RID 2.25.9 - 2024 Transit Safety Plan.pdf

TRANSIT

SAFETY

PLAN

MASSACHUSETTS BAY

TRANSPORTATION

AUTHORITY

10 PARK PLAZA

BOSTON, MA 02116

Photo: CEX

Docusign Envelope ID: C1004119-AF9F-4B33-A869-4E558A8B4ECF

Applicability

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

• Heavy Rail;

• Light Rail;

• Bus; and

• Paratransit Service.

MBTA passenger ferry operations regulated by the United States Coast Guard (USCG), as well as rail fixed guideway public transportation service regulated by the Federal Railroad Administration (FRA) are not subject to the requirements set forth in this safety plan.

This plan is intended to provide information on MBTA’s Safety Management System.

Although MBTA’s Transit Safety Plan complies with 49 CFR Part 673 and 220 CMR 151, the regulations allow for a multi-year implementation period. During the SMS implementation process, acceptance of this Transit Safety Plan by the Department of Public Utilities and the Federal Transit Administration does not constitute approval or acceptance of any process or component of the SMS. Refer to the SMS Implementation Plan and phases found in the preface of this plan for the status of each SMS process/component. MBTA employees and contractors are required to comply with the policies and procedures as they are being implemented during the SMS phases contained within this plan.

Approvals

The MBTA Transit Safety Plan has been signed by:

Phillip Eng Date General Manager and SMS Accountable Executive

Timothy P. Lesniak Date Chief Safety Officer

MBTA’s Joint Labor-Management Safety Committee (JLMSC), established in accordance with requirements of the 2021 Bipartisan Infrastructure Law (BIL), approved this plan by consensus on December 10, 2024.

MBTA’s Safety Management Review Committee (SMRC) reviewed this plan on December 11, 2024.

The MBTA Board of Directors’ Safety, Health, and Environmental (SHE) Subcommittee reviewed this plan in December 2024.

MBTA’s Board of Directors approved this plan by vote on December 19, 2024.

Docusign Envelope ID: C1004119-AF9F-4B33-A869-4E558A8B4ECF

12/20/2024

TABLE OF CONTENTS

PRF 1 SAFETY MANAGEMENT POLICY STATEMENT

PRF 2 MBTA SMS IMPLEMENTATION

1 INTRODUCTION

1.1 MBTA Transit Safety Plan Purpose

1.2 MBTA Transit Safety Plan Scope

1.3 Federal, State, and Local Authority

1.4 Plan Review, Revision, and Approval

2 SMS SUPPORTING ELEMENTS

2.1 Safety Culture

2.2 MBTA Strategic Plan

2.3 Comprehensive Emergency Management Plan

2.4 Transit Asset Management Plan

2.5 Occupational Health and Safety Plan

2.6 MassDOT/MBTA Railroad System Safety Program Plan

2.7 Documentation and Records Management

2.8 Temporarily Suspension of Safety Programs

3 SAFETY PERFORMANCE

3.1 Safety Risk Reduction Program

3.2 MBTA Safety Performance Targets

3.3 Safety and State of Good Repair

3.4 Coordination with MPOs

4 ORGANIZATIONAL STRUCTURE & RESPONSIBILITIES

4.1 Key Safety Management Responsibilities

4.2 Safety Management Committee Structure

5 SAFETY RISK MANAGEMENT

5.1 Application of Safety Risk Management

5.2 Safety Risk Management Process

5.3 Hazard Tracking System

5.4 Safety Risk Management – Safety Assurance Interaction

6 SAFETY ASSURANCE

6.1 Safety Assurance Overview

6.2 System Operation/Monitoring

6.3 Data Collection

6.4 Data Analysis

6.5 Safety Performance Assessments

6.6 Continuous Improvement

7 SAFETY PROMOTION

7.1 Safety Culture

7.2 Safety Communication

8 SAFETY TRAINING

8.1 Personnel Directly Responsible for Safety Oversight

8.2 Personnel Directly Responsible for Safety

8.3 MBTA SMS-Related Training Courses

ACRONYMS

DEFINITIONS

DEPARTMENT SMS SUPPORT PLANS

BUS MAINTENANCE DEPARTMENT

BUS OPERATIONS DEPARTMENT

CAPITAL DELIVERY DEPARTMENT

ENGINEERING & MAINTENANCE DIRECTORATE

RAIL VEHICLE MAINTENANCE DEPARTMENT

TRANSIT RAIL OPERATIONS DEPARTMENT

PARATRANSIT SERVICES

SAFETY ASSESSMENT DECISION TOOL

MBTA REFERENCE DOCUMENTS

REFERENCED STANDARDS AND GUIDANCE DOCUMENTS

REFERENCED SAFETY STANDARD OPERATING PROCEDURES

RISK-BASED INSPECTION PROGRAM ADDENDUM

List of Figures Figure 1: Safety Management Decision-making Process Figure 2: Transit Safety Plan Review and Approval Process Figure 3: MBTA Safety-Related Plans Figure 4: FTA’s TAM – SMS Infographic Figure 5: Safety Management Committee Structure Figure 6: Safety Management Decision-making Process Figure 7: Safety Management Decision-making Process Figure 8: Safety Management Decision-making Process Figure 9: Safety Training Courses Supporting MBTA’s SMS

