Improving the Safety, Health, and Productivity of Transit Operators Through Adequate Restroom Access (2020)

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80 Service Delivery Considerations Even where restrooms have been identified and transit agency (TA) policies and schedules have been adapted with operators’ needs in mind, issues related to restroom access can still have a negative impact on service delivery. Infrastructure and planning steps can also fail to translate into adequate access for operators, leading to unexpected delays, passenger complaints, and other service problems. There are multiple barriers to efficient service: When passenger load, traffic or weather slows service, vehicle operators may find that the turnaround time that is adequate in off-peak hours or in better weather is just not enough. More difficult to plan for are the unforeseen breaks in driving that restroom urgency can lead to. If public or commercial restrooms have not been identified, or if access to them has been lost or limited, operators may to find their own rest- rooms or negotiate terms of use independent of the TA. Sometimes, more subtly, pushback on service delivery can come from supervisors, from dispatch, from passengers, and even from operators’ own sense of commitment to passengers or fear of discipline. The result for about half of the project participants was that, in bus, rail, and paratransit services, vehicle operators could not get to a restroom within 15 minutes of needing one. Delays were often well beyond the Occupational Safety and Health Administration (OSHA) limit of C H A P T E R 5 Service Delivery Organizational environment and practices Infrastruc- ture and capital planning Route planning SchedulingService delivery Cost assess- ment and evaluation

Service Delivery 81 10 minutes, as shown in Figure 5-1. Bus operators always or usually waited 15–30 minutes in 18% of the TAs; in half the TAs, they waited sometimes. Delays of 30–60 minutes occurred in 31% of the TAs sometimes, and delays of more than 60 minutes occurred in about 16% of the TAs sometimes. Delays for train and paratransit operators were only slightly less common. In a large TA, unscheduled restroom use had resulted in rush hour delays that were at least sig- nificant, as reported in the news, affecting up to five connected subway lines (Musumeci 2019). When vehicle operators have to take unscheduled breaks, service delays are likely to occur. Because of this, operators may avoid stopping. As repeatedly described by project participants, they do not want to inconvenience passengers, and they do not want to be criticized by super- vision. This causes discomfort, stress, and, possibly, health problems. In the long run, any resulting operator health problems could further affect service delivery if limited restroom access leads to increased absenteeism or retention problems. However, in the opinion of most project participants, operator availability and retention were not related to restroom access. Overall, TAs had not begun to evaluate any connection there might be between restroom use and service delivery, and they did not typically explore the personnel impacts, including costs related to lost time, disability, or retention. At the same time, they recognized that delays might occur and that operator health and comfort are important in recruiting and retaining a productive workforce. This chapter explores how TAs attempt to minimize service delays caused by the restroom access needs of vehicle operators. The main steps described by project participants were selecting adequate restroom facilities located close to routes at regular and short intervals and keeping them available, clean, and safe. Strong channels of communication between TA divisions, between levels of the workforce, and with potential restroom hosts were considered essential. Good Practices to Maintain Service Delivery In the context of service delivery, the tasks are as shown in Box 5-1. 0% 10% 20% 30% 40% 50% 60% <=15 15-30 30-60 >60 <=15 15-30 30-60 >60 <=15 15-30 30-60 >60 Ra il Ra il Ra il Ra il PT PT PT PT Bu s Bu s Bu s Bu s M in ut es D el ay Always or usually Sometimes Figure 5-1. Survey results: Restroom use delay in minutes, by frequency of delay and percentage of TAs reporting.

