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Answer: There are a few major misconceptions about SMS: SMS is just a new "buzzword" to replace "system safety." To the contrary, SMS applies system safety concepts and adds formal system safety management concepts. Most safety research has shown that major accidents are not simply the result of one individual’s behavior or actions. Major accidents typically have organizational antecedents with multiple causes involving people operating across many levels or functions in an organization. It follows that predicting and preventing major accidents requires addressing the root causes based in organizational practices, management systems, and culture. SMS brings these elements into the system safety approach. SMS requires a separate safety department. While rail transit agencies and larger bus agencies will have specialist safety personnel such as a Director of Safety, safety and quality auditors and analysts, investigators, etc., an SMS is a set of management practices rather than a requirement for an additional organizational "layer" or "stovepipe." SMS focuses on functional expectations by operational departments; therefore resource allocation should be appropriate for the size of the organization. SMS requires Voluntary Employee Reporting to follow specific rules and guidelines. Voluntary employee reporting programs are a major element of SMS, but no specific program is mandated. Each public transportation agency will be able to determine how best to involve employees and obtain voluntary safety reports from employees. SMS is a costly regulation that will hurt the transit agency’s financial performance. To the contrary, SMS can help transit agencies improve their bottom line. The hazards that put our people at risk are the same hazards that disrupt transit operations. Research has shown that improved information sharing regarding potential safety concerns in operations and maintenance will result in the design of more targeted solutions to all sorts of problems saving time and resources. For example, as a result of access to a shared information management system and jointly attended monthly safety committee meetings, vehicle maintainers and track inspectors work together to identify and resolve wheel-rail interface problems enhancing both ride quality and maintenance efficiency.
Answer: Once the SSO Formula Grant is active, States must submit several types of reports, including a Federal Financial Report and Milestone Progress Report. These reports are required quarterly and should demonstrate progress toward milestones. Please see the most recent version of FTA Circular 5010.1 or contact your regional office for details. States should note that all project expenditures, whether paid for with Federal award money or local matching funds, must comply with Federal requirements, including Buy America, civil rights, economic development, etc.
Answer: To achieve FTA certification, an SSO Program must meet several federal statutory requirements. To help clarify the SSO Program requirements, FTA distributed a Certification Toolkit to every SSO agency. The toolkit details the six SSO Program categories that each state is required to meet: SSO Agency independence General program requirements Enforcement authorities Investigations and audits SSO staffing, training, and qualification Program standard
Answer: Any State that was not certified in October 2013 must submit a Certification Work Plan (CWP) to FTA. FTA must approve that CWP prior to the State submitting a grant application. A CWP outlines a transition plan for a State to achieve certification. The plan should identify gaps or deficiencies in a State’s authority to develop and carry out its SSO program and tactical steps the State plans to take to meet the Moving Ahead for Progress in the 21st Century Act (MAP-21) statutory requirements under 49 U.S.C. § 5329(e) under a State-specified timeline. Approved CWPs are intended to provide more certainty that the transition plan will help reach certification. This is a State’s opportunity to receive reasonable assurance that its anticipated SSO program will be MAP-21 compliant and use the available funding for eligible activities that meaningfully and effectively enhance its SSO program. Additional information on the CWP is provided below. Once the CWP is completed and approved by FTA, the SSO agency must file an electronic grant application with its FTA Regional Office using FTA's Transportation Electronic Award Management (TEAM) system. As part of this process, the State must submit documentation, among other things, evidencing its formal designation of the intended recipient of the FTA SSO grant program funds and the source of its 20 percent local match. The State-designated entity, which may or may not be the SSO agency, must also have the required documents, including the signed Certifications and Assurances on file with the Regional Office. Contact your Regional Office for more information. States are reminded that grant applications must be in “submitted” status in TEAM by June 30, 2014 to allow time to make awards by FY 2014. For more information, please see the March 10, 2014 Dear Colleague Letter.