List of Tables

Table 5: SMS Documentation and Recordkeeping Table 6: Summary of Safety Performance Targets for CY2024 & CY2025 Table 7: Fatality Safety Performance Targets Table 8: Fatality Safety Performance Targets Table 9: Injury Safety Performance Targets Table 10: Transit Worker Injury Safety Performance Targets Table 11: Safety Events Performance Targets Table 12: System Reliability Safety Performance Targets Table 13: Collisions Performance Targets Table 14: Pedestrian Collisions Performance Targets Table 15: Vehicular Collisions Performance Targets Table 16: Assault on Transit Workers Performance Targets Table 17: Risk Severity Categories and Levels Table 18: Risk Probability Levels Table 19: Risk Assessment Matrix Table 20: Risk Acceptance Table-Hazard identified outside of SRM Workshops Table 21: Risk Acceptance Table-Hazard identified via SRM Workshops Table 22: MBTA-Controlled Documents Supporting MBTA’s Overarching Safety Program

PRF 1 SAFETY MANAGEMENT POLICY STATEMENT

Presented on the next page

2024 Safety Policy Statement

The Massachusetts Bay Transportation Authority (MBTA) is dedicated to providing safe, reliable, and accessible service to our communities and customers. We aim to foster a culture of safety throughout the organization by establishing safety performance standards and allocating the resources needed to ensure employee and passenger safety. Our Safety Management System (SMS) program is foundational to this effort, outlining safety risk management, safety assurance, and safety promotion activities. The SMS Gap Analysis, completed February 2024, identifies areas for improvement among current safety practices; the SMS Implementation Plan, completed May 2024, establishes the roadmap for implementing, maintaining, and continuously improving these activities over the next several years.

All MBTA employees have a role within our SMS program; we are all accountable for delivering exceptional safety performance, starting with the General Manager (GM). Safety is a core value and primary responsibility for employees and all levels of management, as defined in all MBTA job descriptions. The MBTA’s safety committee structure provides an avenue for reporting hazards, elevating safety issues, and guiding funding allocation. The highest-level safety committees, the Joint Labor-Management Safety Committee and Safety Management Review Committee, cultivate a cooperative relationship between labor and management to identify safety risk mitigations, set safety performance targets, and review and approve the Transit Safety Plan (TSP).

In the coming year, the MBTA will mature our SMS program by achieving the milestones laid out in the first phase of the SMS Implementation Plan:

• Establish visibility into the structure of SMS and supporting processes.

• Build employee trust in the Safety Hotline and Safety Hotline Portal; receiving hazard reporting information is critical to the operation and success of SMS.

• Formalize and document existing SMS procedures, such as hazard reporting, safety risk prioritization, risk assessment, and risk mitigation monitoring.

• Develop a SMS training matrix based on individual roles and responsibilities, the first step towards delivering a comprehensive suite of job-specific training to the MBTA workforce.

The MBTA will also take the following steps to improve its existing safety culture:

• Provide the appropriate resources necessary to support effective, sustainable safety management.

• Ensure that staff and contractors obtain adequate safety-related training, are competent in safety management matters, and are only allocated tasks commensurate with their skills.

• Promote voluntary, non-punitive employee engagement in hazard identification and reporting through the Safety

Hotline and Safety Hotline Portal. Willful disregard for safety is unacceptable and subject to disciplinary action as outlined in MBTA policies and rules.

• Enhance safety investigation efforts by updating and fully implementing the Safety Event Investigation Manual, including education for those with event investigation responsibilities.

• Leverage safety data technologies and reporting products to support and inform decision-making at all levels of the organization.

• Improve the organization and function of our safety committees to support SMS processes.

• Establish and maintain workplace safety programs that meet or exceed state and federal standards.

Approved by:

___________________________________________________ Date___________________

Phillip Eng

MBTA General Manager and SMS Accountable Executive

MASSACHUSETTS BAY

TRANSPORTATION AUTHORITY

REVISION: 4 MBTA Transit Safety Plan PAGE: 9 of 127

PRF 2 MBTA SMS IMPLEMENTATION

The MBTA’s Safety Management System Implementation Plan (SMSIP) identifies actions needed to fully realize a robust culture of safety within the transit agency. The SMSIP builds upon the findings of the updated SMS Gap Analysis Report (2024) to address the major outcomes of the assessment, which noted that the MBTA lacks data-driven resource-based budgeting, formalized processes for SMS components, visibility into SMS structure, and methods for SMS process improvement. To address these gaps, the SMSIP describes a three-phase approach to elevating each of the four Components of SMS to a “Sustaining/Improving” maturity level, which is characterized by safety management training and the implementation of continuous improvement processes.

Each of the SMSIP phases addresses critical aspects of the SMS:

• Phase 1 – Increase Employee Awareness

• Phase 2 – Establish Remaining SMS Processes

• Phase 3 – Institutionalize Continuous Improvement and Address Remaining Training

For more detailed information concerning the methodology of the SMSIP and the actions associated with each phase of the implementation, please refer to the SMSIP available to all employees on T-Stop.

REVISION: 4 MBTA Transit Safety Plan PAGE: 10 of 127

1 INTRODUCTION

The Massachusetts Bay Transportation Authority (MBTA) Transit Safety Plan is a comprehensive document intended to ensure the safety of customers, employees, contractors, emergency responders, and the general public.

The Transit Safety Plan establishes Safety Management Systems (SMS) principles as its foundation. The four Safety Management System (SMS) components that apply to all facets of the Authority are:

1) Safety Policy: to align the entire MBTA under a safety management system for the purpose of prioritizing safety in management decision making.

2) Safety Risk Management (SRM): to implement processes that will identify, evaluate, and resolve risks, and track risk mitigations.