82 Improving the Safety, Health, and Productivity of Transit Operators Through Adequate Restroom Access Good Practices: Rules for Restroom Access Reduce Service Impact TA and local union (LU) sources emphasized the need to keep TA restrooms for employee use only because having to wait makes it diffi- cult to leave on time. This also means that there should be enough stalls to meet the operators’ projected needs for the stop. TAs can improve availability when they choose gender-neutral facilities if there are single or separated stalls, so they can be used as needed. Under OSHA regula- tions and some local and state restroom laws, two gender-designated facilities are required if the stalls are not separated. In A Guide to Restroom Access for Transgender Workers, OSHA (2015) supports using gender- neutral restroom stalls when practical; that document also reviews some relevant state laws. Good Practices: Adequate Restroom Access Is Available Along Routes and at Layovers TAs typically establish and maintain a database of locations including commercial and public facilities, as discussed in Chapter 3. At a minimum, according to WMATA’s detailed report on types and locations of restrooms, they “should have as many of the following characteristics as possible: ADA compliant, within a 3-minute walk of the bus stop, accessible within . . . hours of operation, multiple fixtures (i.e., restroom stalls)” (WMATA 2018). Box 5-1. Service Delivery Policies and Practices Rules for restroom access reduce service impact. • Keep transit agency restrooms employee-only. • Choose gender-neutral facilities if stalls are single or separated; otherwise, two separate gender-designated facilities are required. • Reduce delays related to requesting keys or tokens. Adequate restroom access is available along routes and at layovers. • Maintain database of locations, including commercial and public facilities. • Provide updated lists to operators. • Communicate with host locations. • Establish contracts with host locations as needed. • Adjust to temporary and permanent changes (e.g., construction, parades). • Provide relief driver when needed. Restroom quality is maintained. • Meet OSHA sanitation standards (toilet paper, soap, running water for washing hands, towels or dryers, light and heat when needed, and use of portable toilets as a temporary solution). • Ensure safety (locks, protected space, lighting). • Arrange for cleaning and supplies. • Inspect restrooms regularly. • Schedule and carry out maintenance. Rules for restroom access reduce service impact. • Keep transit agency restrooms employee-only. • Choose gender-neutral facilities if stalls are single or separated; otherwise, two separate gendered facilities are required. • Reduce delays related to requesting keys or tokens.

Service Delivery 83 Collating this information, once it has been collected, does not have to be complicated. The simplest form lists route name, street names, restroom location name, and access hours. TAs can provide updated lists to operators with the driver paddle or electronically and maintain the lists with the headway sheet for the use of dispatchers or service coordinators. Either the file or the line should note when updates have been made. One TA made sure to include locations for both ends of the line and at the middle for longer lines. A recent collective bargain- ing agreement requires the employer to “maintain an up-to-date list of bathroom facilities for each route, with hours of accessibility and location, and . . . make copies of the list readily available to transit employees.” The target for most TAs was to use restrooms on company property, especially at terminals. However, to achieve timely unscheduled access, restrooms were identified along routes; these were typically privately owned. Depending on the size of the service area, TAs may simply rely on operators’ recommendations or may perform a systematic evalua- tion of routes by assigned staff such as restroom committee members, service coordinators, or field supervisors. The contact person will need to communicate with host locations, setting and recording expectations for use and any reimbursement. In some cases, use arrangements were informal and not paid for. In others, TAs made direct contacts with business owners about hours of open- ing, expectations for behavior from both parties, and communication channels. TAs described establishing contracts with host locations as needed. The most practical solution may be to arrange restroom use agreements or lease agreements with nearby establishments. If there are existing restroom facilities near a bus terminal, WMATA can attempt to establish a MOU or lease agreement with the facility owner to permit Metrobus operators to use the facility. Restroom use agreements can be of no cost or inexpensive—less than $250 per year—and do not require ongoing WMATA facilities maintenance. However, because the facility is not owned by WMATA, there is no guarantee of an available restroom when needed, which could delay route performance. In addition, not all nearby restrooms may be available during all Metrobus hours of operation. Lease agreements ensure that a restroom is always available for operators to use but may be costlier and can include maintenance stipulations. (WMATA 2018, p. 5) Many LU project participants reported that operators often felt obliged to purchase some- thing when using food or convenience store restrooms or were required to stand in line to request access. Use arrangements and contracts can be made to reduce delays related to requesting keys or tokens. Delays were also extended at rail stations if the operator had to ask a station agent or supervisor for a key. For paratransit and bus operators, security staff at clinics or libraries were not always aware of access agreements. Where possible, TAs preferred the use of key codes for all restrooms, as these could be changed easily and communicated via text or with route information. “Use and Lease Agreements” in Templates for Restroom Access Policies and Boilerplate Contract Language provides detailed language in the categories recommended in the WMATA report, which are listed in Figure 5-2. The tool also integrates suggestions from other TA exam- ples, and is designed to be adapted by TAs for specific locations and vendors as needed. Restroom use agreements are also included in arrangements made during construction proj- ects, when restrooms resources are temporarily not available, and when building shared facilities. For example, as part of a right-of-entry agreement during construction of transit facilities, a con- tract with the Transbay Joint Powers Authority detailed that “Driver Restroom facilities will be Adequate restroom access is available along routes and at layovers. • Maintain database of locations, including commercial and public facilities. • Provide updated lists to operators. • Communicate with host locations. • Establish contracts with host locations as needed. • Adjust to temporary and permanent changes (e.g., construction, parades). • Provide relief driver when needed.

