Below are the first 10 and last 10 pages of uncorrected machine-read text (when available) of this chapter, followed by the top 30 algorithmically extracted key phrases from the chapter as a whole.
Intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text on the opening pages of each chapter.
Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.
Do not use for reproduction, copying, pasting, or reading; exclusively for search engines.
OCR for page 72
APPENDIX A
Rules Compliance Practices
in Other Industries
Other industries, similar to public transportation, must address safety-related rules com-
pliance in an effort to prevent low-probability, high-consequence events. The research team
selected aviation, railroad, motorcoach, trucking, petrochemical, and construction as industries
that face low-probability, high-consequence events and might offer best practices that are appli-
cable in the public transportation industry. Two criteria led to the selection of these industries:
the individual operator/employee is at significant risk for personal harm as a result of noncom-
pliance and the operator/employee puts the public at significant risk for harm as a result of rules
noncompliance.
Structured interviews with representatives from each industry provided the means to gather
information on current industry practices. The interview questions covered the various activities
these industries use to teach employees the rules, make sure employees understand the rules, ensure
rules are followed, and respond to noncompliance. In addition, the interview explored proactive
measures to encourage rules compliance and voluntary safety reporting programs designed to allow
employees to self-report rule violations and near-misses.
Table 12 summarizes the number of organizations contacted by industry as well as the number
of interviews that were conducted. The research team assured anonymity to the organizations
that were interviewed; consequently, this information is not included in this report.
The interviews produced a great deal of information on each industry. The aviation, railroad,
motorcoach, and trucking industries offer many best practices relevant to public transportation.
To facilitate the organization and presentation of the best practices for these industries, there is
a summary table for each industry that presents the best practices for the following aspects of the
safety-related rules compliance program:
· Initial rules communication
· Communicating new rules
· Validating rules comprehension
· Monitoring adherence
· Responding to noncompliance
· Encouraging compliance
· Evaluating program effectiveness
· Safety reporting mechanisms
Federal Aviation Administration (FAA) regulations govern the training and certification of
pilots. In addition, FAA examiners conduct check rides with commercial pilots to audit their
compliance with FAA safety regulations. Since these procedures do not differ from airline to
airline, this information was available from published sources. Therefore, the interviews with
aviation industry representatives focused on voluntary safety reporting systems for pilots.
72
OCR for page 73
Rules Compliance Practices in Other Industries 73
Table 12. Number of organizations interviewed
by industry.
Number of Interviews
Industry Contacted Completed
Aviation 20 12
Railroad 17 15
Motorcoach 8 6
Trucking 9 6
Petrochemical 8 2
Construction 1 1
Aviation
Table 13 summarizes the rules compliance and safety reporting practices of the aviation
industry.
FAA regulations govern flight operations as well as the certification and training of pilots
(Title 14 C.F.R., although still commonly referred to as the Federal Air Regulations or FAR).
A student pilot who begins training is introduced immediately to the flying regulations that apply
to the student's level of flying. At each level of certification, both a written examination as well
Table 13. Rules compliance practices of the aviation industry.