3) Safety Assurance (SA): to oversee that all the objectives are met through effective data collection and assessment.

4) Safety Promotion: to encourage workplace and public confidence in, knowledge of, and engagement with MBTA’s commitment to ensuring safety.

These four components are the means to achieve the highest level of safety for MBTA’s customers, employees, contractors, emergency responders, and the general public. Figure 1 provides a graphical view of the principal sets of processes of SMS: SRM and SA. Chapters 5 and 6 of this Safety Plan detail the SRM and Safety Assurance processes, respectively.

Figure 1: Safety Management Decision-making Process

REVISION: 4 MBTA Transit Safety Plan PAGE: 11 of 127

SMS is a comprehensive, collaborative approach that brings management and labor together to build on MBTA’s existing safety foundation to mitigate risk, detect and correct safety problems earlier, share and analyze safety data more effectively, and measure safety performance more carefully. SMS applies resources to risk and is based on ensuring that MBTA has the organizational infrastructure to support decision-making at all levels regarding the assignment of resources.

1.1 MBTA Transit Safety Plan Purpose

The MBTA Transit Safety Plan governs and defines the authority, responsibilities, roles, and processes prescribed herein. It assures compliance with and application of federal, state, and local regulations and industry best practices. The MBTA Transit Safety Plan and resulting safety programs, policies, rules, orders, implementation, and processes represent the MBTA’s commitment to safety as a core value.

1.2 MBTA Transit Safety Plan Scope

The scope of the Transit Safety Plan spans all facets of safety management to systematically achieve the highest practical level of safety for MBTA’s transit system. All MBTA employees contribute to safety. This Plan is intended for use by all employees, and all employees have a responsibility to consider safety in all of their actions.

The MBTA SMS applies to all MBTA employees, managers, relevant contractors, and related service providers who are either directly or indirectly involved in providing transportation services. This includes MBTA bus, paratransit, light rail, and heavy rail activities including but not limited to operations, engineering, maintenance, administration, design, and construction; it also includes all equipment, vehicles, systems, sub-systems, and infrastructure.

1.3 Federal, State, and Local Authority

1.3.1 Federal Transit Administration

The Federal Transit Administration (FTA) administers a national transit safety program and program compliance oversight process to advance the provision of safe, reliable, and equitable transit service through adherence with legislative, policy, and regulatory requirements.

In April 2005, the U.S. Congress expanded FTA’s regulatory role by granting authority to develop State Safety Oversight Programs, as defined by 49 CFR Parts 659 and 674, “Rail Fixed Guideway Systems; State Safety Oversight.”

In July 2012, Congress passed Moving Ahead for Progress in the 21st Century Act (“MAP-21”; Pub. L. 112-141), which created a new Public Transportation Agency Safety Program, and brought about major safety-specific changes to all modes of the transit industry. The key elements of the program include 49 U.S.C. § 5326, “Transit Asset Management” and 49 U.S.C. § 5329, “Public Transportation Safety Program,” which resulted in the following FTA rulemakings:

• 49 CFR 625, “Transit Asset Management” (final rule effective October 1, 2016)

• 49 CFR 670, “Public Transportation Safety Program” (final rule effective September 12, 2016)

REVISION: 4 MBTA Transit Safety Plan PAGE: 12 of 127

• 49 CFR 672, “Public Transportation Safety Certification Training Program” (final rule effective August 20, 2018)

• 49 CFR 673, “Public Transportation Agency Safety Plan” (final rule effective July 19, 2019, revised April 2024)

• 49 CFR 674, “State Safety Oversight” (final rule effective April 15, 2016, revised October 2024)

49 CFR 673, “Public Transportation Agency Safety Plan,” formally requires public transportation systems to develop a Public Transportation Agency Safety Plan based on the SMS approach, the development and implementation of which will help ensure that public transportation systems are safe nationwide.

Reauthorization of the FTA programs occurred in June 2021 when Congress passed the Infrastructure Investment and Jobs Act, (“Bipartisan Infrastructure Law” (BIL); Pub L. 117-58). The law authorized funds for several initiatives, including transit programs and other purposes. Key aspects of 49 U.S.C. § 53, “Federal Transit Law” include:

• State safety oversight agencies authority to collect and analyze data and conduct risk-based inspections of rail fixed guideway transportation systems.

• Agency safety plans must be consistent with Centers for Disease Control and Prevention and State health authority guidelines to minimize exposure to infectious diseases.

• The safety plan is developed in cooperation with frontline employee representatives.

• The establishment of a Safety Committee, composed of equal representatives of frontline employees and management, that is responsible for identifying, recommending, and analyzing the effectiveness of risk-based mitigations or strategies to reduce consequences identified in the agencies’ safety risk assessment.

• Development of a risk reduction program for transit operations to improve safety by reducing the number and rates of accidents, injuries, and assaults on transit workers based on data submitted to the national transit database, including a reduction of vehicular and pedestrian accidents involving buses that include measures to reduce visibility impairments for bus operators and the mitigation of assaults on transit workers.

• The setting of risk reduction performance targets using a three-year rolling average of the data submitted to the National Transit Database. Performance targets will be established in the next revision to the National Transportation Safety Plan.

• The allocation of not less than 0.75 percent of section 5307 funds to safety related projects. If the performance targets are not met, then this funding must be re-allocated to meet the performance targets, which includes modifications to rolling stock and de-escalation training.

• Maintenance personnel required to meet the existing safety training requirements, and safety, operations, and maintenance personnel to complete de-escalation training.