84 Improving the Safety, Health, and Productivity of Transit Operators Through Adequate Restroom Access provided, initially as portable trailer mounted facility,” the temporary facility is specified as flush and with sink (Transbay Joint Powers Authority 2017). Another SFMTA agreement addresses shared space used by the municipal parks department, covering the installation of a temporary modular restroom including a deck, fencing, and signage, to be accessed by parks users and by construction and other staff. It guarantees that the public will not be allowed to access transit property via the shared restrooms (SFMTA 2017). These are examples of how TAs adjust to tem- porary and permanent changes in availability. Planning is also needed for shorter-term changes such as parades and athletic events. In addition to affecting routes, such changes can dramatically increase passenger demands, run times, and competition with the public for restroom resources. Some TAs reduce service problems and ensure time for restroom access when they provide relief drivers. Train operator relief was described by one TA to limit train congestion. This required radio communication with control centers to make sure a driver was available or to send one to an agreed-upon stop. A small bus service reported working on providing relief drivers at all terminals, and a larger one reported using field supervisors, who are available across the service area. An LU respondent supported these approaches, calling on the employer “to provide more relief along the lines in terms of relief operators or supervisors.” Good Practices: Restroom Quality Is Maintained As discussed in detail in Chapter 2, employers must meet OSHA sanitation standards—providing toilet paper, soap, running water for washing hands, towels or dryers, and light and heat when needed and using portables as a temporary choice. When project participants were asked if the available restrooms were maintained in compliance with federal sanitation standards, only the bus drivers were confident about the TA’s approach (88% responding usually or always), as shown in Figure 5-3. Rail and paratransit respondents rated compliance at around 50%. The Compliance Checklist for OSHA Standard 141(c): Toilet Facilities, shown in Figure 2-5 and provided in Templates for Restroom Access Policies and Boilerplate Contract Language, includes these and other requirements that transit employers have been cited for violating. Restrooms were reported by 70% to 80% of survey respondents to be usually or always clean. At the same time, cleanliness was a fre- quent concern in interviews. Cleanliness is included on the various inspection forms TAs provided to the project, and restroom teams felt that this was a priority. Contracted restrooms in convenience stores were often not cleaned regularly, and even • Date of agreement and duration • Parties/entities involved • Restroom location and description • Restroom hours and days of operation • Amount to be paid by TA for restroom use and frequency of payment (if any) • Use etiquette • Maintenance expectations (if any) • Termination clause Figure 5-2. Sections of a restroom use agreement or lease. Restroom quality is maintained. • Meet OSHA sanitation standards (toilet paper, soap, running water for washing hands, towels or dryers, light and heat when needed, and use of portable toilets as a temporary solution). • Ensure safety (locks, protected space, lighting). • Arrange for cleaning and supplies. • Inspect restrooms regularly. • Schedule and carry out maintenance.