Program Characteristic Industry Practices
Initial rules communication Classroom presentations
Computer-assisted training
Communicating new rules Through computer-based files indicating
information has been read
Memorandums with copies that must be
signed/initialed and returned
Validating rules comprehension Written or computer-based testing
Recurrent classroom training
Recurrent simulator training
Operational line checks
Monitoring adherence Voluntary Safety Reporting Systems
Operational Flight Monitoring Systems
Operational error and pilot deviations and
reports
FAA violations
Responding to noncompliance Dependent on level of deviation/violation
and current labor agreement
Informal conference with supervisor
Formal investigation within company
Formal investigation with FAA
Encouraging compliance Voluntary safety programs
Crew Resource Management
Top-down safety culture
Emphasizing the causes of safety issues
rather than an emphasis on disciplinary
action
Evaluating program effectiveness Decrease in incidents/accidents
Analysis of voluntary safety reports
Benchmarking with other airlines
Input from the FAA
Line operational safety audits
Safety reporting mechanisms Safety hot lines
Aviation Safety Reporting System
Aviation Safety Action Program
Other company reporting systems
OCR for page 74
74 Improving Safety-Related Rules Compliance in the Public Transportation Industry
as a practical, or flying, test is required. As a pilot moves through the various levels of certification,
he or she is introduced to the appropriate flying regulations, and must understand these regulations
in order to complete the written, oral, and flying evaluations. In order to be hired by an airline
or a corporate flight department, a pilot must be certified at the commercial level, with an instru-
ment rating, and have a certain level of flying experience. During this period of preparation,
the individual will have been exposed to the flight regulations through both the academic and
practical flying environment. Therefore, when the pilot is then hired by a flying corporation, he
or she is already expected to be familiar with the FAR. During the pilot's initial training, he or
she is then presented with the flight regulations that apply to the particular type of flying that he
or she has been hired to do. Follow-on simulator and in-flight training re-emphasize the general
flight regulations, as well as the specific regulations. Thus, when the pilot begins operational flying,
he/she has been exposed to, and is expected to know, all the flight regulations that apply to the
new flight environment. In summary, then, as a baseline, the new employer has trained the new
pilot to understand any specific regulation that applies to the particular type of flying, and has
also re-emphasized general flight regulations.
Once a pilot is employed, the FAA requirements for continuous recurrent training apply.
The basic requirement calls for a certain amount of annual ground school, a certain number
of simulator periods that include flight checks, and the requirement that Pilots-in-Command
(Captains) receive a periodic operational line check. In addition, a flight crew may receive an
unannounced random line check from an FAA flight inspector at any time. In recent times, many
airlines have moved to the Advanced Qualification Program, another voluntary program through
the FAA that emphasizes training outcomes and scenario-based training. In general terms, this type
of training moves away from the pass/fail checkride mode, and highlights training and proficiency
goals. This type of training also uses a simulator exercise called Line Oriented Flight Training
(LOFT), which accomplishes the training in an operational scenario, rather than simply dealing
with specific flight maneuvers. This type of training is a major change to the older concept of
periodic checkrides and results in more effective training and pilot proficiency.
In the distant past, once a pilot began operational flying, the pilot's major concern involved
incidents and potential violations, resulting in discipline from the FAA or the airline. This resulted
in a mentality in which any potential safety issue that was not detected by the system was kept
secret. Pilots feared potential discipline, especially certificate suspension or revocation. In addition,
it was common for a company to terminate a pilot for such incidents or violations. Needless to
say, this did not encourage an environment where a pilot was willing to voluntarily disclose any
safety issue. To help combat this perception, the Aviation Safety Reporting System (ASRS) was
created in the 1970s. ASRS encouraged pilots to report safety data so that safety trends could be
analyzed and system corrections could be made. A detailed description of this system is in
Appendix C.
Data gathered in ASRS revealed that the most common incident or violation involved an
altitude deviation. As a result, a program was developed whereby airlines and corporate aviation
departments could develop a voluntary system for reporting these events, and in return the pilot
would again receive protective provisions. The Aviation Safety Action Program (ASAP) is explained
in more detail in Appendix C. This successful voluntary safety program, which is classified as
confidential and nonpunitive, is today a leading contributor to overall flight safety, and has been
fully accepted by the FAA, the airlines, and the labor unions.
Aviation groups, unions, industry groups, and the FAA offered the following comments
regarding ASAP:
· The system emphasizes the root cause of incidents and violations, rather than a punitive
discipline program.
OCR for page 75
Rules Compliance Practices in Other Industries 75
· Approximately 90% more incidents and violations are being uncovered due to the nonpunitive
aspect of the program.
· All the stakeholders have a high level of confidence in the system.
· Safety concerns are now being examined by all parties and system corrections are being made
so that these concerns do not develop into accidents/incidents.
