RFP 197F-24 Attachment 5 -MBTA-SSCPP.pdf

February 27, 2024

Final

MBTA Safety Division

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MASSACHUSETTS BAY

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Document Control

Rev. Date. Prepared By Description of Changes 1 January 2015 MBTA Safety • Initial program developed and issued.

2 February 2023 MBTA Safety • Updated regulatory references.

3 November 2023 MBTA Safety • Updated responsibilities.

• Updated SSC Project Evaluation Criteria.

• Updated Category 1 and Category 2 criteria.

• Updated requirements and procedures for completing SSC activities.

• Updated risk management requirements.

• Added security assessment requirements.

• Updated documentation requirements.

• Updated SSC templates.

• Updated SSC contract specification.

4 February 2024 MBTA Safety • Updated SSCPP to incorporate FTA and internal MBTA comments.

• Made Final.

Prepared For:

Massachusetts Bay Transportation Authority 10 Park Plaza

Boston, Massachusetts 02110

Prepared By:

K&J Safety and Security Consulting Services, Inc.

3257 Elcano Lane

Cantonment, Florida 32533

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Approval

Sam Zhou Chief Engineer

Jeff Cook Acting Chief Administrative Officer

Ryan Coholan Chief Operating Officer

Daniel F. Laurich Director, Security & Emergency Management

Steven Culp Chief of Safety Engineering & Construction

Timothy Lesniak Chief Safety Officer

Date Approved

2/27/2024

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Table of Contents

Document Control

Approval

Table of Contents

List of Figures

List of Tables

Abbreviations

Definitions

1.0 Introduction

1.1 SSC and Safety Management Systems

1.2 SSC and System Safety

1.3 Goals and Objectives

1.4 Scope

1.5 Purpose

1.6 Applicability

1.7 Authority

1.8 Revisions

1.9 References

2.0 Roles and Responsibilities

2.1 SSC Program Management

General Manager

MBTA Safety

MassDOT Security and Emergency Management

Project Managers, Consultants, and Contractors

2.2 MBTA Departments and SSC Support

Engineering and Capital Division

Vehicle Engineering

Transit Oriented Development (TOD)

MBTA Operations (Vehicle Maintenance, E&M, Transportation, Railroad Operations)

2.3 Safety and Security Certification Committees

Safety Management Review Committee (SMRC)

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Safety Management Working Group

Fire Life Safety Committee (FLSC)

Operational Readiness Committee

3.0 Safety and Security Certification Process

3.1 Category 1 Certification

Requirements for Category 1 Projects

3.2 Category 2 Certification

Requirements for Category 2 Projects

Additional Considerations for Category 2 Projects

3.3 Safety and Security Certification 10-Step Process

Step 1: Identify Certifiable Elements

Step 2: Develop Safety and Security Design Criteria

Step 3: Develop and Complete the Design Criteria Conformance Checklist

Step 4: Perform Construction Verification Checklists

Step 5: Identify Additional Safety and Security Test Requirements

Step 6: Performing Testing and Validation in Support of SSC Program

Step 7: Manage Integrated Tests for the SSC Program

Step 8: Manage Open Items

Step 9: Verify Operational Readiness

Step 10: Conduct Final Determination of Project Readiness

4.0 Project-Specific Plans

4.1 Safety and Security Management Plan

4.2 Safety and Security Certification Plan

5.0 Risk Management

5.1 Safety Risk Management

5.2 Risk-Based Hazard Management

6.0 Security Risk Management

6.1 Physical Security

Step 1: SMWG Determination and Approval

Step 2: Asset Identification

Step 3: Asset Criticality Determination

Step 4: Threat Identification

Step 5: Threat Scenarios

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Step 6: Assess the Consequences of the Threat Scenario

Step 7: Prioritize Vulnerabilities and Countermeasures

Step 8: SMWG Acceptance and Approval

6.2 Cybersecurity

7.0 Documentation

7.1 Safety and Security Certification Workbook

7.2 Documentation Responsibilities

7.3 Procedures for Document Acceptance

7.4 Control of Safety and Security Certification Documentation

Appendix A: Safety and Security Certification Project Assessment Form

Appendix B: Certifiable Elements List

Appendix C: Preliminary Hazard Analysis (PHA)

Appendix D: Risk-Based Hazard Analysis (RBHA)

Appendix E: Security Assessment

Appendix F: Operational Hazard Analysis (OHA)

Appendix G: Hazard Tracking Log

Appendix H: Certifiable Items List (CIL)

Appendix I: Operational Readiness Conformance Checklist (ORCC)

Appendix J: Interim Certificate

Appendix K: Element Certificate of Conformance

Appendix L: Project Certificate of Conformance

Appendix M: Contract Specification

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List of Figures Figure 1: Safety Management System (SMS) Components 14 Figure 2: SSC Committee Structure 28 Figure 3: Project Safety and Security Certification Evaluation Criteria 33 Figure 4: TVA 8-Step Methodology 65 Figure 5: Developing Threat Scenarios 69

