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HomeMy WebLinkAbout2020-11-24 - AGENDA REPORTS - PUBLIC TRANS AGENCY SAFETY PLAN (2)O Agenda Item: 9 P CITY OF SANTA CLARITA AGENDA REPORT CONSENT CALENDAR CITY MANAGER APPROVAL:1 DATE: November 24, 2020 SUBJECT: ADOPT THE PUBLIC TRANSPORTATION AGENCY SAFETY PLAN DEPARTMENT: Neighborhood Services PRESENTER: Adrian Aguilar RECOMMENDED ACTION City Council: 1. Adopt the City of Santa Clarita Public Transportation Agency Safety Plan and authorize the City Manager or designee to submit the plan to the Federal Transit Administration. 2. Authorize the City Manager or designee to amend the plan based on changes in service delivery, organizational changes, and any other changes that significantly affect the components of the City of Santa Clarita Public Transportation Agency Safety Plan. BACKGROUND In 2018, the Federal Transportation Administration (FTA) implemented 49 CFR 673 requiring all public transit agencies that receive federal funding to create, approve, and implement a Public Transportation Agency Safety Plan (PTASP). As a recipient of federal funds, the City of Santa Clarita (City) is required to develop and adopt a PTASP. The PTASP must support the agency's Safety Management System (SMS) plan, which is a comprehensive, collaborative approach to managing safety. The SMS brings management and labor together to better control risk, detect and correct safety problems earlier, share and analyze safety data more effectively, and measure safety performance more precisely. The City contracts for the operation and maintenance of the City's Transit service with MV Transportation (MV). Throughout the term of the contract, the City has required MV to develop and implement a comprehensive safety plan. City staff annually reviews MV's SMS to ensure it meets the City requirements and that it is reflective of the City's Transit operation. Additionally, City staff monitors the implementation and effectiveness of MV's SMS on an on -going basis. Page 1 Packet Pg. 58 O Over the past nine months, City staff has worked closely with MV's safety team to develop the City's PTASP and ensure it meets all FTA requirements. The City's PTASP incorporates all aspects of the SMS currently in place, including Safety Policies, Safety Risk Management, Safety Assurance, and Safety Promotion. The SMS incorporated into the City's PTASP is intended to promote a safety culture that reduces hazardous events by making safety everyone's responsibility, empowering transit employees to play a role in safety, and encouraging employees and contractors to report safety concerns to management. Once adopted by the City Council, the City's PTASP will be updated as needed and submitted to the FTA annually, as required under the new regulation. By not adopting and submitting a PTASP, the City risks losing federal funding in the future. ALTERNATIVE ACTION Other action as determined by City Council. FISCAL IMPACT Approal of the PTASP poses no fiscal impact. ATTACHMENTS City of Santa Clarita Public Transportation Agency Safety Plan (available in the City Clerk's Reading File) Page 2 Packet Pg. 59 PUBLIC TRANSPORTATION AGENCY SAFETY PLAN (PTASP) City of Santa Clarita 2020 TABLE OF CONTENTS Section 1 - Transit Agency Information.......................................................................................4 Section 2 — Authorities, Accountabilities and Responsibilities..................................................5 Section 3 — Plan Development, Approval, and Updates.............................................................7 Section 4 — Safety Performance Targets......................................................................................8 Section 5 — Safety Management Policy.........................................................................................9 Section 6 — Asset Prioritization and Funding Identification based on the Transit Asset ManagementPlan.....................................................................................................10 Section7 — Glossary of Terms.....................................................................................................13 Exhibit A — Santa Clarita Transit Agency Organizational Chart Exhibit B — MV Transportation, Inc. Safety Management System (SMS) Plan Page 1 2 Name of Person/s Corie Zamora, Administrative Analyst, City of Santa Clarita Who Drafted This Garry Brandenburg, Safety and Training Manager, MV Transportation Plan Signature of Accountable Date of Signature by the Executive Signature Accountable Executive Agenda Item Number Date of Approval by the A royal City Council Version Number and Updates Record the complete history ofsuccessive versions of this plan. Version Number Section/Page Affected Reason for Change Date Issued 1 New Plan Plan Origination 11/24/2020 Transit Agency City of Santa Clarita Name Transit Agency 28250 Constellation Road. Santa Clarita, CA 91355 Address Name and Title of Accountable Adrian Aguilar —Transit Manager Executive Name of Chief Safety Garry T. Brandenburg TSSP, ESP — Designated as Chief Safety Officer Officer Modes of Services Fixed Route, Paratransit, and Commuter Covered by this Plan All Modes of Services are MV Transportation Inc. 2711 N. Haskell Ave. Dallas, TX 75204 Contracted to MV Transportation Inc. Page 1 3 SECTION 1 TRANSIT AGENCY INFORMATION The City of Santa Clarita was formed in 1987, incorporating the communities of Canyon Country, Newhall, Saugus, and Valencia. Now the third most populous city in Los Angeles County, Santa Clarita offers an abundance of retail centers, recreational opportunities, educational institutions, medical/healthcare facilities, cultural activities, and employers. The City began operating public transit service on August, 5, 1991, serving the city as well as surrounding unincorporated county communities making up the Santa Clarita Valley service area. The City assumed responsibility for local transit operations from the County of Los Angeles as Santa Clarita Transit; providing supervision over a contract operator responsible for all transit operating and maintenance related services including local, commuter, Dial -a - Ride and Access paratransit. Santa Clarita Transit (SCT) has grown significantly since service was launched in 1991. The City's transit program is comprised of a local fixed -route network, commuter/express network, dial -a -ride, and special trolley service. The local fixed -route service offers eight routes that travel seven days a week and connect the outlying portions of the service area such as Canyon Country, Newhall, and Castaic with key destinations such as the College of the Canyons, Westfield Town Center, Six Flags, and the Valencia Industrial Center. Twenty supplemental routes operate on school days serving area junior high and high schools. SCT offerings also include local operations for Access Paratransit services as well as the City's Dial -A -Ride service. Two additional weekday Station Link routes (Routes 501 and 502) provide a direct link between the Santa Clarita Metrolink Station and to key employment centers including Six Flags, Valencia Industrial Center, and the Valencia Commerce Center. The local transit links residents and visitors with regional transit services via three Metrolink stations (Santa Clarita, Newhall, and Via Princessa), McBean Regional Transit Center (MRTC), and designated park -and -ride facilities throughout the Santa Clarita Valley. The regional commuter/express service network is composed of seven routes connecting the Santa Clarita Valley with Downtown Los Angeles, UCLA/West Los Angeles, North Hollywood (NoHo) Red Line Station, and the western portion of the San Fernando Valley. Most commuter/express routes operate during peak hours Monday through Friday, while Route 757 (North Hollywood Red Line Station) offers service from approximately 5:00 AM to 10:00 PM on weekdays, and approximately 7:00 AM to 7:30 PM on weekends. Page 14 SECTION 2 AUTHORITIES, ACCOUNTABILITES, AND REPSONSIBLITIES This plan has assigned specific Safety Management Systems (SMS) authorities, accountabilities, and responsibilities to the designated Accountable Executive, Chief Safety Officer, Contractor Management and Staff, and City staff as described below: Accountable Executive The Accountable Executive (AE) is the City's Transit Manger who reports directly to the Deputy City Manager. The AE has the ultimate responsibility for carrying out the Public Transportation Safety Plan; responsibility of carrying out the City's Transit Asset Management (TAM) Plan; and direction over the human and capital resources needed to develop and maintain both plans in accordance with 49 CFR Part 673. The AE may delegate specific responsibilities, but the ultimate accountability for the Transit Agency's safety performance cannot be delegated and always rests with the City's Transit Manager. The Transit Manger's roles include: • Decision -making about resources to support asset management, SMS activities, and capital investments; • Ensuring safety concerns are considered and addressed in the City's ongoing budget planning process; • Ensuring transparency in safety priorities to the City Council and employees; • Establishing guidance on the level of safety risk acceptable to the agency; • Assuring the policy is appropriately communicated throughout the agency; • Other duties as assigned/necessary to implement the safety plan. Chief Safety Officer The chief safety officer reports directly to the accountable executive. The CSO is responsible for writing, communicating all policies and procedures where safety is concerned to the departments and employees of the agency. This person will also be responsible for accurately reporting all trending data and actual incident data to the AE. From this date the two positions will strategize plans to decrease from any negative trending which may be identified. The position will be responsible to identify system risks through regular inspections of all aspects of the system which would impact the overall safety of the public, system users, and system employees. The Chief Safety Officer roles include: Page 1 5 • Decision -making about resources to support asset management, SMS activities, and capital investments; • Overseeing the safety risk management program by facilitating hazard identification, safety risk assessment, and the development and implementation of safety risk mitigations; • Monitoring safety risk mitigation activities; • Providing periodic reports on safety performance; • Briefing the Accountable Executive on SMS implementation progress; • Planning safety management training; • Developing and organizing internal audits/reviews of the SMS processes and the Agency Safety Plan to ensure compliance with 49 CFR Park 673 requirements; • Maintaining safety documentation • Other duties as assigned/necessary to implement the safety plan. Contractor Management Contractor management staff includes the General Manager, Assistant General Manager, Safety and Training Manager, Operations Manager, Demand Response Manager, Maintenance Manager, Customer Service Manager, and a Human Resources Manager. The General Manger and Assistant General Manager also report directly to the Accountable Executive. Some of their responsibilities include: • Day-to-day implementation of the Agency's SMS throughout their department and the organization; • Communicating