The FAA's Flight Operations Quality Assurance Program (FOQA) is another example of a
successful voluntary program. This program allows airlines to download information regarding
the movement of an aircraft from one point to another via flight data recorders. The program is
confidential and negotiated through a memorandum of understanding among the FAA, labor,
and airlines. The information obtained is not used punitively. Rather, it provides information
about aircraft handling that otherwise would go unnoticed.
Railroad
Table 14 summarizes the rules compliance practices of the railroad industry.
The Federal Railroad Administration (FRA) regulations prescribe a program of operational or
efficiency testing (40 C.F.R. 217) to determine compliance with operating rules. As of January 1,
2009, this program must place emphasis on those operating rules that cause or are likely to cause
the most accidents or incidents. In addition, FRA requires that locomotive engineers be certified
every 3 years. Each engineer must have a check ride every year. Each railroad sets the frequency
of rules exams but Federal Regulations require that the railroad's program/policy be filed with
FRA. Because of these requirements, the approach of all railroads to validating rules compliance
is similar. Labor agreements and the Railway Labor Act prescribe procedures for progressive
discipline for rules violations so the response is similar from railroad to railroad. In spite of
these common requirements, there are significant differences in each railroad's approach to the
overall rules compliance process.
Locomotive engineers and conductors are trained by the railroad that hires them. The length
of this training may vary but all railroads use some combination of instructor-led classroom
training and action-based training, and sometimes CBT. Feedback from labor indicates that
the most effective rules training is instructor-led, involves practical application or illustration
of the rule, and includes an explanation of the purpose of the rule. Railroads use written tests or
computer-based tests to validate the employee's rules knowledge. When there is a change in a
rule or a new rule, the method for conveying this information will depend upon the complexity and
impact of the rule. For major changes, a class or video and job briefing will occur. Other changes
will be covered in a general order or system bulletin and then be incorporated into the rule book.
All railroads use operational/efficiency testing to monitor rules compliance. In addition, some
download locomotive event recorder data to monitor an engineer's performance relative to
operating and train handling rules. One railroad reported that this method allows it to identify
red light run-throughs that it would not otherwise have known about. Labor expressed the concern
that this technology can be overused and in some cases have a negative impact. Most railroads
also review radio transmissions. Per FRA requirements, all railroads use accident and injury data
to focus their testing programs. One railroad reported focusing on human factors accidents for
possible rules problems.
There is some variation in the responses to noncompliance. Some railroads do not discuss
the operational test results with the employee unless there is unacceptable performance. Many
railroads have a policy that supervisors are to give feedback but the positive feedback usually
comes later while failures are handled at the time of the test. One railroad reported that it gives
feedback immediately, regardless of the outcome. Labor prefers this approach. The supervisor
OCR for page 76
76 Improving Safety-Related Rules Compliance in the Public Transportation Industry
Table 14. Rules compliance practices of the railroad industry.
Program Characteristic Industry Practices
Initial rules communication Instructor-led classroom training with scenarios
Computer-based training
Action-based training
Communicating new rules Track Bulletin, System Bulletin, Timetable
Class or video and job briefing for major
change
Validating rules comprehension A minimum of biennial rules class and
testing
Scenario-based simulator for train handling
Operational/efficiency testing
Monthly meeting of management/labor
committee discusses problematic rules
Review test results to identify areas that
need more attention
Monitoring adherence Operational/efficiency testingmay be
scenario-based
Review accident/injury data with focus on
human factors accidents
Download locomotive event recorder data
to monitor operating and train handling
rules
Audit teams to validate testing
FRA violations
Review radio transmissions
One-day safety assessment of co-workers
Responding to noncompliance Discuss test failure with employee
immediately so cause can be identified
Progressive discipline per labor agreement
Alternative process with minor, serious
and major violation instead of formal
investigation
Supervisor interview to determine
appropriate actions, e.g., training,
coaching
Encouraging compliance Safety briefings
Train supervisors how to coach and
counsel employees
Mutual accountabilityboth supervisor
and employee hold each other to standard
of accountability
Crew Resource Management
Signal awareness forms (conductor
records each signal passed)
Safety audit program not part of discipline
process
Safety Assurance and Compliance
Program at System and Division levels
Debriefing of every accident and incident
with no discipline attached
7Cs Programconfirming,correcting,
caring, collaborating, coaching,
conciliating, clarifying
Evaluating program effectiveness Relationship between results of
operational testing and accidents/incidents
and FRA violations
Change in number of accidents and injuries
Change in operational/efficiency test failures
Benchmarking with other railroads
Safety reporting mechanisms Close Call Reporting System Pilot
Program
Safety hotline
Open communication between supervisors
and their people
OCR for page 77
Rules Compliance Practices in Other Industries 77
may discuss unsatisfactory test results with the employee and recommend an appropriate action
such as training or coaching.