List of Tables Table 1: Project Categories 17 Table 2: Safety and Security Certification and Project Timelines 36 Table 3: Sample Certifiable Elements 37 Table 4: Step 1 Anticipated Outputs 40 Table 5: Step 2 Anticipated Outputs 43 Table 6: Step 3 Anticipated Outputs 45 Table 7: Step 4 Anticipated Outputs 46 Table 8: Step 5 Anticipated Outputs 48 Table 9: Step 6 Anticipated Outputs 49 Table 10: Step 7 Anticipated Outputs 50 Table 11: Step 8 Anticipated Outputs 51 Table 12: Examples of Operational Readiness Sub-Elements 53 Table 13: Examples of Pre-Revenue Service Test Requirements 53 Table 14: Step 9 Anticipated Outputs 54 Table 15: Step 10 Anticipated Outputs 58 Table 16: Examples of Typical Transit Assets 66 Table 17: Example of Asset Criticality 67 Table 18: Example of Critical Assets 68 Table 19: Possible Threats Against the MBTA 68 Table 20: Threat Severity Categories 69 Table 21: Vulnerability Issues to Consider 70 Table 22: Security Risk Vulnerability / Probability Categories 70 Table 23: Security Assessment Criticality Matrix 71 Table 24: Security Assessment Determination 71 Table 25: Example Responsibility Matrix 74

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Abbreviations AAR After-Action Report AHJ Authority Having Jurisdiction ATC Automatic Train Control BOD Basis Of Design CBRN Chemical, Biological, Radiological, and Nuclear CDRL Contract Data Requirement List CEL Certifiable Elements List CFR Code of Federal Regulations CIL Certifiable Items List COC Certificate of Conformance CSCC Construction Specification Conformance Checklist DC Design Consultant DCCC Design Criteria Conformance Checklist DHS Department of Homeland Security DPU Department of Public Utilities DUI Driving Under the Influence DWI Driving While Intoxicated E&M Engineering and Maintenance FLSC Fire Life Safety Committee FRA Federal Railroad Administration FTA Federal Transit Administration HTL Hazard Tracking Log HVAC Heating, Ventilation, and Air Conditioning ISO International Organization for Standardization ITD Information Technology Department LRT Light Rail Transit MassDOT Massachusetts Department of Transportation MBTA Massachusetts Bay Transportation Authority MCP Major Capital Project MOA Memorandum of Agreement MOU Memorandum of Understanding MOV Means of Verification NTP Notice to Proceed O&M Operations and Maintenance

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OHA Operational Hazard Analysis OP Oversight Procedure ORC Operational Readiness Committee ORCC Operational Readiness Conformance Checklist OSHA Occupational Safety and Health Administration PAF Project Assessment Form PHA Preliminary Hazard Analysis PHL Preliminary Hazard List PM Project Manager PMP Project Management Plan PMOC Project Management Oversight Contractor PPE Personal Protective Equipment PTASP Public Transportation Agency Safety Plan QA Quality Assurance QC Quality Control RFC Request For Change RFI Request For Information RFP Request for Proposal RTA Regional Transit Authority SA Safety Assurance SCADA Supervisory Control and Data Acquisition SCIL Safety-Critical Items List SME Subject Matter Expert SITT System Integration Testing Team SMRC Safety Management Review Committee SMS Safety Management System SMWG Safety Management Working Group SOP Standard Operating Procedure SRM Safety Risk Management SSC Safety and Security Certification SSCP Safety and Security Certification Plan SSCPP Safety and Security Certification Program Plan SSCVR Safety and Security Certification Verification Report SSEPP System Security Emergency Preparedness Plan SSI Security Sensitive Information

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SSMP Safety and Security Management Plan SSO State Safety Oversight SSP System Safety Program TOD Transit Oriented Development TSI Transportation Safety Institute TSSP Transit Safety and Security Program TVA Threat and Vulnerability Assessment TVCC Testing Verification Conformance Checklist TVM Ticket Vending Machine USC United States Code WMD Weapon of Mass Destruction

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Definitions Certifiable Element: Project components that can affect the safety and security of transit agency passengers, employees, contractors, emergency responders, or the general public.

These elements define the scope of the project's certification program.

Certifiable Elements List (CEL): Compilation of all identified certifiable elements for a project;

the CEL also includes sub-elements for each identified element.

Certifiable Item: Individual components of each certifiable element for the project.

Certifiable Items List (CIL): A compilation of all identified certifiable items for all certifiable elements of a project.

Certificate of Conformance (COC): Document verifying that all certifiable items of an element or the project have been verified and all hazards and threats related to that element or project have been sufficiently mitigated.

Construction Specification Conformance Checklist (CSCC): A comprehensive checklist outlining construction and installation specifications associated with each certifiable item. The checklist is used to verify that the project is built or installed in accordance with approved designs, technical specifications, drawings, and contract requirements.

Design Criteria Conformance Checklist (DCCC): A comprehensive checklist identifying design criteria and specifications associated with each certifiable item. The checklist is used to verify that the safety- and security-related technical specifications, drawings, and contract documents for the project are incorporated into the project designs.

Hazard Tracking Logs: The collection of documents used to track identified hazards and risks, such as the Preliminary Hazard Analysis, Operational Hazard Analysis, and Security Assessment.

