Memorandum
of Understanding
Between
the
Federal Transit
Administration
American Association
of State Highway and Transportation Officials
American
Public Transportation Association
Community
Transportation Association of America
In Regard to the
FTA
Model Transit Bus Safety and Security Program
(Download
in Adobe PDF Format)
Introduction
The
Federal Transit Administration (FTA) has developed a Model Transit Bus Safety
and Security Program in cooperation with the American Public Transportation Association
(APTA), the Community Transportation Association of America (CTAA), the American
Association of State Highway and Transportation Officials (AASHTO), and other
representatives from the transit bus industry. This effort has culminated in a
draft Program that has been accepted in principle by the FTA and its industry
partners.
This Memorandum of Understanding is an agreement in principle
to:
- Promote the Model Transit Bus Safety and Security Program
- Provide
support to further the Program
- Assess the activities of the signing
parties’ constituents in implementing the Program.
The
four partner organizations’ representatives signify the acceptance of the Model
Program and demonstrate the commitment of their organizations to its objectives
by their signatures to this Memorandum of Understanding.
Model
Transit Bus Safety and Security Program Elements
The Model Program contains
two general categories of Program elements: Core Safety Program Elements
and Enhanced Safety Program Elements. Collectively, these elements
define the comprehensive FTA Model Transit Bus Safety and Security Program.
Core
Safety Program Elements are the safety program elements that all transit
providers should implement. Core elements apply to all Section 5307 and 5311 transit
providers. As the size and resources of the transit provider increase or as operational
experience indicates additional needs, the transit provider should implement applicable
Enhanced Safety Program Elements. In cases where service is contracted with 5307
or 5311 funds, the grantee shall ensure that the contractor would implement the
core and enhanced safety program elements as applicable. Section 5310 provider
participation in a safety and security program is subject to state discretion
however Section 5310 provider participation is encouraged.
The degree of
applicability is largely dependent on operations. The scope of applicability will
be defined in the individual technical assistance materials.
The Core
Safety Program Elements include:
| Security |
Vehicle Maintenance |
| Driver/Employee
Selection | Drug and Alcohol Abuse Programs |
| Driver/Employee Training |
Safety Data Acquisition and Analysis. |
Enhanced
Safety Program Elements improve the transit provider’s safety program
beyond the Core Safety Program Elements. Transit providers in urban areas typically
include these elements. Other transit providers should expand their safety program
as their services, resources, and infrastructures grow to include Enhanced Safety
Program Elements as a part of a continuous improvement approach to transit bus
safety and security. The Enhanced Safety Program Elements are grouped into three
general categories:
- Safety Process-Centric Elements – These
elements focus on understanding the safety issues within the transit bus operations
(accidents, incidents, and hazards) so that resources can be properly directed.
- Human-Centric Elements – These elements focus on processes or procedures
that are directed toward driver and employee safety issues.
- Infrastructure
and Equipment-Centric Elements – These elements address safety issues related
to the transit system vehicles and general infrastructure.
Attachment
A to this Memorandum contains additional definitions of the Core Safety Program
Elements and additional information about the Enhanced Safety Program Element
categories.
Implementation Approach
The
Partners agree that the voluntary approach to implementation will be used to assess
transit provider implementation of the Model Program requirements. The voluntary
approach to implementation requires good faith efforts on the part of grantees
and the national partner organizations with an expectation that the absence of
a more formal regulatory structure will not be detrimental to overall Model Program
objectives.
Under the voluntary approach, implementation
is expected on a voluntary basis – a regulatory or contractual directive for implementation
of the Model Program for transit system grantees (and sub-recipients) is not proposed
by FTA. However, if the FTA determines that this approach to implementation is
not satisfactory for ensuring implementation, the FTA reserves the right to revisit
the issue of the Implementation Approach. States, however, do have the right to
adopt more prescriptive requirements.
Examples of acceptable approaches
include those developed by the partners, individual DOTs, insurance pools, and
other industry groups.
Some of these programs include the following:
- APTA's Bus Safety Management Program
- CTAA's Community Transportation
Training and Safety Review Program
- Bus Safety programs developed by state
transportation departments
- Safety programs of insurance pools
- Fleet
safety program of the National Safety Council
- Safety program guidelines
of transit management training programs
- Local transit operating agency
safety programs and procedures
FTA and
its Partners recognize that under the voluntary approach there is no single safety
model within the industry which must be adopted by transit systems or states overseeing
such systems. The key agreement in this understanding is that the appropriate
safety elements for the type of transit system be developed and implemented. In
other words, any model which embraces the appropriate core elements will comply
with the intent of the FTA approach. Examples of acceptable approaches could include
those developed by the Partners, individual DOTs, insurance pools and other industry
groups.