Railroads reported a variety of proactive strategies for encouraging rules compliance. These
include training supervisors how to coach and counsel employees, adopting a policy of mutual
accountability between the employee and supervisor, conducting safety audits that are not part of
the discipline process, and conducting a debriefing of every accident with no discipline attached.
The railroad industry has been characterized by some as having a culture of blame but there
are efforts to change this. The ongoing Confidential Close Call Reporting System (C3RS) pilot will
determine whether a nonpunitive near-miss reporting system will identify hazardous situations
before an incident or rule violation occurs. (See Appendix C.) Aside from C3RS, one Class I
railroad is implementing a nonpunitive reporting mechanism that will be managed by the labor
organizations that represent its employees. There are also efforts to promote open communica-
tion between supervisors and their people.
Advice from railroad industry and labor representatives to public transit agencies included the
following:
· Train the first line supervisor to deal with individuals that violate an operating rule in a
non-confrontational way.
· Discuss noncompliance issues with other transit agencies and similar industries.
· Implement programs such as job briefings and increased rules classes that promote more
communication between first line supervision and labor.
· Know your people and listen to them. Make sure supervisors are spending time in the field
getting to know their people and talking to them.
· Make sure employees know the rule, the intent of the rule and how the rule is applied.
· In order to take safety and rules compliance to the next level you have to understand why the
violation occurred. A misunderstanding or lack of knowledge should be treated differently
than conscious disregard of a rule.
· Involve employees in the development of operating rules and procedures.
· Consider additional regulations for the public transportation industry that will help improve
its safety performance.
Motorcoach
Table 15 summarizes the rules compliance practices of the motorcoach industry.
Other than medical standards and commercial driver's license (CDL) requirements, Federal
Motor Carrier Safety Administration (FMCSA) has no oversight of driver rules compliance.
Most over-the-road motorcoach companies provide both classroom and over-the-road training.
One company did report that it only hires experienced drivers with a CDL. This company does
a review of all candidates including an extensive background check and a psychological profile
test to be sure that the individual meets the company's requirements for drivers. Orientation at
this company covers company rules and policies and also includes a crisis management program.
Most companies have written exams but one smaller motorcoach operator reported that it relied
on the recommendation of an experienced driver who trains the new hire.
Motorcoach operators use a variety of methods to monitor compliance with safe driving rules.
These methods are the following:
· A majority of the companies that the research team contacted reported that they use a video-
based system for monitoring driver behavior. The system is triggered by an unsafe driving
OCR for page 78
78 Improving Safety-Related Rules Compliance in the Public Transportation Industry
Table 15. Rules compliance practices of the
motorcoach industry.