Interim Certificate: A temporary certificate that allows the system to be placed into service or use with additional safety precautions and protections implemented, as necessary, until all required certification verification is completed.

Maintenance: Regularly scheduled or anticipated work used to restore, inspect, clean, repair, or replace conditions to a State of Good Repair from damage or general wear (e.g., tamping, roof replacements, rail grinding). Repairs or replacements to life-safety critical systems that may be considered maintenance should be reviewed with MBTA Safety to determine certification applicability. Like-in-kind replacement of any kind requires assessment to determine if existing systems are considered code or standard compliant.

Operational Hazard Analysis (OHA): An analysis used to identify, document, analyze, and mitigate operational hazards caused by operating and support (i.e., maintenance) personnel.

Operational Readiness Conformance Checklist (ORCC): A checklist to ensure that the major operational requirements are in place before revenue service, facility occupancy, or system / equipment utilization.

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Rehabilitation: A comprehensive process used to restore existing systems or assets to near original or new condition where maintenance is no longer feasible in preserving the State of Good Repair (e.g., station or facility renovations, vehicle overhauls, major track replacements, etc.).

Risk-based Hazard Analysis: The process to identify, analyze, and determine the specific actions a railroad will take to mitigate or eliminate the hazards and the resulting risks. This process is defined in the MassDOT/MBTA Railroad System Safety Program Plan.

Risk-Based Hazard Management: The processes (including documentation) used to identify and analyze hazards, assess, and rank corresponding risks, and eliminate or mitigate the resulting risks. Risk-based hazard management is hazard management process utilized by MBTA’s commuter rail operation. This process is defined in the MassDOT/MBTA Railroad System Safety Program Plan.

Preliminary Hazard Analysis: The process to identify and categorize potential hazards associated with the operation of a proposed or early-stage project.

Project: An undertaking to implement or modify a facility, infrastructure, systems, or transit-related program, or procure or overhaul a transit vehicle or equipment.

Safety and Security Certification (SSC): Processes that collectively verify a project's safety and security readiness.

Safety and Security Certification Plan (SSCP): A management tool used to execute the SSC program for individual projects; it establishes roles and responsibilities and defines key activities.

Safety and Security Management Plan (SSMP): A plan describing how the recipient of federal funding will address safety and security in a Major Capital Project, from initial project planning through initiation into revenue service.

Safety and Security Certification Verification Report: A report summarizing the project's safety and security certification activities.

Safety Assurance: The processes within SMS that function to ensure the implementation and effectiveness of safety risk mitigation and the transit agency meets or exceeds its safety objectives through the collection, analysis, and assessment of information.

Safety Critical Items List (SCIL): A compilation of all identified certifiable items associated with an Unacceptable or Undesirable hazard.

Safety Management System: The formal, top-down, organization-wide approach to managing safety risk and assuring the effectiveness of a transit agency's safety risk mitigation. SMS includes systematic procedures, practices, and policies for managing risks and hazards.

Safety Risk Management: The processes to assess the likelihood and severity of the consequences of hazards, and prioritize the hazards based on the safety risk.

Significant Operational Change: Any major change to the system that during initial review is determined to adversely impact safety and/or security if additional mitigations are not implemented

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System Integration Testing Team: Team established to manage integration testing, usually for larger or more complex projects.

Testing Verification Conformance Checklist: A comprehensive checklist outlining testing specifications and requirements for each certifiable item. The checklist is used to verify that the components of the project are operational or installed in accordance with approved designs, technical specifications, drawings, and contract requirements; this includes programs for contractual testing, systems integration testing, and pre-revenue operations testing.

Threat and Vulnerability Assessment: Process for identifying, assessing, and mitigating security threats and vulnerabilities.

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1.0 Introduction

The Federal Transit Administration (FTA) defines Safety and Security Certification (SSC) as "the series of processes that collectively verify the safety and security readiness for public use." In November 2002, the FTA published the "Handbook for Transit Safety and Security Certification, Final Report" to assist the transit industry in understanding and implementing safety and security certification processes. Transit agencies are responsible for determining the applicability of the concepts conveyed by the Handbook to their projects or developing other workable methods for Safety and Security Certification. Differences in methodology may exist among transit agencies, as well as among projects within a single agency.

The Massachusetts Bay Transportation Authority (MBTA) has developed this Safety and Security Certification Program Plan (SSCPP) to establish the management responsibilities and the technical processes associated with implementing a Safety and Security Certification (SSC) program. The SSCPP incorporates and builds on the methods described in FTA's Handbook for Transit SSC while establishing MBTA's certification procedures based on the Safety Risk Management (SRM) and Safety Assurance requirements defined in the MBTA's Transit Safety Plan, as well as Security Risk Management Processes contained within the agency's System Security and Emergency Preparedness Plan.

1.1 SSC and Safety Management Systems

Initially established in the Moving Ahead for Progress in the 21st Century Act (MAP-21), the FTA adopted the Safety Management System (SMS) model to develop and implement the National Safety Program. Built on the four (4) interconnected components (identified in Figure 1), SMS is intended to advance a comprehensive approach to safety decision-making and progress modern safety principles. FTA's adoption of the SMS framework elevated the national strategy to safety in transit, shifting from a reactive method to a proactive tactic focused on preventing events. SMS builds a safety culture in public transit dedicated to controlling and reducing safety risks through the early detection and correction of hazards.

