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HomeMy WebLinkAboutAGENDA REPORT 2020 1202 CCSA REG ITEM 10FCITY OF MOORPARK, 
CALIFORNIA City Council Meeting of December 2, 2020 ACTION Approved Staff Recommendation Including Adoption of Resolution No. 2020- 3976. BY B.Garza. F. Consider Resolution Approving and Certifying City of Moorpark Public Transit Agency Safety Plan (PTASP). Staff Recommendation: Adopt Resolution No. 2020-3976 Adopting and Certifying the City of Moorpark Public Transportation Agency Safety Plan. (Staff: Shaun Kroes) Item: 10.F. MOORPARK CITY COUNCIL AGENDA REPORT TO: Honorable City Council FROM: Shaun Kroes, Program Manager DATE: 12/02/2020 Regular Meeting SUBJECT: Consider Resolution Approving and Certifying City of Moorpark Public Transit Agency Safety Plan (PTASP) BACKGROUND The City of Moorpark (City) receives Federal Transit Administration (FTA) funding for local bus and dial-a-ride services. An FTA “final rule” effective July 19, 2019 for Public Transportation Agency Safety Plans as authorized by the Moving Ahead for Progress in the 21st Century Act (MAP-21) requires states and certain operators of public transportation systems develop PTASPs. The PTASP is based on the Safety Management System (SMS) approach. The rule required that a PTASP be developed by July 20, 2020; however, that deadline was extended to December 31, 2020 due to COVID-19. DISCUSSION The new rule requires state departments of transportation (DOT) to prepare plans on behalf of bus operators with fewer than 100 peak-hour buses, unless a bus operator elects to prepare their own plan. A “peak-hour” refers to the time period when the highest number of buses is in revenue service for the public’s availability. A bus operator would have to have 100 or more buses operating at one time to be considered operating more than 100 peak-hour buses. After reviewing the California Department of Transportation (Caltrans) model PTASP, City staff elected to draft its own PTASP. The Caltrans version was an in-house operation model; whereas, the City of Moorpark contracts for bus services similar to the Ventura County Transportation Commission (which also elected to develop its own PTASP). The City’s draft PTASP identifies the City Manager as the designated “Accountable Executive”, the Interim Deputy City Manager as the “Chief Safety Officer” and the Public Works Program Manager as the “Agency Leadership/Executive Management”. All Item: 10.F. 139 Honorable City Council 12/02/2020 Regular Meeting Page 2 serve in roles intended to ensure that the City’s transit operations function in a safe manner. The PTASP also includes Safety Performance Targets for fatalities, injuries, safety events, and system reliability. The City’s Safety Performance Targets are modeled after the City of Thousand Oaks’ performance targets as the City contracts with Thousand Oaks for transit services bus and dial-a-ride operator contracts. If a transit agency does not adopt a PTASP, the FTA can withhold federal funds that the transit agency would normally receive. The PTASP is required to be reviewed annually and updated when necessary. The PTASP will be reviewed for compliance as part of the City’s FTA triennial audit process. FISCAL IMPACT Participating in the PTASP is a requirement of future FTA funding. The City receives an average of $260,000 annually in FTA funding for bus and dial-a-ride services. COUNCIL GOAL COMPLIANCE This action does not support a current strategic directive. STAFF RECOMMENDATION Adopt Resolution No. 2020-____ Adopting and Certifying the City of Moorpark Public Transportation Agency Safety Plan. Attachment: Draft Resolution No. 2020-____ Approving and Certifying the 2020 City of Moorpark Public Transit Public Transportation Agency Safety Plan 140 ATTACHMENT RESOLUTION NO. 2020-____ A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF MOORPARK, CALIFORNIA, APPROVING AND CERTIFYING THE 2020 CITY OF MOORPARK PUBLIC TRANSIT PUBLIC TRANSPORTATION AGENCY SAFETY PLAN WHEREAS, the City of Moorpark/Moorpark City Transit (City) is committed to safety as a core value of the agency; and WHEREAS, Title 49, Code of Federal Regulations (CFR), Subtitle B, Chapter VI, Part 673, Public Transportation Agency Safety Plan (PTASP) requires that an agency PTASP be approved and certified by its governing board; and WHEREAS, Title 49, CFR, Subtitle B, Chapter VI, Part 674, State Agency Oversight, requires the California Public Utilities Commission (CPUC), which is the State Transit Safety Oversight Agency, to ensure the transit agency has a PTASP compliant with 49 CFR Part 673 adopted by the governing board; and WHEREAS, at their regular meeting of December 2, 2020, the City Council considered the adoption of a local PTASP for purposes of compliance with the above stated regulations. NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF MOORPARK DOES HEREBY RESOLVE AS FOLLOWS: SECTION 1. The City Council of the City of Moorpark finds that the PTASP is in compliance with 49 CFR Parts 673 and 674 and hereby approves and adopts the City of Moorpark Public Transportation Agency Safety Plan set forth in full in Exhibit A to this Resolution. SECTION 2. The City Clerk shall certify to the adoption of this resolution and shall cause a certified resolution to be filed in the book of original resolutions. PASSED AND ADOPTED this 2nd day of December, 2020. _____ Janice S. Parvin, Mayor ATTEST: ________________________________ Ky Spangler, City Clerk Attachment: Exhibit A – City of Moorpark Public Transportation Agency Safety Plan 141 EXHIBIT A City of Moorpark 799 Moorpark Avenue Moorpark, CA 93021 Public Transportation Agency Safety Plan Adopted December 2, 2020 Resolution No. 2020-____ Page 2 142 Page 2 of 22 Contents Definitions ....................................................................................................................... 3 Section 1 Transit Agency Information.............................................................................. 6 Subsection 1.1 Accountable Executive ........................................................................... 6 Subsection 1.2 Chief Safety Officer................................................................................. 6 Section 2 Plan Development, Approval, and Updates ..................................................... 7 Section 3 Safety Performance Targets (SPTs) ............................................................... 8 Subsection 3.1 Target Development ............................................................................... 8 Section 4 Overview of the Agency’s Safety Management Systems (SMS) ..................... 9 Section 5 Safety Management Policy .............................................................................. 9 Subsection 5.1 Safety Management Policy Statement .................................................. 10 Subsection 5.2 Safety Management Policy Communication ......................................... 10 Subsection 5.3 Employee Safety Reporting Program ................................................... 10 Subsection 5.4 SMS Authorities, Accountabilities, and Responsibilities ....................... 12 Subsection 5.4.1 Accountable Executive ...................................................................... 12 Subsection 5.4.2 Chief Safety Officer............................................................................ 12 Subsection 5.4.3 Agency Leadership and Executive Management ............................... 13 Subsection 5.4.4 Key Staff ............................................................................................ 13 Section 6 Safety Risk Management (SRM) ................................................................... 14 Subsection 6.1 Safety Hazard Identification .................................................................. 15 Subsection 6.2 Safety Risk Assessment ....................................................................... 15 Subsection 6.3 Safety Risk Mitigation ........................................................................... 17 Section 7 Safety Assurance .......................................................................................... 18 Subsection 7.1 Safety Performance Monitoring and Measurement .............................. 18 Section 8 Safety Promotion ........................................................................................... 20 Subsection 8.1 Safety Communication.......................................................................... 20 Section 9 Documentation……………………………………………………………………..22 Resolution No. 2020-____ Page 3 143 Page 3 of 22 Definitions The City of Moorpark incorporates all of the Federal Transit Administration’s (FTA) definitions that are in 49 Code of Federal Regulations (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; an evacuation for life safety reasons. Accountable Executive means the single, identifiable person who has ultimate responsibility for carrying out the Public Transportation Agency Safety Plan of the 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 United States Code (U.S.C.) § 5329(d), and the Agency’s Transit Asset Management Plan in accordance with 49 U.S.C. § 5326. Agency or Transit Agency means the City of Moorpark. Agency Safety Plan (ASP), also referred to as the Public Transportation Agency Safety Plan (PTASP), means the comprehensive agency safety plan for a transit agency, including a Rail Transit Agency, that is required by 49 U.S.C. 5329(d) and based on a Safety Management System. Board or Board of Directors means the City of Moorpark City Council. Caltrans means the California Department of Transportation. Chief Safety Officer means the adequately trained individual who has responsibility for safety and reports directly to the Transit Agency’s chief executive officer. City Council means the governing body of the City of Moorpark. CFR means Code of Federal Regulations. Event means any Accident, Incident, or Occurrence. FTA means the Federal Transit Administration, an operating administration within the United States Department of Transportation. 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 the system, or damage to the environment. Resolution No. 2020-____ Page 4 144 Page 4 of 22 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 the Transit Agency. 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. Chapter 53. 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 the Transit Agency. Part 673 means 49 CFR (Code of Federal Regulations) Part 673. 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. 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 the Transit Agency’s Safety Management Systems 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 (SMP) means the 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 Systems (SMS) means the formal, top-down, organization-wide approach to managing safety risk and assuring the effectiveness of a Transit Agency’s safety risk mitigation. Safety Management Systems includes systematic procedures, practices, and policies for managing risks and hazards. Resolution No. 2020-____ Page 5 145 Page 5 of 22 Safety Performance Target (SPT) means a Performance Target related to safety management 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 (SRA) means the formal activity whereby the Transit Agency determines Safety Risk Management priorities by establishing the significance or value of its safety risks. Safety Risk Management (SRM) means a process within the Transit Agency’s Public Transportation 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 seven (7) days from the date 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 five percent of the body surface. State of Good Repair (SGR) means the condition in which a capital asset is able to operate at a full level of performance. Transit Agency means an operator of a public transportation system. Transit Asset Management Plan (TAM) 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. U.S.C. means United States Code. Resolution No. 2020-____ Page 6 146 Page 6 of 22 Background The Public Transportation Agency Safety Plan (PTASP) final rule (49 C.F.R. Part 673) requires operators of public transportation systems that are recipients or sub-recipients of FTA grant funds to develop safety plans that include the processes and procedures necessary for implementing a Safety Management System (SMS). A SMP is defined as the formal, top-down, organization-wide, data driven approach to managing safety risk and assuring the effectiveness of safety mitigation. It includes systematic policies, procedures, and practices for the management of safety risk. The goal is to deliver positive, measurable results and ensure the best use of available resources to identify safety hazards, analyze safety risks, and mitigate potential risks. The following Agency Safety Plan addresses all applicable requirements and standards as set forth in FTA’s Public Transportation Safety Program and the National Public Transportation Safety Plan. Section 1 Transit Agency Information City of Moorpark (hereinafter referred to as “City”) is a California municipal corporation and a general law City. The City contracts for fixed route and demand response (Senior and Americans with Disabilities Act paratransit). The City’s primary contractor is the City of Thousand Oaks (Thousand Oaks) which has a contract with MV Transportation Inc. (MV Transit) to provide bus and demand response services. Thousand Oaks maintains the City’s bus fleet. The City is a recipient/subrecipient of Federal Urban Area Formula Program (5307); Enhanced Mobility Seniors & People with Disabilities Program (5310) funds. The City does not provide transportation services on behalf of another entity. Subsection 1.1 Accountable Executive The City’s Accountable