49 CFR Part 659 establishes FTA’s State Safety Oversight (SSO) Program, mandates the development state agencies, and outlines the requirements for state program standards to oversee the safety and security of local rail transit systems.  The original requirements for FTA’s State Safety Oversight (SSO) Program went into effect on January 1, 1997.  On March 9, 2004, FTA initiated its Notice of Proposed Rulemaking (NPRM) process to revising the SSO rule.

Approach

Prior to the initiation of the NPRM process, we solicited feedback from all SSO agencies and rail transit agencies by asking them to revise the existing Part 659 implementation guidelines.  We encouraged SSO agencies to make changes that they would like reflected in a revised Part 659.  We managed all changes in a master document and facilitated a series of teleconferences to discuss proposed changes and gain revision consensus.  Based on all SSO input, we developed language for the revised Part 659 for FTA’s NPRM process.  Throughout the NPRM process, we managed all formal comments, and developed all response language, as well and any final Part 659 revisions prior to finalization.  To provide SSO community members with useful tools for implementing the revised rule, we developed a series of reference materials and SSO documentation templates to facilitate the state and transit agency documentation development process.

Results

FTA’s revised Part 659 was published on April 29, 2005.  BCG’s support and revision process ensured that the final rule incorporated the concerns and addressed the needs of the SSO Community.  Additionally, BCG provided SSO agencies and rail transit agencies with a revised Implementation Guidelines document to assist agencies to comply with the new rule, as well as a resource toolkit containing SSO documentation samples to help agencies to develop compliant program documents.

BCG is a subcontractor to Savantage Solutions which provides support services for the National Transit Database (NTD).  In this capacity, BCG conducts data validation for the NTD Safety and Security Module in accordance with the reporting requirements specified by the NTD Reporting Manual and the NTD Rule.

Approach

BCG reviews all safety and security incident and monthly summary reports submitted by transit systems to NTD to ensure validity based on NTD requirements and correct reporting of modes of transportation operated.  Validation also includes reminders to reporting transit systems to meet deadlines for monthly reports.  By developing an intimate familiarity with and a detailed understanding of NTD safety and security reporting requirements, BCG also responds to a wide variety of situations requiring technical assistance on safety and security reporting.   These requests from transit systems include inquiries on how to report incidents and whether an incident is reportable or not.   Assistance is provided to reporters through telephone and e-mail communication.  Based on experience with the NTD safety and security module, communication with reporters, and clarification from FTA, BCG developed recommendations to improve the NTD safety and security reporting module.  These enhancements included defining reporting requirements to advance the effectiveness of incident reporting, developing webinar training materials to assist reporters to better understand reporting requirements, developing an updated Safety and Security Reporting Manual, and suggesting revisions to the NTD safety and security reporting web site to improve understandability and provide ease of reporting.

Results

These efforts have increased the timeliness and accuracy of NTD safety and security reporting, thus providing better data than previously was available to FTA to meet its statutory requirements.

FTA performs onsite audits and makes findings to state oversight agencies and rail transit agencies that do not meet the requirements established in 49 CFR Part 659.  FTA asked us to develop a tracking system to manage all data related to its SSO Audit Program, including the tracking of finding resolution.

Approach

We designed FTA’s SSO Audit Program Database to support several key functions, including tracking of all SSO Audit findings and corrective actions, tracking all SSO Program effective practices, managing all audit submission due dates, the establishing and tracking SSO Audit Program performance measures, and generating various reports to support FTA’s SSO program as a whole.  We designed the database to incorporate criticality, distinguishing minor documentation-related findings from more severe implementation issues.

We developed a user interface that allows auditors and SSO Program staff to continuously update findings status and resolution activities based on ongoing interaction with audited agencies.  Additionally we developed a reporting module that produces a monthly report for FTA regional offices, highlighting concerns of regional interest, and an SSO audit program status report that provides analyses of state and transit agency performance, from both compliance and safety-critical perspectives.

Results

Our audit database is the central mechanism powering the SSO audit program.  The system produces tracking matrices for distribution to states identifying all open audit findings, FTA feedback, and actions required for closeout; provides FTA with an instant read on SSO Community safety concerns, and assesses the SSO audit program itself by measuring program performance through a wide range of tracked measures.

FTA’s Office of Safety and Security conducts Safety and Security Readiness Reviews (SSRRs) to identify and resolve safety and security concerns prior to the initiation of New Starts and major extension projects into passenger service.  This required development of a formal approach for the conduct of the SSRRs.  BCG has been instrumental developing FTA’s SSRR program and has successfully conducted six FTA SSRR reviews since 2001, including the Utah Transit Authority (UTA) to ensure their ability to provide safe and effective transportation for those attending the 2002 Winter Olympic Games.

Approach

Using 49 CFR Part 659 as the basis, BCG established the necessary requirements for new systems including integrated testing of the system and pre revenue operations leading to the revenue operations date (ROD).  Next BCG developed a list of required documents for both the state safety oversight agency and the rail transit agency necessary to bring the project from planning to ROD.  Requirements included all necessary standards, procedures, and planning documentation to ensure the system has been built in accordance with the Full Funding Grant Agreement (FFGA) that the rail transit agency has with the FTA.