Revisions to 49 CFR 673 in 2024 aligned the regulation with the requirements of the BIL and expanded on certain requirements in the Law. Key changes included:

REVISION: 4 MBTA Transit Safety Plan PAGE: 13 of 127

• Requirements for documentation of how the frontline employee Safety Committee is composed, how meetings are scheduled and recorded, how disputes are resolved, and how frontline individuals are compensated for their participation

• Clarified expectations for the relationship between the Safety Committee and the risk reduction program as a whole Additional detail on the transit agency’s risk reduction program and its relationship with performance monitoring, risk management, and safety assurance

49 CFR 674, “State Safety Oversight,” carries out the mandate of 49 U.S.C. 5329 for State safety oversight of rail fixed guideway public transportation systems. Part 674 underwent revisions in 2024, and the updates will be in effect starting January 1, 2025. This update to the TSP includes the 2024 revisions for 49 CFR 674.

1.3.2 FTA Safety Management Inspection

In 2022, MBTA demonstrated a pattern of safety events which included revenue and nonrevenue derailments, train and grade crossing collisions, fatalities, and other events involving both MBTA employees and passengers.

In addition, MBTA’s safety performance, as monitored through data reported to the National Transit Database (NTD), indicated a higher overall rate of safety events and increase in severity of events. As a result of these two observations, the FTA conducted a Safety Management Inspection (SMI) in 2022.

FTA’s 2022 SMI included a review of rail transit operations, training, vehicle maintenance, signals and train control, and track access. It also covered capital project delivery, traction power, facilities, and safety management. As a result of the inspection, the FTA issued eight Special Directives to the MBTA. In response, MBTA developed Corrective Action Plans (CAP) and Action Items that detail how the Authority will address each FTA Special Directive and implement safety improvements across the organization. Remaining recommendations from the 2019 Safety Panel Report were considered and woven into the CAP process.

1.3.3 Massachusetts Department of Public Utilities

FTA recognizes the Massachusetts Department of Public Utilities (DPU) as the State Safety Oversight Agency (SSOA) for the state of Massachusetts.1 M.G.L. c. 161A, s. 3(i) empowers the Massachusetts Department of Public Utilities (DPU) to regulate the safety of equipment and operations at MBTA as prescribed in 220 C.M.R.

151.00, et seq., “Rail Fixed Guideway System: System Safety Program Standard.”

DPU exercises jurisdiction over the safety of MBTA equipment and operations and is responsible for establishing standards for rail safety practices In addition, DPU oversees the execution of these practices and procedures to ensure compliance by utilizing a broad range of tools and powers.

The FTA’s Special Directive 22-34 requires that the DPU and MBTA (as the Rail Transit Agency) include in MBTA’s ASP provisions stating that MBTA will comply with DPU’s SSOA Program Standard as it relates to inspections of the RTA and the DPU’s Risk-Based Inspection (“RBI”) program. DPU’s RBI program is set forth

1 Refer to 49 CFR 674, “State Safety Oversight” for detailed regulatory information.

REVISION: 4 MBTA Transit Safety Plan PAGE: 14 of 127 in its Standard Operating Guideline Manual Section 5.8. Additionally, the MBTA complies with the inspection and access provisions applicable to the MBTA in DPU’s Standard Operating Guideline Manual (SOG) Sections 2.7a, 5.6, and 5.6a.

The BIL authorizes SSOAs including DPU to conduct risk-based inspections of the transit agencies they oversee.

The BIL also authorizes SSOAs to collect and analyze the qualitative and quantitative data required to prioritize inspections in accordance with levels of safety risk. Under 220 CMR 151, this authority includes the ability of DPU personnel to access MBTA facilities and property both with and without advance notice, and to inspect infrastructure, equipment, operations, records, personnel, and data. Further, 220 CMR 151.10(5) identifies specific items that the DPU may request access to regarding data; including defect data, work orders, and inspection data. See 220 CMR 151.10(5) for details.

To support DPU’s Risk-Based Inspection (RBI) program, the MBTA coordinates with DPU on policies and procedures for inspection access and data collection. The policies and programs defining the DPU’s authority to carry out a risk-based inspection program are outlined further within the DPU’s Program Standard, including but not limited to, conducting risk-based inspections, a description of the types of activities, and data collection.

The MBTA will comply with the inspection provisions applicable to MBTA in DPU’s SOG Section 5.8.2 regarding RBI, including inspections with and without prior notice. This includes but is not limited to, when necessary or requested by DPU, MBTA will provide support resources including but not limited to flaggers or facility escorts to ensure DPU staff have the access necessary to conduct inspection and RBI activities. MBTA also will provide DPU with access to safety reporting data, including but not limited to MBTA’s Hazard Tracking database, incident reporting data, and inspection data. MBTA will respond to DPU’s formal Requests for Information within the designated timeframe indicated in the request or the timeframe in any DPU approved extension. MBTA will comply with the provisions applicable to MBTA in DPU’s SOG Section 5.8.3 regarding providing DPU with the data MBTA collects when identifying hazards and assessing and mitigating safety risks, and will provide such data to DPU.

MBTA is required to develop and implement the MBTA Transit Safety Plan to comply with 49 CFR Parts 673 and 674 and 220 CMR 151.00, subject to acceptance by DPU and ultimately FTA. MBTA’s relationship with its SSOA is a multi-level safety partnership, through regulation and collaboration. DPU and MBTA’s Chief Safety Officer (CSO) meet at least monthly. DPU and MBTA management meet at least quarterly and DPU meets at least annually with the Accountable Executive and Board of Directors, or equivalent authority.

