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Do you have the data you need to respond to an FTA safety directive?

Jul 05, 2022
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Safety

Here’s how RISC will put safety data in your hand to respond quickly and thoroughly

The primary use case for what would become our safety product, and has been an essential part of the product since, was designing a method to track and report on safety directives from an FTA audit. From my first day at Trapeze, we saw tracking and reports as key challenges for agencies and started to build a tool to help. Years later RISC is taking shape with tracking and reporting ready for people to try out.

When I read this post about the Federal Transit Administration (FTA) issuing five special directives to the Massachusetts Bay Transportation Authority (MBTA) and the Massachusetts Department of Public Utilities (DPU), I thought about those early days and that first use case and wondered how the MBTA and DPU were responding to those directives.

Despite being in the news, tracking and reporting on mandated safety directives has not been a hot topic with agencies recently. Agencies are focused on the process of implementing an Agency Safety Play for PTASP or a System Safety Plan for SSPP—tracking and reporting are the least of their worries right now.

This doesn’t mean the need has gone away, it’s just not top of mind at the moment.

But when the time comes, here’s how RISC (Risk, Incident, and Safety Compliance) will let you track and report on mitigations and their effectiveness, so you’ll be prepared to report on any mandated safety directives handed down by the FTA.

PTASP Requirements

Part of the FTA’s checklist for a well-developed Agency Safety plan includes the following elements:

  • H-3. The RTA specifies, or references documentation that specifies, its methods or processes to monitor operations to identify any safety risk mitigations that may be ineffective, inappropriate, or were not implemented as intended.
  • H-4. The RTA specifies, or references documentation that specifies, its methods or processes to conduct investigations of safety events to identify causal factors and that address:
    • H-4-c. What must be included in any investigation report developed on behalf of the SSOA, including, at a minimum, identification of factors that caused or contributed to the accident and setting forth a Corrective Action Plan (CAP) as appropriate.
  • J-3: The RTA specifies, or references documentation that specifies, how the RTA will manage immediate or emergency corrective actions.
  • J-4. The RTA specifies, or references documentation that specifies, the required contents of a CAP, including describing the actions the RTA will take to minimize, control, correct, or eliminate the risks and hazards identified by the CAP, the schedule for taking those actions, and the individuals responsible for taking those actions.
  • J-5. The RTA specifies, or references documentation that specifies, how the RTA must periodically report to the SSOA on its progress in carrying out CAPs.

If you had to rate your own agency, how well would you say you responded to those requirements? If a major incident occurred, and your agency is asked to produce documentation of how you monitored the effectiveness of a mitigation strategy, what would you show? If asked to show the status of investigations or of corrective actions, where would you direct them? If asked about the schedule and ownership of task completion, how would you demonstrate compliance?

Could you pull the data together quickly or is this a “put on some coffee and order pizza; it’s going to be a long night” effort? RISC is designed to have safety data from across your agency consistently labeled and organized to answer questions about your safety programs whenever they come up.

 

RISC gives you the tools to respond to regulators

 

Regulatory audits will always happen, better prepared than not

Recently For this post, the “what” and “why” of the directives aren’t important; what’s important is this part from the article:

Each directive includes specific timeframes ranging from 24
hours to 30 days for the MBTA to provide responses and take actions.

The directives probably weren’t a surprise to either the MBTA or the DPU, but the timeframes for responding might have been. During the audit process, both agencies were probably developing plans to address deficiencies, so responses would be ready when the directives came down.

But what if they weren’t?

And what about the audit process itself? Were the agencies scrambling to provide answers to auditors’ questions? Were some of the directives made because MBTA and DPU couldn’t answer the FTA’s questions?

As many agencies who employ EAM (Enterprise Asset Management) know, having information at your fingertips is much better than hunting through digital files or file cabinets of paper reports to get the answers. Pulling safety data and your Safety Management System (SMS) into a single system makes responding to audit requests, and subsequent directives, a lot easier to manage.

