Safety Management Audit Program

System Safety

And The

System Safety Program Plan

 

            The transit agency System Safety Program Plan (SSPP) was developed and refined by APTA, becoming the primary means of ensuring that the safest transit services possible are being provided by the transit agency.  The APTA SSPP methodology has been mandated by the U.S. Federal Transit Administration for all rail transit systems and represents the document to which the transit agency can look to for operational guidance in all matters critical to the safety of its operation, inclusive of its employees, passengers, contractors, general public, and agency property and assets.  APTA provides guidance manuals on how to develop a System Safety Program Plan for each operational mode – bus, rapid transit, and commuter rail.

            The SSPP is the core of the APTA Safety Management Program and represents a “living” document that continues to grow and change with the agency and its services.  The most important element of the SSPP is the safety culture of the agency’s employees.  Each person who works at or for the agency is responsible to ensure that SSPP standards are effectively implemented and supported.

            As a member of the American Public Transportation Association (APTA) Safety Management Program, your transit agency will be provided with support services to develop and manage its SSPP and attendant safety programs.  The Safety Management Program also provides for periodic safety audits of each member system to assist in their assessment of the effectiveness of their SSPP and the level of compliance achieved.  The safety and security audit program is available as an external audit, internal review, or targeted peer review.  These will be discussed individually further in this presentation.

            The System Safety Program Plan is the key document that outlines the safety and security philosophy and management commitment that guides agency policies, procedures, practices, and procedures.  The SSPP provides the authority and responsibility for conducting business safely throughout the organization.  The SSPP also provides the means by which risk of accident is managed to a level as low as reasonably practical; and hazards are controlled within the constraints of time, cost, and operational effectiveness.

Review and Revision of the SSPP

            The transit agency System Safety Program Plan should be reviewed and updated each year to ensure that current commitments to safety are reflected.  It is recommended that before a major revision to the SSPP is scheduled and/or affected, a letter of support and commitment to the SSPP process is secured from the transit system Chief Executive Officer or equivalent.  This written commitment will accompany the documents received for review so everyone understands the importance and authority associated with the SSPP process.

            The transportation organization should also include its labor associations in the SSPP revision process, where applicable, as their comments and participation are essential to achieving commitment from all employees.

            An excellent resource to assist in evaluating the SSPP is to review the System Safety Program Plan of other transit systems to gain different perspectives on how organizations have approached system safety and thus constructed their SSPP.  Most transit systems are willing to share their SSPP, and a transit agency safety department can obtain support documentation through the APTA “Effective Practices Program.”  In time, when the SSPP is a fully implemented tool that accurately reflects the agency’s safety commitment and methodologies, other transit organizations will ask for a copy of the SSPP to help develop and revise their own.

            After a new SSPP draft is developed, the document will be distributed to all representative stakeholders for comment and further revision.  This process is essential to keeping the SSPP a living, working, and effective document that maps a transit agency system safety program and to ensure the agency becomes the safest transportation organization possible and thereby a model for other organizations to emulate.

Purpose of A SSPP

            The System Safety Program Plan (SSPP) provides a comprehensive and systematic approach to workplace and service safety, through management of hazards.  This risk-based approach is closely aligned with safety assurance and quality standards.  Many manufacturing industries have already accepted quality standards for production because it is an effective way for management to reduce costly errors and waste by taking a management “systems” approach.  Some of these concepts may be familiar.  One example is “Total Quality Management.”

            The highest standard of quality for transportation is SAFETY.  No other component of the service you provide is as important.  It is for this reason that the U.S. Federal Transit Administration and the Federal Railroad Administration have placed a high priority on system safety programs.  These federal agencies monitor and/or audit safety commitment and system safety program standards in the United States through the regulated State Safety Oversight Program and by self-regulation of the commuter railroads.  However, not everyone in our industry is familiar with system safety or quality management.  Some feel that any new process suggests a change in the work methodology of their system that has worked in the past, and may infringe upon their professional expertise.  Some industry folks could possibly infer that management system programs are only for weak managers and are developed without any specific knowledge of day-to-day operations.  Such programs may be incorrectly regarded as an added burden on their valuable time when supervisors and managers already work hard to achieve agency objectives.  This simply is not true with regard to system safety.

            What is true about system safety is that a written confirmation of responsibilities, expectations, and objectives provides assurance of a healthy transit system.  Once the initial hurdle of understanding system safety and practical application has been achieved, a well implemented System Safety Program Plan (SSPP) can provide a structured approach to managing system safety and assist both managers and supervisors in their pursuit of improved productivity.  Change will not come quickly, though.  Usually it takes about five years for an organization to accept a change in “culture” or the way an organization thinks about system safety.  The introduction and implementation of a SSPP is a change for both the employee and the system – it will take time and effort to maximize the benefits.