safety accountability and responsibility from the frontline employees to the top of the organization; • Ensuring employees are following their working rules and procedures, safety rules, and regulations in performing their jobs, and their specific roles and responsibilities in the implementation of the Agency Safety Plan and the Agency's SMS; • Ensuring the employees comply with the safety reporting program and are reporting unsafe conditions and hazards to their department management; and making sure reported unsafe conditions and hazards are addressed internally or reported to City staff in a timely manner; • Ensuring that resources are sufficient to carry out employee training/certification and re-training as required by their job classifications. Page 1 6 Key Staff Key staff also involved with this safety plan include City staff and contractor staff and may include coordinators, analysts, technicians, maintenance specialists, road supervisors, dispatchers, mechanics, clerks, and other key employees who are preforming highly technical work and/or overseeing employees performing critical tasks and providing support in the implementation of this Agency Safety Plan. Some of their responsibilities include: • Ensuring the employees are complying with the safety reporting program; • Promoting safety in employee's respective area of responsibilities; • Ensuring safety of passengers, employees, and the public; • Responding to customer complaints and expectations for frequency, reliability, and convenience of service; • Replacing and maintain aging facilities, equipment, and infrastructure; • Meeting increasing demands for fixed route, commuter service, and demand response service; • Developing and maintaining programs to gather pertinent data elements to develop safety performance reports and conduct useful statistical analyses to identify trends and system performance targets; SECTION 3 PLAN DEVELOPMENT, APPROVAL, AND UPDATES The City of Santa Clarita and its bus operations contractor, MV Transportation, drafted this plan to meet requirements specified in 49 CFR Park 673. This plan is based on the four (4) principles or pillars of the Safety Management Systems (SMS). SMS is defined as the formal, top -down, organization -wide, data -driven approach to managing safety risk and assuring the effectiveness of safety mitigations. It included systematic policies, procedures, and practices for the management of safety risk. The four (4) principals or pillars of SMS are: (1) Safety Management Policy; (2) Safety Risk Management; (3) Safety Assurance; and (4) Safety Promotion. This plan will be jointly reviewed and updated, as needed, by the Accountable Executive or delegate and the Chief Safety Officer annually. The Accountable Executive will approve any changes, then forward to the City Council for adoption, if needed. This plan may need to be reviewed and update more frequently based on the following: • We determine our approach to mitigating safety deficiencies is ineffective; Page 1 7 • We make significant changes to service delivery; • We introduce new processes or procedures that may impact safety; • We change or re -prioritize resources available to support this plan; • We significantly change our organization structure. SECTION 4 SAFETY PERFORMANCE TARGETS Safety Performance Targets (SPTs) are included in this plan. These targets are specific numerical targets set by the City and its bus operations contractor and based on measures established under the National Public Transportation Safety Plan. The City will coordinate directly with the State and the local Municipal Planning Organization (MPO) to provide safety targets to aid in the planning process upon certification of this plan. The Accountable Executive will identify safety performance targets annually by the month of June. The Accountable Executive will review, approve, and sign the PTASP which shall then include any updated safety performance targets annually. These finalized targets will then be submitted to the State and local MPO annually as required. Following any and all updates made to the PTASP, copies of these updates shall be placed within all copies of this plan throughout the agency. These copies shall be made readily available, upon request, by any employees or associates effected by this plan and its contents. Safety Performance Targets — Incident Frequency Rate Mode of Fatalities Injuries Safety Safety System Transit Fatalities (per 100k Injuries (per 100k Events Events Reliability Service (Total) -VRM) (Total) VRM) (Total) (per pVRMOk Failures Fixed Route 0.00 0.00 0.00 0.00 1.00 1.04 4000 Demand 0.00 0.00 0.00 0.00 0.03 0.03 4000 Response Page 1 8 SECTION 5 SAFETY MANAGEMENT POLICY The first component of this safety plan is the Safety Management Policy which is the foundation of our safety program between the City of Santa Clarita and its bus operations contractor. Contractually, the bus operations contractor is responsible for the preparation and day to day implementation of the Safety Management System (SMS) as they employee, train and manage the frontline staff that operates Santa Clarita Transit. Therefore, they have prepared a Safety Management System (SMS) Plan which can be found as Exhibit B to this document. This plan includes an SMS Policy Statement and addresses Safety Risk Management, Safety Assurance, and Safety Promotion. Safety Management Policy Communication The Safety Management Policy is issued as a document within all new employee's orientation packets. The plan is also included in the Chief Safety Officer's personal orientation held during agency on -boarding classes and periodically in regularly scheduled employee Safety Meetings. The policy is posted where other postings are commonly located such as near time clocks and in break rooms. Employee Safety Reporting Program MV Transportation/Santa Clarita Transit has implemented a process by which employees are encouraged to report any safety sensitive issue to management. There are Safety Suggestion boxes attached to the wall in several convenient locations in the workplace. On the front of these boxes there is a plastic card holder which contains blank comment or suggestion cards. Employees are encouraged to complete these cards anytime they learn of a safety issue they feel should be addressed by management. There is a place on the front of the card where the person may identify themselves however, they may choose to leave this area blank thus remaining anonymous. Employees are promised however, if they do identify themselves, a phone call from the Chief Safety Officer will follow receipt of their comment card so the issue can be discussed with greater detail. These cards are collected by the safety department on a monthly basis. Upon collection, the data on the cards is entered into a spreadsheet for tracking and resolution purposes. Page 1 9 SECTION 6 ASSET PRIORITIZATION AND FUNDING IDENTIFICATION BASED ON THE TRANSIT ASSET MANAGEMENT PLAN To keep transit assets in a "state of good repair" requires prioritizing assets which need immediate focus to either replace or rehabilitate. Priorities are identified locally based on policies, critical needs, and cost. The asset prioritization list is updated annually. As funding is identified and projects considered they are included in the city's overall budget process. Once approved, project funding is managed using the Transit Forecast prepared by city Finance and Transit staff. Therefore, by utilizing various existing documents and programs, the city can prioritize, fund, and manage projects throughout the city. Below is a brief description of each process: Transit Forecast The Transit Forecast is a multi -year financial planning tool used to forecast revenues and expenditures planned at least five years out into the future. It is prepared and shared between the City's Transit and Finance Divisions and updated continuously throughout the year for planning and budgeting purposes. The forecast keeps historical financial data as well as programs funding anticipated in future years for projects identified as part of various city plans and programs including the Santa Clarita 2020 Plan, the Capital Improvement Program, the Federal Transportation Improvement Plan, the Short -Range Transit Plan, the Transportation Development Plan, the Fleet Maintenance Schedule, inventory and condition assessments, and this Transit Asset Management Plan. Santa Clarita 2020 Vision, anticipation and prioritization are the essential elements in preparing for a successful future and to ensure that City of Santa Clarita continues to provide superior municipal services that will meet the current and future needs of the community. This Plan is intended to: • Align services and projects with the community values and quality of live expectations; • Provide a communication tool for staff so they are able to understand and explain the City's vision and priorities; • Serve as a budget tool to prioritize spending and remain focused on what needs to be done to achieve our vision. Several major work areas were synthesized into six quality of life themes that best describe Santa Clarita's amazing quality of life. They are as follows: • Public Safety Page 1 10 • Building and Creating Community • Enhancing Economic Vitality • Community Beautification • Sustaining Public Infrastructure • Proactive, Transparent and Responsive Government Services Within each theme several goals and performance measures have been identified. To accomplish these goals, projects are identified based on need, condition, or future planning. The Santa Clarita 2020 project list is a fluid document with projects continuously being added as other projects are completed. Capital Improvement Program The Capital Improvement Program (CIP) is a key component of the city's project planning and budgeting process and is of vital importance to the community as a whole. The CIP represents a balanced approach for meeting the community's current and future capital improvement needs. The CIP accomplishes the City's major goals for projects, while maintaining critical ongoing maintenance and is comprised of a variety of multi -year and multi -funded capital projects. The Capital Improvement Program includes projects that fall under different categories, including Beautification and Landscaping, Circulation, Facilities and Buildings, Maintenance, Parks, Resource Management and Conservation, Streets and Bridges, and Trails and Transit. The projects in the program also support many of the quality of life themes contained in Santa Clarita 2020. Fleet Replacement Schedule The City of Santa Clarita, Transit Division, is assigned the overall responsibility for managing the City's fleet of transit rolling stock. City staff works in conjunction with the bus operations and maintenance contractor to: develop vehicle and equipment specifications; develop vehicle and equipment replacement schedules; acquire vehicles and equipment; and reassign and dispose of vehicles and equipment. An ongoing schedule is used to track current in-service vehicles as well as planned or on order vehicles purchases. The City's current guidelines target rolling stock replacement adhering to the Federal Transit Administration's (FTA) Useful Life Policy. The useful life in years refers to total time in revenue transit service, not time spent stockpiled or otherwise unavailable for regular transit