1.3.4 Public Health Guidelines

As required by the BIL, MBTA follows all guidelines and standards set by the Centers for Disease Control (CDC) and Massachusetts Department of Public Health with regard to preventing the spread of and minimizing exposure to infectious disease such as COVID-19. MBTA follows all applicable federal and state guidelines and requirements, including those regarding face coverings, vaccinations, testing, social distancing, and cleaning and sanitizing of vehicle and facilities. MBTA’s Environmental Department maintains services to neutralize and

REVISION: 4 MBTA Transit Safety Plan PAGE: 15 of 127 remove needles and syringes found in MBTA vehicles and facilities as part of broader efforts to limit exposure to infectious disease and manage blood-borne pathogens. MBTA has joined the American Public Transportation Association (APTA) Health & Safety Commitments Program to publicly pledge to follow all official guidance and prioritize the health of its customers, employees, and contractors. MBTA deploys the appropriate risk management methodology as needed to address identified hazards and risks.

1.4 Plan Review, Revision, and Approval

The plan may require revision due to changes identified during the annual internal review process or when modifications are required off-cycle.

Modifications to the plan are sometimes initiated in response to regulatory changes. MBTA’s Senior Director of Regulatory Affairs within the General Manager’s office, as well as Safety’s Director of SMS and Safety Oversight and other key Safety Division mangement, are enrolled in applicable FTA distribution lists and regulatorly monitor federal and state regulatory changes impacting MBTA’s safety program.

Per 220 CMR 151 (4), DPU requires an annual review of the Safety Plan on or before August 1st of every year.

If updates to the Safety Plan are required, the Safety Plan and any accompanying procedures and supporting references must be submitted to DPU for approval on or before September 1st. If no update is required, MBTA must notify DPU in writing on or before September 1st. The Authority may request an extension of the deadline for submission, which may be granted or denied at the discretion of DPU.

Modifications may be requested by DPU due to internal audit report results, on-site reviews and investigations, changing trends in safety event or security data, or other reasons that may come to the attention of DPU.

Modifications may also be necessary where MBTA management identifies necessary updates such as organizational changes, procedural updates, or reassignment of functional responsibilities. If the Safety Plan is revised outside of the annual review cycle, then MBTA must submit the Safety Plan and any accompanying procedures and supporting references to DPU within 30 calendar days of the event requiring an update.

The MBTA Transit Safety Plan will be reviewed using the following internal review process prior to submitting the revised Transit Safety Plan to the DPU for review and approval as required by state regulation 220 CMR 151(4) as illustrated in Figure 2.

REVISION: 4 MBTA Transit Safety Plan PAGE: 16 of 127

Figure 2: Transit Safety Plan Review and Approval Process

1.4.1 MBTA Transit Safety Plan Internal Review

MBTA adheres to the MBTA Transit Safety Plan internal review process, which ensures labor and executive management have reviewed and approved the revised Transit Safety Plan before it is submitted to DPU for review and approval.

1.4.1.1 Joint Labor-Management Safety Committee (JLMSC) Review and Approval

• The Safety Division submits the MBTA Transit Safety Plan to the JLMSC for review and approval, fulfilling the BIL requirement that a joint labor-management safety committee review and approve the Transit Safety Plan. Any substantive changes received from other reviewers in this process must be reviewed and approved by the JLMSC.

• Upon receiving comments and/or corrections from the JLMSC, the Safety Division will review and update the Safety Plan as applicable. The revised Plan will be resubmitted to the JLMSC for approval.

1.4.1.2 Safety Management Review Committee (SMRC) Review

• The Safety Division submits the updated MBTA Transit Safety Plan to the SMRC for review for any comments and/or corrections.

• Upon receiving comments and/or corrections, the Safety Division will review and update the Safety Plan as applicable. The revised Plan will be resubmitted to the JLMSC for approval.

1.4.1.3 Accountable Executive Review and Signature

• The MBTA CSO submits the updated Safety Plan to the Accountable Executive for review and signature.

DPU Review & Approval

Board of Directors Review & Approval

BOD Safety, Health & Environment Subcommittee Review

Accountable Executive Review & Approval

SMRC Review

JLMSC Review & Approval

REVISION: 4 MBTA Transit Safety Plan PAGE: 17 of 127

• Upon receiving comments and/or corrections from the Accountable Executive, the Safety Division will update the Safety Plan and resubmit the updated Safety Plan to the Accountable Executive for approval and signature. The revised Plan will be resubmitted to the JLMSC for review and approval, and then provided to the Accountable Executive.

• MBTA’s Accountable Executive provides certification of compliance with 49 CFR Part 673 and 220 CMR 151 by signing this Transit Safety Plan (and subsequent revisions) and providing the date of their signature as the certification date.

1.4.1.4 MBTA Board of Directors (BOD) Review and Approval

• The signed Safety Plan is first submitted to the Safety, Health & Environment Subcommittee within the MBTA Board of Directors for review, and then to the full Board of Directors for vote of approval prior to its submission to the DPU.

• Upon receiving comments and/or corrections from the BOD or its Safety, Health, & Environment Subcommittee, the Safety Division will update the Safety Plan, resubmit it to the JLMSC for review and approval, resubmit the updated Safety Plan to the Accountable Executive for approval and signature, and then submit the signed, updated Safety Plan for BOD vote of approval.