Figure 1: Safety Management System (SMS) Components

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The principles of SMS must be incorporated as early as possible into the MBTA’s procurement processes. While each of the four components are interrelated, the following two (2) will be well-engrained in the certification process:

1. Safety Risk Management (SRM)

2. Safety Assurance (SA)

1.2 SSC and System Safety

The Federal Railroad Administration (FRA) requires agencies to implement a System Safety Program through an approved System Safety Program Plan (SSPP). The Program defines proactive processes and procedures for the identification and subsequent mitigation or elimination of hazards on an agencies system. This SSCPP is intended to support the requirements of the Commuter Rail SSPP by prescribing a set of procedures and requirements to identify and mitigate or eliminate the risk presented by new hazards during the implementation of a project.

49 CFR Part 270 requires that each SSPP include requirements for Safety and Security Certification based on the Safety Assurance and Risk-Based Hazard Analysis processes. Similar to SMS, all hazards will be assessed using the Risk-Base Hazard Analysis process to analyze system changes and modifications do not adversely impact safety. Verification of the hazard’s mitigations are then done in accordance with the certification program based on the Safety Assurance methodologies.

1.3 Goals and Objectives

Consistent with FTA’s Handbook for Transit Safety and Security Certification, the MBTA is a “self-certifying” agency responsible for determining which projects require SSC, the means and methods through which SSC will be carried out, and the process through which SSC requirements and outcomes will be documented and maintained. The MBTA has implemented a Safety Management System (SMS) that establishes Safety Policy, SRM, Safety Assurance (SA), and Safety Promotion activities, including training requirements.

MBTA’s SA program requires impacts to safety from any change must be evaluated through the SRM or Risk-Based Hazard Analysis processes to determine if the risk and mitigations are appropriate to eliminate or reduce the risk to an acceptable to MBTA. It is, therefore, the goal of MBTA’s SSC process to assure that system extensions and new and rehabilitated facilities, systems, and equipment, including vehicles, are as safe and secure as reasonably possible, within available resources, for use by passengers, employees, contractors, emergency responders, and the general public.

The MBTA aims to help achieve and demonstrate an acceptable level of risk for each project by:

● Implementing a systematic approach to hazard and threat/vulnerability management.

● Complying with safety and security codes, standards, and industry practices.

● Adhering to safety and security design criteria and specification requirements.

● Verifying safety and security requirements are identified, incorporated into, and achieved during project design, construction/installation, testing, and start-up.

Specific SSC Program objectives supporting the above goals include:

● Evaluating and resolving potential safety hazards and security vulnerabilities at the earliest possible phase of the project, with resolutions tracked and documented.

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● Ensuring appropriate codes, guidelines, and standards, as determined by MBTA, are reviewed and applied to provide a basis for safety and security considerations in the design criteria.

● Verifying that facilities, vehicles, systems, and equipment are designed, constructed, built, inspected, and tested according to design criteria and specifications.

● Creating new or making necessary changes to existing system safety and security plans, operating and maintenance plans and procedures, rulebooks, and training programs where appropriate.

● Demonstrating and documenting that personnel are trained and certified to operate and maintain the facilities, systems, and equipment.

● Familiarizing and providing initial training to emergency response agencies, including refresher training for the inherent hazards of MBTA operations and response to MBTA emergencies as necessary.

1.4 Scope

The SSCPP applies to projects whose results may affect the safety and security of the MBTA system. This includes, but is not limited to, projects that involve stations, system extensions, rail/bus rolling stock, all new infrastructure directly supporting revenue service, and any equipment addressing a major safety- or security-critical system. MBTA Safety and MassDOT Security and Emergency Management work with Project Managers to evaluate and determine the level of Certification required for each project.

The SSCPP addresses three separate but overlapping functional areas:

1. System Safety and Security

2. Fire Life Safety

3. Occupational Safety

Additionally, this SSCPP scope established an SSC management and administrative mechanism, a framework of project team responsibilities, a detailed SSC 10-step process, documentation requirements, and configuration management covering all MBTA potential projects needing SSC.

These projects fall within the following four (4) major categories with the stipulation that the example project types are not all-inclusive:

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Table 1: Project Categories

Systems

• Traction power

• Traction Power Substations

• Tiebreaker Stations

• Emergency and standby power systems

• Uninterruptible Power Supply (UPS)

• Generators

• Automatic Train Control (ATC) systems

• AC switchboard rooms

• Communications

• Signal systems

• Supervisory Control and Data Acquisition

(SCADA)

• SPTO Monitors/Cameras

• Fare Collection

• Ticket Vending Machines (TVMs)

• Fire Protection and Suppression Systems,

• Auxiliary (non-revenue) vehicles

• Equipment

• Signage

• Conventional and Alternate fueling systems

• Vehicle lifts

• CCTV

• Intrusion detection

• Controlled entry/access systems

• Blue light stations

Facilities and Equipment

• Stations/terminals

• Parking Garages and Parking Lots

• Pedestrian Bridges

• Maintenance facilities and storage yards

• Structures (elevated, ground surface, and sub-terrain)

• Track

• Administrative and Operational Control Facilities (e.g., Kiosk, HVAC, escalators, elevators, lighting, charging equipment for battery-electric buses, and photovoltaic equipment maintenance)

• Equipment installed along the guideway (e.g., tunnel lighting, emergency access/exits, signage, and pump systems).