Executive is Troy Brown, City Manager. The City Manager is the single, identifiable person who has ultimate responsibility for carrying out this Agency Safety Plan and the City’s Transit Asset Management (TAM) Plan, and control or direction over the human and capital resources needed to develop and maintain both this Plan and the TAM Plan. The City Manager is accountable for ensuring that the Agency’s Safety Management Systems (SMS) is effectively implemented throughout the Agency’s public transportation system. The City Manager is accountable for ensuring action is taken, as necessary, to address substandard performance in the Agency’s SMS. The City Manager may delegate specific responsibilities, but the ultimate accountability for the Transit Agency’s safety performance cannot be delegated and always rests with the City Manager. Subsection 1.2 Chief Safety Officer The City Manager designates the Interim Deputy City Manager as the City’s Chief Safety Officer who has the authority and responsibility for day-to-day implementation and operation of the Agency’s SMS. The Chief Safety Officer holds a direct line of reporting to the Accountable Executive and has a strong working relationship with the Resolution No. 2020-____ Page 7 147 Page 7 of 22 operations and asset management functions at the City. The Chief Safety Officer, Agency leadership/Executive Management shall, with the City’s contractor, ensure operations are performed safely. Section 2 Plan Development, Approval, and Updates Name of Entity that Drafted this Plan City of Moorpark Signature by the Accountable Executive Signature of Accountable Executive Date of Signature Approval by the Board of Directors Name of Entity that Approved this Plan Date of Approval City of Moorpark 12/02/2020 Relevant Documentation (Title and Location) City of Moorpark City Council Agenda Item (# to be filled in) dated 12/02/2020 – PTASP File Certification of Compliance Name of Entity that Certified this Plan Date of Certification City of Moorpark 12/02/2020 Relevant Documentation (Title and Location) Self-certified Pursuant to 49 CFR Parts 673.13(a) and 673.13(b), the City certifies that it has established this Agency Safety Plan, meeting the requirements of 49 CFR Part 673 and will certify its compliance with 49 CFR Part 673. Version Number and Updates Version Number Section/Pages Affected Reason for Change Date Issued 1 Original Document 12/02/2020 Annual Review and Update of the Agency Safety Plan City shall update this Safety Plan when information, processes or activities change within the Agency and/or when applicable regulations change, whichever comes sooner. The Plan will be reviewed and updated by the Chief Safety Officer with the assistance of subject matter experts annually in July. The Accountable Executive will approve any changes, signing the revised Plan, then bringing it to the City of Moorpark City Council for review and approval. Additionally, FTA will oversee compliance with the requirements of Part 673 through the existing Triennial Review processes. Resolution No. 2020-____ Page 8 148 Page 8 of 22 Section 3 Safety Performance Targets (SPTs) Safety performance measurement is a key aspect of a safety management process, and provides the basis for continuous safety improvement. Measurement and evaluation of safety performance requires a carefully structured program of planning, identifying valid measures, setting targets, conducting proper data analysis, and implementing appropriate follow-up activities. Subsection 3.1 Target Development Successful performance targets are specific, measurable, attainable, relevant and time- bound. The specific safety performance targets that the City adopted are based on the Safety Performance Measures established by FTA in the National Public Transportation Safety Plan. In the most recent version (2017 NSP3), FTA adopted four initial Safety Performance Measures: (1) Fatalities, (2) Injuries, (3) Safety Events, and (4) System Reliability. Targets in the following table are based on review of the previous three (3) years of the City’s safety performance data specific to each mode of transit service that the City contracts for services. As the City contracts with Thousand Oaks for bus services and demand services and City passengers on demand service travel with Thousand Oaks residents, City’s performance targets match Thousand Oaks’ performance targets. Safety Performance Targets Mode of Transit Fatalities (Total) Fatalities Rate (per 100k VRM) Injuries (Total) Injuries Rate (per 100k VRM) Safety Events (Total) Safety Events Rate (per 100k VRM) System Reliability (Mean distance between Major Mechanical Failures) Fixed Route 0 0% 0 0.01 <1 0.01 To be developed in 2021 Demand Response 0 0% 0 0.01 <1 0.01 To be developed in 2021 Safety Performance Target Coordination FTA requires Caltrans to coordinate with FTA Region 9 and Ventura County Transportation Commission (VCTC) to the maximum extent practicable. Pursuant to 49 CFR Part 673.15(a), Caltrans will make safety performance targets available to VCTC to aid in the planning process upon certification of this plan. Additionally, the City will transmit performance data against the safety performance targets to Caltrans, VCTC and the Southern California Association of Governments (SCAG) on an annual basis. The City will also coordinate, to the maximum extent practicable, with Caltrans, SCAG and VCTC to support the selection of State and Metropolitan Planning Organization (MPO) transit safety performance targets. Resolution No. 2020-____ Page 9 149 Page 9 of 22 Targets Transmitted to the State (Caltrans) State Entity Name Date Targets Transmitted Caltrans Targets Transmitted to the Metropolitan Planning Organization (MPO) Metropolitan Planning Organization Name Date Targets Transmitted Southern California Association of Governments Targets Transmitted to the Transportation Planning Body Transportation Planning Body Date Targets Transmitted Ventura County Transportation Commission Section 4 Overview of the Agency’s Safety Management Systems (SMS) SMS is a comprehensive, collaborative approach that brings management and labor together to build on the transit industry’s existing safety foundation t o control risk better, detect and correct safety problems earlier, share and analyze safety data more effectively, and measure safety performance more carefully. The City’s SMS focuses on applying resources to risk and is based on ensuring that the City has the organizational infrastructure to support decision-making at all levels regarding the assignment of resources. Some key parts of the City’s SMS include:  Defined roles and responsibilities;  Strong executive safety leadership;  Formal safety accountabilities and communication;  Effective policies and procedures; and  Active employee involvement. Furthermore, the City’s SMS is based on the four (4) principles of SMS which are discussed in more detail in subsequent sections to this Safety Plan:  Safety Management Policy  Safety Risk Management  Safety Assurance  Safety Promotion Section 5 Safety Management Policy The first component of the City’s SMS is the Safety Management Policy (SMP), which is the foundation of the City’s safety management system. It clearly states the organization’s safety objectives and sets forth the policies, procedures, and organizational structures necessary to accomplish the safety objectives. The Safety Management Policy clearly defines management and employee responsibilities for safety throughout the organization. It also ensures that management is actively engaged in the oversight of the system’s safety performance by requiring regular review of the Safety Management Policy, budget and program by the designated Accountable Executive. Resolution No. 2020-____ Page 10 150 Page 10 of 22 Subsection 5.1 Safety Management Policy Statement Safety is a core value at the City, and managing safety is a core business function. The City will develop, implement, maintain, and continuously improve processes to ensure the safety of our customers, employees, and the public. The City’s overall safety objective is to proactively manage safety hazards and their associated safety risk, with the intent to eliminate unacceptable safety risk in our transit operations. The City will:  Clearly, and continuously explain to all staff that everyone working within the City must take part and be responsible and accountable for the development and operation of the Safety Management System (SMS).  Work continuously to minimize safety risks. Work to comply with and, wherever possible, exceed legislative and regulatory requirements and standards for passengers and employees.  Work to ensure that all employees are provided appropriate safety information and training, are competent in safety matters, and assigned tasks commensurate with duties and skills.  Reaffirm that responsibility for making our operations safer for everyone lies with all employees – from executive management to frontline employees. Each manager is responsible for implementing the SMS in their area of responsibility and will be held accountable to ensure that all reasonable steps are taken to perform activities established through the SMS. The City’s established safety performance targets help measure the overall effectiveness of our processes and ensure we meet our safety objectives. The City will keep employees informed about safety performance goals and objectives to ensure continuous safety improvement. Subsection 5.2 Safety Management Policy Communication The Safety Management Policy is communicated throughout the Agency, which includes applicable employees, contractors, and the City Council. The Chief Safety Officer introduces principles of SMS and the Safety Management Policy Statement to the Agency for dissemination to applicable employees and contractors and posting on notice boards at applicable facilities. Distribution and review of the Safety Policy Statement is also included in applicable new hire training, safety bulletins, toolbox/tailgate safety meetings and/or safety committee meetings. Subsection 5.3 Employee Safety Reporting Program Employees who identify safety concerns in their day-to-day duties are encouraged to report these safety concerns in good faith and without fear of retribution directly to senior management or anonymously through reporting software or other alternatives. Currently, MV Transit employees can report safety concerns anonymously through a 24-Hour Hotline. Thousand Oaks also has an Employee Safety Reporting Program. The purpose, description and protections for employees to report unsafe conditions and hazards are described in more detail in the following section. Resolution No. 2020-____ Page 11 151 Page 11 of 22 Purpose: a) To establish a system for City employees to identify unsafe conditions or hazards at work and report them to their department management without fear of reprisal. However, disciplinary action could result if the condition reported reveals the employee willfully participated in or conducted an illegal act, gross negligence or deliberate or willful disregard of regulations or procedures, including reporting to work under the influence of controlled substances, physical assault of a coworker or passenger, theft of agency property, unreported safety events, unreported collisions, and unreported passenger injuries or fatalities. b) To provide guidelines for facilitating the timely correction of unsafe conditions or hazards by the City’s management. Description: a) This program provides a method for the City’s management to identify, evaluate, and correct or avoid unsafe conditions or hazards, procedural deficiencies, design inadequacies, equipment failures, or near misses that adversely affect the safety of employees. Examples of voluntary safety reports include:  Safety hazards in the operating environment (for example, county or city road conditions),  Policies and procedures that are not working as intended (for example, insufficient time to complete pre-trip inspection),  Events that senior managers might not otherwise know about (for example, near misses), and  Information about why a safety event occurred (for example, radio communication challenges). b) The program also involves recommending corrective actions and resolutions of identified unsafe conditions or hazards and/or near miss. c) All employees have the obligation to report immediately any unsafe conditions or hazards and near miss to their immediate supervisor/department manager and may do so without fear of reprisal. d) Unsafe conditions or hazards may also be identified as a result of occupational injury or illness investigations and/or by accident investigation. e) Other means by which hazards may be identified are inspections/audits or observations made by the supervisors/management staff. f) Findings will be published immediately following mitigation actions. If employee identification is available, direct feedback regarding mitigation will be provided. Resolution No. 2020-____ Page 12 152 Page 12 of 22 Subsection 5.4 SMS Authorities, Accountabilities, and Responsibilities This Plan has assigned specific SMS authorities, accountabilities, and responsibilities to the designated Accountable Executive; Chief Safety Officer; Agency’s Leadership/Executive Management; and Key Staff/Employees as described below: Subsection 5.4.1 Accountable Executive The City’s Accountable Executive is the City Manager. The City Manager is accountable for ensuring that the Agency’s SMS is effectively implemented throughout the Agency’s public transportation system. The City Manager is accountable for ensuring action is taken, as necessary, to address substandard performance in the Agency’s SMS. The City Manager may delegate specific responsibilities, but the ultimate accountability