How can Safety Management Software help your Transit Agency Comply with Public Transportation Agency Safety Plan Final Rule (PTASP) 49 C.F.R. Part 673?
So, your organization has charged you and your team with implementing and complying with the Public Transportation Safety Plan Final Rule (PTASP) 49 C.F.R. Part 673 and you are looking for tools; easy to use tools that will allow you to comply with this standard. This blog article describes how safety management software in general and the IndustrySafe Safety Management Software in particular can assist you with compliance of the different components of the standard, including:
- Safety Plans
- Safety Management Systems
- Safety Plan Documentation and Recordkeeping
What is PTASP 49 CFR Part 673?
Final Rule 49 CFR Part 673, Public Transportation Agency Safety Plan (PTASP) was published in July 18, 2018 with an effective date of July 19, 2019 and a compliance date of July 20, 2020. This rule requires that covered transit agencies develop and implement safety management plans that meet the requirements of this rule.
Rail systems (not governed by the FRA) and bus agencies with larger than 100 buses have to develop their own plans and have more requirements; while the state can develop the plan for bus agencies with fewer than 100 buses.
This Federal Transit Agency (FTA) webinar provides a good overview of the rule and how requirements differ by agency size and mode(s).
49 CFR 673 Safety Plans Subpart B
At first, its easy to miss the safety data implications in Subpart B as most of Subpart B is focused on having a written plan, but a key piece of Subpart B requires the transit agencies' safety plan to include performance targets based on the safety performance measures established under the National Public Transportation Safety Plan.
These performance measures included in the National Public Transportation Safety Plan are:
- Safety Events
- System Reliability
Most transit agency safety professionals have a good handle on the reporting of fatalities, injuries and system reliability (though the system reliability reporting piece is often handled by the maintenance group (not the safety group) but the safety event component includes a wide range of occurrences that may not currently be tracked by the safety department including property damage, vandalism, or theft.
The IndustrySafe software has a robust Incident Module that will allow transit agencies to keep track of all of these safety events (including fatalities and injuries) but transit agency safety professionals may need to work with other departments within their agency to determine the best way to consolidate this safety event data into one centralized repository. We recommend the IndustrySafe Incident Module as this central repository as it is also designed to analyze the causal factors, risk, and risk mitigation strategy of any event entered into the Incident Module.
As for the plan itself, while it is possible that software exists out there to help you actually write the safety plan that is required under 49 CFR 673 (years ago we actually offered a software product (EZSSPP) that helped you write a System Safety Program Plan), the team at IndustrySafe has decided that we did not have a strong business case to develop software to help transit agencies write the actual plan documentation.
The FTA has put out a template that helps bus transit agencies write their plans and is working on guidance documents to help large rail agencies transition their system safety program plans to safety management systems plans. We also have worked closely with the consultants at Transportation Resource Associates, Inc. (TRA) and we know they can assist agencies with writing their applicable plans.
49 CFR 673 Safety Management Systems Subpart C
OK, take a breath, because the IndustrySafe software can help you with much of Subpart C. We will break down each of the components of Subpart C as follows:
- Safety Management Policy
- Safety Risk Management
- Safety Assurance
- Safety Promotion
673.23 Safety management policy
Our software can’t help you write the policy, but a key component of this section of the rule requires the agency to establish and implement a process that allows employees to report safety conditions to senior management and to provide protections for employees who report safety conditions to senior management.
Our IndustrySafe software includes public web forms that allow all employees and stakeholders to enter and report hazards, incidents and inspections without logging into the system. Employees can report hazards anonymously with the public web forms. Anonymous hazard reporting is a key protection agencies can provide to employees to allow them to report safety conditions to senior management without fear of reprisal.
673.25 Safety risk management
As part of this component of the rule, the transit agency must have a process is place to identify hazards and risk and strategies for risk mitigation. Our safety management software can assist in identifying hazards by providing a system to track and manage hazards using a configurable hazard risk matrix. Check out how to calculate risk using our risk assessment matrix.
The IndustrySafe software allows organizations to reevaluate risk based on risk mitigation strategies and corrective actions. In addition to the hazard module, multiple other modules within IndustrySafe such as incidents, job safety analysis, inspections and behavior-based safety allow for the identification and tracking of hazard risks.
673.27 Safety assurance.
Transit agencies must follow the rule’s requirements for safety assurance including safety performance monitoring and measurement. For larger transit and rail agencies, safety assurance must also include management of change and continuous improvement.
