AdminPTASP-TAC Support Team (Admin, Department of Transportation)

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    You are not required to incorporate existing safety procedures or process documents into your ASP. The PTASP regulation requires agencies to develop an ASP that meets the requirements defined in the regulation. To do this, agencies may develop a new plan that addresses all requirements, modify an existing plan to meet the new requirements, or develop a new plan that includes references to portions of existing documents that define how the agency meets specific requirements. An agency may use referenced materials to satisfy ASP requirements as long as the final ASP and any referenced information, when taken together, satisfy all requirements of the PTASP regulation.

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    FTA recently published a sample Agency Safety Plan (ASP) for small public transportation providers on the PTASP Technical Assistance Center website. You can view this sample ASP here: https://www.transit.dot.gov/regulations-and-programs/safety/public-transportation-agency-safety-program/sample-small-public

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    The PTASP rule applies to transit agencies that are recipients and subrecipients of Section 5307 funding (49 C.F.R. § 673.1), not its contracted providers of service. Contractors are not required to develop their own Agency Safety Plans (ASPs). If a recipient or subrecipient of Section 5307 funds contracts another entity to provide transit service, the recipient or subrecipient is responsible for ensuring that the terms and conditions of its contract satisfy Part 673 requirements.

    A 5307 recipient with only one contracted provider of transportation services could request that the contractor develop the ASP, but the recipient has the responsibility to ensure compliance with the regulation and certify compliance annually—not its contractor. Alternatively, the recipient could develop the plan and ensure that the contractor follows it.

    For a recipient that uses contractors to provide transit service, it will be beneficial for the agency or State DOT drafting the ASP to collaborate with the contractors during plan development to help ensure the ASP is realistic, implementable, and fits the unique needs of the transit service providers.

    FTA published resources related to these topics on the PTASP-TAC website:

    The PTASP Applicability Infographic illustrates which agencies must prepare an ASP.

    FTA’s April 24, 2019, webinar, “Contractors and Other External Service Providers,” addresses the issue of ASPs for recipients that use contractors.

    The Key Points for Developing Agency Safety Plans for Recipients with Contractors and Other External Providers Fact Sheet discusses the roles and responsibilities of recipients and contractors in developing and implementing ASPs.

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    FTA has not developed a sample Agency Safety Plan (ASP) for the transit industry. However, FTA has published templates and other resources that you may find very useful when developing your ASP.

    For bus agencies:
    1. PTASP Template for Bus Transit (https://bit.ly/33zpKZG)
    2. PTASP Template for Bus Transit Reference Tool (https://bit.ly/2K1POoH)
    3. PTASP Checklist for Bus Transit (https://bit.ly/34Nb5dH)

    For rail agencies:
    1. Transition Roadmap Guidance on Using SSPPs to Develop PTASPs (https://bit.ly/2rsWLIX)
    2. RTA and SSOA PTASP Review Checklist (https://bit.ly/2p0RI1v)
    3. Comparison of Definitions Part 673 Versus Part 659 (https://bit.ly/33uXuYj)

    Please check back regularly here and on FTA PTASP-TAC Resource Library (https://www.transit.dot.gov/PTASP-TAC) as FTA continues to publish additional guidance in advance of the July 20, 2020 deadline.

    FTA encourages transit agencies and State Departments of Transportation to use this forum to share ASPs or elements of their plans with other members of the transit community once they are developed. Also, you can request a review of your ASP by FTA’s PTASP-TAC review team by contacting us at PTASP-TAC@dot.gov.

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    FTA recently published a sample Agency Safety Plan (ASP) for small public transportation providers on the PTASP Technical Assistance Center website. You can view this sample ASP here: https://www.transit.dot.gov/regulations-and-programs/safety/public-transportation-agency-safety-program/sample-small-public

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    The Agency Safety Plan (ASP) template on the website is currently not in a fillable-PDF format. FTA will also be uploading a fillable version soon. In the meantime, you can follow these steps to save the template as a Word document, which you can then fill and edit to suit your needs.

    Windows:
    1) Download the PDF ASP to your computer desktop;
    2) Open the PDF, click on the “File” tab, from the dropdown list select “Save As,” choose the location on your computer where you want to save the template;
    3) In the “Save as type” dropdown box, click on the arrow and choose “Word Document (doc. or docx.).”
    4) Click the “Save” button.

    MAC:
    1) Download the PDF ASP to your computer desktop;
    2) Open the PDF, click on the “File” tab, from the dropdown list select “Save As,” choose the location on your computer where you want to save the template, but before you click on the “Save” button, first select “Word Document” in the “Format” dropdown;
    3) Click the “Save” button.

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    FTA recently published a sample Agency Safety Plan (ASP) for small public transportation providers on the PTASP Technical Assistance Center website. You can view this sample ASP here: https://www.transit.dot.gov/regulations-and-programs/safety/public-transportation-agency-safety-program/sample-small-public

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    Yes, the FTA will soon be publishing sample Agency Safety Plans (ASP) on the PTASP Technical Assistance Center website (https://www.transit.dot.gov/PTASP-TAC) including an example of an ASP for a large transit agency and another example for a small public transportation provider. You can sign up to receive updates on safety information from FTA through GovDelivery (https://public.govdelivery.com/accounts/USDOTFTA/subscriber/new).