            The System Safety Management Program will provide a method for APTA to assist the transit agency to achieve maximum performance through the SSPP process.  This is one responsibility APTA has to you as a member of the program.  The concepts included in the program have been gathered from the wealth of experience of transportation industry peers.  The ideas presented in this program are those which have been found to be effective in learning how to apply system safety to advantage.

 

Management Requirements for System Safety

            System safety is primarily a management tool.  A safe organization is one that can effectively self-regulate and manage its safety priorities.  The following are examples of areas wherein solid self-regulation is demonstrated.

• Clear written procedures documented and disseminated to all affected personnel.
• A structured process to identify, document, and control system hazards is established.
• Self-audits conducted to ensure compliance with the SSPP.
• Invitations to have outside audits for verification of safety compliance objectives.
• Monitored safety compliance of contractors who perform safety-related services for the organization.

            The system safety program concept grew from the U.S. National Aeronautic and Space Administration (NASA) programs to improve safety for the astronauts.  Aviation adopted system safety principles several decades ago.  Over the past 30 years commercial aviation has exceeded all industrial standards for safety and quality.

            System safety has three major components:

• Develop and implement effective programs to ensure the safety of all aspects of the system.
• Monitor and update all programs on a regular basis to ensure the system is operating at optimum level.
• Document every safety-critical aspect of the operations to (1) verify that what said is what is being done and (2) provide tangible proof of safety practices applied throughout the organization.

System Safety and Individual and Organizational Responsibilities

            Before any system safety program can work, the transportation organization’s CEO and governing board or oversight agency must profess a commitment to the SSPP and actively participate in the safety program.  A common misconception about transit safety is that it is the sole responsibility of the safety department.  Safety is the responsibility of every employee in every department, as much as it is their responsibility to perform other tasks that enable the transit system to function.  The simple fact is that if a transit system is not safe, who will want to ride?

            Another misconception is that absence of accidents means your organization has a safe system.  If there are no goals, objectives, or activities to support safety program implementation, a transit agency is running with “luck behind the wheel.”  Under that type of operations, luck can turn at any time.  Relying upon a good safety record as the only indication of safety performance means only being along for the ride and not knowing who the driver is.  When the next accident happens, diligence to safety cannot be demonstrated and trust in system operations is damaged.

            It may have been said that safety is the product of good management.  This is true.  A safe system has fewer claims by both employees and passengers.  A safe system has fewer costs due to reduced accidents and vehicle downtime, and enjoys a deserved reputation for safe transport that encourages rider growth.  Because safety is the result of good management, it is the responsibility of management to effectively implement the System Safety Program Plan (SSPP) in a systematic fashion.

The Safety Department

            It may be asked, “What is the responsibility of the safety department”?  The safety department is the “watchdog” of the transit agency by monitoring and supporting safety activities agency-wide.  The department responsibilities include:

• safety audits
• safety training
• SSPP training
• safety inspections
• emergency drills
• safety program review and approval
• training program review and approval
• transportation program review and approval
• contractor safety
• construction safety program review and approval
• design review and approval
• safety information and program dissemination
• safety data review and analysis
• substance testing and abuse program review and analysis
• safety recommendation and program development agency-wide
• safety certification program
• hazard management
• documentation and oversight of safety policies and procedures

            To ensure an organization maintains an effective safety program the safety department must be properly empowered.  Empowerment means the authority to access the entire system and to determine if the SSPP is being implemented properly and effectively.  It also means the authority to address hazards effectively and immediately, and the authority to ensure that no unacceptable known hazards exist.  Additionally empowerment means ensuring that the safety department reports directly to the CEO, a vice president, or a chief officer who does not have direct operational conflict of interest, such as operations, finance, risk management, or others, that could compromise full implementation of safety programs.  Without this authority, the safety department is rendered ineffective and subject to unacceptable compromise.

Safety Management Audits

            The purpose of the APTA Safety Management Audit Program is to equip transit systems with industry created formats for developing a System Safety Program Plan (SSPP) and to provide formal evaluations of how well the SSPP has been implemented.  The APTA program services developed for transit organizations include the Rail Safety Audit Program, the Commuter Rail Safety Management Program, and the Bus Safety Management Program.

            The APTA Safety Management Programs include audit protocols that provide external audits, internal audits, peer views, and security assessments.  These audit protocols will examine the following queries with respect to the transit organization’s safety and security programs:

• Does the transit system have a SSPP developed in accordance with latest transit safety management practices and/or APTA guidelines?
• Is the transit system SSPP fully implemented?
• Is the transit system utilizing an internal safety audit program to identify, track, and resolve safety program deficiencies?
• What safety management practices exist in the areas of operations, maintenance, training, inspections, employee testing, and security?

            The goal of the audit program is to guide a transit system through a series of safety management processes that will strengthen and hone the quality of safety practices and thus create a safer environment for your customers and employees.  While the Safety Management Program will not focus on actual physical conditions of a transit system, the safety management practices in place will be fully evaluated to assist each system in determining if its own system safety management program is being implemented at a level consistent with industry best practices.