Program Characteristic Industry Practices
Initial rules communication Initial training that may include self-directed
study via CBT, classroom and over-the-road
training
Communicating new rules Notices mailed to drivers' homes
Memorandum posted in drivers' area
Safety meetings
Update training
Validating rules comprehension Written exam
Check out by veteran driver or trainer
Discussion at safety meetings
Monitoring adherence Onboard cameras for video recording
GPS tracking data
Mystery riders
Public feedback via internet or 800-number
On-road observation by field safety staff
Ride-along by operations staff
Responding to noncompliance Coaching
Retraining
Progressive discipline
Encouraging compliance Awards or financial incentive for no
preventable accidents or other safety
violation such as cell phone use while on
duty
Evaluating program effectiveness Track at fault collisions, customer
complaints
Accident Review Board
Review events from video data recording
system
Safety reporting mechanisms 800-number for reporting; treated as
confidential
Safety committees
Driver suggestion box
Management open door policy
behavior such as hard braking or speed. When the event occurs, the system saves a video
recording of the event along with engine data.
· Some companies hire mystery riders who purchase a ticket and ride the bus to observe the
driver with regard to speed, customer service, distracting activities while driving, following
distance, and other safety behaviors.
· Some companies have GPS tracking systems on their vehicles. These systems provide position
and speed data.
· Some companies rely on observation by safety managers from a trailing vehicle.
In addition to the above activities, motorcoach operators also review customer complaints
that come through an 800 number or email.
When management becomes aware of an unsafe driving behavior through one of the methods
described above, the driver's supervisor will meet with him or her to discuss the observation. The
driver may be coached or sent for retraining. The information from the video monitoring system is
used as a training tool, not as a means to discipline drivers. In every place where this system is in
operation, labor initially resisted it. After a number of instances where the video data showed that
the driver was not at fault in an accident, that is, it was a non-preventable accident, the drivers began
to support its use. Discipline is an option when the driver does not respond to coaching and training.
All motorcoach companies evaluate their compliance programs based on the number of
avoidable accidents. Those with video monitoring also look at the number of events that are
OCR for page 79
Rules Compliance Practices in Other Industries 79
reported. Motorcoach operators that use video monitoring all reported a decline in accidents
after the system was installed.
Nearly all of the motorcoach companies have an incentive program to reward safe driving.
Many of the people interviewed stressed that the drivers value these programs because the programs
recognize the drivers as professionals. Both labor and management made this point. In some
companies, compensation is based on safe driving.
Motorcoach industry and labor representatives offered the following advice to the transit
industry:
· The most important way to encourage safe driving is to have open communication between
the employees and management. Have an open-door policy and do one-on-one counseling.
· Safety must be a goal for everyone. Management sets the tone for safety, starting at the top.
· Conduct periodic safety meetings that include a review of actual situations that have occurred.
· Do a thorough background check and conduct a comprehensive road test before hiring a driver.
If you hire the right people, there are fewer performance issues.
Trucking
Table 16 summarizes the rules compliance practices of the trucking industry.
FMCSA has no direct oversight of driver rules compliance. Therefore, the agency thought the
interview efforts of this project would best be suited for specific fleets and industry organizations.
The following summarize these efforts.
Table 16. Rules compliance practices of the trucking industry.
Program Characteristic Industry Practices
Initial rules communication Instructor-led training
Practice in nonrevenue service
Read and sign policy
Communicating new rules Read and sign policy
Safety briefing
Validating rules comprehension Periodic safety quizzes
Periodic driver re-certification
Quarterly Internet-based safety training
Monitoring adherence Ride-along
Public reporting via 800 phone number
Private monitoring services for covert
observation
Hard braking data from engine recorder
Responding to noncompliance Remedial training
Peer coaching
Progressive discipline
Conduct root cause analysis
Encouraging compliance Periodic safety meetings
Monthly newsletter
Posters
Incentive award system for positive safety
behavior
Employee recognition program
(nonmonetary)
No tolerance policy for use of electronic
devices
Defensive driving program
Evaluating program effectiveness Evaluate rule book and modify for clarity
Hard braking frequency
Safety reporting mechanisms Confidential report to safety department
OCR for page 80
80 Improving Safety-Related Rules Compliance in the Public Transportation Industry
The trucking industry is a proud proponent of safe operating practices. These companies realize
they can either pay up front for proactive safety measures, or they can pay later (most likely at
greater loss to the company) for accidents resulting in injury and claims. Therefore, they consider
safety to be an investment.