1.4.2 DPU Review and Approval

MBTA is committed to open communication with DPU regarding newly-proposed updates to the Transit Safety Plan, and will coordinate DPU annually before the updated Plan is presented to the Board of Directors to ensure that major inputs, comments, and questions are addressed in the forthcoming revised version.

At the conclusion of MBTA’s review process, the Safety Plan will be delivered to DPU in electronic format via email. Supporting procedures and referenced materials may be submitted in hard copy, by fax, mail, email, or in-hand delivery. Once the Safety Plan has been approved by DPU, MBTA must submit a copy to DPU in an unalterable format (electronic or hard copy).

Within fifteen (15) calendar days of receipt of the revised MBTA Transit Safety Plan, DPU will issue a response that it approves, conditionally approves, or is unable to approve the Plan, along with the checklist used to review the MBTA Transit Safety Plan. If the Department rejects the document, the Transportation Authority has 20 days from notice of rejection to submit a revised document to the Department for approval. The DPU may grant an extension beyond the 20 days for good cause shown.

If DPU is unable to approve a final document, or to resolve a dispute with the MBTA resulting from the development of the document, DPU must either:

1. Report the areas of disagreement in writing to, and negotiate with, MBTA until the dispute is resolved;

2. Develop its own document according to the requirements of the relevant section, and submit it to MBTA for implementation; or

3. Issue any Order that it deems necessary.

REVISION: 4 MBTA Transit Safety Plan PAGE: 18 of 127

2 SMS SUPPORTING ELEMENTS

SMS is the framework that mitigates and controls safety risk within the organization. The MBTA uses this framework to ensure its employees are safe, who then, in turn, deliver safe and reliable service to its communities and customers. Many elements within this framework manage safety risk at the MBTA, each of which is described in the following sections. Each supporting element is intended to strengthen safety at the MBTA.

2.1 Safety Culture

MBTA is committed to improving its safety culture through implementation and support of a formal SMS.

MBTA defines its culture as the product of the individual and group values, attitudes, competencies, and patterns of behavior that determine the commitment to, and the style and proficiency of, an organization’s health and safety programs. Organizations with a positive safety culture are characterized by communications founded on mutual trust, shared perceptions of the importance of safety, and confidence in the efficacy of preventative measures.

It is the intention of senior management to institute a positive safety culture throughout the organization. MBTA’s Strategic Plan establishes Safety as one of eight goals for the organization, and empowers and supports staff to develop a culture which prioritizes and promotes safety. To accomplish this, all employees must be responsible for, and consider the impact of, safety in every task they perform. This approach must be so inherent that it defines MBTA’s culture. This safety-centric approach sets the expectations for safe behavior at MBTA.

As part of its SMS implementation, MBTA will measure its safety culture using surveys, or an equivalent method.

Having a baseline understanding of employees’ perception of safety at the MBTA will help management understand what components of the SMS should be improved and where MBTA has success in implementing SMS to support a positive safety culture.

2.1.1 Informed Culture

In an informed culture, the organization collects and analyses relevant data, and actively disseminates safety information. Management fosters a culture where people understand the hazards and risks inherent in their areas of operation. Personnel are provided with the necessary knowledge, skills, and job experience to work safely, and they are encouraged to identify threats to their safety and to seek changes necessary to reduce or eliminate exposure to these hazards.

2.1.2 Reporting Culture

A reporting culture means cultivating an atmosphere where people have confidence to report safety concerns without fear of blame or reprisal. Employees must know that confidentiality will be maintained and that the information they submit will be acted upon, otherwise they will decide that there is no benefit in their reporting.

The workforce must feel confident that reported hazards will be addressed. They must also be assured that the reporting will not result in retaliation. Any retaliating act against an employee who exercises their workplace

REVISION: 4 MBTA Transit Safety Plan PAGE: 19 of 127 rights will be investigated as this type of behavior is not accepted at the MBTA. Violation of any employee workplace rights could lead to action up to and including discharge.

2.1.3 Learning Culture

A learning culture means that an organization can learn from its mistakes and make changes. It will also ensure that people understand the SMS processes at a personal level.

Learning extends beyond initial skills training and is valued, instead, as a continuous process. Employees are encouraged to develop and apply their skills and knowledge to enhance organizational safety. Safety reports are shared amongst employees so that they can learn from the findings associated with the near miss or event.

2.1.4 Just Culture

In a just culture, errors and unsafe acts will not be punished if the error was unintentional. However, those who act recklessly or take deliberate and unjustifiable risks will still be subject to disciplinary action.

A just culture is described as an atmosphere of trust in which people are encouraged, and even rewarded, for providing essential safety-related information, but also delineates between acceptable and unacceptable behavior.

Throughout MBTA’s SMS implementation, employees should begin to perceive that atmosphere of trust for coming forward with safety concerns and issues.

While a non-punitive environment is fundamental for a good reporting culture, all employees must understand the difference between acceptable and unacceptable behavior.2 Reckless, or intentional violations will not be tolerated, even in the non-punitive environment. MBTA’s just culture will recognize that, in certain circumstances, there may be a need for punitive action and management will define the line between acceptable and unacceptable actions or activities.

Safety culture is the product of personal dedication and accountability of all employees. Individual efforts alone do not necessarily result in the desired outcome. MBTA realizes that a positive safety culture only develops with an aggregate attitude that is manifested by a pervasive type of safety thinking. This type of organizational thinking will permit employees to have an inherently questioning attitude, a resiliency to complacency, a commitment to excellence, and a sense of personal accountability. Senior management provides a vibrant, encouraging atmosphere in which individual growth is recognized and rewarded.