use. Minimum useful life for buses, vans, and trolleys is determined by years of service or an accumulation of miles, whichever comes first as follows: • Large, heavy-duty transit buses including over the road buses (approximately 35'- 40', and articulated buses): at least 12 years of service or an accumulation of at least 500,000 miles. • Medium -size, medium duty transit buses (approximately 25'-35'): at least seven years or an accumulation of at least 200,000 miles. Page 1 11 As vehicles approach their useful life age, forecasting process to identify funding refurbishment. Short Range Transportation Plan staff works through the budget and transit and gain approvals for replacement or The Short -Range Transit Plan (SRTP) is a document required by the Los Angeles County Metropolitan Transportation Authority (LACMTA) as a means of justifying the receipt of Federal and State grants for transit operations and capital improvement projects as well as prioritizing the distribution of said funds. Each of the municipal transit operators develops their own SRTP which details their respective services, highlights system performance, details perceived challenges, and discusses future service changes and capital improvements. LACMTA compiles all operator's submissions into a single document which includes an action plan that takes into consideration the priorities of individual operators and the region as a whole, as well as an accompanying financial analysis. Federal Transportation Improvement Plan The Federal Transportation Improvement Program (FTIP) is a federally mandated four- year program of all surface transportation projects that will receive federal funding or are subject to a federally required action. The FTIP is a comprehensive listing of such transportation projects proposed over a six -year period. As the Metropolitan Planning Organization (MPO) for the region, Southern California Association of Governments (SLAG) is responsible for developing the FTIP for submittal to the California Department of Transportation (Caltrans) and the federal funding agencies. The FTIP for the SCAG region is developed in partnership between the six County Transportation Commissions (CTCs) of Imperial, Los Angeles, Orange, Riverside, San Bernardino, and Ventura as well as Caltrans Districts 7, 8, 11, 12 and Headquarters. This listing identifies specific funding sources and fund amounts for each project. It is prioritized to implement the region's overall strategy for providing mobility and improving both the efficiency and safety of the transportation system, while supporting efforts to attain federal and state air quality standards for the region by reducing transportation related air pollution. Projects in the FTIP include highway improvements, transit, rail and bus facilities, high occupancy vehicle (HOV) lanes, high occupancy toll (HOT) lanes, signal synchronization, intersection improvements, freeway ramps, non -motorized projects, bicycle and pedestrian. The FTIP must include all federally funded transportation projects in the region, as well as all regionally significant transportation projects for which approval from federal funding agencies is required, regardless of funding source. The projects in the FTIP have been found to be consistent with SCAG's approved Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS). Page 1 12 Transportation Development Plan (TDP) The Transportation Development Plan (TDP) is intended to present the service needs and corresponding financial plan necessary to meet projected needs. The TDP covers a planning period of five to ten years and is updated with similar regularity. The TDP evaluates service needs on a regional basis covering the current service areas of Canyon Country, Newhall, Saugus, and Valencia. Additional rapidly developing Santa Clarita Valley communities in unincorporated areas, such as Sunset Pointe, Southern Oaks, Stevenson Ranch, Westridge, Newhall Ranch, Val Verde, Castaic and Tesoro Del Valle, are also included. The TDP will provide the mechanism for Santa Clarita Transit's ongoing planning activities and act as the document by which the City can communicate its service plans and financial needs to the various funding jurisdictions. Annual City Budget The basic purpose of the City of Santa Clarita's budget is to serve as a "blueprint" for providing City services and a working financial plan, as well as providing a communication tool for City residents, businesses, and employees. Every year, the City uses the budget process to evaluate our practices and determine if our operations continue to provide the best services our City can offer. The budget is a major policy document and serves as the City's plan to achieve critical goals and priorities identified by the City Council and the community. The budget is designed to help City staff and the public better understand the proposed plan of operation for the new fiscal year. SECTION 7 GLOSSARY OF TERMS This plan incorporates all of FTA's definitions that are in 49 CFR § 673.5 of the Public Transportation Agency Safety Plan regulation. • Accident means an Event that involves any of the following: A loss of life; a report of a serious injury to a person; a collision of public transportation vehicles; a runaway train; an evacuation for life safety reasons; or any derailment of a rail transit vehicle, at any location, at any time, whatever the cause. • Accountable Executive means a single, identifiable person who has ultimate responsibility for carrying out the Public Transportation Agency Safety Plan of a public transportation agency; responsibility for carrying out the agency's Transit Asset Management Plan; and control or direction over the human and capital resources needed to develop and maintain both the agency's Public Transportation Agency Safety Plan, in accordance with 49 U.S.C. 5329(d), and the agency's Transit Asset Management Plan, in accordance with 49 U.S.C. 5326. • Equivalent Authority means an entity that carries out duties similar to that of a Board of Directors for a recipient or subrecipient of FTA funds under 49 U.S.C. Chapter 53, including sufficient authority to review and approve a recipient or subrecipient's Public Page 1 13 Transportation Agency Safety Plan. • Event means any Accident, Incident, or Occurrence. • Hazard means any real or potential condition that can cause injury, illness, or death; damage to or loss of the facilities, equipment, rolling stock, or infrastructure of a public transportation system; or damage to the environment. • Incident means an event that involves any of the following: a personal injury that is not a serious injury; one or more injuries requiring medical transport; or damage to facilities, equipment, rolling stock, or infrastructure that disrupts the operations of a transitagency. • Investigation means the process of determining the causal and contributing factors of an accident, incident, or hazard, for the purpose of preventing recurrence and mitigating risk. • National Public Transportation Safety Plan means the plan to improve the safety of all public transportation systems that receive Federal financial assistance under 49 U.S.C. Chapter53. • Occurrence means an Event without any personal injury in which any damage to facilities, equipment, rolling stock, or infrastructure does not disrupt the operations of a transitagency. • Operator of a public transportation system means a provider of public transportation as defined under 49 U.S.C. 5302. • Performance measure means an expression based on a quantifiable indicator of performance or condition that is used to establish targets and to assess progress toward meeting the established targets. • Performance target means a quantifiable level of performance or condition, expressed as a value for the measure, to be achieved within a time period required by the FTA. • Public Transportation Agency Safety Plan (or Agency Safety Plan) means the documented comprehensive Agency Safety Plan for a transit agency that is required by 49 U.S.C. 5329 and Part 673. • Risk means the composite of predicted severity and likelihood of the potential effect of a hazard. • Risk mitigation means a method or methods to eliminate or reduce the effects of hazards. • Safety Assurance means processes within a transit agency's Safety Management System that function to ensure the implementation and effectiveness of safety risk mitigation, and to ensure that the transit agency meets or exceeds its safety objectives through the collection, analysis, and assessment of information. • Safety Management Policy means a transit agency's documented commitment to safety, which defines the transit agency's safety objectives and the accountabilities and responsibilities of its employees in regard to safety. • Safety Management System means the formal, top -down, organization -wide approach to managing safety risk and assuring the effectiveness of a transit agency's safety risk mitigation. SMS includes systematic procedures, practices, and policies for managing risks and hazards. • Safety performance target means a performance target related to safety management Page 1 14 activities. • Safety Promotion means a combination of training and communication of safety information to support SMS as applied to the transit agency's public transportation system. • Safety risk assessment means the formal activity whereby a transit agency determines Safety Risk Management priorities by establishing the significance or value of its safety risks. • Safety Risk Management means a process within a transit agency's Agency Safety Plan for identifying hazards and analyzing, assessing, and mitigating safety risk. • Serious injury means any injury which: (1) Requires hospitalization for more than 48 hours, commencing within 7 days from the date when the injury was received; (2) Results in a fracture of any bone (except simple fractures of fingers, toes, or noses); (3) Causes severe hemorrhages, nerve, muscle, or tendon damage; (4) Involves any internal organ; or (5) Involves second- or third-degree burns, or any burns affecting more than 5 percent of the body surface. • Transit agency means an operator of a public transportation system. • Transit Asset Management Plan means the strategic and systematic practice of procuring, operating, inspecting, maintaining, rehabilitating, and replacing transit capital assets to manage their performance, risks, and costs over their life cycles, for the purpose of providing safe, cost- effective, and reliable public transportation, as required by 49 U.S.C. 5326 and 49 CFR Part 625. Page 1 15 Exhibit A 11 U 11 CSO has direct reporting access to Accountable Executive `o m a' N CO m Exhibit B Safety Management System ( ) Ran 1. Safety Management IPoillcyy............................................................................................................................................................... 3 Safety Management Systeirn (SMS) IPol licy Statement ........................................................................................................................ 3 1.1 Commitment to Safety Statement................................................................................................................................................. 5 1.2 Safety Management System Development................................................................................................................................... 