In regards to bus safety and security programs,
FTA Triennial Reviews and State Management Reviews will identify areas of concern
relative to the voluntary compliance practices and specify recommended improvements
rather than audit compliance on a "comply/not comply" basis.
Role
of the FTA and the States in Assessing Transit Provider
The
FTA will assess implementation with the Model Transit Bus Safety and Security
Program by its direct grantees through the Triennial Review Program or another
similar approach.
The States will assess the implementation
of the Model Transit Bus Safety and Security Program by their Section 5311 sub-recipients
in a manner similar to that which the States use for assessing sub-recipient compliance
with other FTA requirements. Section 5310 grantees would be exempt from the Model
Program requirements, but encouraged to implement the Core Safety Program Elements.
FTA and the States will conduct these assessments in a
cooperative and positive manner with the grantees, promoting a proactive environment
to assist transit systems in meeting the Model Program requirements.
FTA
Technical Assistance and Outreach
The FTA, in
cooperation with the Partners, will develop and disseminate appropriate technical
assistance and outreach materials to be used by the FTA staff, the Partners, and
the transit system grantees in implementing the Model Program. FTA efforts will
include training through the Transportation Safety Institute (TSI), the National
Transit Institute (NTI) and other activities, to the extent possible. Attachment
B contains additional descriptions of anticipated FTA technical assistance and
outreach.
Responsibility of All Parties in Promoting
the Program
The Partners to the Model Program will actively promote
the Program and its objectives; will provide support to further the Program;
and will assess the activities and performance of their constituents in
implementing the Model Program. These efforts will incorporate all reasonable
actions necessary to ensure good faith efforts by transit providers in developing
and maintaining their own Transit Bus Safety and Security Programs.
Commitment
to Program Improvement Efforts
The Partners will review
the Model Program on a regular basis and revise it, as appropriate, to meet the
objectives of furthering transit bus safety and security. The Partners agree to
meet on a regular basis to discuss positive aspects of the Program, along with
areas needing improvement. The Partners also agree to implement those changes
to the Program, as appropriate, to continue to enhance transit bus safety and
security.
|
_________________________________ Federal
Transit Administration | __________________________________ American
Public Transportation Association |
|
__________________________________ American Association
of State Highway and Transportation Officials |
___________________________________ Community Transportation
Association of America |
American Association of State
Highway and
Transportation Officials
Standing Committee on Public
Transportation
Date __________________
Attachment
A
Safety
and Security Program Elements
FTA
Model Transit Bus Safety and Security Program
The
comprehensive requirements for the FTA Model Transit Bus Safety and Security Program
consist of two parts; (1) the core safety program elements and (2) enhanced safety
program elements.
The concept of a core safety program
element is simply a safety activity that every transit bus provider should
be doing as part of a minimum safety and security program. Core safety program
elements should receive adequate resources to support these core activities. While
all activities are subject to resource limitations, these core safety and security
activities should be a high priority in resource allocation.
All
transit providers should implement the core safety program elements as the minimum
acceptable approach to transit bus safety. The remaining "enhanced"
elements of the comprehensive safety and security program should be incorporated
into safety efforts as needs are identified and resources are available.
The
concept of an enhanced safety program element is used to describe safety and security
activities that go beyond the scope of the core requirements. Enhanced program
elements are those safety and security activities that will enhance safety and
security program effectiveness for the larger and more complex transit bus providers.
The transit provider’s safety and security program should grow with the transit
provider’s services, resources, and infrastructure to continuously and proactively
manage safety throughout their operations.
Large transit
bus providers, with adequate resources, typically have a need for all or most
of these enhanced elements in their safety and security programs. Smaller transit
bus providers should incorporate these enhanced elements as their size and/or
responsibilities grow or as the need is indicated by operational safety and security
experience to further improve their safety program.
The
following table lists the program elements for the comprehensive FTA Model Transit
Bus Safety and Security Program. Core program elements are identified in the table
and are further defined in the paragraphs following the table. Enhanced elements
are further described in the FTA report defining the Model Program. This attachment
describes the current delineation of core and enhanced program elements. However,
FTA may, from time to time, redesignate the core and enhanced program elements
as indicated by industry needs.