            The APTA system safety audit is conducted as a management systems audit.  Because commitment to safety comes from the top, the audit works from the top down.  The APTA Safety Management Program provides safety audits for each program member system to assist in the periodic assessment of their SSPP and the level of conformance achieved.  Members of APTA’s Safety Management Programs are automatically placed in an audit cycle when they join.

            External audits of the entire safety and security programs of a transit organization can be provided every three years. These audits are thorough evaluations of every appropriate department within the organization, and a detailed report is provided that analyzes deficiencies that may exist as well as identifies areas that are performing well.  Areas found to be “high achieving” are further identified as an “effective practice” in our industry benchmark process.

            A corrective action plan (CAP) will be requested from the audited transit agency.  This CAP will require the person or persons whose area of responsibility is identified in the report as an area of concern to address the finding and/or recommendation.  A plan for correcting the problem and a schedule or time frame for implementing the solution will be requested, as well as a contact person for the audit staff as necessary.  The CAP is generally due within 45 business days after the audit preliminary report is delivered to the transportation organization.

            The transit organization is expected to have an internal review process that utilizes a three-year cycle to audit compliance with the SSPP.  The safety department usually is tasked with the authority and responsibility to perform these audits and to verify the process is in place.  APTA has an internal review program available to help set up the transit agency’s own internal review process, train the agency’s audit team, guide the internal review process over a 3 year period, and to provide documentation of conformance to each of the 21 elements.  The internal audit program provides a degree of separation when reporting to state agencies and protects confidentiality of information from potential litigation.  It is highly recommended that an audit committee comprised of individuals with expertise to adequately administer and provide oversight to the internal audit program oversee the internal audit process.

            APTA Peer Reviews are targeted audits.  A peer review can be held for a wide variety of purposes other than safety or security.  Peer Reviews are a very popular way to problem solve for operational planning and improvements.  A peer review team is made up of transit industry employees that have expertise in specific areas.   Detailed information about Peer Reviews can be found on the APTA website.

            An important aspect of the APTA Safety Management Program, whether operations involve mass transit rail, light rail, commuter railroad, or bus, is receipt of an independent evaluation of the transit organization’s safety management processes by a team acknowledged both in North America and the international community.  This evaluation will assist in optimizing safety practices within the transit system, and participation in the APTA Safety Management Program will benefit the transit organization’s ability to demonstrate safety diligence and the industry’s ability to maintain self-regulation.

Continual Improvement Process

            The APTA safety management programs include an exhaustive review of all safety-related functions of an organization over a three-year cycle.  The APTA program protocol addresses policies, processes, and procedures as set out in a transit agency’s System Safety Program Plan.  This includes a comprehensive audit of support documentation, interviews with numerous agency personnel, and a variety of operational field observations.  The audit also addresses both past and current corrective action plans, if applicable, established by the transit agency.

            The final audit report, as submitted, summarizes the measure of progress and effort that a transit agency has affected through the course of its past audits and also the effectiveness of the agency in its diligence for safety.

Conclusion

            As systems participate in subsequent audits, APTA works towards providing audit reviews with a “tighter” scope in addition to offering more feedback and insight to coincide with the level of system safety sophistication that evolves within transit agencies.  In keeping with the intent that a System Safety Program Plan is a “living” document, APTA encourages support and commitment to SSPP revisions to ensure the plan is kept current and practical.

            Transit agency responses to an audit, as reflected in the Corrective Action Plan (CAP), demonstrate a commitment to strengthening performance standards within all elements of their system safety plan and to assurance that the processes in place are effective and prevalent throughout the organization.  Many elements of the safety program may be found to be effectively implemented and very sound while others may need further attention.  The agency’s safety program establishes a set of corrective action plans to which the agency staff is committed to implement.  Corrective action plans guide a transit agency in the development of a formal framework of safety performance standards within all departments, as well as in the development of standard operating procedures (SOP) for management and their respective safety-critical functions.

            The safety audit process also highlights efforts achieved in specific areas such as emergency preparedness planning, safety inspections, fire/life safety management, and security.  The audit process also provides acknowledgement by both management and transit agency staff of being strongly dedicated to full implementation of the system safety program and to building upon those strengths already in place.

            It is important to note the following:

• No transit system can guarantee that incidents will not happen.  The fact is that the transportation of millions of customers annually creates an inherent level of risk exposure.  The key, therefore, is to have a comprehensive safety program in place to address various areas of workplace safety and service delivery, and to mitigate risk exposures within those areas.

• APTA does not comparatively rate transit systems as to how effective they are in the management and implementation of their respective safety programs.  What is important is to gauge your own status and improvement over time.

            For more information on the APTA Safety Management Program and related audit programs, please contact APTA’s Safety Director Bill Grizard at 202-496-4878 or email wgrizard@apta.com.
           

 

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