6 1.3 Operations and Maintenance Procedures.................................................................................................................................... 6 1.4 Employment and Recruitment Selection...................................................................................................................................... 8 1.5 Drug and Alcohol Programs........................................................................................................................................................... 8 1.6 Workplace Violence Program........................................................................................................................................................ 8 1.7 Fitness for Duty............................................................................................................................................................................... 9 1.8 Policies and Procedures Review.................................................................................................................................................... 9 1.9 Employee Safety Reporting Program(ESRP)................................................................................................................................. 9 1.10 Authorities, Accountabilities & Responsibilities......................................................................................................................... 11 1.11 Emergency Management Integration and Procedures.............................................................................................................. 12 1.12 Communication of the Safety Management Policy.................................................................................................................... 12 2,, Safety IRiisl'k Management .................................................................................................................................................................. 12 2.1 Accident and Incident Reporting................................................................................................................................................... 13 2.2 Safety Hazard Identification and Analysis..................................................................................................................................... 14 2.3 Evaluation, Mitigation and Communication of Safety Risk.......................................................................................................... 16 ISafety Assurance ............................................................................................................................................................................... 16 3.1 Safety Performance Monitoring and Measuring.......................................................................................................................... 17 3.2 Management of Change................................................................................................................................................................. 17 3.3 Continuous Improvement.............................................................................................................................................................. 18 4„ Safety Piroirre aUoin.............................................................................................................................................................................. 18 4.1 Competencies and Training........................................................................................................................................................... 18 4.2 Safety Communication................................................................................................................................................................... 20 S„ Supporting Resources ....................................................................................................................................................................... 21 6. Phan Development ............................................................................................................................................................................ 22 6.1 Approval and Updates.................................................................................................................................................................... 22 6.2 Version Updates............................................................................................................................................................................. 22 6.3 Annual Review of Plan.................................................................................................................................................................... 23 PTASP Addendum ................................................................................................................................................................................. 24 TransitAgency Information.................................................................................................................................................................. 24 SafetyPerformance Targets................................................................................................................................................................. 24 Safety Performance Target Coordination............................................................................................................................................ 25 AttachmentA ........................................................................................................................................................................................26 AttachmentB........................................................................................................................................................................................ 27 Safety IManagement System (SIMS) Po116cy Statement MV Transportation, Inc. is committed to providing the highest level of safety for the public, our employees and contractors. Satisfying our customers' special needs with 100% regulatory compliance and the lowest possible risk is our first operational priority. We will never increase our risk of accident or injury to solve operational problems in the course of providing the Best Customer Experience. To meet that commitment, MVTransportation has adopted the Safety Management System (SIMS) and developed safety policies and activities in support of an effective SIMS. This plan is based on the four components of SIMS: Safety Management Policy, Safety Risk Management, Safety Assurance, and Safety Promotion. Every employee and contractor are directed and empowered to administer the SIMS and its specific activities for the prevention, control, and resolution of unsafe conditions and actions. The primary objectives of this SIMS plan are to proactively identify and mitigate safety hazards and risks, promote a positive safety culture, and maintain regulatory compliance. Our safety objectives are to: Ensure that effective safety management systems and processes are integrated into all of our activities. Designate an individual responsible for the safety function who reports directly to the Chief Executive Officer of the company and authorize that individual to develop and implement programs to promote safety. Ensure all employees and contractors are aware that safety is their primary responsibility and they are held accountable for delivering the highest level of safety in their daily work activities. • Clearly define the safety accountabilities and responsibilities to all employees and contractors, including the responsibility of managers and supervisors to develop, implement, and enforce safety rules and procedures in their respective work areas. • Provide all employees and contractors with appropriate safety information and skills training, ensure employee and contractor competence in all safety matters related to their position with the company. • Develop and embrace a positive safety culture in all of our activities that recognizes the importance and value of effective safety management and acknowledges that safety is the number one operating value in everything we do. • Ensure a culture of open reporting of all safety hazards, ensuring that no action will be taken against any employee who discloses a safety concern through the proper chain of command, unless such disclosure indicates, beyond any reasonable doubt, an illegal act, gross negligence, or a deliberate or willful disregard of regulations or procedures. 3 0 Promote and maintain a positive safety culture with positive recognition and reinforcement of safe behaviors. Ensure that all equipment, systems and services meet our safety performance standards through periodic audits and inspections. 0 Establish performance metrics and measures of our safety performance against our safety performance indicators and safety performance targets. Continually develop and improve our safety processes through actively monitoring, measuring, and reviewing our performance against our objectives and targets. 0 Conduct safety and management reviews to improve our safety performance and ensure that relevant and corrective actions are taken. 0 Comply with all state and federal regulatory requirements and standards. Sine Thomas Egan, Chief Executive Officer 0 1.1 Commitment to Safety Statement Providing the highest level of safety for all MV Transportation employees, passengers, and the communities we serve is our core operating value. Safety is at the forefront of delivering the Best Customer Experience and is the first of our key components of successful performance. Doing work safely must be the foundation of all operational activities. Safety standards will never be compromised, subordinated or diminished by any other goal. Safety is the process that drives all functions and activities and is at the center of everything we do at MV Transportation. MV Transportation is committed to being the safest organization possible and is committed to an incident and injury free workplace and security excellence. We will review and continually improve our practices to continuously drive improvements in safety, health, environmental, and security performance. Accountability is fundamental to our mission. Every individual at MV is responsible for working and acting safely and embracing safety as a lifestyle. Compliance with this Commitment, applicable laws, and other requirements is the responsibility of every employee and contractor acting on our behalf. Safety leadership is a core responsibility of management and is the company's most important management value. Managers at all levels will set the standard in our industry, from the Chief Executive Officer to the first -level supervisor. Every employee is responsible to: • Promote and maintain a safe work environment for all personnel and our passengers. • Act consistently to influence safe behaviors and eliminate unsafe behaviors, actions and decisions. • Go above and beyond the minimum safety standards of his / her job. • Directly participate in all aspects of our safety program. • Abide by all applicable safety rules and regulations. • Work with management to decrease our exposure to risk. • Immediately report all incidents/accidents and hazards. • Complete all assigned safety training programs to continuously enhance safety skillset. • Intervene in an activity if it is observed that its being conducted with an unacceptable level of risk. • Encourage and reinforce the safe behaviors of others. • Resolve circumstances responsibly that require corrective action. • Insist upon an unwavering commitment to safety. MV leadership is committed to supporting this statement with the resources and accountability necessary to achieve safety excellence. Tom Egan Chief Executive Officer Mark Collins 5 President and Chief Operating Officer Contractor Management It is the responsibility of MV Transportation to ensure that contractor work practices meet established safety standards of the agency and any and all federal, state, and local regulations and requirements. (Safety Policy S-10). MV Transportation will monitor contractor compliance through scheduled and unscheduled safety audits of equipment, work sites and practices, regulatory compliance, and required records. Significant violations, especially in areas of safety, will be addressed by the appropriate management person, and may include termination of the contract or other legal action. 