Answer: The status table provides a snapshot of the SSO certification process in four stages: Stage 1 – State is working on its submission to FTA Stage 2 – State has submitted some requirements to FTA. Where applicable, all required legislation has not yet been enacted. Stage 3 – State has submitted all required documents to FTA, and is engaged in a dialogue with FTA to address comments and questions. Where applicable, all required legislation has been enacted. Stage 4 – State has successfully met all SSO Program requirements, including the resources to carry out the requirements, and has received FTA certification.
Answer: For each corrective action, WMATA must submit a closure request to FTA. FTA then reviews the request, including a comprehensive verification process. A corrective action will be closed after FTA verifies that WMATA has demonstrated successful implementation.
Answer: The date shown for each corrective action refers to the “original estimated date” in the Corrective Action Plan WMATA submitted to FTA in September 2015.
Answer: If a state fails to meet the certification deadline, the FTA is prohibited by federal transportation law from obligating funds to any public transportation system or program throughout that entire state until certification is achieved.
Answer: FTA published the Interim Safety Certification Training Program Provisions for comment. After FTA reviews the comments collected through this notice, FTA may publish a subsequent notice indicating any substantive revisions that may be warranted based on public comment. In the alternative, should public comments indicate that no substantive revisions are necessary, FTA will publish guidance for implementing the requirements noted in the Federal Register. (H.R. Rep. No. 112-557, at 603 (2012).) After the interim provisions are in place, FTA will prepare a Public Transportation Certification Training Program, which will be established by regulation. Regulations are developed in two major steps – a Notice of Proposed Rulemaking and a Final Rule. FTA will share each in the Federal Register with an opportunity for public comment.
Answer: The time frame for FTA verification will vary depending on the corrective action under review and will result in either the item being closed or being sent back to WMATA for further action. The FTA verification process may take a few weeks, several months or multiple quarters.
Answer: April 15, 2019. This deadline was established by the SSO final rule. FTA is prohibited by federal transportation law from granting waivers or extensions to the deadline.
What is the difference between participants in the Interim Provisions for the Safety Certification Training Program and participants in the Public Transportation Agency Safety Plan?Answer: The Interim Provisions covers Federal, State, and other designated personnel who conduct safety audits and examinations of public transportation agencies and transit system personnel with direct safety oversight responsibility. There is another group of transit employees to be trained under the “Transit Agency Safety Plan”; this group does not have direct safety oversight responsibility. Public Transportation Agencies must develop a Public Transportation Safety Plan (transit agency safety plan) that is approved by the board of directors of the transit agency and certified by the recipient or the State. The participants in this plan will most likely be required to take training required by their individual transit agency. A critical element of SMS is safety awareness at all levels of an organization. FTA is developing a one-hour Safety Management System Awareness course that will have universal applicability throughout the public transportation industry. Therefore, FTA is also encouraging that transit system personnel at all levels voluntary participate in the one-hour SMS Awareness training as it becomes available.
Answer: SMS is about risk management and ensuring that resources are allocated appropriately to manage risk commensurate with the size and complexity of the public transportation agency and its operations. The exact source of the risk is not limited by discipline to “safety” versus "security" versus "emergency preparedness." Instead risk in SMS is all-hazards in nature. All considerations that threaten the safety and well-being of passengers, employees, system equipment and infrastructure must be managed as part of the total risk profile of the organization.
Answer: The SSO apportionment notice is an official announcement from the Federal Transit Administration (FTA) regarding the apportionment of FY 2013 and FY 2014 SSO Formula Grant Program funds. This notice responds to public comments on the May 13, 2013 SSO Illustrative Apportionment, describes the final formula used to apportion funds, and identifies grant requirements and next steps to apply for this grant program. SSO Formula Grant Program funds must be used to develop or carry out SSO programs in accordance with the Moving Ahead for Progress in the 21st Century Act (MAP-21).
Answer: The transition to an SMS approach is a phased process that is organized to provide a manageable series of steps to follow, including the allocation of resources and management of the workload. The experience of Transport Canada, as well as SMS Pilot Project Participants in the United States aviation industry, indicate phased implementation of a robust SMS takes approximately three to five years. One of the benefits of the pilot projects FTA will be undertaking is to determine realistic timelines.