The industry hires inexperienced as well as experienced drivers and uses various employee
screening methods. The most predictive of these methods are the drug and alcohol offender
screening process and the review of moving violations. The types of initial training for each differ
based on experience. Subsequent information regarding rules may be relayed during periodic
safety briefings. Some have traditional types of training (e.g., biennial spring/winter training).
In the winter, specific types of safety rules can be revisited such as driving in icy weather, whereas
spring training will highlight different driving challenges (e.g., fatigue resulting from the driver
pushing him- or herself because of the extra daylight hours). There is a trend toward moving
from these traditional types of training to more frequent (sometimes five times a year) CBT along
with an annual rules recertification and in-truck assessment.
One company recently revised its rulebook examining each operating rule for relevance.
It assigned employees, including drivers, to working groups for each section of the operating
manual. The process took 3 months and uncovered areas where retraining was necessary. The
end product was a streamlined version of the rulebook that was driver-friendly and provided
much-needed clarity of the written rules.
The trucking profession consists of primarily two types of drivers. Some have dedicated routine
assignments while others are long-haul operators. Both types of drivers present unique challenges
to the companies that employ them. It is particularly difficult to manage long-haul drivers and
create a sense of cohesiveness among the workforce. Large companies feel the need to create an
atmosphere of individual responsibility given the sometimes geographically distributed workforces.
In addition to fostering self-monitoring, these companies will require periodic ride-alongs,
monitor motorist reports, as well as review automated truck-handling reports. They also keep
track of accident data to inform risk assessment. These monitoring strategies act as proactive ways
to prevent accidents, but they also provide a means for the company to identify noncompliant
individuals, intervene through coaching or procedural changes, and then track subsequent
behavior.
The industry is proactive in many regards. One trucking company reported that it looks
beyond the cause of accidents attributed directly to driver error. This company recognizes the
fact that 65% of accidents are due to reasons other than faulty driving. As a result, the company
looks at these incidents to identify ways to improve driver ability to prevent similar occurrences.
To facilitate this proactive approach, the company relies heavily on a private methodology geared
toward teaching drivers to be aware of their surroundings.
These companies rely on incentive programs to engage their employees. They report traditional
bonus programs, but also use non-monetary rewards like safety recognition (e.g., the CEO of the
company might send a personalized letter to a valued employee). One trucking company reported
that it believes these programs are undervalued. The interviewee stated that many trucking
companies spend so much time identifying when things potentially go wrong, that they sometimes
forget the importance of acknowledging the people who provide safe and efficient transport
services.
A labor representative commented that it is important to train and recognize vehicle operators
as professionals. While much of the responsibility of professionalism falls on the shoulders of the
drivers, the companies that employ these individuals are responsible for providing the opportunity
for professional certification, honoring good driving behavior, and compensating their drivers
competitively. These company actions will go a long way toward encouraging safe driving behavior
OCR for page 81
Rules Compliance Practices in Other Industries 81
and helping drivers not feel the need to take shortcuts or make unsafe actions in the interest of
generating more income (e.g., violating hours of service, speeding, etc).
When asked what advice to offer the public transportation industry, one company remarked
that you "must start with a foundation of safety culture." Management commitment from the
top-level down is the only way this can be accomplished. Labor also remarked on the importance
of fostering a safe culture.
Petrochemical
The research team conducted interviews with two petrochemical companies. Table 17
summarizes the practices of these two petrochemical companies.
All employees, including office workers, receive safety training as part of their initial orientation.
Those employees who handle chemical products are trained in the standards relevant to their
particular job. Some training is computer-based/online, but most is on-the-job with an experienced
employee. In addition, one petrochemical company reported holding monthly safety meetings.
This company emails new or changed rule details to employees if the monthly meeting is scheduled
more than a few days after a rule change is effective.