1.2 Safety Management System Development This Safety Management System (SMS) plan was developed to outline our systematic procedures, practices, and policies for managing risks and hazards. Additional plan elements are available as references to support the information outlined in this document. Key definitions of our process throughout our Safety Risk Management includes the following: • A hazard is a condition or object with the potential of causing injuries to personnel, damage to equipment or structures, loss of material, or reduction of ability to perform a prescribed function. The potential for harm is defined as safety risk. It refers to the chance that people, equipment, or the environment could be harmed by the consequences of a hazard. • What is done to address and reduce that risk is mitigation. • Consequence means an effect of a hazard, involving injury, illness, or death; damage to or loss of the facilities, equipment, rolling stock, or infrastructure of a public transportation system; or damage to the environment. • Event means any accident, incident, or occurrence. This SMS plan will be reviewed periodically to continuously improve in our mitigation of safety risk. We will review and continuously improve our practices to drive continuous improvement. Effectiveness at the site level will be determined at least annually through the Safety Director audit. Reviews may occur more frequently. This plan outlines the SMS activities for all employees and contractors employed by MV Transportation. Additional manuals and procedures should be referenced for more in-depth procedural detail. We will work with the transit agency at the site -location level to ensure these activities are also featured in their Agency Safety Plan. 1.3 Operations and Maintenance Procedures It is the policy of MV Transportation that company operations and all personnel will comply with all applicable requirements federal and state safety regulations (Safety Policy S-10). The system will be monitored for compliance with and sufficiency of operations and maintenance procedures. Non-compliance will be addressed through training, coaching, and management oversight, among other approaches. Non-compliance may result in disciplinary action, in 6 accordance with our policies and procedures. Insufficient procedures will be addressed through the Safety Risk Management process outlined in this plan. Any task that cannot be done safely should not be attempted until it can be done safely. It is the responsibility of the operator to perform thorough Daily Vehicle Inspections (DVIs) and submit those reports to dispatch personnel. It is the responsibility of the mechanics to review and repair all defects before the vehicle goes back into service. The procedure is listed out in greater detail in our Maintenance Manual. Monthly audits of facilities including yard and surrounding areas will also be conducted to verify OSHA compliance and hazard identification, mitigation and resolution. A vehicle with a safety defect is reported immediately by the operator. The vehicle shall be removed from service and not returned until repaired or replaced as soon as possible. In cases when the defect prevents the vehicle from being safely driven back to the garage, it is towed using a contracted service. No operator or other authorized employee is asked, required, or permitted to drive a vehicle with a known major safety defect and is required to wear a safety vest as well as any other appropriate PPE. As outlined in our Maintenance Manual, it is the responsibility of the maintenance manager to provide the general manager with a detailed account of the day's vehicle status and maintenance activities. The maintenance manager shall ensure the operations manager is kept up-to-date on all daily meetings and reports. It is the policy of MV Transportation that maintenance managers are responsible to ensure all fleet vehicles are systematically inspected, maintained, and repaired. The preventative maintenance intervals shall conform to the OEM service specifications, FTA standards, and contractual requirements. (MP-03-02 — Preventative Maintenance). All seasonable maintenance services are to be conducted in accordance with OEM standards. (MP-03-10 — Seasonal Maintenance). Please refer to the Maintenance Shop Safety Manual and Maintenance Manual for further detail outlining policies and procedures, as well as our Safety Vest Policy 5-46 and Yard Safety Procedures. Safety in Design, Acquisition and Procurement Operational safety and passenger safety are the highest priorities when defining vehicle and facility design requirements. Design criteria are established to ensure the equipment meets or exceeds all safety, flammability and environmental requirements and meets all state and federal standards and regulations. MVTransportation's Procurement Department owns the procurement process and works closely with all impacted departments. Conditions covered in the Contract Specifications include verification of compliance, commencing with the design phase and periodic inspections and testing during the construction phase performed by qualified consultants. A thorough inspection and system testing is performed before the equipment is conditionally accepted. The Procurement Group works in conjunction with the maintenance, safety, and operations department when purchasing personal protective equipment for employees, controlling 7 chemicals and other hazards in the workplace, mandating safety requirements in specific contracts and requiring compliance from specific vendors and clients with MV Transportation's safety requirements. 1.4 Employment and Recruitment Selection MV Transportation follows industry practices when hiring employees and contractors, including employment, criminal background, and MVR reports as required. Our hiring practices are compliant with FTA regulations on pre -employment / new hire testing and onboarding. 1.5 Drug and Alcohol Program The Drug and Alcohol Program Manager is responsible for administering the corporate program. The location Designated Employer Representative (DER) are responsible for location program compliance. The policies and procedures conform to the drug and alcohol regulations of the United States Department of Transportation's (DOT), Federal Transit Administration (FTA) and/or the Federal Motor Carrier Safety Association (FMCSA), based on the service environment that the agency and contract operates under. The policy identifies that employees are subject to testing and includes the testing requirements, prohibited behavior, consequences of positive results and resources for employee assistance and rehabilitation. MV Transportation is committed to a Drug and Alcohol free workplace through a Zero Tolerance policy. Participation by covered employees in MV Transportation's prohibited drug use and alcohol misuse program is a condition of employment. Supervisors must not permit a safety - sensitive employee to perform his/her job function if the employee has violated any provision of the Policy. Our Drug and Alcohol -Free policy extends to contractor personnel in safety -sensitive positions. 1.6 Workplace Violence Program MV Transportation is firmly committed to providing a workplace free from acts of violence or threats of violence. In keeping with this commitment, the Company has established a policy strictly prohibiting any employee from threatening or committing an act of violence in the workplace, while on duty, while on company related business, or while operating any vehicle or equipment owned or leased by the Company. Assistance is needed from all employees to achieve a workplace secure and free from violence. MV is committed to a "zero tolerance" policy and compliance with this policy in respect to workplace violence is every employee's responsibility. Any and all incidents involving an act or threat of violence must be reported immediately to the employee's supervisor or the Human Resources department. Any employee may do so without fear of retaliation of any kind. After the incident is reported to a supervisor, he/she will report the matter to the Human Resources department, who will conduct an investigation and take appropriate action. 8 Any employee who engages in or contributes to violent or threatening behavior may be subject to disciplinary action, up to and including termination. 1.7 Fitness -For Duty Fitness for duty is determined by Human Resources and Safety Management. It is the policy of MV Transportation that all drivers are professionals that manage fatigue and come to work well rested and prepared to provide a full measure of safe and reliable customer service (Safety Policy 5-18). All employees that take medical leave must provide a return to work release from his/her health care provider prior to returning to work. The return to work statement should be submitted to the Leaves Manager in the Benefits department. Employees returning to work after 30 days or more break in service will be required to undergo a background check, return -to -work physical and drug test, as permitted or required by applicable federal or state law which includes but is not limited to regulations and requirements set forth by the DOT, FTA, FMCSA, OSHA and ADA. 1.8 Policies and Procedures Review All policies and procedures require periodic reviews for applicability and accuracy. Policies and procedures include a revision date to ensure that all copies of the document are current. Specific policies and procedures are reviewed by department managers with the assistance of the Human Resources Department. Changes to policies and procedures will be made at the corporate level after a thorough review has been performed. The contractor's safety policies and procedures will also be reviewed periodically for accuracy and compatibility with MV Transportation policies and procedures. To submit a request for revision, individuals must complete a Change Request. Details of the request must include the policy or procedure, description of the requested process change, any known impact, and implementation efforts. 