Testing

• Contractual

• Systems Testing

• Integrated Testing

• Pre-Revenue Testing

Operations

• Emergency Preparedness Plan

• Snow and Ice Plan

• Operations and Maintenance Training

Programs

• Employee Qualifications

• Emergency Responder Training

• Rule Book

• Standard Operating Procedures (SOPs)

• Quality Assurance/ Quality Control Plans

• Maintenance Manuals

• Inspection/Maintenance Procedures

• Operations and Administrative Procedures

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1.5 Purpose

The purpose of this Plan is to meet the requirements of 49 USC Chapter 53 Section 5327, FTA Circular 5800.1, 49 CFR Part 673, 49 CFR Part 670, 49 CFR Part 270, and those of the Massachusetts Department of Public Utilities (DPU) as they pertain to SSC, change management, and SRM. The SSCPP has been developed to ensure that:

● Hazards and security vulnerabilities are identified, evaluated, and adequately controlled or mitigated before the commencement of passenger service, consistent with MBTA's SRM processes.

● Critical system elements are evaluated to comply with identified safety and security requirements during the design, construction/installation, testing, and start-up phases.

● MBTA facilities, vehicles, equipment, and systems are operationally safe and secure for customers, employees, emergency personnel, and the public before entering or re-entering after modification, revenue service, or use by MBTA personnel.

● Project Managers establish and utilize a management system to execute the SSC Program.

Key project team members have a common understanding regarding specific responsibilities and how the SSC program process is executed.

1.6 Applicability

The development and implementation of this Plan applies to all MBTA directly operated and contract activities related to:

● Heavy Rail

● Light Rail

● Bus

● Paratransit Service

● Commuter Rail

● Passenger Ferry

This Plan is intended to provide information on MBTA's Safety and Security Certification Program Plan (SSCPP).

1.7 Authority

The authority for establishing and performing SSC is derived from the following:

● 49 USC Chapter 53 Section 5327

● 49 CFR Part 633: Project Management Oversight

● FTA Circular 5800.1, Safety and Security Management Guidance for Major Capital Projects

These references require developing management plans for Major Capital Projects that document safety and security management requirements, including a safety and security verification process (i.e., safety and security certification). Additionally, 49 CFR Part 673 requires the MBTA to develop, document, and implement processes for managing change. Specifically, 49 CFR Part 673.27(c)(1) requires that the MBTA establish the following processes:

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A process for identifying and assessing changes that may introduce new hazards or impact the transit agency's safety performance.

Further, 49 CFR Part 673.27(2) states that:

If a transit agency determines that a change may impact its safety performance, then the transit agency must evaluate the proposed change through its Safety Risk Management process.

Therefore, developing and implementing this SSCPP assists MBTA in meeting these requirements for all modes regulated by the Federal Transit Administration (FTA).

For modes governed by the Federal Railroad Administration (FRA), 49 CFR Part 270 provides the following requirements:

270.103 (s)(3) Each passenger rail operation shall establish and set forth a statement in its SSP plan that describes the certification process used to help ensure that safety concerns and hazards are adequately addressed before the initiation of operations or major projects to extend, rehabilitate, or modify an existing system or replace vehicles and equipment.

Lastly, the Massachusetts Department of Public Utilities (DPU) State Safety Oversight (SSO) Program Standard requires MBTA to adhere to the following requirements:

151.03(2(h) A description of the safety certification process required by the Transportation Authority to ensure that safety concerns and hazards are adequately addressed prior to the initiation of major projects to extend, rehabilitate, or modify an existing system or to replace vehicles and equipment.

1.8 Revisions

The SSCPP is reviewed by MBTA Safety at least every three years and amended or revised as required to reflect process changes. Proposed revisions are reviewed and approved by members of the Safety Management Review Committee (SMRC). 1

1.9 References

The SSCPP presents a comprehensive approach to ensuring the safety and security of future extensions, capital improvements, and integration of new and rehabilitated facilities, vehicles, systems, and equipment. The following documents were used either in the preparation of the SSCPP or are references for related information:

Source documents:

● FTA Handbook for Transit Safety and Security Certification, November 2002 Final Report

● FTA Circular 5800.1 - Safety and Security Management Guide for Major Capital Projects -

Safety and Security Management Plan (SSMP)

● 49 USC Chapter 53 Section 5327, Project Management Oversight

● 49 CFR Part 633 – Project Management Oversight

● Massachusetts DPU State Safety Oversight Program Standard

1 Even if no changes are made after the SSCPP is reviewed, the date of the document date should be updated, and appropriate parties provide new signatures to show that a review was completed.

