SMS/ASP Gap Analysis Checklists
In 2015, “FTA piloted its new SMS gap analysis tool and provided training to apprise [WMATA] executive, safety, and technical management personnel of SMS concepts and requirements.”
The 2015 SMS gap analysis appears to have overlapping checklist items compared to the latest FTA ASP checklist published in August 2019. The assessment scales are also different - understandably so - given the 2015 checklist was meant for what appears to be an effort to assess WMATA’s SMS implementation “maturity” while the 2019 checklist appears to be more of a documentation effort, using a simplified assessment scale.
Does FTA consider the checklist items found in the 2015 SMS gap analysis significantly different from the 2019 FTA ASP checklist?
May the FTA please provide guidance for RTAs considering the use of both checklists or if FTA believes there is a distinct difference between the majority of checklist items found in the 2015 and 2019 checklists?
Given the two checklists may be assessing two different elements of an RTAs SMS implementation (maturity vs. ASP compliance), may FTA please provide guidance on what checklist to use first and when to use each checklist, if FTA believes RTAs should be using both checklists?
The 2015 Safety Management System (SMS) Gap Analysis Checklist used at WMATA can be a valuable tool for transit agencies to use when developing similar checklists for their own SMS assessments. Please keep in mind that the requirements for a transit agency’s SMS are defined by the PTASP regulation (49 CFR Part 673), which FTA published after the development and use of the 2015 SMS Gap Analysis Checklist. FTA recommends that any assessment you undertake or checklist you develop reflects the current PTASP regulation requirements. FTA is presently focused on Agency Safety Plan (ASP) development tools and guidance to help agencies develop a compliant ASP by the July 20, 2020 deadline, but may provide additional tools to support SMS implementation at a later time.
You are correct, the Gap Analysis Checklist and the ASP Review Checklist were developed for different purposes. FTA developed and used the Gap Analysis Checklist in 2015 to assess WMATA’s Safety Management System (SMS) implementation. FTA published the ASP Review Checklist for Rail Transit Agencies (RTAs) and State Safety Oversight Agencies (SSOAs) in 2019 to assist RTA’s in ensuring their ASPs meet all the requirements of the PTASP regulation.
The 2015 Gap Analysis Checklist was developed three years before FTA published a final rule for the Public Transportation Agency Safety Plan (PTASP) regulation (49 CFR 673). The 2015 checklist is strictly based on the SMS Framework that FTA published in 2015. You are correct that FTA used the Gap Analysis Checklist to assess SMS implementation maturity against the SMS processes that FTA published in its SMS Framework.
The ASP Review Checklist for RTA’s and SSOAs published in 2019 aims to help RTA’s ensure their ASPs meet all the requirements of the PTASP regulation. The regulation requires certain transit agencies to adopt SMS principles and methods and document them in their ASPs. The ASP Review Checklist is not an assessment of SMS maturity.
While FTA provides the ASP Review Checklist specifically to support agencies in their development of compliant ASPs, FTA has no prescriptive requirements regarding the use of checklists or forms.