To further promote a positive safety culture throughout MBTA, senior management has instituted an employee recognition program, the annual Agents of Safety Awards, to honor individuals who make a significant contribution to safety.

2.1.5 Flexible Culture

A flexible culture is one where the organization and the people in it are capable of adapting effectively to changing demands.

2 Different MBTA departments have specific rulebooks that address prohibited acts for employees.

REVISION: 4 MBTA Transit Safety Plan PAGE: 20 of 127

2.2 MBTA Strategic Plan

The MBTA Strategic Plan lays out the vision, mission, values, and goals for the MBTA, establishes its priorities, and is a blueprint for continuous improvement that will fulfill the vision of the MBTA that is needed to support the Authority’s broader goals.

Figure 3 documents the different safety plans that work together to inform one another and support the Board of Directors’ MBTA Strategic Plan.

Figure 3: MBTA Safety-Related Plans

2.3 Comprehensive Emergency Management Plan

While MBTA has taken every precaution to avoid emergency events and situations, it is inevitable that safety events may still occur. In order to deal with these unexpected situations in a predefined manner, the Comprehensive Emergency Management Plan (CEMP) has been developed and is maintained by the MassDOT/MBTA Security & Emergency Management Department. Furthermore, facility evacuation procedures are located on-site across the MBTA. Due to the security sensitive nature of this plan, only publicly available content may be included in this section. The CEMP is available for review by those possessing the appropriate security clearance.

REVISION: 4 MBTA Transit Safety Plan PAGE: 21 of 127

Transit evacuation drills take place at least annually at the MBTA. Coordination between MBTA departments and first responders provides a proactive approach to effectively managing safety risks. Lessons learned from real and simulated evacuations are reviewed for ineffective risk mitigations, which initiates the Safety Risk Management process described in Chapter 5 of this Transit Safety Plan.

The MBTA CEMP satisfies FTA’s requirement to include or incorporate by reference an emergency preparedness and response plan or procedures that addresses, at a minimum, the assignment of employee responsibilities during an emergency; and coordination with Federal, State, regional, and local officials with roles and responsibilities for emergency preparedness and response in the transit agency’s service area.

2.4 Transit Asset Management Plan

MBTA’s Transit Asset Management (TAM) Plan describes: the capital asset inventory; condition of inventoried assets; TAM performance measures, targets, and prioritization of investments aligned with the agency’s TAM and State of Good Repair (SGR) policy, strategic goals and objectives; as well as the strategies, activities, and resources required for delivering the plan (including decision support tools and processes); and other agency-wide approaches to continually improve TAM practices. Figure 4 is an infographic FTA created to illustrate the nexus between TAM and SMS components.

REVISION: 4 MBTA Transit Safety Plan PAGE: 22 of 127

Figure 4: FTA’s TAM – SMS Infographic

2.5 Occupational Health and Safety Plan

MBTA developed an Occupational Health & Safety (OHS) Plan which is made available to employees on TSTOP, MBTA’s intranet. The MBTA OHS Plan governs and defines the authority, responsibilities, roles, and processes that provide MBTA Executive and Senior Management with a framework to conduct workplace safety analysis and decision-making, and to implement related workplace safety programs. As MBTA implements SMS, occupational health and safety programs will also be implemented using SMS processes and procedures documented in this Plan. The Massachusetts Department of Labor Standards provides oversight of workplace safety programs and the OHS Plan.

2.6 MassDOT/MBTA Railroad System Safety Program Plan

MassDOT/MBTA’s Railroad System Safety Program (SSP) Plan is regulated under 49 CFR Part 270 and is not subject to review by the Federal Transit Administration. However, it supports the Strategic Plan, which is MBTA’s blueprint for continuous improvement. The SSP Plan provides MBTA’s strategic and management goals

REVISION: 4 MBTA Transit Safety Plan PAGE: 23 of 127 to affirm and execute its commitment to provide a safe, reliable, and sustainable commuter rail transportation service and ensures compliance with federal, state, and local regulations, and appropriate industry best practices.

MBTA’s commuter rail and transit rail management teams coordinate to address safety issues common to both systems, including management of maintenance and construction in corridors with adjacent transit rail and commuter rail.

2.7 Documentation and Records Management

MBTA maintains critical files, important records, and other information as dictated by regulatory compliance obligations. These active documents and records are maintained as paper copy and/or electronic files. All records are maintained in structured systems that provide legibility, original dates, revision dates, and easy retrieval.

49 CFR 673.31 requires a transit agency to maintain documents related to this Safety Plan and the implementation of the SMS, and results from SMS processes and activities, for a minimum of three years after they are created.

FTA, any other Federal entity, and the DPU have access to any SMS documentation maintained by the MBTA, upon request. Regulatory agencies may perform on-site visits to review any SMS documentation.

Table 5 lists SMS records that are retained in accordance with state and federal standards. Some documents listed in Table 5, including this Plan, are subject to permanent retention under the Massachusetts State Records Schedule; further guidance is available from the Records & Information Management staff in Document Management:

REVISION: 4 MBTA Transit Safety Plan PAGE: 24 of 127

SMS Record

Bus/Rail

Responsible Department

Key Reports or Actions Required

Internal Safety Audits All Final Internal Audit/Review Report, which is submitted to DPU annually.

Reporting Safety & Security Data to NTD

MBTA Safety Electronically submitted to NTD monthly and certified for accuracy annually.