1.9 Employee Safety Reporting Program ( SI P) Our front line employees are our best source of information for identifying hazards. Nobody knows more about the actual safety performance of the transit system than the employees who deliver the service. The Employee Safety Reporting Program (ESRP) is intended to help the Accountable Executive and other senior managers get important safety information from across the transit agency. It can be an agency's most important source of safety data. There are two types of safety reporting programs: mandatory and voluntary. 9 • Mandatory: Employees must report hazards that are compliance -based and address regulatory issues. Employees are required to immediately report every incident and accident. An employee's failure to report or provide false information of an unsafe hazard or act could result in disciplinary action. • Voluntary: Employees are strongly encouraged to report hazards and can report anonymously. Every employee is empowered to report any unsafe hazard / risk to their supervisor or senior management without fear of retribution or penalty. Employees will have the option to report anonymously to maintain confidentiality. The ESRP is non -punitive and employees will not be disciplined for the act of reporting the Hazard or Near Miss. However, employees must report hazards that are compliance -based and address regulatory issues. Record falsification, Drug & Alcohol violations, gross negligent behavior, and failure to report accidents/incidents and serious safety hazards are examples of employee behaviors that may result in disciplinary action. Forms of reporting can include submitting a completed SMS Hazard/Risk Report Form (found in the Appendix) or utilizing a centrally located Safety Suggestion Box at the division location. The transit agency may also have an additional form of Employee Safety Reporting. The Hazard/Risk Report Form shall be completed immediately, so proactive measures can be taken as soon as possible. Depending on the perceived level of risk and severity, the report shall be submitted immediately or by the end of their shift. Input by employees into the ESRP can include safety concern reporting, operational system description, hazard identification, safety deficiencies, risk assessments, potential consequences of hazards, or recommended safety risk mitigations. Examples of reports may include the following; • Safety hazards in the operating environment (for example, county road conditions) • Policies and procedures that aren't working as intended (for example, insufficient time to complete pre -trip inspections) • Events that senior managers might not otherwise know about (for example, near misses) • Information about why a safety event occurred (for example, radio communication challenges contributed to an incident) The information we receive through this source will help us resolve the reported hazard and notify the supervisor or senior management of changes that may need to be made to mitigate safety hazards in the future. The Safety Department will lead the effort on collection, analysis, resolution, and monitoring of hazards and feedback entered through the ESRP. The Safety Department will take the lead on the Safety Risk Management process, with inputs from subject -matter experts in operations and maintenance. Information collected through our ESRP will feed into our hazard identification and analysis process. Please reference that section of the plan for further information on mitigation, resolution, and communication. 10 1.10 Authorities, Accountabilities & Responsibilities Safety accountabilities and responsibilities span from corporate organizational roles to contract management and front-line employees. All employees are responsible for safe operations, as outlined in our Commitment to Safety statement. The CEO provides strategic direction and has the responsibility for providing the leadership and resources to carry out the Safety Management System plan. Agency Leadership and Executive Management are tasked and authorized with making sure that the organization safety policies and procedures are followed and communicated to their direct reports, general managers, managers and front-line supervisors. They will provide positive leadership and direction in maintaining the safety policy as a major priority in all operations. This group is responsible for providing resources to acquire and maintain safety and health equipment, devices and programs. They will support safety standards and behaviors ensuring that steps are made to identify and mitigate hazard and risk. The Safety Leadership team, including the Chief Safety Officer, VPofSafety, or Director of Safety, has the authority and responsibility for making sure the safety policies and procedures are adhered by and promoted by senior management, department supervisors and managers, area safety directors and key safety team members. The Safety Leadership team will stay informed of law changes Or updates concerning employee safety and record keeping and will amend safety policies as required. This group will conduct periodic reviews Of safety standards to remain current with federal and state requirements. They will provide guidance in maintaining a high standard Of safety training programs and assist in analyzing safety data to identify future mitigation strategies. The Directors of Safety will conduct an annual audit to ensure compliance with Federal, State and Local rules and regulations as well ascompany policies and procedures. Key Staff, including Department Supervisors, Managers and all other employees, are tasked with following all company safety policies to include, but not limited to, FTA, FM[SA, USDOT, ADA safety regulations. Managers and Supervisors are responsible for staying current on all internal and external safety training. They are also responsible with reporting or responding to accidents, injuries, near misses, unsafe working conditions and potential hazards within their scope of influence. Supervisors and Managers will evaluate employee performance ensuring each employee's safe behavior and work methods and coach, retrain and discipline as required. They will conduct monthly facility audits to ensure compliance. They are also responsible for promoting the ESRP and reviewing and resolving all submissions responsibility. In addition to the above overview of safety roles and responsibilities by group, the following highlights the site -specific roles and responsibilities. This is in addition to the responsibilities listed out in our Commitment to Safety (page 4) and SMS plan objectives (page 2). General Manager: Ultimate responsibility for the safety performance of the location and authorizes activities to support an effective SMS. Operations Manager: Responsible for promoting operational safety and adhering to our policies and procedures. Safety and Training Manager: Responsible for the day-to-day implementation and operation of the SMS. 11 Maintenance Manager: Responsible for OSHA compliance and site -specific maintenance activities. Trainers / Instructors: Responsible for ensuring that we are training every employee to proficiency in accordance with our performance standards. Supervisors: Responsible for playing an active role in SMS activities, including sufficient road observations and identifying potential safety hazards with recommended solutions. Location Safety Committee: Responsible for ensuring that reported safety items are reviewed and addressed, as well as discussing proactive measures to mitigate future risk. 1.11 Emergency Management Integration and Procedures Every site location is to maintain an updated Emergency Action Plan (Safety Policy S-21). The purpose of the Emergency Action Plan is to assist employees and management in making quality decisions during times of crisis, and to comply with regulatory standards for Emergency Action Plans. The Facility Emergency Action Plan will be reviewed and updated annually. Certain practice drills are to be planned and carried out for preparedness during emergency scenarios. The Emergency Action Plan is available on our intranet site and should be printed and stored in the division. 1.12 SIVIS Documentation and Records Processes that require documentation or forms to support an effective SMS are listed out in this plan within the corresponding section. Site locations that are subject to the PTASP Final Rule will be required to maintain documentation and recordkeeping for a minimum of 3 years. a Safety Risk Management The FTA defines Safety Risk Management as a process within the agency's Public Transportation Agency Plan for identifying hazards and analyzing, assessing, and mitigating the safety risk. Through risk identification and assessment, a determination is made of the probability and severity of potential losses. Safety and loss control programs are developed to modify and eliminate or reduce the risks of these exposures. 12 2.1 Accident and Incident Reporting and Response It is the policy of MV Transportation to minimize injury, damages, pain and suffering for people involved in vehicular mishaps involving MV vehicles, to promptly respond, report and to thoroughly investigate these occurrences. (Safety Policy 5-32) All incidents, including near misses and minor events, should be reported as soon as possible — whether or not the incident did or could have resulted in personnel injuries, illnesses, or property damage. The incidents shall be immediately reported from the scene. Operator at scene shall immediately contact Dispatch and provide incident details. When possible, it is the responsibility of the General Manager to make sure that a manager or supervisor responds to the accident to ensure care for our driver and equipment, secure the incident site, preserve evidence, review of accident investigation and proper review of company liability. The initial accident/incident claim line information sheet should be completed with details to convey to our claims hotline. Accident and incident response procedures will vary depending on the severity of an incident ("major' vs. "minor" definition thresholds outlined in Safety Policy 5-32). All employees, supervisors and managers should be knowledgeable on response procedures outlined in Risk Management SAF-001 Accident Procedures guideline and High Priority Event notification procedures. The General Manager and Safety Manager are responsible for ensuring a timely investigation and report is completed. Reports are reviewed by the department manager, who determines preventability (Safety Policy S-1). Reports may also be reviewed by Risk Management and the Director of Safety. Additional actions and activities may be requested from the Risk Management department or Regional Director of Safety. Copies of the accident/incident reports and a summary are kept for review and reporting as necessary. Work Injuries Work injuries include any injury, occupational disease, or disability that arises out of, or in the course of, any work -related activity and requires first aid or medical treatment. Worker's compensation OSHA -related injuries are considered work injuries for the purpose of this policy. Injuries should be reported by the injured employee or a witness to dispatch or his/her immediate supervisor as soon as possible. If the injured employee needs medical attention, the appropriate response by coworkers (dispatch, supervisor, manager) is to: • Assess the injury. • Call 911 if necessary. • Begin emergency