Safety and
Security Program Elements
FTA Model Transit Bus Safety
and Security Program
| Security* Safety
Process-Centric Elements - Safety Data Acquisition/Analysis*
- Accident/Incident
Reporting & Investigation
- Hazard Identification/Resolution Process
- Emergency
Response Planning, Coordination and Training
- Internal Safety
Audit Process
Human-Centric Elements - Driver/Employee
Selection*
- Driver/Employee Training*
- Drug
& Alcohol Abuse Programs*
- Fitness for Duty (additional requirements beyond the drug and alcohol FFD
requirements)
| - Rules/Procedures
Review
- Contractor Safety Coordination
Infrastructure &
Equipment-Centric Elements - Vehicle Acquisition
- Vehicle
Maintenance*
- Facilities Inspections
- Maintenance Audits/Inspections
- Hazardous
Materials Program
- Alternative Fuels and Safety
- System
Modification Review/Approval Process
- Interdepartmental/Interagency Coordination
- Configuration
Management
- Procurement
- Operating Environment and Passenger
Facility Management
- Dedicated Busway or Roadway Inspection and
Maintenance
* Core Safety Program Element |
|
Core Safety and Security Program Element
Descriptions
Security: The security of passengers and employees
is paramount to promoting the objectives of the FTA and its partner organizations
in developing a Model Program. Transit providers must take all reasonable and
prudent actions to minimize the risk associated with intentional acts against
passengers, employees and equipment/facilities. To further this objective, transit
providers will need to develop security plans and procedures and emergency response
plans and procedures. The plans must include coordination with local law enforcement
and with other regional transit providers, the conduct of exercises for their
emergency plans, and assessment of critical assets and measures to protect these
assets.
Driver/Employee Selection: Driver selection
is critical to safe transit operations. The driver of a transit vehicle is directly
responsible for the safety of their passengers and other motorists that share
the road with transit buses. The transit provider should have a clear definition
of driver qualifications and background. This applies to all safety-critical employees,
both paid and volunteer.
Driver/Employee Training:
Once qualified candidates are identified and hired, initial and on-going training
is critical to insure proper operations and adherence to the transit providers’
rules and regulations. Proper qualification of operating and maintenance personnel
is a vital part of a safe transit environment. Driver training should address
specific safety-related issues appropriate to the type of vehicle and driving
assignment including fitness for duty.
Vehicle Maintenance:
Proper maintenance of vehicles and equipment is critical to the continued safe
operation of the transit system. Unsafe vehicles present unnecessary hazards to
the driver, passengers, and other vehicles on the road. Basic vehicle maintenance
practices must regularly address safety-related vehicle equipment to ensure that
no unsafe vehicles are dispatched for service.
Drug and
Alcohol Abuse Programs: Since many transit providers receive FTA operating
and capital funds, the FTA Drug Testing Requirements form the basis for drug abuse
programs. An alcohol abuse program is also required. The bottom line is protection
of the riding public and transit employees, and all efforts should be geared toward
this end. The transit provider’s safety program should outline the specific policies,
procedures and responsibilities, or reference the appropriate master document
containing that information.
Safety Data Acquisition/Analysis:
Understanding safety data is an important step toward allocating important (and
often scarce) resources to implement safety program elements. Safety data relative
to transit provider operations can be used to determine safety trends in system
operation. These data include information gathered from within the system on safety-related
events such as passenger injuries or claims, employee injuries, accidents, incidents,
and preventability. Driver reports (sometimes called logs) can be an important
source of safety problems, such as dangerous stop locations, problems with bus
equipment, safety problems with the route, and other issues. The data are useful
in a formal hazard identification and resolution process to help identify hazards
before they cause accidents. The data may also help improve system performance,
not only in respect to safety, but also in overall delivery of service to the
riding public. In addition, trend analyses of safety data can help determine the
effectiveness of safety initiatives that have been implemented.
Attachment
B
FTA
Technical Assistance and Outreach Activities
FTA
Model Transit Bus Safety and Security Program
The
FTA in concert with its Partners is committed to develop and disseminate appropriate
technical assistance and outreach materials to be used by its staff, its Partners
(AASHTO, APTA, and the CTAA), and the transit system grantees in implementing
the Model Program. These technical assistance activities will include training
through TSI, NTI and other Partner and industry sources, as resources permit.
The following list provides examples of technical assistance activities and products
that, to the extent possible, FTA will provide as part of their continuing promotion
and support of the Model Program.
- Technical guidance on criteria to
be used for determining appropriateness of "Enhanced" Safety Program
Elements
- Manuals for the development of model Transit Bus Safety and Security
Programs
- Manuals for assisting the states in conducting assessments of
sub-recipients
- Training programs for transit providers and states
- Training
classes for transit providers and state representatives
- Manuals for developing
System Safety Program Plans and Security Program Plans
- Identification
and dissemination of transit bus safety "best practices"
- Presentations/facilitation
of discussions at conferences and workshops
- Informational brochures and
program summaries
- Program awareness/marketing products
- Guidelines
for data collection/analysis that address both rural and suburban systems.
- Identification
of funding resources that may be used by states to perform voluntary assessments
of subrecipients’ implementation of the model program.
- Identification
of information resources, such as websites developed by its Partners, on the elements
of the model program and how those elements may be applied.
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