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● § 673.25 Safety Risk Management and § 673.27 Safety Assurance, Final Rule, July 19, 2018

● MBTA Transit Safety Plan

● MBTA Railroad System Safety Program Plan

● MBTA System Security Emergency Preparedness Plan (SSEPP)

● FTA Public Transportation Security and Emergency Preparedness Planning Guide, January

2003.

● FTA Construction Project Management Handbook, February 2016

● FTA Project and Construction Management Guidelines, March 2016

● FTA Oversight Procedure 22 – Safety and Security Management Review

● 49 CFR Part 270.103 (s) Safety Assurance

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2.0 Roles and Responsibilities

Implementation of the MBTA's SSCPP requires a coordinated effort with all MBTA staff. MBTA's Executive Leadership and various departments, staff, consultants, and contractors may be involved with a project requiring SSC. Therefore, it is the responsibility of project staff to become familiar with the requirements of MBTA's SMS, System Safety Program Plan (Commuter Rail only), and this SSCPP.

MBTA Safety also provides an SSC training program for Project Managers (PMs), consultants, contractors, and staff. The training includes information on the SSC program and a summary of their expected responsibilities. MBTA staff's responsibilities to ensure successful SSCPP implementation are described in this section.

Projects may have additional requirements for startup activities in addition to Safety and Security Certification. The responsibilities identified below do not amend or supersede any of those requirements (e.g., permitting, FRA’s New Start Program, DPU vehicle certifications, etc.).

2.1 SSC Program Management

General Manager The MBTA General Manager is responsible for delegating duties and responsibilities to ensure the overall SSCPP goals and objectives are achieved through coordination and integration between the MBTA, PMs, consultants, contractors, and supporting agency staff. Additionally, the General Manager is responsible for ensuring adequate resources are allocated to meet the goals and objectives of the SSC program and monitors its progress.

MBTA Safety MBTA Safety is responsible for managing and monitoring the implementation of this SSCPP and verifying the completion of tasks that address safety and security-critical certifiable elements, sub-elements, and Certifiable Items List (CILs). Additionally, MBTA Safety will provide SSC support to the project team.

Responsibilities include, but are not limited to, the following:

● Completing the SSC Project Assessment Form with each MBTA PM to validate all SSC requirements based on the assigned project certification category.

● Establishing and chairing project Safety Management Working Groups (SMWG).

● Reviewing and assisting MBTA PMs in developing project-specific SSMPs (if required) and directing the development of project-specific SSCPs, Preliminary Hazard Analyses (PHAs), Threat and Vulnerability Analyses (TVA), and CILs.

● Facilitating the development of the Operational Hazard Analysis (OHA), utilizing support from the project team, SMEs, and (if necessary) the Operational Readiness Committee (ORC).

● As necessary, developing CILs and PHAs to facilitate the SSC process under unique project circumstances, such as when the project SSC process starts late in the project life cycle.

● Performing verification on all project CILs covering design, construction/installation, testing, pre-revenue service, and operational requirements.

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● Reviewing verification documentation for all project CILs to ensure compliance with the identified safety and security requirements.

● Establishing Open Item Lists and hazard and vulnerability tracking logs for each assigned project to track all identified safety hazards and security vulnerabilities to resolution.

● Providing an SSCVR from the SMWG to the SMRC.

● Issuing and distributing Interim Certificates, as needed, for signature.

● Issuing and distributing Element Certificates of Conformance for signature.

● Issuing and distributing Project Certificates of Conformance for signature.

MassDOT Security and Emergency Management MassDOT Security and Emergency Management is a shared service with the MBTA and is responsible for all the Authority's planning and infrastructure programs associated with security and emergency management. Specific to the SSC process, Security and Emergency Management will be responsible for coordinating with a project's PMs to ensure:

● Security requirements are incorporated in project contracts, designs, specifications, and operational procedures.

● Security provisions are included in the CILs for each project lifecycle phase.

● Security verification documents that support compliance with MBTA's security requirements are submitted and sufficient for certification.

● The project TVA or Security Assessment has the appropriate security risk index assigned to identified vulnerabilities or security threats based on severity and probability, consistent with this Plan.

● Leading the design, development, and execution of drills and exercises as required by the project.

The Security Assessment results are shared and appropriately addressed with the design PMs through the SMWG meetings for inclusion in the project design criteria. However, all Security Assessments performed for a project will be handled as Security Sensitive Information (SSI) following the MBTA's SSI Policy.

Project Managers, Consultants, and Contractors All MBTA offices responsible for project planning and management of feasibility studies, design, construction/installation, testing, integration testing, and pre-revenue service phases are principally involved in the SSC process. Depending on the project’s scope, other MBTA departments may be required to participate in the SSC process.

MBTA Project Managers

All MBTA personnel leading projects, regardless of department, may manage projects subject to SSC requirements and the processes described in this SSCPP. While SSC activities will depend on the project’s scope, all MBTA PMs must be familiar with this Plan and its requirements.

The responsibilities identified below are not intended to amend or supersede any contractual requirements or process that the Project Manager, Design Consultant, or contractor must follow.

When implemented correctly, the responsibilities to implement the SSC program will supplement current processes to review and verify project submittals such as calculations, drawings, and specifications.