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    responded  ·  1 comment  ·  PTASP Technical Assistance Forum » Applicability  ·  Flag idea as inappropriate…  ·  Admin →
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    The PTASP regulation applies to transit agencies that are recipients and subrecipients of Section 5307 funding and includes transit modes such as vanpool. Subrecipients that receive Section 5307 Federal funding need to have their own Agency Safety Plans (ASPs). If a subrecipient is a small public transportation provider, then the State must draft and certify an ASP on behalf of the small public transportation provider, unless that agency notifies the State that it will draft its own plan (49 CFR § 673.11(d)).

    FTA established reduced ASP Safety Assurance requirements for small public transportation providers. Small public transportation provider ASPs only need to include Safety Assurance processes for safety performance monitoring and measurement and not processes for Management of Change and Continuous Improvement.

    The PTASP regulation allows agencies flexibility in how they will meet the minimum PTASP requirements. A smaller transit agency may have simpler SMS processes and procedures than a larger operator with more system complexity.

    FTA will soon release a sample small public transportation provider ASP.

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    At a minimum, you must keep documentation related to your employee safety reporting program for three years.

    Per 49 CFR § 673.31, a transit agency must maintain documents that set forth its Public Transportation Agency Safety Plan, including those related to the implementation of its Safety Management System (SMS), and results from SMS processes and activities. A transit agency must maintain documents that are included in whole, or by reference, that describe the programs, policies, and procedures that the agency uses to carry out its Public Transportation Agency Safety Plan. A transit agency must maintain these documents for a minimum of three years after they are created.

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    Under Part 673, transit agencies must establish and implement a comprehensive safety training program for all agency employees—including contractors—who are directly responsible for safety.

    FTA does not define what “directly responsible for safety” means, but transit agencies must establish their own definition and demonstrate how they meet that definition in their Agency Safety Plans (ASPs). The comprehensive safety training program must include refresher training.

    The PTASP regulation does not require a transit agency to list all of its safety training courses or detailed information on each of its safety training programs within the Safety Promotion section of the ASP. You may consider providing references to your safety training programs to demonstrate that you are meeting this Part 673 requirement. You may consider specifying which job positions are directly responsible for safety and the training requirements you established for those positions, including SMS and refresher training requirements. You may also choose to define the competencies necessary to perform different job roles, including the essential knowledge, skills, and abilities required of various positions.

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    For the safety event measure, FTA used the National Transit Database (NTD) major event thresholds and excluded security events (events that do not have a nexus to safety). The NTD defines a safety event as “a collision, derailment, fire, hazardous material spill, act of nature (Act of God), evacuation, or [other safety occurrence not otherwise classified] occurring on transit right-of-way, in a transit revenue facility, in a transit maintenance facility, or involving a transit revenue vehicle and meeting established NTD thresholds.”
    Safety events may involve injuries and fatalities. If your agency experiences a major safety event that results in an injury, you count the event for the safety event performance measure and the related injury as an injury for the injury safety performance measure.
    FTA’s National Public Transportation Safety Plan (NSP) (https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/National Public Transportation Safety Plan_1.pdf) documents the four required safety performance measures, including safety events.
    On page 39 of the NSP, FTA explains that safety performance measure "data includes safety events (reportable derailments, collisions, fires, and evacuations), fatalities (not including suicides or trespassers), and injuries (not including assaults or injuries due to crimes)."
    For the injury measure, FTA used all injuries reported on both the S&S-40 (major) and S&S-50 (non-major) forms, but excluded injuries related to assaults or crimes. FTA used the definition established by the NTD for an injury (“any damage or harm to persons as a result of an event that requires immediate medical attention away from the scene”).
    For more information on this topic, please see FTA’s Safety Performance Targets Guide (https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/regulations-and-programs/safety/public-transportation-agency-safety-program/134716/safety-performance-targets-guide.pdf) and Introduction to Safety Performance Indicators and Targets (https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/regulations-and-programs/safety/public-transportation-agency-safety-program/134106/introduction-safety-performance-indicators-and-targets.pdf).
    For more information on NTD reporting thresholds and definitions, please see the NTD Safety Policy Manual (https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/ntd/130586/2019-ntd-safety-and-security-policy-manual-v2.pdf) and the NTD Glossary (https://www.transit.dot.gov/ntd/national-transit-database-ntd-glossary).

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    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.

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    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.

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    Yes. According to the National Public Transportation Safety Plan (https://bit.ly/35D3rTV), FTA is using mean distance between major mechanical failures (as defined by the National Transit Database (NTD)) for the reliability safety performance measure (SPM). NTD defines a major mechanical failure as “a failure of some mechanical element of the revenue vehicle that prevents the vehicle from completing a scheduled revenue trip or from starting the next scheduled revenue trip because actual movement is limited or because of safety concerns.”
    For more guidance on SPMs and Safety Performance Targets, please see FTA’s Safety Performance Targets Guide at https://bit.ly/2Z8f0A3.

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    The FTA will use its existing Certifications and Assurances process, through its Transit Award Management Award System (TrAMS), for agencies to annually certify that their ASP meets all the requirements of 49 CFR Part 673. FTA will be releasing guidance on the Agency Safety Plan certification procedures soon.

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