Service Delivery 85 TA-operated locations did not always receive adequate attention. Frequently, the public was seen as the culprit; as one source put it, “We have had to provide separate portable toilet facili- ties for passengers because when they were allowed access to the operator restrooms, there were vandalism, cleanliness, and hoteling issues.” Some TAs and LUs blamed the operators themselves for messes; one said the main problem they faced was, “Operators abusing rest- rooms, such as defecating on [the] ground or defacing walls, forces [the] restroom to be shut down until cleaned or repaired.” There was a general sense that women were both neater and more fastidious than men and that some postponed using designated locations out of hygiene and safety concerns. One TA investigated the use of a self-cleaning restroom module to be installed where all the other potential restrooms were 5 minutes or more from the stop. However, the municipality insisted that the public be allowed to use it, and the TA decided that the delays would not be reduced in this case. More than 80% of survey respondents felt that the facilities were usually or always safe, although, in interviews, the need to ensure safety (locks, protected space, lighting) was one of the most important considerations for siting and selecting restrooms. In some TAs, the safety department was a regular member of the restroom team, although sometimes staff were called in only when events occurred. Planning for safety is discussed in more detail in Chapter 3. Finally, there are the day-to-day quality assurance steps. It is routine for TA facilities manage- ment teams to arrange for cleaning and supplies for operator restrooms on transit property. Some include this in the usage fees agreed upon. A facilities supervisor explained that their in-house cleaning crews also clean some of the restrooms at contracted commercial or other public-sector locations. It added very little to the demands on the crews and allowed for quality monitoring and assurance. Beyond this, facilities teams schedule and carry out maintenance of restroom facilities. The staff participating in one restroom committee meeting demonstrated how well they were integrated into the process, describing plans to install the same hardware over time in every location so as to make responding to repair orders more efficient. They had also changed the kind of wall paint and kickboards used, so that floors could be cleaned without 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% Bus Rail PT safe clean in compliance Figure 5-3. Survey results (percentage of 114 surveys with responses of usually or always): Are restrooms in compliance with standards, clean and safe?

86 Improving the Safety, Health, and Productivity of Transit Operators Through Adequate Restroom Access damaging the infrastructure. They were also aware of problems at specific locations that had been reported by operators and other staff. All of these steps require that someone be assigned to inspect restrooms regularly. Who this is is less important than making sure they have enough time and clear instructions and that the restroom team responds quickly and systematically to problems as they are identified. Two TAs were developing programs to use release time or light-duty bus operators provided with cameras to document issues. The role of field operations in inspecting restrooms to ensure they are adequately maintained is shown in Figure 5-4, which is drawn from “Detailed Transit Operator Restrooms Policy” in Templates for Restroom Access Policies and Boilerplate Con- tract Language. Templates for Restroom Access Policies and Boilerplate Contract Language also includes a “Restroom Inspection Report Card for Field Inspections” and a “Restroom Inspection Report Card for Vehicle Operators.” This was adapted from the “Finder-Inspection Checklist” in Transit Operator Restroom Inventory Tools. Conclusion The suggested practices in this chapter are of course closely linked to the organizational, infrastructure, and route and schedule planning steps already covered. They are more focused on day-to-day practices and quickly changing issues. The steps also support the data collection and adjustments that are discussed in the final chapter. Service Quality’s First Line field supervision staff will support the Restroom Program by inspecting and submitting [a paper/an electronic] report for all restroom facilities [state schedule ex. each quarter]. The form will comprehensively cover the status of the restroom’s key elements, including • Safety and security, • Distance documentation, • Cleanliness, • Running (tepid or hot) water, • Soap and paper products, • Ease of access, • Hours of availability, • Vendor status changes, • Investigation and documentation of complaints by operators or vendors, and • Maintenance issues and hardware concerns. Figure 5-4. Maintaining restrooms.