Public transit is always under public scrutiny

This article published in the Seattle Times— Seattle's most dangerous light-rail stretch -- and how to make it safer—drew on data from Sound Transit and other agencies to talk about light rail safety and accident rates. If your local paper wanted to know more about your safety record while reporting on an incident, would you be able to get back to them quickly?

The same way you can pull together answers for an auditor, you can answer the media’s questions quickly and completely. The data provided by Sound Transit is compelling and underscored the complexity of transit and rail safety. The data showed what had been done, what is being tried, and the plans for more robust safety measures.

But, what if the Seattle Times didn’t get data in time for the article? How would that have looked? What kind of article would people have been reading?

If the media called, how would you answer?

The problem sits where the data sits

One of the biggest problems I’ve found—and detailed in my blog post and Inside Trapeze episode—isn’t that safety data isn’t collected, but that it’s collected all over your agency. From maintenance to facilities to dispatch, you might have data on the same incident in several places without even realizing it.

Breaking down data silos so there is a single source of (safety data) truth is essential to answering questions from auditors, the media, or even internal staff.

Coordinate across departments and be on the same page

One the key parts of breaking down data silos is connecting and coordinating safety data across departments. Let’s say there is an incident with a bus that:

  • Needed a repair in the garage
  • Triggered training with HR
  • Caused an injury

That single incident could be in several different systems, include different kinds of data, and even be called different things. If you had to report back to agency management or regulators, would you be sure you found all the information, responses, and resolutions?

If your safety data isn’t in a single location with standardized fields, there is a good chance you aren’t getting the complete picture. Departments can still flexibly enter and report incidents in their systems like EAM or Workforce Management, but once the data are compiled together, everything is reported and named consistently across the agency.

Reporting beyond dashboard and automated reports

Having all your safety data in one place and thoroughly organized is great, but it’s not useful if you can’t get information from it. A key part of RISC is a robust reporting tool. A lot of systems take your data and build beautiful dashboards and reports. They have reports emailed to people every day, week, month, quarter with KPIs and incidents.

And people stop reading them.

Dashboards get stale almost as soon as they are finished and stop answering the questions you have about what’s going on at your agency. And the reason is simple: people can’t quickly create their own reports or customize dashboards themselves to answer the new questions they have over time.

There is a saying in the data world that “good reports generate good (or better) questions”, which means when you get a good report, you should have more questions that you’d like to answer. And then you should be able to generate another report to answer that question, and so on. As Garrett Vandendries talks about with ViewPoint, building a dashboard is just the first step, it’s using data analytics to get you to the next level that’s the key.

For something like working with an auditor or answering a media inquiry, you might need to create a report on incidents at a particular location, at a particular time, and what happened next. Chances are you won’t have that specific report handy just waiting for the question to be asked. No, you’re going to need to run that report manually. Robust and useful safety compliance systems let you do that—without needing a degree in data science to pull it off.

Dashboards need to evolve over time. Maybe when you start your safety compliance program your lead KPI is incidents per mile, but over time you might have more KPIs to track. Your dashboard should grow to meet your needs, not be a wall you’re pushing up against.

Without flexible, easy-to-use reporting tools, having all your data in once place means you’ll still have to put a lot of work into answering questions because it will be hard to get the insights from the data. The only thing worse than having data scattered across systems all over your agency, is having your data in one place, but just out of reach because you can’t tap into it.

RISC collects, coordinates, and reports on your safety programs

If you want to be able to:

  • Respond to auditor’s questions
  • Reply to regulatory directives
  • Reply to media inquiries
  • Understand the whole safety picture at your agency

You need a single place for all your safety data and the tools to generate reports as you need them. Trapeze RISC was developed after speaking to agencies across North America and understanding the safety challenges they face today.

RISC is a cloud-based risk, incident, and safety compliance solution that creates a single safety data warehouse with robust reporting, automated workflows, accountability, reporting, and integrations with your other transit systems.

 

Learn more about RISC and get a demo


 
 
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