medical treatment, if willing and able. 13 • Continue treatment until emergency responders arrive. • Inform Management or Director of Safety. • Complete a written report as soon as possible. The injured employee must complete an Employee Injury Report for the Human Resources and Safety department as soon as possible. In compliance with OSHA regulations, all reportable employee injuries will be recorded by a representative from the Safety department and a summary will be posted from February 1 to April each year for employee review. The Supervisor will conduct an investigation to determine the root cause of the incident surrounding the injury (Safety Policy 5-30). The Supervisor will issue a written report for review by Risk Management, Regional Manager - Maintenance, General Manager and Area Safety Director. Recommendations may be issued and will follow normal channels of communication. Investigative resources will include the Employee Injury Report, eyewitness accounts, employee interviews, equipment testing, and any other reasonable means to determine root causes. Injury reports will be kept on file for future analysis. Accident and Incident Investigation It is the policy of MV Transportation to investigate all incidents/injuries, to identify causes, and to correct deficiencies, if any (Safety Policy S-1). Effective incident investigation is an essential step towards making improvements in the system or process that can prevent future incidents from similar causes. It is the key to correcting and improving unsafe behavior in the workplace. Identifying all factors that came into play to cause an incident, accident, or injury, and getting down to the root cause, is the only way to ensure proper steps will be taken to prevent a recurrence. This includes examining driving and work procedures and revising them if found faulty, and identifying violations of MV, OSHA, DOT, FTA, or other procedures, rules or regulations. (Safety Policy 5-32) After corrective actions have been identified and put in place, the management team or Regional Safety Director will follow-up to ensure that corrective actions remain in place and have effectively corrected incident causes 2.2 Safety Hazard Identification and Analysis Hazards identifications could be submitted directly, or could be derived from trends or other data analyses. Hazards can be identified through a variety of sources, including, 1. Reviews 2. Observations 3. Investigations 4. ESRP 5. Passenger feedback 14 When a hazard has been identified, it will be tracked in a Safety Risk Register log, using the FTA template provided. This includes the description of the risk, rating of the risk, the action to address it, and how we are going to monitor that action for its effectiveness. The hazard will be rated with an "as reported" risk assessment ranking, which will be followed up for a re-evaluation after a mitigation strategy has been implemented. Reviews • DriveCam scored or coachable events — driver specific or aggregated trends of at -risk behaviors • Monthly performance or quarterly reviews of both leading and lagging indicators Observations • Road observations and ride checks • Mystery rider program (if applicable at the site location) • Customer/passenger comments • Third -party notifications Audits and Inspections • Monthly facility inspection • Daily walk-through • Pull-out procedures • New driver assessments (Safety Policy S-37) • Refresher training (Safety Policy S-12) • Annual safety director audit • Maintenance audit Investigations • Accident and incident investigation • Injury root cause investigation Hazard Analysis Once a hazard has been identified, it must then be analyzed. Analysis may include a description of the hazard, supporting results documents, photos, and/or suggestions for resolution. Unless a hazard can be eliminated, it's safety risk must then be managed. We analyze this in terms of how likely it is to happen (probability or frequency) and how bad it could be (severity). Hazard Probability Categories and Hazard Resolution Matrix, see Attachment A, and then by determining the best method for remediation. Near Miss reporting will be collected through Dash Camera Systems, as well as encouraged through the ESRP. If not captured through a Dash Camera System, Near Miss reporting can be completed on the Hazard Risk Form and reported to the location Safety Manager or Supervisor. 15 2.3 Evaluation, Mitigation and Communication of Safety Risk The last step is to develop possible mitigation strategies that address identified safety risks. In evaluating safety risks, identifying what is being done now vs. what can be done in the future is an important consideration. The review must identify facts, establish root causes, and suggest methods for mitigating or preventing recurrence. Statistics from accident and incidents are tracked and compared to performance measures and targets to identify where mitigations may or may not be effective. The identified hazards are reviewed and assessed, and a priority is set based on severity of risk using the Hazard Resolution Matrix. The Location Safety Committee plays an important part of hazard reduction and hazard resolution. The committee should provide inputs/ideas to ensure a safe work environment is established and maintained. (Safety Policy S-39). Hazard Resolution and Communication When the safety hazard and analysis has been completed, the location supervisor or manager who will then coordinate efforts with essential personnel to resolve the hazard in a timely manner. In cases where an immediate threat to safety exists, work will be immediately suspended by the location management while the hazard is addressed and mitigated. Many hazards can be resolved through more than one means, but the general process for determining the best method should be by considering engineering controls, administrative work practices, or employee actions. Communication of resolution and status of SMS activities is listed out in section 4 of this plan. 3. Safety Assurance The FTA defines Safety Risk Management as a series of processes within a transit agency's Safety Management System that function to ensure the implementation and effectiveness of safety risk mitigation, and to ensure that the transit agency meets or exceeds its safety objectives through the collection, analysis, and assessment of information. Safety Assurance subcomponents includes: 1. Safety Performance and Monitoring and Measurement 2. Management of Change 3. Continuous Improvement 16 :3.1 Safety Performance and Monitoring and Measurement Data is constantly collected through the transit agency's Safety Assurance activities. This will include both leading and lagging indicators. Safety performance indicators will help measure inputs, outputs, outcomes, or impacts. It is a signal or early warning sign. Safety performance targets are quantifiable and is the expected change over a period of time. Daily monitoring will be conducted through inspections, observations, and evaluations. Safety Performance Targets are spelled out in Section 8 of this plan. Mitigation Monitoring The Mitigation Monitoring plan helps ensure safety performance monitoring and measurement activities are performed to confirm that mitigations are effective, appropriate, and fully implemented. A Mitigation Monitoring plan may include the selected safety risk mitigation, the indicators or targets, description of how it will be monitored, timeframe, responsibility, and updates. While the Mitigation Monitoring plan addresses the mitigation and monitoring activities, the Corrective Action Plan documents the corrective action and helps address short-term defects or compliance issues. The Corrective Action Plan is intended to eliminate the behavior that caused the event, while Mitigation Monitoring is to continuously monitor the hazard. The Mitigation Monitoring process is owned by the location's management team, with assistance from the Regional Safety Director. The Mitigation Monitoring process requires periodic reviews to ensure that the risk level is being mitigated and reduction of the frequency of the hazard is taking place. A periodic audit of contractor safety plans, Safety Data Sheets, and Personal Protective Equipment requirements will be conducted by the Safety Team and the General Manager. :3.2 Management of Change Our operating environment has many areas that can and will be subject to a change. Prior to implementation of a proposed change, an assessment will be performed by using the Hazard/Risk Report form to determine if the change will impact safety performance or if there are any new hazards that will be present. If a new hazard is identified, it is put through the SRM process and evaluated. A risk mitigation strategy will be created or modified to mitigate risk for that change. Once the change is made it will be monitored for effectiveness. The size and scope of the change can vary from something small to something as large as new service or routes. Efforts will be made to assess if there is a possible impact to safety prior to operations taking place. 17 :3.3 Continuous Improvement The overall safety performance of the system and the performance of SMS activities will be continuously measured and evaluated to determine the effectiveness and appropriateness of risk mitigations. The data and information that will be collected through Safety Assurance activities will tell us how we are doing and what areas we can improve on. Insight through these sources may trigger more frequent reviews and a revised strategy to ensure that mitigations are effective. Local management will work with the agency to determine frequency of meetings with the contractor management to review the SMS process. a Safety Promotion 4.1 Competencies & Training It is the policy of MV Transportation that all employees will undergo new hire training based upon type of service and experience level. Mastery is verified through evaluations prior to being released to revenue service. Job -specific training programs have been developed to enhance safety skills necessary for safe, secure, and reliable customer service. This includes training for operators, trainers, supervisors, maintenance staff, operations, and management personnel. MV Transportation maintains a continuous safety communication campaign through the form of safety meetings (Safety Policy S-27). Every month, a fleet safety and injury prevention topic will be reviewed to refresh the fundamentals and key learning points. Annual refresher training on key areas will also be conducted along with periodic promotion of prevention activities. Maintenance monthly training will focus on OSHA compliance for shop safety. The training complies with current state and federal standards and covers potential safety and health hazards as well as safe work practices and procedures to eliminate or minimize hazards. Information concerning safety hazards or issues is provided to employees through new hire orientation, location safety committee meeting minutes, company -wide or departmental meetings, Safety Team briefings, monthly safety meetings, bulletin board postings, memos, or other written communications. All MV operators will receive refresher or remedial training, as necessary, throughout their employment with the Company (Safety Policy S-12). This can include, but is not limited to, defensive driving techniques, ADA and Wheelchair Securement activities, Fatigue Management, Pedestrian and Bicyclist awareness, as well as hands-on training. This training provides a procedure for evaluation job skills and determining subsequent retraining needs or employees who are returning to work after an extended leave, employees who have been involved in an accident and refresher skill training. 