractions are not eligible rimand with or without remedial training efforts, and then dis- for the program including decertification missal as a last resort. violations specified by federal regulation and other high-risk incidents. The employee % and number of discipline cases may be disqualified for alternative handling % and number of dismissals if repeated noncompliance occurs in a % and number of coaching cases % and number of remedial training cases 12-month period. 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.

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58 Improving Safety-Related Rules Compliance in the Public Transportation Industry 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. 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

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Best Practices You Can Use 59 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. Number of annual awards per 100 employees