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Frequently Asked Questions

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Answer:

No. We appreciate that several States are still working to identify the source of their local matching funds; however, a State cannot apply for a grant under FTA's MAP-21 SSO program while, at the same time, receiving funding from the rail transit agency. However, no State or any other agency should deprive a SSOA of the funds it needs to ensure the safety of public transportation during this transition period. FTA therefore expects a clear transition plan for the SSOA to attain financial independence.

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States will submit a schedule and budget as part of the grant application. In order for the grant to remain active, States must demonstrate adequate progress toward their objectives, based on the schedule and budget submitted.

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GREEN means the corrective action is closed which will occur only after FTA completes a comprehensive verification process.
YELLOW means the corrective action remains open -- either because the estimated original date WMATA said it would submit a closure request has not yet expired, or because a WMATA closure request is under review by FTA and undergoing a comprehensive verification process.
RED means WMATA has not submitted a closure request by their original estimated date or because FTA has rejected the closure request and sent it back to WMATA for additional action.

Answer:

SMS Pilot Program participants in aviation found that SMS enabled them to integrate safety as a core management value. They also have identified lessons learned from their experiences. Although each organization is different, common themes include:
The need for ongoing senior leadership commitment,
The need to integrate SMS training across the organization,
Data/analytical lessons learned regarding what to capture, how to capture it, and how to distribute it across the organization,
The need for oversight agency participation early in the process, and
The critical role of communication, awareness and culture

Answer:

SMS allows an organization to adapt to change, increasing complexity, fluctuations in resources, and changes in employee skills and experience. An effective SMS offers many benefits, including:
Accountability for the management of safety at the highest level of the transit agency.
Collaboration between management and labor to ensure agreement on safety risk priorities.
Structured and strategic decision making for safety resource allocation.
Enhanced safety performance through proactive safety risk analyses.
Increased confidence in safety risk controls through safety assurance.
Partnership and knowledge sharing between public transportation agencies, state agencies, and FTA.
A positive safety culture that supports safety communication and reporting.

Answer:

SMS is composed of four functional components:
Safety Policy
Safety Risk Management
Safety Assurance
Safety Promotion
Safety Policy is the foundation of the organization's safety management system. It clearly states the organization's safety objectives and sets forth the policies, procedures, and organizational structures necessary to accomplish the safety objectives. The safety policy clearly defines management and employee responsibilities for safety throughout the organization. It also ensures that management is actively engaged in the oversight of the system's safety performance by requiring regular review of the safety policy, budget and program by a designated accountable executive.
The second component, Safety Risk Management, requires development of processes and procedures to provide an understanding of the public transportation system’s operations and maintenance to allow individuals to identify hazards associated with those systems. Once hazards are identified, other procedures must be developed under safety risk management to analyze and assess the risk resulting from these hazards, as well as to institute controls to reduce or eliminate the risks from these hazards.
The third component, Safety Assurance, ensures the performance and effectiveness of safety risk controls established under safety risk management. Safety assurance is also designed to ensure that the organization meets or exceeds its safety objectives through the collection, analysis, and assessment of data regarding the organization's performance. Safety assurance also includes inspection activities to support oversight and performance monitoring.
The fourth component of an SMS is Safety Promotion. Safety promotion requires a combination of training and communication of safety information to employees to enhance the organization's safety performance. How an organization seeks to comply with this component depends on the size and scope of the organization. It may include formal safety training for employees, a formal means of communicating safety information, and a means for employees to raise safety concerns without fear of retribution.
What are lessons learned for SMS implementation?
SMS Pilot Program participants in aviation found that SMS enabled them to integrate safety as a core management value. They also have identified lessons learned from their experiences. Although each organization is different, common themes include:
The need for ongoing senior leadership commitment,
The need to integrate SMS training across the organization,
Data/analytical lessons learned regarding what to capture, how to capture it, and how to distribute it across the organization,
The need for oversight agency participation early in the process, and
The critical role of communication, awareness and culture.

Answer:

State Safety Oversight (rail fixed guideway systems); Transit Bus Safety/Security; Drug and Alcohol Compliance; Fatigue Management; Transit Work Safety; and many others. Offerings are constantly evolving. Therefore, it would be advisable to check back often.
Who is the key Point of Contact at Federal Transit Administration should I have additional questions, suggestions or comments?
Ruth Lyons, Transit Safety and Security Training Specialist, 202-366-2233 or ruth.lyons@dot.gov

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.

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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.

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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. Stage 3 – State has submitted all required documents to FTA and is engaged with FTA to address comments and questions. Where applicable, all required legislation has been enacted. Stage 4 (Certified) – State has successfully met all SSO Program requirements, including the resources to carry out the requirements, and has received FTA certification.

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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.

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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.

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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:

A stop signal overrun occurs when a rail transit vehicle fails to stop as required in advance of a stop signal, flag, or other indicator, as specified in a rail transit agency’s operating rules and procedures. The FTA considers a stop signal overrun to be a significant safety event, with the potential to result in the derailment or collision of passenger trains and the striking of workers, passengers or equipment on the rail transit right-of-way.

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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.

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April 15, 2019. This deadline was established by the SSO final rule, pursuant to federal law. FTA is prohibited by federal transportation law from granting waivers or extensions to the deadline.

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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.

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