18 Training, retraining, proficiency checks, and safety meeting attendance will be recorded and documented. Training records are kept by the department supervisors and managers and will include: • Date of training • Employee names • Copies of training materials • Training subject • Location of training • Name of trainer • Signature of trainer and trainee A training audit and training needs assessment will be conducted at least bi-annually, or as a result of activities that come out of the SRM process. Safety Culture Our Vision is to deliver the Best Customer Experience with industry -leading Safety, Reliability, and Innovation. Our fundamental safety belief is that Safety is a core business value and there is nothing more important than promoting and maintaining a safe operation. Our Safety Culture Guide outlines the importance of implementing initiatives at the local level to promote a positive safety culture. To foster a positive safety culture, supervisors and management should make every effort to demonstrate their commitment to safety, offering the highest level of respect and dignity and a genuine concern for the welfare of their workers. Supervisors and management will exhibit the behaviors they want to see as part of their location's safety culture. Elements of our Safety Culture Guide include: • Employee engagement and buy -in • Accountability and ownership of employees • Positive recognition • Reinforcement of safe behaviors • Safety award programs • Administration of the Katherine McClary Safe Operator Award program • Safety campaigns and blitzes • Incentive and reward contests Supervisors and managers will pay attention to, measure, and publicly acknowledge the desired behaviors and performance outcomes by workers. The purpose of this and other safety -related programs is to focus our employees on working safely, and then reward them for their success. 19 4.2 Safety Communication Communication of the SMS A variety of methods may be used to communicate the SMS plan, including updates or memos. Communication can include updates related to SMS concerns/issues, lessons learned, analysis, new requirements or tracking mechanisms, and/or roles and responsibilities. It is the responsibility of the location management to train employees on how to identify and report hazards. Management and supervisors will encourage employees to report their safety concerns or hazards. Safety actions that are taken in response to reports submitted through the ESRP will be communicated to employees during the safety meetings or posted in a common area. Our Policy and Commitment to Safety statement will be distributed to all managers to be reviewed with all employees during initial onboarding. This will be reviewed at least annually to continuously promote a safe work environment and communicate our commitment to an incident and injury free workplace. Our policies, procedures, written statements, and formalized plans that support our SMS activities are available to all managers through our intranet site. Continuous Awareness and Safety Communication Management and supervisors will facilitate in daily safety communication and planning engagement blitzes and campaigns accordingly. Dispatchers will play an active role in this process by delivering safety radio announcements. The Daily Safety Message will be printed and posted throughout the facility. Material that supports the monthly fleet safety topic and/or injury prevention topic that is distributed from corporate will be displayed throughout the facility. Additional means of communication includes: • New Hire Orientation Training • Operational Safety Calls • Safety Meetings • One-on-one dialogue between supervisors and employees • Safety Briefings/Toolbox Talks 20 • Safety Bulletin Board • Safety Committees • Posters, Flyers, & Memos • E-mail Communications • Internal Websites • Video/TV Displays So Supporting Resources Maintenance Shop Safety Employee Handbook Code of Federal Regulations (CFR) Handbook Safety Manual Crime Prevention Environmental Vehicle Maintenance Plan (PM) Design (CPTED) New Hire Orientation Aerial Platform Certification Emergency Action Plan Fitness for Duty Evaluation Powered Industrial Truck Fire Prevention Plan (Forklift) Certification Operations Policies and Procedures Handbook HAZCOM Plan Clean Air Act (608,609) Recruiting and Hiring Practices Hearing Conservation Program Noise Protection Incident Management and Heat Illness Prevention Lock Out/Tag Out Investigation Lockout Tagout Program Personal Protective Equipment Safety Audits/Inspections Safety and Security Program Respiratory Protection Safety Reports and Forms System Safety Program Plan Welding, Cutting and Brazing Safety Communication TV Displays Safety System security and Emergency Wheelchair Certifications Preparedness Plan OSHA 10-Hour Defensive Driving Program KMA Safe Driver Award Program OSHA 30- Hour Operator Refresher Training Monthly Safety Meetings Heat Stress Safety Committees Customer Service Training Housekeeping Safety Calendar — Weekly & Monthly Continuity of Operations Plan HAZCOM Topics Bloodborne Pathogens Bi-monthly Safety Stand -down 21 6. Plain Development El Approval and Updates Name of Entity That Drafted MV Transportaion This Plan Signature of Accountable Executive Date of Signature Signature by the Accountable Executive Name of Individual/Entity That Approved This Plan Date of Approval ................................................................................................................................................................................................................................................................................................................................................................................... Approval by the Board of Directors or an Equivalent Authority Relevant Documentation (title and location) Name of Individual/Entity That Certified This Plan Date of Certification Certification of Compliance Relevant Documentation (title and location) ........................................................... 6.2 Version Updates Version Number and Updates Record the complete history of successive versions of this plan. Version Section/Pages Affected Reason for Change Date Issued Number ............................................................... I Creation 10/2019 ............................................................... ................................................................ ............................................................... ................................................................ .............................................................................................................................................................. ....................................................................................................................................................................................................................................... ............................................................................... 22 Annual Audit & Review and Update of the Safety Management Systems Plan Describe the process and timeline for conducting an annual review and update of the Safety Management Systems Plan. During the final quarter the Safety Plan Committee will meet and review current SMS plan and make changes accordingly and update this SMS document. A communication will be sent out with an explanation of changes and a pdf copy of the updated plan will be made available vie e-mail or web. 23 Transit Agency 11 information Transit Agency Name Transit Agency Address Name and Title of Accountable Executive Name of Chief Safety Officer or SMS Executive Mode(s) of Service Covered Bus List All FTA Funding Types None by This Plan (e.g., 5307, 5310, 5311) Mode(s) of Service Provided by the Transit Agency Bus (Directly operated or contracted service) Does the agency provide transit services on behalf of Yes No Description of another transit agency or Arrangement(s) entity? Name and Address of Transit Agency(ies) or Entity(ies) for Which Service Is Provided Safety Performance Safety Performance Targets Safety Performance Targets Specify performance targets based on the safety performance measures established under the National Public Transportation Safety Plan. Mode of Transit Service Preventable Accidents per NTD Recordable Employee Injuries 100K miles Accidents per 200k hours Paratransit Mode of Transit Service Miles Between Road Calls PMI OTP % Number of Vehicles COS Maintenance 24 Safety Performance Target Coordination Safety Performance Target Coordination MV Transportation will work with the agency to support them in their PTASP which includes analyzing historical trends to establish safety performance targets. Agency will coordinate directly with MPO and MV will help in this process as needed. Name Date Targets Transmitted .............................................................................................................................................................................................. Targetstransmitted .................................................................................................................................................................................................................. ............................................................................................................................................................................................. to stakeholders .............................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................. 25 0 2 W HAZARD IPROBABILffY,..FABLE ISIK ASSESSMENT E UEINCY/SE II U 'FR Frequency 1/D HAZARD IRIES0II...UTION 1 ABLE 1/D I 2/C I 2/D I 3/B I 3/C I Severity 3/13 2/C 3/C 2/D Unacceptable —correction may be required after review by CEO. 26 Attachment MV Transportation SMS Hazard/Risk Report Form This report concerns: ❑ Hazard ❑ Risk ❑ Near Miss ❑ Other Hazard Type: ❑ Policy/Procedure ❑ Operational ❑ Environmental ❑ Equipment/Design ❑ Training REPORTED BY: ❑ Employee ❑ Customer/Passenger ❑ Other: le FD or PD NAME: LOCATION: Description of Safety Concern: PHOTOS: ? ❑ Yes ❑ No Hazard Analysis: According to Hazard Severity Matrix El1 Catastrophic El2 Critical El3 Marginal ❑ 4 Negligible Recommended Safety Risk Mitigation: Supervisor/Safety Manager Comments/Actions: Supervisor/Safety Manager: 27 Hazard/Risk Resolution Is Hazard/Risk corrected "On the Spot"? ❑ Yes ❑ No I If the answer is "No" then proceed with the steps below: This report must be forwarded to the SAFETY DEPARTMENT; report is assigned to specific department(s) for hazard rectification; report is assigned a priority Priority: ❑ High ❑ Medium ❑ Low Hazard/Risk/ Near Miss deficiency corrected? ❑ Yes ❑ No Date closed if "Yes" Date If answer is NO, notify Safety department to begin continuing action for resolution, and send to the Safety Team or Staff for recommendations. List how the Hazard/Risk/Near Miss was resolved Date Resolved (.lick or tap to cm r a data. 28