Annual Revision of MBTA Transit Safety Plan

GM MBTA Transit Safety Plan submitted to DPU.

Safety Data Analysis Report

(SDAR)

All MBTA management SDARs are distributed to all MBTA management monthly.

Comprehensive Emergency Management Plan

All MBTA’s emergency preparedness and response plan.

Transit Asset Management Plan All MBTA TAM Plan certified by the Accountable Executive.

Safety Certification of Capital Infrastructure Projects

Capital Delivery, and other affected departments

Certification letter sent to MBTA GM at completion of project including final signed Certified Items List (CIL) and open items log.

Safety Certification of Systems and Vehicle Procurements and Overhauls

Vehicle Engineering, and other affected departments

Certification letter sent to MBTA GM prior to system or vehicle entering revenue service. Signed CIL completed and Certificates of Conditional Safety Certification completed for each vehicle.

Root Cause Analysis Transportation, E&M, CD, Vehicle Maintenance

Conducted for certain safety event investigations. Safety works with other departments to develop report and attainable corrective actions.

Assessments JLMSC as applicable Formal reports are finalized and retained, or submitted to other departments, DPU, or outside agencies as applicable.

SRM Outputs/Products JLMSC as applicable Formal reports are finalized and retained, or submitted to other departments, DPU, or outside agencies as applicable.

Safety Event Investigation Transportation, E&M, CD, Vehicle Maintenance

Formal deliverables are submitted to DPU (or DLS, for employee injuries) through a preliminary report within one business day and a final report submitted with sixty days.

Responses to FTA and NTSB advisories and regulations

JLMSC as applicable Formal responses are submitted to DPU and/or the relevant federal or state agency.

Table 5: SMS Documentation and Recordkeeping

2.8 Temporary Suspension of Safety Programs

In the case of unforeseen circumstances (e.g., COVID-19) that interfere with MBTA’s ability to perform safety activities described in this Transit Safety Plan, MBTA may take the unusual step of temporarily suspending a Safety Program (e.g., Safety Rules Compliance Program) associated with those activities. MBTA will notify DPU within two business days of any safety-related program suspension. An explanation will be provided to DPU as to why a particular Safety Program is suspended. A plan will be developed within 30 calendar days of Safety Program suspension to understand when MBTA may be able to proceed with its Safety Program requirements.

REVISION: 4 MBTA Transit Safety Plan PAGE: 25 of 127

3 SAFETY PERFORMANCE

FTA has established safety performance criteria standards (for fatalities, injuries, assaults, safety events, and system reliability) in the National Public Transportation Safety Plan that all transit agencies must meet at a minimum. This section of the Safety Plan establishes MBTA’s specific safety performance targets. The Accountable Executive reviews the Safety Plan and incorporates updated safety performance targets annually for approval.

MBTA Safety facilitates a monthly Executive Safety Performance Management Session meeting which is attended by Authority leadership and senior management representatives from all impacted departments and functions. This recurring meeting is dedicated to review and discussion of safety performance, key recent events, and notable trends and patterns; results from the Session inform management decision-making performed via SMS processes and the formal SMS-based safety meeting structure.

3.1 Safety Risk Reduction Program

MBTA’s process for establishing, tracking, and updating safety performance targets, along with aspects of its Safety Risk Management and Safety Assurance activities, combine to form the Authority’s safety risk reduction program. This program improves safety performance by reducing the number and rate of safety events, injuries, and assaults on transit workers. Among the objectives of the risk reduction program are to:

• Reduce and mitigate vehicular and pedestrian safety events involving transit vehicles

• Reduce and mitigate assaults on transit workers

The safety performance targets within this document, set annually by the Joint Labor-Management Safety Committee and approved by MBTA leadership, are established in support of the safety risk reduction program.

Safety risk mitigations identified and recommended by the Joint Labor-Management Safety Committee are considered by the MBTA on a continuous basis to improve performance in relation to targets and achieve an overall reduction in risk.

MBTA monitors safety performance against annual safety performance targets for the safety risk reduction program. If MBTA does not meet established annual safety performance targets, the Authority must:

• Assess associated safety risk

• Mitigate associated safety risk based on the results of a safety risk assessment

• Document these mitigations in the Transit Safety Plan and a plan to address deficiencies identified through performance assessment that is developed and carried out under the direction of the Accountable Executive

• Allocate the safety set-aside in the following fiscal year to safety-related projects that are reasonably likely to assist MBTA in meeting performance targets in the future

REVISION: 4 MBTA Transit Safety Plan PAGE: 26 of 127

3.2 MBTA Safety Performance Targets

The MBTA Transit Safety Plan provides collaborative strategic and management performance objectives to affirm and execute its commitment to provide a safe, reliable, and sustainable regional transportation service, and to ensure compliance with federal, state, and local regulations and appropriate industry best practices. Safety performance measures are among the many measures established by MBTA to gauge the organization’s effectiveness.

MBTA safety performance targets assist management in determining the status of the SMS and making informed safety-related decisions for resource allocation, management oversight, and intervention. Safety performance targets are reviewed monthly in the Safety Data Analysis Report (SDAR); they are also discussed routinely within the safety committee structure (see chapter 4) and at the MBTA Board of Directors’ Safety, Health, and Environmental subcommittee.

In accordance with new FTA regulations within the BIL, the Joint Labor-Management Safety Committee (JLMSC) and Safety Management Review Committee (SMRC) must establish new performance targets using the 3-year rolling average of data submitted to the National Transit Database.