Approximately one year prior to ROD, BCG schedules with the affected state safety oversight agency and rail transit agency for the conduct of the SSRR.    Following agreement on the date, BCG officially sends notification for the FTA which includes the agenda and expected attendees along with the list of required documentation to be submitted to BCG prior to the SSRR.  Once the documentation is received, BCG conducts a thorough review and prepares a list of preliminary issues for onsite discussion and verification. The SSRR is conducted onsite over a three day period.  An exit briefing is provided with preliminary findings/recommendations and a final report is issued in the subsequent two week period.

Results

SSRRs that have been developed, coordinated and conducted by BCG have provided valuable recommendations to New Start systems.  This has played a valuable role in the safe start up of nascent heavy and light rail systems throughout the county.

As specified in 49 CFR part 659, “Rail Fixed Guideway Systems; State Safety Oversight; Final Rule” (April 29, 2005), SSO Program Managers (PMs) are designated by their States to oversee the safety and security of the rail transit agencies operating within their state borders. Understanding that the resources of state agencies are increasingly limited yet the need for qualified rail safety oversight personnel continues, this program offers direct financial assistance to PMs for components of this training curriculum.  The goal of this program is to have each SSO complete the five core courses to achieve TSI’s Transit System Safety & Security Certification by the end of FY 2010.  SSOs are also encouraged to take three additional advanced courses, at no cost to the agency, for additional industry certifications.

Approach

Initially, BCG contacted each PM to determine what TSI or related training each Manager had already completed or who had already received the TSI Safety and Security Certificate.  We then developed a two-tiered individualized training program (ITP) for each of the 28 PMs.  We organized the ITP according to a yearly schedule, and issue certifications to PMs annually.  We submit a monthly progress report to FTA depicting a number of training statistics, including training attendance, individuals who have earned the TSI TSS Certification, those expected to earn the TSS Certificate during the current fiscal year, and expectations for PM Tier One and Tier Two completion.

Results

Since we initiated this process, seven PMs achieved the TSS Certification. Seven already maintained the certification.  Twelve additional SSOs are expected to achieve TSS certification by the end of FY2010.  We expect the final two PMs to achieve TSS Certification by the end of FY2011.  One PM Program Manager has been awarded the World Safety Organization Safety Specialist certification.  This effort has increased the ability of PMs to effectively administer their oversight programs.

Preparedness requires a significant amount of planning and the involvement of all members of the emergency community including law enforcement, fire services, emergency management agencies, and emergency medical services. The objective of this NCHRP project was to develop a guide for use by transportation drill and exercise coordinators to assist them in the design, development, and implementation of a range of training drills and exercises. The training drills and exercises in this guide covers preparedness activities to prevent, respond to, and recover from threatened and actual domestic terrorist attacks, major disasters, and other emergencies.

Approach

Leveled tasks were performed to support the Interim Report 1, Interim Report 2, the Preliminary Draft Final Report and the Revised Final Report.  Overall, an extensive literature review was conducted, telephone interviews with personnel responsible for developing and evaluating exercises in the transportation environment were held.  An analysis of recommendations and guidance provided by the Department of Homeland Security (DHS), Federal Emergency Management Agency (FEMA) and the DHS, Office for Domestic Preparedness (ODP) was conducted.  A series of tables, matrices and graphics that transportation exercise and drill coordinators could use to support their efforts in preparing exercises for their agencies were developed.

Results

BCG created a report containing a comprehensive set of guidelines for emergency exercise development, implementation and evaluation.  This includes: information on the National Response Plan and the National Incident Management System and how they affect transportation agencies; a Transportation Exercise Evaluation Guide in compliance with DHS recommendations; a template for performing a needs assessment to direct exercise programs; a set of exercise design objectives; a set of materials to support exercise development, implementation and evaluation; and a set of materials that support the development of transportation incident response typologies, for use in developing emergency exercises.  This product also includes a CD-ROM of all materials.

The objective of this NCHRP project was to provide flexible, ongoing, quick-response research on transportation issues related to emergency incident prevention, mitigation, preparedness, response, and recovery, paying particular attention to potential terrorist threats.  BCG was to develop improvements to analytical methods, decision support tools, procedures, and techniques employed by practitioners to support statewide, local, and metropolitan transportation organizations in planning, exercising, and evaluating their continuity of operations programs.

Approach

In collaboration with McCormick Taylor, Inc., BCG distributed a 15-question survey to 199 Transportation Management Centers (TMC), transit agencies and state Departments of Transportation (DOT) to determine: the need for COOP guidelines; if agencies have developed COOP plans and why and, if so, what elements the COOP plan contains; and if agencies have identified key resources and personnel to support COOP functions.  We developed a database of survey results and findings were analyzed.  BCG conducted extensive literature review and developed an annotated bibliography.  Telephone interviews were conducted with personnel responsible for developing and maintaining COOP plans at state DOTs, TMCs, and transit agencies around the nation.  Finally, COOP plans gathered from submitted agencies were reviewed and analyzed.

