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Frequently Asked Questions

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Answer:

Safety Management System (SMS) is a comprehensive, collaborative approach to managing safety. It brings management and labor together to control risk better, detect and correct safety problems earlier, share and analyze safety data more effectively, and measure safety performance more precisely. 

SMS helps transit agencies apply resources to risk and ensure they have the organizational infrastructure to support decision-making at all levels regarding the assignment of resources.  

Some key parts of SMS include:

  • Defined safety roles and responsibilities;
  • Strong executive safety leadership;
  • Formal safety accountabilities and communication;
  • Effective policies and procedures; and
  • Active employee involvement.

Operators of public transportation systems that are subject to the PTASP rule must develop and implement SMS processes as part of their agency safety plans.

Answer:

The key difference between SMS and system safety is how safety is managed under each approach. FTA’s PTASP rule requires transit operators to manage their safety risks through the implementation of SMS. SMS is a top-down, data-driven management system which involves the continuous collection and analysis of information that helps a transit operator become proactive about how it addresses safety risks. In contrast, system safety—a common transit industry approach to safety—is an engineering discipline that incorporates safety into a system during its design and construction. 

System safety assumes that technical compliance with engineered solutions will result in safe operations. The safety plan requirements for rail transit agencies under FTA’s original State Safety Oversight Rule (49 C.F.R. Part 659) implemented system safety through 21 specific requirements for System Safety Program Plans (SSPPs). The major focus of system safety is to integrate risk management into the overall system engineering process rather than addressing hazards as day-to-day operational considerations.

While the system safety approach effectively resolves many hazards, new safety risks may emerge over time with deviations in work practices, performance changes in system equipment or component parts, degraded conditions, aging infrastructure, integration of old and new technologies, and workforce changes. Using methods prescribed in the typical SSPP, it is difficult to identify and assess these new safety risks. By using the principles of SMS, the PTASP promotes the collection and analysis of more information from the frontline, supervisors, automated systems, customers, audits of normal operations, and other activities to help the rail transit agency manage safety risks and regularly monitor the effectiveness of safety risk mitigation. SMS also brings accountability for safety to the top levels of the organization, so the PTASP final rule requires each transit operator to designate an accountable executive who is ultimately responsible for managing safety and allocating resources to improve safety. SMS requires each employee and function within an organization to assume responsibility for safety, not just the safety office. Two other key components of SMS are the safety risk management and safety assurance processes, where data is collected and analyzed, priorities are established, and solutions are introduced then measured against performance, and monitored and evaluated to ensure the solutions are effective.

A rail transit agency may use the safety process and procedures established under its SSPP as a baseline for SMS implementation under its new safety plan. Please refer to FTA’s PTASP website for a crosswalk document that provides guidance on how to transition an SSPP to a safety plan that meets the PTASP rule requirements.

Answer:

SMS improves on the SSPP framework by integrating and harmonizing the various elements of a safety plan so that they work together to manage safety risks throughout all aspects of a transit agency’s operations. SMS provides structure and accountability to supply management with ongoing information about safety risks concerning an agency’s operations. SMS supports management decisions to prioritize actions and allocate resources to resolve identified safety concerns or reduce safety risk to an acceptable level. SMS also includes routine monitoring of service delivery operations in order to evaluate the safety performance of activities and programs.

Answer:

No. Only operators of public transportation systems that are subject to this rule must develop and implement SMS processes.

To reduce the administrative, financial, and regulatory burdens on small public transportation providers, FTA has developed a condensed SMS framework for operators of 100 or fewer vehicles in peak revenue service. Small public transportation providers only need to develop processes for safety performance monitoring and measurement. A process for safety performance and monitoring will enable the agency to monitor its system for compliance with the agency’s procedures for operations and maintenance and identify and address inefficiencies. The process ensures that mitigations are implemented, adhered to, and effective.

Answer:

FTA’s National Public Transportation Safety Plan provides an overview of SMS. Additionally, FTA publishes other SMS resources on its website as they are developed. Individuals may access those resources at https://www.transit.dot.gov/regulations-and-guidance/safety/safety-management-systems-sms. The Transportation Safety Institute offers online and in-person courses on SMS for public transportation.

Answer:

Yes, a Chief Safety Officer or SMS Executive also can be responsible for security in their transit system. In rail transit systems, Chief Safety Officers cannot have additional operational and maintenance responsibilities, they must be dedicated to ensuring safety within the system as a full-time responsibility. Rail transit agencies may petition FTA to allow its Chief Safety Officer to serve multiple roles given administrative and financial hardships with having a single, dedicated, and full-time Chief Safety Officer. Similarly, FTA recommends bus transit systems that operate more than 100 vehicles in peak revenue service to have a dedicated Chief Safety Officer, given the increased safety risks in those systems, although, this is not a requirement.