Answer: Other eligible activities may include office supplies; personal protective equipment; technical engineering and inspection tools; uniforms; vehicle operational expenses; furniture; course registration and fees; conferences, workshops, and seminars; and travel, per diem, mileage, and lodging. Please see Appendix B of 2 C.F.R. Part 225 (PDF) and consult with your FTA regional office.
Answer: States that must continue to meet 49 CFR Part 659 requirements may use existing resources to do so. However, each State is responsible for identifying an independent local match in order to receive funding under FTA’s SSO Formula Grant Program, which cannot include funding received from the RTA. FTA will not award a grant until this match is identified and the SSO agency is no longer dependent upon funds received from the RTA.
What specific actions will FTA take to incorporate SMS into the Public Transportation Safety Program?Answer: Based on SMS concepts and principles, FTA will develop a roadmap for carrying out the comprehensive Public Transportation Safety Program authorized by 49 U.S.C. 5329. Specific activities include the following: FTA will first focus on establishing an SMS oversight framework through rulemakings, complemented by technical assistance and outreach. As authorized by 49 U.S.C. 5329(e), FTA will award grants to eligible States to help them strengthen their rail transit safety oversight, attain certification for their State Safety Oversight (SSO) programs, and institute strong safety training programs for SSO staff, emphasizing the components of SMS. For bus, FTA will work to ensure that bus operators receive the tools and technical assistance they need to apply SMS principles in ways that are cost-effective and add value for the millions of riders who depend on bus service every day. FTA will enlist the support of the Transit Rail Advisory Committee for Safety (TRACS), established by the U.S. Secretary of Transportation in accordance with the Federal Advisory Committee Act, on several of the rulemakings and other safety initiatives under the Public Transportation Safety Program authorized by 49 U.S.C. 5329. FTA will reach out to leaders in SMS, both in transportation and other fields, for support and assistance in bringing SMS to public transportation. The agency and its partners will pursue gap analyses, pilot projects, development of specific SMS programs, plans and guidelines, and training and technical assistance for staff and other designated personnel at SSOAs, public transportation agencies, and FTA.
Answer: State funds or in-kind contributions from the State can count toward the State’s local match. At the time of application, you must certify that your State has funds or approved in-kind resources to serve as the local match. See FTA’s Annual Certifications and Assurances and the FTA Master Agreement that all applicants for grant funds must submit for details. For States that oversee multi-State rail transit systems, funds spent by partner States may be used as part of the local share as long as those funds meet all requirements of the grant program. As part of the grant application and award process, these States will need to show evidence of agreement regarding how the local share will be met amongst the States. Additionally, MAP-21 requires SSO Programs to be financially independent from the rail transit systems they oversee and restricts the type of funding that can be used as the State’s local match. As such, States that currently rely upon fees, assessments, or funding from rail transit systems in their jurisdictions will be unable to use those funds for any SSO Formula Grant Program activities. In addition, the State may not use other Federal funds as all or a part of its local match. FTA will work with each State on an individual basis to identify permissible local share sources.
Answer: All training supported by the FTA grant must be related to developing or carrying out a State’s SSO program under MAP-21, and each State should clearly demonstrate how each training course proposed in its grant does this. FTA will approve the training activities through the grant application process. FTA encourages each SSO Agency (SSOA) to develop and implement a training plan that identifies skill gaps and appropriate training to fill those gaps. In particular, FTA encourages States to focus training activities on Safety Management System (SMS) training, which will be offered by FTA, and technical training related to the operating conditions of the rail transit systems the State oversees. Eligible training may be offered by the US Department of Transportation’s Transportation Safety Institute, the National Transit Institute, post-secondary institutions, non-profit organizations, industry organizations, or other third-party providers. The training program does not have a post-secondary degree-seeking purpose, and as noted above, all training funded through this grant must be related to developing or carrying out a State’s SSO program under MAP-21. Thus, FTA does not anticipate that such degrees will be a typical result of training funded by the grant. FTA is developing an interim safety certification training program, as required under 49 U.S.C. 5329(c), that may provide further guidance on eligible training activities. Once established, this interim program will become the basis for determining eligible training activities in future funding years. FTA expects to publish a proposed interim program for comment in Spring 2014.