for the City’s safety performance cannot be delegated and always rests with the City Manager. The City Manager is accountable for ensuring that the Agency’s SMS is effectively implemented, and that action is taken, as necessary, to address substandard performance in the Agency’s SMS. The Accountable Executive may delegate specific responsibilities, but not accountability for the City’s safety performance. The City Manager’s roles include, but are not limited to:  Decision-making about resources (e.g. people and funds) to support asset management, SMS activities, and capital investments;  Signing SMS implementation planning documents;  Endorsing SMS implementation team membership;  Ensuring safety concerns are considered and addressed in the agency’s ongoing budget planning process;  Ensuring transparency in safety priorities: for the Board of Directors and for the employees;  Establishing guidance on the level of safety risk acceptable to the agency;  Assuring safety policy is appropriately communicated throughout the agency; and  Other duties as assigned/necessary. Subsection 5.4.2 Chief Safety Officer The Chief Safety Officer has the authority and responsibility for day-to-day implementation and operation of the City’s SMS. Chief Safety Officer’s Roles include:  Decision-making about resources (e.g., people and funds) 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 and City Council on SMS implementation progress;  Planning safety management training; Resolution No. 2020-____ Page 13 153 Page 13 of 22  Developing and organizing annual audits/reviews of SMS processes and the Agency Safety Plan to ensure compliance with 49 CFR Part 673 requirements;  Maintaining safety documentation; and  Other duties as assigned/necessary. Subsection 5.4.3 Agency Leadership and Executive Management Agency Leadership/Executive Management also have authorities and responsibilities related to day-to-day SMS implementation and operation of the SMS under this plan. Agency Leadership and Executive Management include the City’s Public Works Program Manager and the service contract providers’ General Managers, Maintenance Managers, Operations Managers and Safety Managers. 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 this Agency Safety Plan and the Agency’s SMS.  Ensuring that employees comply with the safety reporting progra m and are reporting unsafe conditions and hazards to their department management; and making sure reported unsafe conditions and hazards are addressed in a timely manner.  Ensuring that resources are sufficient to carry out employee training/certification and re-training as required by their job classifications.  Providing subject matter expertise to support implementation of the SMS as requested by the Accountable Executive or the Chief Safety Officer, including Safety Risk Management activities, investigation of safety events, development of safety risk mitigations, and monitoring of mitigation effectiveness. Subsection 5.4.4 Key Staff The agency Key Staff/Employees may include managers, supervisors, specialists, analysts, database administrators, and other key employees who are performing highly technical work and overseeing employees performing critical tasks and providing support in the implementation of this Agency Safety Plan and SMS principles in various departments throughout the agency. The City’s Key Staff/Employees responsibilities include:  Ensuring that employees are complying with the safety reporting program.  Ensuring supervisors are conducting their toolbox safety meetings.  Promoting safety in employee’s respective area of responsibilities – that means: zero accidents; absence of any safety concerns; perfect employee performance; and compliance with agency rules and procedures and regulatory requirements.  Ensuring safety of passengers, employees, and the public. Resolution No. 2020-____ Page 14 154 Page 14 of 22  Responding to customer complaints and expectations for frequency, reliability, and convenience of service.  Replacing and maintaining aging facilities, equipment, and infrastructure.  Meeting increasing demands for fixed route, commuter service and paratransit 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.  Establishing clear lines of safety communication and holding accountability for safety performance.  Assisting as subject matter experts in safety risk assessment and safety risk mitigation processes. Section 6 Safety Risk Management (SRM) The second component of the City’s SMS is Safety Risk Management, which includes processes and procedures to provide an understanding of the Agency’s operations and vehicle maintenance to allow individuals to identify hazards associated with those activities. The City uses the Safety Risk Management (SRM) process as a primary method to ensure the safety of its contracted operations, passengers, employees, vehicles, and facilities. It is a process whereby hazards and their consequences are identified, assessed for potential safety risk, and resolved in a manner acceptable to the City’s leadership. The SRM process allows City staff and/or service contractors, to carefully examine what could cause harm and determine whether sufficient precautions have been taken to minimize the harm, or if further mitigations are necessary. In Carrying out the SRM process, the following terms are used:  Event: Any accident, incident or occurrence;  Hazard: Any real or potential condition that can cause injury illness, or death; damage to or loss of the facilities, equipment, rolling stock, or infrastructure belonging to the City or service contractors; or damage to the environment;  Risk; Composite predicted severity and likelihood of the potential effect of a hazard;  Risk Mitigation: Method(s) to eliminate or reduce the effects of a hazard;  Consequence: An effect of a hazard involving injury, illness, death, or damage to City or Operations property or the environment. The Safety Risk Management includes the following activities that are described in more detail in the subsequent sections: 1. Safety Hazard Identification 2. Safety Risk Assessment 3. Safety Risk Mitigation Resolution No. 2020-____ Page 15 155 Page 15 of 22 Subsection 6.1 Safety Hazard Identification The safety hazard identification process offers the City the ability to identify hazards and potential consequences in the operation and maintenance of the City’s transit services. Hazards can be identified through a variety of sources, including:  Employee safety reporting;  Review of monthly performance data and safety performance targets;  Observations from supervisors;  Maintenance reports;  Comments from customers, passengers, the public and third parties;  Drivers’ and All-Staff meetings;  Results from audits and inspections of vehicles and facilities;  Results of training assessments;  Investigations into safety events, incidents, and occurrences;  Review of vehicle camera footage; and  FTA and other oversight authorities. When a safety concern is observed by management or supervisory personnel, whatever the source, it is reported to the Chief Safety Officer. The Chief Safety Officer may conduct further analysis of hazards to collect information and identify additional consequences and to inform which hazards should be prioritized for safety risk assessment. In following up on identification hazards, the Chief Safety Officer may:  Reach out to the reporting party, if available, to gather all known information about the reported hazard,  Conduct a walkthrough of the affected area, assessing the possible hazardous condition, generating visual documentation (photographs and/or video), and taking any measurements deemed necessary,  Conduct interviews with employees in the area to gather potentially relevant information on the reported hazard,  Review any documentation associated with the hazard (records, reports, procedures, inspections, technical documents, etc.),  Contact other departments that may have association with or technical knowledge relevant to the reported hazard,  Review any past reported hazards of a similar nature, and  Evaluate tasks and/or processes associated with the reported hazard. Any identified hazard that poses an immediate risk to transit operations, the health and safety of employees or the public, or equipment must immediately be brought to the attention of the Accountable Executive and placed through the Safety Risk Management Process for safety risk assessment and mitigation. Otherwise, hazards will be prioritized for further Safety Risk Management activity. Subsection 6.2 Safety Risk Assessment Safety risk assessment defines the level or degree of the safety risk by assessing the likelihood and severity of the consequences of hazards and prioritizes hazards based on the safety risk. The Chief Safety Officer, with assistance from key staff subject Resolution No. 2020-____ Page 16 156 Page 16 of 22 matter experts, is responsible for assessing identified hazards and ratings using the safety risk matrix below. Prioritizing safety risk provides the Accountable Executive with the information needed to make decisions about resource application. The following matrix, adopted from the TSI Participation Guide – SMS Principles for Transit, facilitates the ranking of hazards based on their probability of occurrence and severity of their outcome. The measuring goes from A to F with A being frequent or likely to occur frequently and E being improbable or expected that this event will most likely never occur. The designation F is used when potential hazards are identified and later eliminated. Probability Levels Description Level Specific Individual Item Fleet Inventory Frequent A Likely to occur often in the life of an item. Continuously experienced. Probable B Will occur several times in the life of an item. Will occur frequently. Occasional C Likely to occur sometime in the life of an item. Will occur several times. Remote D Unlikely, but possible to occur in the life of an item. Unlikely, but can reasonably be expected to occur. Improbable E So unlikely, it can be assumed occurrence may not be experienced in the life of an item. Unlikely to occur, but possible. Eliminated F Incapable of occurrence. This level is used when potential hazards are identified and later eliminated. Incapable of occurrence. This level is used when potential hazards are identified and later eliminated. The Safety Risk Severity Table presents a typical safety risk. It includes four categories to denote the level of severity of the occurrence of a consequence, the meaning of each category, and the assignment of a value to each category using numbers. In this table, 1 is considered catastrophic meaning possible deaths and equipment destroyed and 4 is considered negligible or of little consequence with two levels in between. Severity Levels Description Level Mishap Result Criteria Catastrophic 1 Could result in one or more of the following: death, permanent total disability, irreversible significant environmental impact, or monetary loss equal to or exceeding $10M. Critical 2 Could result in one or more of the following: permanent partial disability, injuries or occupational illness that may result in hospitalization of at least three personnel, reversible significant environmental impact, or monetary loss equal to or exceeding $1M but less than $10M. Resolution No. 2020-____ Page 17 157 Page 17 of 22 Severity Levels Marginal 3 Could result in one or more of the following: injuries or occupational illness resulting in one or more lost work day(s), reversible moderate environmental impact, or monetary loss equal to or exceeding $100k but less than $1M. Negligible 4 Could result in one or more of the following: injuries or occupational illness not resulting in lost work day, minimum environmental impact, or monetary loss less than $100k. Safety Risk Probability and Safety Risk Severity are combined into the Safety Risk Index Ranking to help prioritize safety risks according to the table below. Safety Risk Assessment Matrix Severity  Probability  Catastrophic 1 Critical 2 Marginal 3 Negligible 4 A-Frequent 1A 2A 3A 4A B- Probable 1B 2B 3B 4B C-Occasional 1C 2C 3C 4C D- Remote 1D 2D 3D 4D E- Improbable 1E 2E 3E 4E F- Eliminated Safety Risk Index Ranking 1A, 1B, 1C, 2A, 2B High Unacceptable 1D, 2C, 3A, 3B Seriou s Undesirable - with management decision required 1E, 2D, 2E, 3C, 3D, 3E, 4A, 4B, Mediu m Acceptable - with review by management 4C, 4D, 4E Low Acceptable - without review The Chief Safety Officer documents recommendations regarding hazard rating and mitigation options and reports this information to the Accountable Executive. Subsection 6.3 Safety Risk Mitigation The Chief Safety Officer, with assistance of key personnel, reviews current safety risk mitigations and establish procedures to 1) eliminate; 2) mitigate; or 3) accept specific risks. Prioritization of safety remediation measures is based on risk analysis and a course of action acceptable to City management. The safety risk must be mitigated if ranked as Unacceptable (High- Red). Those safety risks that have been mitigated, even those mitigated risks shown as Acceptable status (Low -Green) undergo regular and consistent monitoring to ensure the mitigation strategy is effective. Key strategies to minimize the types of risks that potentially exist include: Resolution No. 2020-____ Page 18 158 Page 18 of 22  Development and deployment of policies and procedures that address known hazards and risks,  Discussion of other actions, strategies and procedures that might help safeguard against unknown/unforeseen risks,  Training of drivers and other agency staff on all safety policies and procedures,  Training of drivers and other agency staff on methodologies for handling emergencies, and  Training of drivers and staff on proper and