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Primary responsibilities include the following:

● Establishing direct communication with MBTA Safety.

● Completing the “Safety and Security Certification Project Assessment Form” in coordination with MBTA Safety, prior to issuance of a Request for Proposal.

● If required, develop a project-specific Safety and Security Management Plan (SSMP) within

60 Days of NTP (required for all Category 1 Projects, may be required for Category 2 projects).

● Establishing and organizing project SMWG in coordination with MBTA Safety.

● Presenting the signed Project Safety and Security Certification Assessment Form at the first project SMWG meeting for review and acceptance.

● Participating in SMWG meetings.

● Ensuring the design, construction/installation contractors designate an SSC representative for the project SMWG meetings.

● Ensuring that the recommended mitigations from the project PHAs and Security

Assessments (as required) are reviewed and accepted by the SMWG and the design team to consider inclusion in the project design criteria or Basis of Design (BOD).

● Establishing and maintaining a systematic, documented, comprehensive, and verifiable project submission system.

● Providing project status reports to the SMRC when requested on design, construction or installation, testing, SSC progress status, and any unresolved safety hazards with recommended mitigations.

● Providing design, construction or installation, and testing Request for Information (RFI) and Request for Change (RFC) requests and modification submittal logs to MBTA Safety and SMWG for review.

● Ensuring MBTA and contractor Subject Matter Experts (SMEs) that review and approve submittals attend SMWG meetings as needed.

● Including MBTA Safety and SMEs with the design review process and comment resolution meetings.

● Ensuring that the MBTA Safety team and operational SMEs receive construction safety training from the contractor to conduct site visits.

● Providing support through the SMWG with the finalization and signatures of certificates.

Design Consultant

Key responsibilities for Design Consultants include:

● Supporting and participating in the Project SSC Program process outlined in this SSCPP and participation in project SMWG meetings.

● Designating an SSC representative to manage all SSC activities and requirements.

● Developing a project-specific Safety and Security Certification Plan (SSCP).

● Developing the Preliminary Hazard Analysis.

● Developing the Security Assessment if required.

● Ensuring that PHAs and Security Assessments, if required, are reviewed by the SMWG and considered for the final design.

● Developing the project’s Certifiable Items List (CIL) and ensuring the CIL is linked to the

CEL, PHA, and Security Assessment.

● Developing the Design Criteria Conformance Checklist (DCCC) and ensuring it’s linked to the PHA, Security Assessment, and CIL.

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● Providing Means of Verification (MOV) to MBTA Safety to ensure verification of items in the

DCCC.

● Developing the baseline Construction Specification Conformance Checklist (CSCC).

● Developing the baseline Testing Verification Conformance Checklist (TVCC).

● Ensuring the DCCC is reviewed and approved by the SMWG and SMRC.

● Ensuring that if there are no project design criteria, Basis of Design (BOD), technical specifications, or Contract Data Requirement Lists (CDRLs), that mitigations identified in hazard or security analyses are utilized as the design criteria for DCCC.

● Performing Hazard Analyses as needed to support approved technical design changes for systems, subsystems, and software.

Construction, Installation, and Testing Contractors

Key responsibilities include:

● Supporting and participating in the SSC program as outlined in this SSCPP.

● Participating in SMWG meetings.

● Designating an SSC representative to manage all SSC activities and requirements.

● Ensuring that the CIL, Construction Specification Conformance Checklists (CSCC), and

Testing Verification Conformance Checklists (TVCC) are completed, including the specification requirements.

● Identifying and reporting additional hazards and vulnerabilities to the SMWG.

● Updating the CIL as construction/installation and testing submittals are reviewed and approved.

● Provide adequate Means of Verification (MOV) in a timely manner to MBTA Safety to allow for appropriate verification as the project progresses.

● Performing Hazard Analysis, as needed, to support approved technical construction/ installation changes for systems, subsystems, and software.

● Providing access to the project submittal system, document management systems, and

RFI/RFC logs.

● Ensuing that any changes or deviations from approved designs, specifications, manufacturer recommendations, or other criteria for construction are reviewed to assess their impacts to safety and security in coordination with the project SMWG.

2.2 MBTA Departments and SSC Support

The following section provides an overview of how departments support the overall SSC process.

Specific requirements for project managers within each department listed below can be referenced in Section 2.1 of this Plan.

Engineering and Capital Division Key responsibilities include:

● Implementing and enforcing this Program with MBTA Safety oversight.

● The procurement, management, and oversight of all design and construction projects for the

MBTA, in accordance with internal processes, standards, procedures, and controls as defined in internal project manuals, contract-specific plans and specifications, and applicable codes, standards, and regulations.

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● Working collaboratively with all MBTA departments, including MBTA Safety, to ensure that the Safety and Security Certification process is initiated at the onset of the project.

● Establishing a critical path to ensure that all safety-critical elements property verified prior to revenue service.

● Ensuring that all safety-critical issues are documented and resolved through the certification process.

● Ensuring that Safety and Security Certification activities and requirements are considered and included in the project budget and timeline from the beginning.

● Initiating Project Review Committees when projects are being developed to assess the effect on system safety and potential risk of injury to passengers and/or employees.