Results

BCG created a complete guide to initiating COOP planning, including testing and executing the plan and revising it as necessary.  We included customizable worksheets, a series of brochures that can be used to explain the COOP planning process to employees, a presentation developed to obtain support for the COOP planning process from transportation executive leadership, and a CD-ROM containing electronic versions of all COOP planning worksheets, COOP figures and tables, the COOP plan template, and the outreach materials.  In addition, we included over 300 resource documents, organized in an electronic COOP library.

In July 2008, FTA Administrator James Simpson called the CEO Safety Summit to facilitate discussion regarding critical safety issues in the rail transit industry.  Administrator Simpson was aware that recent accidents had highlighted weaknesses in programs designed to protect workers, to ensure the integrity of critical infrastructure, and to facilitate rapid and effective evacuations from tunnels and vehicles under smoke conditions.  The Administrator also understood that, in some agencies, chief executive officers or executive directors might not be fully aware of the challenges faced in safety departments.

Approach

FTA and BCG developed a program of activities for this Safety Summit designed to: enhance CEO awareness regarding emerging safety trends that place workers, passengers, and infrastructure at risk; to share effective practices developed by some of the Nation’s CEOs; to reverse negative safety trends; and to provide an opportunity to discuss options currently being evaluated by FTA to enhance rail transit safety in the then upcoming re-authorization of the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU).

We sent letters to selected CEOs, inviting them to serve as speakers and to share how their agencies have worked to enhance their capabilities to protect wayside workers, to ensure the integrity of track, and to address emergency response readiness for evacuations in tunnels.  We also developed all summit materials, including a briefing book incorporating an attendee list, agenda, speaker biographies, menu, and participant contact information.  We oversaw all accommodations and ensured premium facilitation services.

Results

69 guests attended the 1.5-day.  Attendees included key FTA Headquarters personnel, top leadership from rail transit agencies, industry representatives, state oversight agency personnel, and FTA SSO program support staff.  Following the summit, we developed a detailed meeting report-back, documenting discussions and an analysis of summit evaluations.  We also distributed a CD-ROM of all summit materials to attendees.

Heavy rail service reported 315 passenger injuries resulting from derailments since 2006.  These heavy rail derailments have proved the most severe in terms of injuries.  Five derailments resulted in injury totals of five or more, including one 257-injury event.   Derailments caused by equipment failure or poor maintenance account for 290 of the reported derailment injuries. The Federal Transit Administration (FTA) in an effort to address underlying causes to rail transit derailments needed a track inspection refresher training program to be developed and delivered.

Approach

Following an FTA kickoff meeting, we requested materials from 36 rail transit agencies, documenting their practices to inspect and maintain track and ensure the safety of maintenance employees and contractors on the right-of-way.  This material along with standards and recommended practices published by AREMA, FRA, APTA, and other known authorities were assembled and reviewed to develop a “recommended best practice for track inspection”.  Next we coordinated with the Chicago Transit Authority (CTA) through a “Maintenance Oversight Workshop” to finalize the training materials and determine who from CTA would attend the training.

Results

The effort culminated in the delivery of a pilot track inspection refresher training course comprised of industry best practices that was delivered to approximately 85 track inspectors and track engineers in two, two-day courses.  CTA used the training to build on annual re-certification of its track inspectors.  Additionally, the effort targeted and practical technical assistance and training that can be implemented by the rail transit agencies and supported by the SSO agencies.

Following a series of track worker fatalities at heavy rail transit systems in the United States, FTA decided to respond by developing a variety of track worker safety training and educational initiatives.  FTA asked BCG to spearhead efforts such as track inspection refresher training, safety culture brochures, and track inspection and wayside worker protection technical assistance guidelines.  Additionally, FTA decided to increase the visibility and effectiveness of its assistance efforts by asking BCG to create an hour-long educational video for track inspectors, supervisors, and operations control center personnel.

Approach

BCG first conducted outreach to heavy rail representatives within the transit community to identify appropriate themes and proposed content for the training video. The video covers critical track worker safety concepts and highlights common mistakes and misconceptions. To elevate the video’s impact, BCG framed the video around the damage complacency and disregard of procedures causes not only track workers themselves, but also families, coworkers, and other communities.

The film begins with “a knock at your door,” placing the viewer at the vantage point of a family that is about to learn that their father, a transit track worker, is not coming home.  BCG and partnered with a firm to help develop the video script, organize shooting, film reenactments of real-world track worker fatalities at Washington Metro and New York City Transit, and edit all footage.

Results

On April 23, 2009, BCG organized a premier of the “A Knock At Your Door” video at the NTSB Conference Center in Washington, DC.  With opening remarks by the NTSB Chairman, FTA Executive Director, WMATA General Manager, NYCT President, and Union representatives, FTA premiered its video to federal representatives, transit employees, and family members of those lost in track worker tragedies.