effective use of emergency equipment and communication technologies and protocol. Safety risk mitigations are tracked and updated in the Hazard Log by the Chief Safety Officer. Section 7 Safety Assurance The third component of the Agency’s SMS is Safety Assurance, which ensures the performance and effectiveness of safety risk controls established under safety risk management. Safety assurance also helps ensure that the organization meets or exceeds its safety objectives through the collection, analysis, and assessment of data regarding the organization's performance. Safety assurance includes inspection activities to support oversight and performance monitoring. The City monitors its operations and maintenance protocols and procedures, and any safety risk mitigations to ensure that it is implementing them as planned. Furthermore, the Agency investigates safety events and any reports of non-compliance with applicable regulations, standards, and legal authority. The City also has an Injury Illness Prevention Program (Appendix I). Finally, the Agency continually monitors information reported to it from the management of contracted services. Some of the key elements of the City’s Safety Performance Monitoring and Measurement are described in the following section. Subsection 7.1 Safety Performance Monitoring and Measurement As part of the Safety Assurance Process, the City, staff and/or service contractors:  Monitors the system for compliance with, and sufficiency of, the Agency’s procedures for operations and maintenance through: o Safety audits, o Informal inspections, o Regular review of on-board camera footage to assess drivers and specific incidents, o Employee safety reporting program, o Investigation of safety occurrences, o Safety review prior to the launch or modification of any facet of service, o Daily data gathering and monitoring of data relating to the delivery of service, o Regular vehicle inspections and preventative maintenance, and Resolution No. 2020-____ Page 19 159 Page 19 of 22 o Continuous feedback loop between leadership and all levels of the agency. Results from the above processes are compared against recent performance trends to determine where corrective action needs to be taken.  Monitors its operations to identify any safety risk mitigations that may be ineffective, inappropriate, or were not implemented as intended through: o Reviewing results from accident, incident, and occurrence investigations, o Monitoring employee safety reporting, o Reviewing results of internal safety audits and inspections, and o Analyzing operational and safety data to identify emerging safety concerns. If the mitigation is not implemented or performing as intended, a different course of action is proposed to modify the mitigation or other action is taken to manage the safety risk.  Conducts investigations of safety events to identify causal factors and determines whether: o The accident was preventable or non-preventable, o Personnel require discipline or retraining, o The causal factor(s) indicate that a safety hazard contributed to or was present during the event, and o The accident appears to involve underlying organizational causal factors beyond just individual employee behavior. The City and/or service contractors maintain documented procedures for conducting safety investigations of events (accidents, incidents, and occurrences as defined by FTA) to find causal and contributing factors and review the mitigations in place at the time of the event. These procedures also reflect all traffic safety reporting and investigation requirements established by the California Highway Patrol (CHP).  Monitors information reported through any internal safety reporting programs or other means: o The Chief Safety Officer in coordination with the Public Works Program Manager and Operations’ General Managers routinely reviews safety data captured in contract safety reports, safety meeting minutes, customer complaints, and other safety communication channels. When necessary, the Chief Safety Officer ensures that the issues and concerns are investigated or analyzed through the safety risk assessment process. o The Chief Safety Officer, in coordination Public Works Program Manager and Operations’ General Managers, also reviews the results of internal and external reviews, including audits and assessments, with findings Resolution No. 2020-____ Page 20 160 Page 20 of 22 affecting safety performance, compliance with operations and maintenance procedures, or the effectiveness of safety risk mitigations. o The Chief Safety Officer discusses relevant safety issues and concerns with the Accountable Executive and executive management and documents the results of these reviews.  Compares system performance against established Safety Performance Targets as described in Section 3 (Fatalities, Injuries, Safety Events and System Reliability). In the event of a fatality, the City complies with all FTA drug and alcohol requirements. In California, every driver involved in an accident that results in death, injury, or property damage over $1,000, effective January 1, 2017, must report the accident on a Report of Traffic Accident Occurring in California (SR 1) form to the Department of Motor Vehicles (DMV). The report forms are available at www.dmv.ca.gov, by calling 1-800-777-0133, and at CHP and DMV offices. Also, under California Vehicle Code §16002(b) the driver of a vehicle that is owned or operated by a publicly owned or operated transit system, or that is operated under contract with a publicly owned or operated transit system, and that is used to provide regularly scheduled transportation to the general public or for other official business of the system shall, within 10 days of the occurrence of the accident, report to the transit system any accident of a type otherwise required to be reported pursuant to subdivision (a) of Section 16000. The City requires driver notification to the City immediately and maintains records of any report filed pursuant to this paragraph. Section 8 Safety Promotion The fourth component of the City’s SMS is Safety Promotion, which includes a combination of training and communication of safety information to employees to enhance the Agency’s safety performance. Safety Promotion sets the tone for the SMS and helps the City to establish and maintain a robust safety culture. Safety Promotion has two-components: (1) Safety Communication; and (2) Competencies and Training. Subsection 8.1 Safety Communication Ongoing safety communication is critical and the City ensures communication occurs up, down, and across all levels of the organization. Any lessons learned are communicated to all concerned. Management commitment to address safety concerns and hazards is communicated on a regular basis. Management encourages and motivates employees to communicate openly, authentically, and without concern for reprisal; ensures employees are aware of SMS principles and understand their safety- related roles and responsibilities; conveys safety critical information such as accident data, injuries, and reported safety concerns and hazards and their resolutions to employees. The City and contract services provide tools to support safety communication include:  Safety bulletins  Safety notices Resolution No. 2020-____ Page 21 161 Page 21 of 22  Posters  CDs or thumb drives or online safety video access  Newsletters  Briefings or Toolbox talks  Seminars and workshops  New employee training and refresher training  Intranet or social media  Safety Committee Meetings Competencies and Training: Executive Management ensures that all applicable employees attend the training provided to understand their specific roles and responsibilities for the implementation of SMS. The City ensures SMS training in the following areas: All Employees:  Understanding of Safety Performance Targets  Understanding of fundamental principles of SMS  Understanding of Safety Reporting Program – Reporting unsafe conditions and hazards/near misses  Understanding of their individual roles and responsibilities under SMS Managers and Supervisors  Understanding of Safety Risk Management  Understanding of Safety Assurance  Understanding of Safety Promotion  Understanding of their individual roles and responsibilities for SMS Executive Management:  Understanding of management commitment to and support of all SMS activities All employees are required to acquire the competencies and knowledge for the consistent application of their skills as they relate to safety performance objectives. The City and its service contractors dedicates resources to conduct effective safety-related skill training. The scope of the safety training is appropriate to each employee’s individual safety-related job responsibilities and their role in SMS. Components of skill- related training include:  Conducting training needs analyses to ensure that the right information is being taught to the right employees using the most efficient training methods.  Communicating purpose, objectives, and outcome.  Ensuring relevant content by directly linking training to the trainee’s job experiences so trainees are more motivated to learn.  Using active hands-on demonstrations and practice to demonstrate skills that are being taught and provide opportunities for trainees to practice skills.  Providing regular feedback during hands-on practice and exercises. Resolution No. 2020-____ Page 22 162 Page 22 of 22  Reinforcing training concepts in the post-training work environment by giving employees opportunities to perform what they have learned. The City’s contractor, Thousand Oaks, also has a Public Transportation Agency Safety Plan, and the City’s bus operator, MV Transit, conducts refresher training monthly during employee safety meetings. Safety training topics include, but are not limited to: Left Turns and Pedestrians, Winter Driving, Mobility Device Securement, and Fire Safety/Fire Extinguisher Training. A copy of the MV Transit System Safety Program is included in Appendix II. Section 9 Documentation Pursuant to 49 CFR Part 673.31, the City maintains records related to this Safety Plan and SMS implementation for a minimum of three years. These documents include but are not limited to the results from SMS processes and activities. City will make these documents available to FTA Region 9, Caltrans, and other Federal and state agencies upon request. Resolution No. 2020-____ Page 23 163 Appendix I CITY OF MOORPARK INJURY AND ILLNESS PREVENTION PROGRAM October 24, 2016 Resolution No. 2020-____ Page 24 164 - 2 - 10/24/2016 I. INTRODUCTION In California, every employer is required by law (Labor Code Section 6400) to provide a safe and healthful workplace. In addition, General Industry Safety Orders Section 3203 requires every employer in the State, regardless of size or industry, to implement an Injury and Illness Prevention Program (IIPP). A written plan is required that describes the procedures to be put into practice. II. STATEMENT OF SAFETY POLICY It is the policy of the City of Moorpark (City) to strive for the highest safety standards. Safety does not occur by chance. It is the result of careful attention to all operations by those who are directly and indirectly involved. Employees at all levels must work diligently to execute the City's policy of maintaining safety and occupational health. This safety program has been developed to assure compliance with Federal, State, and Local regulations with particular emphasis on the Occupational Safety and Health Act (OSHA), and the OSHA requirements that apply to our operations. It is the obligation of all employees to be knowledgeable of the standards established by these agencies and to implement the rules and regulations contained therein on projects under their direction. Employees are encouraged to access the California Joint Powers Insurance Authority (CJPIA) Policy Library available through their website at www.cjpia.org to read or obtain a copy of the current safety related sample policies, manuals, fact sheets, checklists and other safety related forms. Regard for the safety of our citizens, the general public, our own employees, and the employees of our contractors is a responsibility of all levels of our organization. We intend to prevent any human suffering. Accidents, even minor ones, cause pain, both physical and mental. Prevention of injury and illness is a goal well worth achieving. A safe operation is organized, clean, and efficient. If every employee views accidents in the same way we consider all other aspects of our operations, we will be in a better position to control accidents and to improve the total performance of our organization. It is, therefore, of utmost importance that all aspects of our safety program are strictly adhered to, and that the intent of this program is followed to the letter. Resolution No. 2020-____ Page 25 165 - 3 - 10/24/2016 III. ASSIGNMENT OF RESPONSIBILITIES A. SAFETY PROGRAM COORDINATOR The City Manager is the administrative head of the government of the City, administers the City personnel system, and has overall responsibility for compliance with and enforcement of laws and the ordinances of the City. Section 2.12.060 of the City’s Municipal Code identifies the powers and duties of the City Manager, including appointment authority. In compliance with OSHA requirements, the City Manager has appointed the Assistant City Manager, Administrative Services Department, as the City’s Safety Program Coordinator with the following responsibilities: 1. Coordinate all loss control activities. 2. Establish minimum safe standards, rules, and regulations. 3. Review all supervisor accident investigation reports and follow up on corrective action. 4. Establish training programs for employees and supervisors, as required, and ensure safety training has been conducted as required. 