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Appendix A - Rules Compliance Practices in Other Industries
Pages 72-82

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From page 72...
... 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.
From page 73...
... 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 Table 13. Rules compliance practices of the aviation industry.
From page 74...
... 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.
From page 75...
... 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.
From page 76...
... Rules compliance practices of the railroad industry.
From page 77...
... • 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.
From page 78...
... Those with video monitoring also look at the number of events that are 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 Table 15. Rules compliance practices of the motorcoach industry.
From page 79...
... The following summarize these efforts. 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)
From page 80...
... 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 80 Improving Safety-Related Rules Compliance in the Public Transportation Industry
From page 81...
... Both companies use leading/lagging indicators to monitor the effectiveness of their safety compliance programs. Examples of leading indicators are monthly safety meeting attendance, 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 Table 17.
From page 82...
... 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.


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