Sub-contractors in ASP?
If fixed route and paratransit is provided by a contracted entity, does ASP also need to address sub-contracted companies such as security, janitorial, visiting personnel, etc. If so, do they need a separate section in the ASP?
An Agency Safety Plan (ASP) does not need to address such services as security or janitorial that are contracted/subcontracted by a recipient/subrecipient. An ASP must address the contracted services related to operations (e.g., rail, fixed-route, demand response, or paratransit services) and vehicle and infrastructure maintenance.
FTA’s April 24, 2019, Contractors and Other External Service Providers Webinar Presentation (https://bit.ly/2XvhcTF) and Webinar Recording (https://bit.ly/39Qzlha) provide information about how the PTASP regulation affects transit agencies that use contractors. The Key Points for Developing Agency Safety Plans for Recipients with Contractors and Other External Service Providers Fact Sheet (https://bit.ly/2yKJ77B) on the PTASP-TAC website is another resource for recipients with contractors.