5. Report to the City Manager concerning safety concerns. 6. Serve as City representative for any OSHA audit or inspection of City property or facilities. 7. Designate a Chair of the Safety Committee (Reference: "SAFETY COMMITTEE CHAIR’S RESPONSIBILITIES" under the "SAFETY COMMITTEE" section for more specific responsibilities). 8. Appoint a Secretary to record activities of the Committee. 9. Supervise preparation of the OSHA Injury and Illness Reporting Forms 300, 300A, and 301, and maintain records for legal retention period. 10. Conduct audits of the City’s safety programs to evaluate compliance with OSHA requirements. 11. Report to City management regarding safety compliance status, new or upcoming regulations, and other safety issues that require their attention. B. MANAGEMENT Department directors shall support the City safety policy by: 1. Delegating and assigning safety responsibilities to all levels of personnel. 2. Becoming fully knowledgeable of hazards and injury potentials in their departments. 3. Ensuring employees and contractors are aware of and comply with safety standards, work procedures, and OSHA regulations. Resolution No. 2020-____ Page 26 166 - 4 - 10/24/2016 4. Disciplining employees per the City’s discipline policy for violations of safe practices and work procedures. 5. Correcting in a timely manner any unsafe conditions or work practices that are observed or reported. 6. Appointing a Department Safety Coordinator. 7. Consistently monitoring safety program developments, progress, and effectiveness. 8. Providing a budget to support loss control efforts. C. SUPERVISORS Division managers and supervisors have the following responsibilities: 1. Become fully knowledgeable of hazards and injury potentials in their departments and/or divisions. 2. Communicate and enforce all City policies and procedures relating to job safety, including safety rules and regulations to employees under their supervision and ensure that contractors adhere to the provisions of their contracts. 3. Respond to employee suggestions concerning safety matters, including investigating any complaints or recommendations for changes to commonly accepted safety practices or procedures. 4. Become knowledgeable of safety codes and regulations. 5. Conduct timely and effective hazard identification surveys and accident investigations, and submit all related documentation to the Safety Committee. 6. Conduct employee safety training and orientation, and submit documentation of this training to the Safety Coordinator. 7. Correct in a timely manner any unsafe conditions or work practices that are observed or reported. 8. Discipline employees per the City’s discipline policy for violations of safe practices and work procedures. D. EMPLOYEES 1. Safe Work Practices. Employees shall follow all safety rules and procedures and ensure safety on the job for themselves and other employees by complying with the following safe work practices: a. Know the job and always apply safe work practices. b. Recognize the hazards of the job and take precautions to ensure the safety of themselves and others. c. Adhere to all City policies and procedures relating to job safety including both general safe work rules and task specific rules and regulations. d. Report all unsafe working conditions, tools, or equipment to supervisory personnel immediately. Resolution No. 2020-____ Page 27 167 - 5 - 10/24/2016 e. Actively participate and cooperate in the overall safety program. f. Use all personal protective equipment as required. g. Comply with all safety instructions from supervisors. h. Obey all health and safety warning signs and standards. i. Immediately report all accidents (vehicular or personal) regardless of severity to the supervisor. j. Do not jump from truck beds, platforms, fences, or other elevated places. k. Do not take shortcuts in or over dangerous places. l. Do not participate in practical jokes and horseplay. m. Do not wear loose clothing and jewelry while working on or near equipment and machines. n. Lift heavy objects using proper techniques and assistive equipment when needed, and comply with supervisor’s safety instructions when lifting. 2. Safety Suggestion and Complaint Procedure. Employees shall have the right to make suggestions or complaints concerning safety matters, including anonymous suggestions or complaints. Safety suggestions or complaints may be made at any time, and an open communication process between an employee and supervisor is encouraged. If an employee has a suggestion or complaint pertaining to job safety that has not been resolved informally with their supervisor or division head, then the following safety complaint reporting process should be followed, unless the department head, Safety Program Coordinator, or City Manager determines an immediate response to a safety complaint is required based on the potential for injury or illness: a. If the employee is not in agreement with the decision rendered in the informal suggestion or complaint procedure, an employee shall have the right to present a formal complaint in writing to the department head. The department head shall review the complaint and meet with the employee within ten (10) work days of receipt of the complaint. The department head shall prepare a written response and return it to the employee with a copy to the City Manager, within five (5) work days after meeting with the employee. b. If the employee does not agree with the decision reached by the department head on the safety complaint, the employee may present in writing a formal, signed complaint to the City Manager, with a copy to the Safety Program Coordinator, within five (5) work days after the employee's receipt of the department head's decision. The Safety Program Coordinator shall schedule a meeting with the employee and City Manager within ten (10) work days. Within seven (7) Resolution No. 2020-____ Page 28 168 - 6 - 10/24/2016 work days after the meeting, the City Manager shall render a formal decision in writing, with a copy to the employee, department head, and Safety Program Coordinator. The decision of the City Manager shall be final. c. Employees that prefer to submit an anonymous complaint may submit such complaint directly to the Safety Program Coordinator, for a recommendation to the City Manager. The Safety Program Coordinator shall provide a written notice of the complaint resolution decision of the City Manager to all applicable supervisory personnel and the department head within seventeen (17) work days of receipt of complaint. The decision of the City Manager shall be final. IV. CITY SAFETY COMMITTEE A. At the request of the Safety Program Coordinator, department directors will designate committee members. The Safety Program Coordinator will designate the Safety Committee Chair and may designate a Vice-Chair if determined necessary. B. Committee membership will include representatives from each City Department. The Administrative Services Department will represent the City Manager’s Office. C. The Safety Committee will assist the Safety Program Coordinator in carrying out a planned safety program. D. The Committee should confine all activities to the safety of employees, City vehicles and property, and public liability exposures. E. The functions of the Committee shall include: 1. Review accident trends, analyze records and reports, and take appropriate action where trend indicates need. 2. Discuss injury prevention strategies. 3. Check on all activities to see that they are being carried out effectively. (Some examples are: monthly department inspections by first line supervisors, accident investigations by supervisors, meetings on safety between employees and first line supervisors, prompt action on safety work.) 4. Assist all supervisors in their efforts to implement accident prevention. 5. Review recommendations submitted by supervisor, and take appropriate action. 6. Promote and maintain interest in departmental safety activities, inspections, etc. 7. Review and discuss accident experience. Resolution No. 2020-____ Page 29 169 - 7 - 10/24/2016 8. Investigate accident reports as a basis for recommending means to prevent recurrence. 9. Review recommendations resulting from departmental inspections and establish a procedure for handling suggestions. 10. Develop and review safety rules. 11. Discuss non-confidential safety complaints received from employees. 12. Conduct safety inspections. F. This Committee will meet not less than quarterly each year. Each meeting will be documented through the use of the Minutes form in the Staff Share/Risk Management/Injury & Illness Prevention Program folder. The Minutes shall be prepared by the Safety Committee Chair, or by any other designee of the Safety Program Coordinator. Each committee member is responsible for reporting back to his/her department or division any pertinent information discussed at the safety meeting. G. The following is presented as a suggested order of business for Safety Committee meetings: 1. Call to Order - the meeting should be called to order promptly at the appointed time. 2. Roll Call - names of members and others present and absent should be recorded. 3. Minutes of Previous Meeting - should be read and corrections made. 4. Unfinished Business - all matters on which definite decisions have not been made should be brought up for reconsideration. 5. Review of Accidents and Statistics - any accidents, which occurred since the prior meeting, should be reviewed and preventative measures discussed. 6. Safety Education- when time permits, the Chair will head a discussion on a selected safety topic. 7. Inspection and Recommendations - review Department Inspection Reports and include in the minutes. 8. New Business - safety suggestions and potential hazards and recommendations should be discussed. 9. Adjournment H. The agenda will be published and sent to each Committee member prior to the meeting. It will also be posted on the bulletin boards for employees to observe at least twenty-four (24) hours prior to the scheduled meeting. I. The date, time, and place of the meeting will be noted on the posted agenda. J. The duties of the Chair of the Safety Committee will include: Resolution No. 2020-____ Page 30 170 - 8 - 10/24/2016 1. Through consultation with Safety Program Coordinator, direct activities of the Safety Committee. 2. Schedule and conduct quarterly meetings. 3. Supervise selection and distribution of safety educational and motivational literature or posters on bulletin boards. 4. Determine, with the Safety Program Coordinator, the need for authoritative safety references (codes, standards, etc.), procure them and place them in the hands of persons who are to apply them. 5. Assist in the review and critique of accident investigation reports. 6. Assist in the safety education of Committee members. 7. Assign Committee members special projects, with the approval of the Safety Program Coordinator. 8. Assist and advise the Safety Program Coordinator in the formulation and presentation of safety training programs. 9. Assist the Safety Program Coordinator with coordination with the CJPIA insurance company(ies) and other safety representatives serving the CJPIA, accompanying them on their surveys, if requested by the Safety Program Coordinator, and make maximum utilization of their assistance. V. EMPLOYEE EDUCATION AND TRAINING A. Apathy about safety and unsafe actions are often the cause of accidents in business and industry. Training is one way to change the way employees think and act. Training of employees should start the first day on the job. It should continue thereafter. B. All employees shall receive safety training to assist them in effectively completing their responsibilities in this regard. C. All new hires shall review the IIPP and sign an acknowledgement as a part of the new employee orientation. The IIPP shall be subsequently reviewed and acknowledged in writing by employees each time the IIPP is amended. D. Safety training and orientation must be documented by the supervisor in the mid-probation and annual performance evaluations. Evidence of completion of mandatory OSHA Safety training shall be provided to the Safety Program Coordinator for filing purposes. E. Supervisors are responsible for observing the new employee on the job after initial orientation and training have been completed and establishing a period for evaluating employee safe work habits to ensure compliance with safety standards. F. Supervisors are responsible for providing safety training to the employees under their supervision. Basic safety training will be provided to all new Resolution No. 2020-____ Page 31 171 - 9 - 10/24/2016 employees and to current employees when given new or different job assignments. Supervisors should also periodically review safety training topics with employees under their supervision. Basic safety training will include the following: 1. Management’s intent and attitude towards safety. 2. City safety policies, rules, and procedures. 3. Written job description information to compliment actual on the job training activities. 4. Use, care, and maintenance of any required personal protective equipment. 5. Potential exposure to any major hazards (e.g., chemicals, toxic materials, hazardous equipment, etc.) and ensure that they fully understand the degree of hazard and the necessary precautions. 6. City disciplinary policies for violation of safety rules and regulations. . G. Periodic safety training, typically provided by CJPIA or another professional organization, will be scheduled by the Human Resources/Risk Management Division and includes the following: 1. Blood-borne pathogens. 2. Fire extinguisher use. 3. Driver awareness. 