Small transit providers who are Section 5307 Grant Program recipients and subrecipients may have their Chief Safety Officer serve other functions, including the areas of operations, maintenance, and grant administration. For these transit agencies, the Chief Safety Officer may be a full-time employee of the transit system who has responsibility for duties other than safety, a part-time employee of the transit system, or a contractor.  To illustrate, in a small bus agency, the general manager or operations manager may be the same individual as the Chief Safety Officer or SMS Executive.

Answer:

See each detailed course listing/registration forms for this information.

Answer:

For rail transit agencies, General Directive 17-1 would require to:

  • Complete a safety risk evaluation of the potential consequences of hazards related to stop signal overruns within 90 days of the issuance of a final General Directive 17-1;
  • Evaluate the current safety performance monitoring activities in place to assess the effectiveness of stop signal overrun mitigations within 90 days of the issuance of a final General Directive 17-1; and
  • Develop and submit a corrective action plan, as necessary to its State Safety Oversight Agency within 150 days of the issuance of a final General Directive 17-1.

For State Safety Oversight Agencies, General Directive 17-1 would require:

  • Participating in the safety risk evaluation conducted by the rail transit agency;
  • Reviewing and approving the evaluation within 60 days after its completion;
  • Reviewing and approving any needed corrective action plan within 60 days of its receipt; and
  • Reporting the status of the corrective action plan to FTA, as part of the SSO Program Annual Report to FTA (per 49 CFR 674.39).
Answer:

States may apply for an amount that is less than what is available under the SSO Formula Grant Program. States may ask FTA to later amend the grant to add all or a portion of the remaining available funds until the end of the period of availability, which is one year from the end of the fiscal year that the grant funds are apportioned.

Answer:

Yes. At least until one year after the effective date of a final rule to require public transportation agency safety plans (PTASP) (49 U.S.C. § 5329(d)), a state may use SSO formula grant funding to comply with security requirements under 49 U.S.C. part 659. FTA will issue further guidance on this issue after publication of the final PTASP rule.

Answer:

Yes. At least until one year after the effective date of a final rule to require public transportation agency safety plans (PTASP) (49 U.S.C. § 5329(d)), a state may use SSO formula grant funding to comply with security requirements under 49 U.S.C. part 659. FTA will issue further guidance on this issue after publication of the final Public Transportation Agency Safety Plan (PTASP) rule.

Answer:

Sure.  We are always looking for transit system experts who have a desire to share their important knowledge with others in the industry.  Contact Ruth Lyons.

Answer:

Yes, based on the period of availability, FY 13 grant funds can be obligated through September 30, 2015 and FY 14 grant funds through September 30, 2016. FTA, however, encourages you to submit as soon as you possibly can, to ensure that your state's program, and the rail transit agency's safety oversight, receives the benefits of federal funding.

Answer:

Yes. Expenditures for equipment that is directly related to the SSO program are allowable. Such equipment may include, for example, two-way radios, cellular phones, digital cameras, accident investigation kits, electronic tablets, personal protective equipment, as well as office equipment, including computers, servers, printers, and other durable goods or equipment. Items with a unit cost of $5000 or more must have prior FTA approval. If equipment is shared with non-SSO functions, please follow 2 C.F.R. Part 225 for guidance on how to calculate the appropriate reimbursement amount for the equipment’s use in support of SSO activities.

Answer:

Yes. The services paid for must be to develop or carry out SSO programs under MAP-21.

Answer:

Yes. States may use such grant funds for in-state or out-of-state travel or training under this program. Meetings and conferences are eligible if the primary purpose is the dissemination of technical information. For more information, see section 27 of Appendix B of 2 C.F.R. Part 225.

Answer:

Yes. Costs associated with membership in business, technical and professional organizations directly incurred as a result of one’s SSO job functions are allowable. Note that membership in organizations substantially engaged in lobbying are unallowable. Please see section 28 in Appendix B of 2 C.F.R. Part 225 for more information.

Answer:

Yes. States may use SSO Formula Grant Program funds to pay reasonable compensation to employees who are working on the SSO program. All labor must be identified in a staffing plan shared with FTA. You may pay the following types of employees, as identified in the staffing plan:
Full or partial wages for all SSO personnel.
Overtime wages for SSO employees who perform activities such as accident investigation or corrective plan verification.
Partial wages for State employees who support the SSO program.
Refer to section 8 of Appendix B to 2 C.F.R. Part 225 for specific information, and speak to your Regional Office for additional assistance.

Answer:

Yes. Vehicles purchases and vehicle operating costs to develop or carry out the SSO program are eligible, but may require prior FTA approval.

Answer:

Yes, an SSO agency may use existing federal grant funds for reimbursement of operational and administrative costs incurred during the development of its SSO Program. Since 2013, FTA has provided approximately $112.4 million in SSO formula grant funds to help states develop and implement an SSO Program that meets federal requirements.

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