● Ensuring that MBTA Safety and other key departments/stakeholders such as Operations, System-Wide Accessibility, Engineering and Maintenance, MassDOT Security and Emergency Management, and the MBTA Transit Police Department (TPD) are incorporated into the Safety and Security Certification process.

● Developing and maintaining MBTA Design Criteria and updating it to include lessons learned from previous project experience.

● Ensure CILs conform to MBTA Design Criteria, plans and specifications, and applicable codes, standards, and regulations.

● Coordinate final Safety and Security Certification walkthroughs for acceptance of the certifiable items.

● Ensuring that documents such as the Project Manager’s Manual, Construction Field Staff Manual, and the individual contracts specific to a particular project contain all appropriate language to provide a framework that outlines the specific responsibilities of all parties regarding Safety and Security Certification.

● Ensure the timely resolution of all safety-critical elements identified through the Safety and Security Certification process. If, for any reason, critical issues cannot be resolved before the completion of a project or the transfer of a facility to Operations, all outstanding items will be documented and tracked until resolution.

● Maintaining final project documents, including but not limited to as-built drawings, submittals, affidavits, permits, inspection reports, certificates, etc. These documents will be utilized as the baseline for future modifications and changes.

Vehicle Engineering Vehicle Engineering works with MBTA Safety to ensure that the Safety and Security Certification process is initiated at the onset of the project. The Vehicle Engineering team will also ensure that a process is established to ensure that all elements of the Safety and Security Certification are addressed before the vehicles are entered into revenue service. All safety and security-critical issues identified by MBTA Safety and MassDOT Security and Emergency Management will be resolved using the certification process. As with infrastructure projects, Vehicle Engineering projects involving rolling stock will be certified using the methodologies outlined in this program plan.

Key responsibilities for Vehicle Engineering include, but are not limited to, the following:

● Implementing and enforcing this Program with MBTA Safety oversight.

● New vehicle design and procurement projects, vehicle overhaul projects, and oversight for the MBTA.

● Ensuring that, with collaboration with MBTA Safety, SSC activities and requirements are considered and included in the project budget and timeline from the beginning.

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● Initiate project review meetings when vehicle programs are being developed to assess the effect on safety and the potential risk of injury to equipment, passengers, and/or employees.

● Routinely engage with MBTA Safety, key stakeholders such as Operations, System-Wide Accessibility, Engineering and Maintenance, MassDOT Security and Emergency Management, and the TPD to ensure SME involvement in the Safety and Security Certification process.

● Developing, implementing, and effectively overseeing safety management and safety engineering processes, controls, verifications, and assurances.

● Initiating the development of Certifiable Items Lists (CILs) and any other subsequent items, either internally or with the assistance of the contractor and/or Design Consultant.

● Developing and maintaining the Technical Specifications and updates to include lessons learned from previous Safety and Security Certification/project experience, as applicable, ensure CILs conform to the Technical Specifications, applicable codes, and standards and regulations.

● Coordinate final Safety and Security Certification acceptance of the certifiable elements and major sub-elements.

● Working with MBTA Safety to ensure that documents, such as the contract, contain all appropriate language to provide a framework that outlines the specific responsibilities of all parties regarding Safety and Security Certification.

● Ensuring the timely resolution of all safety-critical items identified through the Safety and Security Certification process. If, for any reason, critical issues cannot be resolved prior to the completion of a project or the transfer of a vehicle to Operations, all outstanding items will be documented and tracked until resolution.

● Compiling final project documents, including but not limited to as-built drawings, submittals, affidavits, acceptance reports (such as First Article Inspection reports) and certificates, etc.

These documents will be utilized as the baseline of future modifications and changes as part of the Configuration Control and Management program.

Transit Oriented Development (TOD) MBTA Transit Oriented Development (TOD) is responsible for reviewing development projects that impact the MBTA’s operations or infrastructure. As such, certification of TOD projects presents unique challenges to the MBTA. In many circumstances, the MBTA does not have direct control of a TOD project and is constrained in implementing the safety and security certification process. However, TOD has responsibility for implementing the Safety and Security Certification process when a project is identified as having a potential safety or security implication to the MBTA in collaboration with MBTA Safety. The goal is therefore to identify and control safety and security risks introduced into the MBTA’s system. Due to the challenges associated with TOD activities, not all projects will undergo certification. Only those that become known to the MBTA will be assessed to determine if certification is required.

Key responsibilities for TOD, include, but are not limited to:

● Implementing and enforcing this Program with MBTA Safety oversight when a project is identified as impacting the MBTA.

● Ensuring that, with collaboration with MBTA Safety, SSC activities and requirements are considered and included in the project budget and timeline from the beginning.

● Ensure the timely resolution of all safety-critical elements affecting the MBTA identified through the Safety and Security Certification process. If, for any reason, critical issues

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● Initiating Project Review Committees when projects are being developed to assess the effect on system safety and potential risk of injury to passengers and/or employees.

● Working with MBTA Safety to ensure that documents, such as the contract, contain all appropriate language to provide a framework that outlines the specific responsibilities of all parties regarding Safety and Security Certification.

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