4. Hazard communication. H. Additional specialized training, typically provided by CJPIA or another professional organization, may be scheduled by a department director, a supervisor (with the department director’s approval), or the Human Resources/Risk Management Division. Specialized training may include the following: 1. Respiratory training and fit test. 2. Confined space entry. 3. Hearing conservation. 4. Heat stress. 5. Ergonomics. 6. First aid, CPR, and AED. 7. Preventing substance abuse, safety sensitive positions. I. Training shall also be provided directly by a supervisor, or if a more specialized level of training is needed, scheduled with a professional organization by a department director or a supervisor (with the department director’s approval) whenever: 1. New substances, processes, procedures, or equipment are introduced to the workplace and represent a new hazard. Any new Resolution No. 2020-____ Page 32 172 - 10 - 10/24/2016 substances or equipment shall include training that follows the manufacturer’s guidelines. 2. Management becomes aware of a new or previously unrecognized hazard. VI. FACILITY INSPECTIONS A. Inspection procedures have two basic objectives: 1. Maintaining a safe work environment and controlling the unsafe actions of people, and 2. Maintaining operational profitability. B. Inspections will not be limited to a search for unsafe conditions but will also try to detect unsafe practices. C. Corrective actions needed and other recommendations resulting from inspections will be prioritized, assigned to a responsible individual and given a time limit for completion. D. Inspections shall be completed annually. E. The Facilities Office Hazard Checklist and Safety Checklist will be used during facility inspections (the Inspection Checklist Forms are available in the Staff Share/Risk Management/Safety Committee folder). 1. All formal inspections must be documented. 2. The Facilities Office Hazard Inspection for each workplace facility is to be conducted by the employee designated by the Parks and Recreation Director. 3. The Safety Inspections are to be conducted by the employee designated by each department director. The Administrative Services Department will represent the City Manager’s Office. 4. Copies of the Inspection Checklists or a summary report prepared by the Safety Committee Chair shall be submitted to the Safety Committee for review. VII. ACCIDENT INVESTIGATIONS A. The objective of an accident or incident investigation is to find the causes of an accident or other incident that results in injury, illness, or property damage. This will allow corrective action to be devised and implemented and minimize a recurrent problem. Resolution No. 2020-____ Page 33 173 - 11 - 10/24/2016 B. Employees must report all accidents, injuries, and work-related illnesses, as well as any incident that could have resulted in an injury or property damage (including near miss incidents) to their supervisor immediately. If their supervisor is not immediately available, the accident, injury, illness, or incident must be immediately reported to the Human Resources/Risk Management division and the department director. C. Investigation procedures are as follows: 1. Investigations will be conducted for all accidents or incidents which require an employee to seek a physician's care, prevent an employee from completing all of their job duties, or cause property damage. An accident investigation will also be required for all first aid cases, which might have resulted in more serious consequences. 2. The investigation will be made by the supervisor in charge of the injured employee, or that supervisor having jurisdiction over the damaged equipment and/or property. 3. The investigation shall be made within 24 hours of the accident or incident. 4. The supervisor conducting the investigation will record the results of the investigation on the Supervisor’s Injury or Illness Event Report (for any work-related employee injury or illness) available in the Staff Share/Human Resources/Workers Compensation folder, and may be asked by the Safety Program Coordinator to also complete the CJPIA Significant Incident Form available in the Staff Share/Risk Management/Forms folder (including for recording of property damage and/or non-employee injury or illness). 5. The completed investigation form(s) will be reviewed by the Safety Program Coordinator and discussed with the Safety Committee. 6. The investigation report shall indicate the specific causes of the accident or incident. Specific actions or conditions which led to the accident or incident must be included. Statements such as "the cause of the accident was carelessness" are not useful or acceptable. 7. When applicable, the Workers’ Compensation Claim form (DWC 1 form) available in the Staff Share/Human Resources/Workers Compensation folder, and the Employer’s Report of Occupational Injury or Illness form (Form 5020) will be completed and submitted to the City’s Workers Compensation claims adjuster company within the time limits required by State law. California law requires employers to complete the Employer’s Report of Occupational Injury or Illness Form 5020 within five (5) days of knowledge of every occupational injury or illness which results in lost time beyond the date of the incident or requires medical treatment beyond first aid (this report is typically completed online by the City’s Human Resources/Risk Management staff). Every serious injury/illness or death must be reported immediately by telephone or FAX to the Resolution No. 2020-____ Page 34 174 - 12 - 10/24/2016 nearest office of the Division of Occupational Safety and Health (OSHA) and the CJPIA. All supervisors have direct responsibility to immediately accomplish the serious injury/illness or death reporting as required by law. VIII. CHEMICAL, EQUIPMENT, AND PROCEDURE INSPECTIONS A. Inspections shall be conducted when new substances (including chemicals), processes, procedures, or equipment are introduced into the workplace that represent a new occupational safety or health hazard. This inspection shall be conducted by the Department Safety Coordinator or other designee of the Safety Committee Chair or Safety Program Coordinator. The purpose of the inspection shall be to determine what, if any, new training is needed for the new substances, processes, procedures, or equipment and to ensure the proper use and/or implementation of the new substances, processes, procedures, or equipment. B. Substances, equipment, and procedures not currently in use or operation must be reviewed and approved by the Department Safety Coordinator prior to purchase, use, and/or implementation. IX. CORRECTING UNSAFE AND/OR UNHEALTHY CONDITIONS A. All employees should be cognizant of unsafe and/or unhealthy conditions, and are responsible for either correcting or reporting unsafe and/or unhealthy conditions. Employees must correct unsafe and/or unhealthy conditions when it is within their job description and capability to do so. If an employee is unable to correct an unsafe and/or unhealthy condition, he/she must report it to his/her supervisor, or complete a work order to have the condition corrected. B. Methods of correcting unsafe or unhealthy conditions will vary depending upon the degree of hazard and control of the work site. Minor hazards, such as housekeeping issues, trip hazards, minor spills, etc. shall be corrected immediately. Hazardous conditions of a more serious nature, or conditions which cannot be immediately remedied, must be handled so as not to result in injury, illness, or property damage. This may require work to be stopped, equipment to be tagged and taken out of service until repaired, or the area to be cleared until corrective action can be taken. C. Hazards of an imminent nature will require emergency notifications and evacuation. If an emergency situation arises that results in an imminent hazard that cannot be immediately abated, employees will be evacuated (per the City’s evacuation procedures) from the area to a safe location until the situation is corrected. Resolution No. 2020-____ Page 35 175 - 13 - 10/24/2016 D. Any injury, illness, or property damage that results from an unsafe and/or unhealthy condition must be reported, and an investigation will be completed as described in the Accident Investigation section of this IIPP. X. SAFETY PROGRAM EVALUATION A. In order to ensure that the City’s Safety program is adequately monitored and maintained, it is necessary to conduct periodic evaluations of the program and the supervisors' activities that are a vital part of it. B. These evaluations are designed to complement the ongoing monitoring conducted by the Safety Committee through their efforts. C. Annually, each department director will complete the Annual Safety Program Evaluation Form in the Staff Share/Risk Management/Injury & Illness Prevention Program folder for submission to the City Manager on the due date as determined by the City Manager. D. The Annual Safety Program Evaluation forms will then be reviewed and discussed at a Management Staff Meeting. “Unsatisfactory” and “Needs Improvement” ratings shall be discussed and included as a focal point of management efforts during the next year. E. For the Public Works and Parks, Recreation, and Community Services Departments, the Report of Supervisor’s Safety Activities Form (available in the Staff Share/Risk Management/Injury & Illness Prevention Program folder) should be submitted by supervisors of maintenance staff to department directors no less than annually for review and action as necessary. A copy of those reports should be attached to the Annual Safety Program Evaluation Form when submitted to the City Manager. Resolution No. 2020-____ Page 36 176 SYSTEM SAFETY PROGRAM PLAN for MV Transportation, Inc. Appendix II Resolution No. 2020-____ Page 37 177 December 2019 2 Table of Contents Section 1: Introduction .................................................................................................. 6 1.1 Introduction ................................................................................................................................ 6 1.2 Policy Statement and Mission .................................................................................................. 6 1.3 Purpose ........................................................................................................................................ 6 1.4 Scope ............................................................................................................................................ 6 1.5 Goals ............................................................................................................................................ 7 1.6 Objectives .................................................................................................................................... 7 1.7 Introduction and System Description ..................................................................................... 7 1.8 MV Transportation as a Company .......................................................................................... 8 1.9 Measures of Service ................................................................................................................... 9 1.10 Operations ................................................................................................................................... 9 1.11 Scope of Services and Organizational Structure .................................................................. 10 1.12 Elements of MV Transportation’s Plan ................................................................................ 10 1.13 Paratransit Van and Bus System Service ............................................................................... 17 1.14 Operations ................................................................................................................................. 17 1.15 Maintenance .............................................................................................................................. 18 1.16 Systems Modifications ............................................................................................................. 18 Section 2: Safety Activities - MV Transportation Executive Safety Committee ......... 20 2.1 Introduction – Control and Update Procedures ................................................................. 20 2.2 ESC Description ...................................................................................................................... 20 2.3 ESC Committee Chairperson and Chairperson Elect ........................................................ 20 2.4 ESC Member Responsibilities ................................................................................................ 20 2.5 Methodology to Achieve SSPP Goals ................................................................................... 21 2.6 Hazard Identification and Resolution Process (MIL - 882D) ........................................... 22 1. Hazard Identification .................................................................................................... 22 2. Hazard Assessment ....................................................................................................... 22 2.7 Risk Assessment ....................................................................................................................... 23 2.8 Follow-Up ................................................................................................................................. 25 Section 3: Safety Activities: Risk Management, Safety & Training ............................ 26 3.1 Risk Management Department .............................................................................................. 