Safety Performance Monitoring and Measurement
For all organizations, safety performance monitoring and measurement includes compliance monitoring of operations and maintenance procedures, hazards, and risks; conducting investigations of incidents; and monitoring information reported through internal safety systems.
The IndustrySafe software has a continual feedback loop for monitoring hazard information entered into the system and an inspection and audit module for monitoring compliance with operations nd maintenance procedures. Both the job safety analysis module and hazard module include the ability to track risk controls and reanalyze risk after the implementation of these controls. All modules include automatic email notifications based on user roles and workflow and the ability to create scheduled reports to notify and monitor safety events throughout the system.
The PTASP final rule requires agencies to conduct investigations of safety events to identify causal factors. The IndustrySafe incident module allows transit agencies to conduct detailed event investigation for multiple types of incidents including employee injuries, property damage, security events, and other operational events. In fact, multiple transit agencies currently utilize our software to track, analyze and report on their safety events.
Check out our transportation customer page for more details or contact us directly for more information about how our transit clients utilize our software.
Management of Change
Larger transit (and rail) agencies must establish a process for identifying and assessing changes that may introduce new hazards or impact the transit agency’s safety performance. If the change may impact performance, the transit agency must evaluate the proposed change through a safety risk management process.
The IndustrySafe Software does not currently have a module devoted specifically to management of change (but may in the future). However, IndustrySafe DOES allow organizations to track hazard changes through a robust job safety analysis module as well as through the hazard module. The software also provides tools within multiple modules, including our home module, that can help manage management of change. Desperate for more management of change in IndustrySafe? We would love to hear from you on what you think those modules would entail.
For all larger bus and for rail agencies, the final rule requires that agencies focus on continual improvement and establish a process to assess safety performance and then address deficiencies related to this performance.
The IndustrySafe software includes a detailed dashboard module that includes over 80 safety metrics that help agencies monitor, measure and evaluate their performance. IndustrySafe’s dashboard allows for senior managers and executives to have key review and insight into the safety activities of the organization. Like all IndustrySafe modules, you can configure this dashboard to measure the safety metrics important to your organization. The IndustrySafe corrective action module also allows for easy follow up of deficiencies related to performance.
Overwhelmed by safety metrics?
673.29 Safety promotion
As part of safety promotion, organizations must develop a comprehensive safety training program for all agency employees and contractors directly responsible for safety in the agency’s public transportation system. The training program must include refresher training as necessary.
The IndustrySafe’s training module provides training tracking and training content allowing transit agencies to track employees and contractors. The IndustrySafe software includes alerts for upcoming and overdue training providing for ease of use in refresher training. IndustrySafe’s training content library includes over 120 training classes that can be delivered via video on demand or as computer based training.
Transit agencies such as the MBTA utilize our training content to delivery training to their workforce. Several other transit agencies, such as Metrolink in Southern California, utilize our training module to track and manage roadway worker training. The IndustrySafe software also includes multiple organizational hierarchies to allow for an organization to manage the training and safety performance of multiple contractors.
Also as part of safety promotion, transit agencies must communicate safety performance information throughout the agency. This includes hazard and safety risks relevant to employees' roles and responsibilities. In addition, agencies must inform employees of safety actions taken due to the submittal of employee reports.
The IndustrySafe software allows for automatic email notification and reports to be distributed to employees across the agency, allowing easy communication of safety performance information. All action items taken to in response to safety concerns submitted through the IndustrySafe hazard module can be easily tracked and disseminated with the IndustrySafe corrective action module. IndustrySafe also has an employee user level specifically designed for employee participation. This affordable user level allows employees to take training classes, conduct inspections and observations, follow up on corrective actions, and report incidents and hazards.
Safety Plan Documentation and Recordkeeping § 673.31 Subpart D
As part of this rule, transit agencies must maintain all of the documentation regarding their Safety Management System and Public Transportation Agency Safety plans, including results. This documentation must be available to federal and state auditors and must be maintained for at least three years.
IndustrySafe Software allows organizations to easily keep track of safety documentation including the storing of documentation in a document library that's available in our home module. Each form within the IndustrySafe software also includes a tracking and audit history so that System Administrators and users can track modifications to records. System Administrators can also access a more detailed audit log within the System Functions area of IndustrySafe. The IndustrySafe summary screen and search features allows IndustrySafe users to quickly and easily access various reports, records, and events.
If you're are a transit agency, state organization, or safety consultant looking to comply with the PTASP final rule, sign up for a free demo of IndustrySafe today, or contact us to learn more about the IndustrySafe software.