One company conducts safety audits of all hazardous material remediation projects as well as
its plant operations. Audit results are summarized in a Safe Act Index. Any employee found to
be non-compliant during the safety audit will be educated appropriately. The other petrochemical
company relies on its shift supervisors in the plant to monitor adherence to safety rules. This is
the primary way that management becomes aware of rule noncompliance. Employees at both
companies are also strongly encouraged to self-report incidents as well as near-misses, also
referred to as unanticipated occurrences (UO).
Remedial training may be recommended when there is a safety violation. Dismissal would
occur only in the most egregious cases or if there are repeated willful actions. One company
reported that management expects supervisors and managers to intervene and coach on the spot
for any actions that do not follow policy, regardless of whether or not it results in an event.
Both companies use leading/lagging indicators to monitor the effectiveness of their safety
compliance programs. Examples of leading indicators are monthly safety meeting attendance,
Table 17. Rules compliance practices of the
petrochemical industry.
Program Characteristic Industry Practices
Initial rules communication Computer-based training
OJT
Communicating new rules Email changes
Monthly safety meetings
Validating rules comprehension Safety audit
Monitoring adherence Safety audit
Supervisor observation
Responding to noncompliance Remedial training
Coaching
Encouraging compliance Monthly safety meetings
Coaching
Safety audit
Evaluating program effectiveness Leading/lagging indicators
Safety reporting mechanisms Self-report incidents and near-misses
OCR for page 82
82 Improving Safety-Related Rules Compliance in the Public Transportation Industry
completion of UO reports on time, and the requirement for one safety contact per employee
quarter. Safety contacts can be providing training at monthly safety meetings, audit completion,
completing a Project Safety Analysis, or calculating a Safe Act Index. Lagging indicators are
environmental deviations, incidents, and injuries.
The petrochemical companies report that they use safety training, safety meetings, peer
coaching, and auditing to encourage compliance. Representatives at one company reported
that "Safety is not an option; it is a culture." Management expects employees to comply.
When asked for advice to public transportation industry management, interviewees offered
the following:
· You will achieve the level of safety excellence that you demonstrate that you want to achieve.
· There must be a way to check if rules are being followed.
· A clear focus from senior management that safety is important and is a fundamental policy of
the company will set the tone for how people work.
Construction
The research team contacted a major construction company based in Massachusetts to learn
about its safety rules. Because this industry involves the use of construction equipment and large
trucks, there was a possibility that some useful practices with application to transit operations
would exist. (Its vehicles cover 3 to 5 million miles a year in total.)
Most of the initial training to new hires involves personal safety but the training also covers
driving safety. The company has the employee sign a safety "agreement" after reviewing the safety
handbook. New hires are assigned a mentor, usually a senior foreman, who works with them to
help them identify and avoid hazards.
There is no formal rules compliance testing or evaluation. Foremen are responsible for
monitoring employees. If an incident occurs, a superintendent or project manager may then
increase monitoring of the foreman and the foreman's people. The company keeps a record of
all safety infractions. Depending upon the nature of the safety infraction, there is a progressive
discipline policy.
The company evaluates the effectiveness of its safety program by monitoring the number
of injuries requiring first aid, number of recordable injuries, and lost-time injuries per hours
worked.
The company treats near-misses as an incident and asks employees to report them on the
incident report form. These reports, which go to the safety director, are confidential but not
anonymous.
The safety director reported that the company tries to maintain a culture of safety but that this
requires personal involvement from management. When asked what advice he would offer to
public transit management, his comments were more about safety culture than rules compliance.
He offered the following:
· Share information with everyone, be it good or bad. Report the what and why, not the who.
· Management involvement and support is very important. If the management is involved, then
the employees will follow.
· Be constantly alert; just because there has not been an incident does not mean it cannot happen.
Since the practices of the construction industry did not appear to offer any practices or strategies
that were not present in the other industries, there were no additional interviews with construction
companies.