26 1. Insurance Program ........................................................................................................ 26 2. Claims Management ...................................................................................................... 26 3. Employee Related Work Injuries................................................................................. 27 4. Third Party Contracts .................................................................................................... 27 3.2 Operations Safety & Training Group ................................................................................... 27 1. Safety & Training Compliance Procedures ................................................................ 28 2. Training and Certification Programs........................................................................... 29 3. Employee Safety Programs and Training ................................................................... 30 4. Maintenance Safety Committee ................................................................................... 30 Resolution No. 2020-____ Page 38 178 December 2019 3 Section 4: Safety Activities: Bus/van Transportation and Maintenance .................... 31 4.1 Introduction .............................................................................................................................. 31 4.2 Operations Department .......................................................................................................... 31 1. Safety Rules and Procedures ........................................................................................ 31 2. Safety Monitoring .......................................................................................................... 31 3. Accident / Incident Investigation ............................................................................... 31 4. Safety Awards ................................................................................................................. 31 5. Drivers Licenses ............................................................................................................. 32 6. Substance Abuse Program ............................................................................................ 32 7. Maintenance Inspections .............................................................................................. 32 8. Safety-Related SOPs ...................................................................................................... 32 9. Safety Manual ................................................................................................................. 32 10. First Aid........................................................................................................................... 33 11. Industrial Incident Investigation ................................................................................. 33 12. Equipment and Facility Inspection ............................................................................. 33 4.3 Interdepartmental Coordination as it Pertains to Operations ........................................... 33 4.4 Configuration Management .................................................................................................... 34 Section 5: Other Organizational Units ........................................................................ 35 5.1 Safety Activities: Other Organizational Units - Introduction .......................................... 35 1. Department and Division Heads (Vice Presidents and Directors) ........................ 35 2. Operations General Managers ..................................................................................... 35 3. Supervisors ...................................................................................................................... 35 4. Employees ....................................................................................................................... 35 5.2 Human Resources Department ............................................................................................. 35 5.3 Business Development Department ..................................................................................... 36 5.4 Legal Issues ............................................................................................................................... 36 5.5 Procurement Handled by the Operations Department ...................................................... 36 5.6 Information Technology Department .................................................................................. 37 Section 6: Required Safety Doctrines .......................................................................... 38 6.1 Understanding .......................................................................................................................... 38 6.2 Safety Training .......................................................................................................................... 38 6.3 Fire Protection .......................................................................................................................... 38 6.4 System Security and Emergency Preparedness Plan (SSEPP) ........................................... 38 6.5 Hazard Communication (HAZCOM) .................................................................................. 39 6.6 Lock-out/Tag-out .................................................................................................................... 39 6.7 Environmental Management Program ................................................................................. 39 6.8 Drug and Alcohol Program .................................................................................................... 40 6.9 New Systems Design and Control Safety Procedures ........................................................ 41 1. New Systems User Requirements ................................................................................ 41 2. New Systems Safety Design Review ........................................................................... 42 3. New Systems Specifications ......................................................................................... 42 4. New Systems Acceptance Testing and Inspection ................................................... 42 5. New Systems Configuration Management ................................................................. 42 Resolution No. 2020-____ Page 39 179 December 2019 4 6. Construction Safety Plan .............................................................................................. 43 7. Drug-free and Alcohol-free Workplace Policy .......................................................... 43 Section 7: Updates, Audits and Regulatory Agencies ................................................. 44 7.1 Implementation / Revisions ................................................................................................... 44 1. Updates ............................................................................................................................ 44 2. Audits ............................................................................................................................... 44 3. Audit Responsibilities .................................................................................................... 44 4. Audit Schedule ............................................................................................................... 45 5. Audit Content ................................................................................................................. 45 6. Follow-Up/Action Plans .............................................................................................. 45 7. Documentation .............................................................................................................. 45 8. External Safety Audits ................................................................................................... 45 7.2 Regulatory Agencies ................................................................................................................ 46 1. Local Regulatory Agencies ........................................................................................... 46 2. State Regulatory Agencies ............................................................................................. 46 3. Federal Regulatory Agencies ........................................................................................ 46 Resolution No. 2020-____ Page 40 180 December 2019 5 System Safety Policy Statement MV Transportation has developed this System Safety Program Plan (SSPP) with the goal of providing the safest transportation possible for our customers and the clients of our service area and the safest work environment possible for our employees. Each department and division is directed and empowered to administer the SSPP and its specific activities for the prevention, control and resolution of unsafe conditions and actions. MV’s safety policy shall at all times be guided by the following principles: 1. Safety is the responsibility of every employee. 2. Our operating environment can be safeguarded. 3. Injuries and occupational illness can be prevented. 4. Preventing injuries and incidents is good business. 5. Management will train all employees to work safely. MV Transportation’s management is responsible for providing leadership in promoting safety throughout the agency. Management will ensure that all employees are committed to the safety of MV Transportation passengers, employees and property, as well as to members of the general public who use our transportation services. The management team will provide and maintain a safe and healthy working environment and follow practices to safeguard employees and other persons interacting with agency personnel, property and equipment. Employees have a duty to carry out daily work assignments in a safe manner and maintain work areas in accordance with established departmental safety procedures. Employees are required to abide by all procedures relating to security and safety and must not engage in any conduct that poses a threat to themselves, other employees, the general public or MV Transportation property. The Senior Vice President of Safety & Training, the Vice Presidents of Safety & Training, the Executive Vice President of Risk Management and the MV Transportation Executive Safety Committee have the responsibility to develop and implement programs to promote safe operations, reduce or eliminate accidents and monitor SSPP compliance and maintenance. All managers and supervisors have the responsibility to develop, implement and enforce safety rules and procedures in their respective areas. Resolution No. 2020-____ Page 41 181 December 2019 6 Section 1: Introduction 1.1 Introduction This document is the System Safety Program Plan (SSPP or Plan) of MV Transportation. System Safety is defined by the U.S. Department of Transportation as follows: “The application of operating, technical and management techniques and pr inciples to the safety aspects of a system throughout its life to reduce hazards to the lowest level possible through the most effective use of available resources.” This Plan describes the MV Transportation system and provides a methodology for identifying hazards and implementing plans for their resolution. It establishes accountability for safety throughout the organization. 1.2 Policy Statement and Mission Our mission is to be The Standard of Excellence in the provision of passenger transportation services. We will provide these services to both public and private agencies nationwide. We will accomplish this mission in a safe, efficient and cost effective manner while treating our employees as part of our family and our customers as our most important asset. 1.3 Purpose The purpose of the SSPP is to establish formal mechanisms to be used by all MV Transportation departments to:  Identify hazards associated with MV Transportation systems.  Eliminate, minimize or control these hazards.  Coordinate and establish system safety throughout the company.  Provide a leadership safety document that is fluid and changing with our operating environments. The SSPP will be used as a means of preventing injuries, accidents and other losses. It demonstrates MV Transportation’s commitment to safety and compliance through loss prevention programs. The Plan is consistent with federal, state and local regulations, and assures that industry standards are maintained in accordance with the SSPP standards of the American Public Transportation Association (APTA) and the Federal Transit Administration (FTA). 1.4 Scope The SSPP applies to all organizational units affecting or affected by MV Transportation’s operations, planning, procurement, testing, operation and maintenance activities. Resolution No. 2020-____ Page 42 182 December 2019 7 1.5 Goals The goals of the SSPP are as follows:  Identify, eliminate, minimize and/or control safety hazards and their associated risks.  Provide a superior level of safety in our transit and student transportation operations.  Support the safety efforts of the clients we serve throughout the country.  Achieve and maintain a superior level of safety in the company’s work environment.  Comply with the applicable requirements of regulatory agencies.  Maximize the safety of future operations through the procurement process. 1.6 Objectives The following objectives provide a means of achieving the SSPP goals and measuring the effectiveness of MV Transportation safety initiatives.  Establish safety policies, procedures and requirements that integrate safety into decision- making and operations.  Assign responsibilities related to safety policies, procedures, and requirements.  Thoroughly investigate all accidents, fires, injuries and near misses.  Identify, analyze and resolve all hazards in a timely manner.  Meet or exceed safety requirements in specifications, equipment installation, and system testing, operations and maintenance.  Meet or exceed safety requirements in vehicle operations and maintenance.  Evaluate and verify operational readiness of new contracts.  Minimize bus and van system modifications on company vehicles in the operational stages by establishing and utilizing safety controls at system procurement and design stages.  Thoroughly evaluate the safety implications of all proposed system modifications prior to implementation.  Establish doctrines, standards and procedures for employee qualifications, selection, training and performance.  Establish doctrines, standards and procedures for scheduling MV Transportation System Description 1.7 Introduction and System Description MV operates transportation services in many communities across the nation for transit authorities, cities, counties, state agencies, private parties, and any other entities that desire high quality, cost effective transportation services. By remaining true to our core values and providing excellent service, MV has become one of the largest transportation management firms in the United States. Resolution No. 2020-____ Page 43 183 December 2019 8 1.8 MV Transportation as a Company MV has been providing transit services throughout our company history, beginning in 1975. We serve many public organizations today in ongoing paratransit and transit operations contracts. MV is a professional and innovative contractor who supplies top quality, safe and reliable transit service for our customers at reasonable prices. Approximately one half of our operations are dedicated paratransit operations and one half dedicated to fixed route/multimodal services. We perform maintenance functions in nearly 80% of our current contracts across the nation. Please also see our locations map on the previous page for a graphic representation of the national scope of our services. Paratransit MV has provided Paratransit services since our company’s founding in 1975, predating the Americans with Disabilities Act. MV’s experience in Paratransit operations ranges from countywide ADA paratransit services to door-through-door, stair-assist ADA paratransit services. Included in the scope of many of these services, MV operates reservations and dispatch call centers utilizing a variety of different reservations and dispatch systems. Today, MV is the largest provider of paratransit services in the nation and has a greater ability to support automated scheduling software systems than any other firm. MV works effectively with their clients in customizing their systems to meet the needs of the community, from implementing high-end scheduling software products to building in-house software, to recommending use of technology such as Mobile Data Terminals (MDT), Automated Vehicle Locator (AVL) or Geographic Information Systems (GIS) products. We analyze each of our operations periodically throughout our contract term to ensure that we operate high levels of efficiency and productivity. Fixed Route MV has extensive experience in managing and operating Fixed Route services. Encompassed in this experience are contracts that include unique projects where MV has implemented new services into communities who previously did not have a transit system, and expanded on existing fixed route systems to further meet passenger demand. MV also has many contracts where we operate Multimodal Systems, providing both Fixed Route and complementary Paratransit transit systems. MV’s Fixed Route services range from small employee shuttle bus services to large transit operations in major U.S. cities. Each of these current fixed route service contracts requires extensive interaction with our client agencies to ensure that the needs of the agency and the passengers are met. We approach our Fixed Route services as a truly dynamic service that must change to meet the growing and diverse communities we serve. Resolution No. 2020-____ Page 44 184 December 2019 9 MV Student Transportation MV Student Transportation, Inc (MVST) offers safe, reliable operation and maintenance of student transportation systems. We partner with educational institutions throughout the U.S. to provide a wide range of contracted services in a variety of academic settings. MVST provides standard home-to- school services and special needs services, extracurricular activity trips, and charter transportation services. MVST has contracts with public, private and charter schools and provides university shuttle services. MVST has been successful at providing excellent service quality, at substantial savings to our clients through effective cost control and service efficiency. MVST also provides routing expertise and assistance to our clients. Fleet Services MV's comprehensive and detailed approach to maintenance has resulted in higher fleet reliability and improved physical appearance in a number of operations for which we have assumed responsibility. MV invests significant resources in the training and support of our maintenance teams. We commit the time, resources and effort to ensure we exceed our customers’ expectations in this important area, a reason a number of the people have joined the MV. The majority of divisions of MV have a dedicated service and maintenance shop on-site to conduct vehicle maintenance. The shops are either owned by our clients or leased by MV Transportation. 1.9 Measures of Service Typical Modes of Service: Demand Response and Fixed Route Measure of Service Indicator Exposure  Fixed route  Public bus stops, shelters, transit centers owned and maintained by our clients.  Paratransit  Door-to-door, curb-to-curb, other  Multi-modal services  Special trip requests  Outside public domain  Charter  Other 1.10 Operations Resolution No. 2020-____ Page 45 185 December 2019 10 MV Transportation’s Operations Department includes Operations, Vehicle Maintenance and Safety & Training. Vehicle Maintenance The Vehicle Maintenance Group is responsible for the day-to-day revenue vehicle maintenance at our operating divisions. They also maintain support vehicles. There is more detailed information about this in Section 5. Safety & Training Group The Safety & Training Group supports the entire operation to ensure that workers are knowledgeable, skilled and always focused on safety. There is more detailed information about this in Section 4. 1.11 Scope of Services and Organizational Structure The MV Transportation system includes operation of paratransit vehicles, transit buses and a fleet of non-revenue support vehicles. These are explained in detail in Sections 3, 4 and 5. 1.12 Elements of MV Transportation’s Plan APTA recognizes 26 elements for a system safety program plan. MV Transportation’s plan includes all the elements, below in APTA’s order: Element 1: Policy Statement and Authority for System Safety Program Plan This is listed in Section 1.2 of SSPP. Element 2: Description of Purpose for System Safety Program Plan This is listed in Section 1.3 of SSPP. Element 3: Clearly Stated Goals for Bus Safety Management Program This is listed in Section 1.5 of SSPP. Element 4: Identifiable and Attainable Objectives This is listed in Section 1.6 of SSPP. Element 5: System Description This is listed in Section 2.1 of SSPP. Element 6: Control and Update Procedures This System Safety Plan will be reviewed every two years and updated as needed by the Senior Vice President of Safety & Training and the Executive Vice President of Risk Management in consultation with the Executive Safety Committee and senior management. Resolution No. 2020-____ Page 46 186 December 2019 11 The SSPP Committee, which is also called the Executive Safety Committee or ESC, will conduct reviews of all proposals for changes of the Plan. All proposed regulatory changes will be reviewed by the Committee and will be published as addenda to the SSPP. If system changes occur, the Senior Vice President of Safety & Training, the Executive Vice President of Risk Management, the ESC Chairperson and the Committee will ensure that any changes outside a scheduled SSPP review are incorporated into the SSPP. Change bulletins may be issued within the two-year period, provided they are properly authorized by the Committee and distributed through the company. The final decision of whether a change is issued as addenda or requires a revision and redistribution of the Plan lies with the Senior Vice President of Safety & Training, the Executive Vice President of Risk Management, ESC Committee Chairperson and the Committee. Element 7: Hazard Assessment, Recognition, Evaluation and Control Establish and maintain safe and healthful conditions by identifying hazards, evaluating their potential effects, developing ways to eliminate or control them and planning action priorities. MV Transportation will use numerous tools to recognize and evaluate hazards. Then, given the nature of the hazards identified, MV Transportation will take specific actions to control them. MV Transportation’s Safety and Training Group of the Operations Department is heavily involved in hazard evaluation and control. This group is responsible for conducting periodic occupational and operational inspections of facilities and equipment to identify hazards on a proactive basis. All MV Transportation employees are responsible for hazard identification and reporting any potential hazards to their supervisor. There is more information about this listed in Section 3.5. Element 8: Accident / Incident Reporting and Investigation This is listed in Section 4.3. Element 9: Facilities Inspections (Systems, Programs, Equipment and Rolling Stock) All operating facilities are subjected to periodic safety and maintenance programs inspections/audits to ensure compliance with Company policy and regulatory requirements. It is each division General Manager’s responsibility to ensure on-going inspections are conducted. It is the responsibility of each region’s Vice President to follow up on this audit task. Facility Inspections include monthly salf-inspections, annual facility audits, preventive maintenance inspections, annual fire inspections and insurance underwriter inspections. Our clients who are contracted to serve may also inspect the facilities. Typically, in many MV locations, the client or agency we serve owns the facility that MV Transportation uses to conduct its business. Resolution No. 2020-____ Page 47 187 December 2019 12 Annual Facility Audits – Each Operating Division is subject to a comprehensive audit by members of the MV Transportation maintenance and safety teams on an annual basis. Members of Operations will also support this process by performing and documenting a monthly facility self-inspection. Standard inspection forms and photographs are used to document the condition of all major components at each facility. Components include foundations, substructures, superstructures, exterior closures, roofing, doors, walls, floors, conveyors, plumbing, electrical and safety systems. These audits are used to prepare condition profiles that assist in planning and programming all maintenance repair and rehabilitation projects into annual budget plans. Preventive Maintenance Inspections – Each division operating facility has a scheduled PM program that ensures the facilities and their equipment are inspected and serviced based on the manufacturers’ recommendations. These inspections are performed by in-house staff and are typically on a quarterly basis. The client who may own the facility may incorporate additional inspection guidelines. Fire Safety Inspections – Each division is subjected to an unannounced fire inspection. These inspections are based on compliance with all City fire and life safety codes. Inspections are documented in the form of reports, with follow-up on any areas of identified weaknesses. These inspections should happen at least once a year. Insurance Inspections – Each division is subjected to a scheduled inspection by MV Transportation’s insurance provider on a recurring basis. Insurance inspectors conduct the inspections and provide written reports, documenting their findings and recommendations. In addition to the above scheduled inspections, various members of MV Transportation staff conduct daily walk-throughs at each division operating facility with a focus on safety. Transit Centers and bus stops in fixed route service also are subject to routine inspections focusing on the safety and security of the traveling public. The goal of each of these inspections is to provide MV Transportation employees, the clients we serve and the riding public with safe, reliable, high -quality service throughout the country at all of MV’s locations. External Audits – Audits of our safety procedures and systems at the Division and Corporate level shall be used as directed by the Sr. VP of Safety. Element 10: Maintenance Audits and Inspections MV Transportation’s safety compliance assessment involves the process of spot-checking maintenance documents such as DVI forms to find problems before they cause a negative situation. Each maintenance area performs internal inspections daily. There is more information in Maintenance Section 5.3. MV Transportation System Audits are covered in Section 8.2. Element 11: Rules and Procedures Review MV Transportation ensures that annual and biannual reviews and necessary revisions are performed for all safety rules/procedures or when a change in conditions may dictate such Resolution No. 2020-____ Page 48 188 December 2019 13 revisions. The Executive MV Transportation Safety Committee (ESC) must approve any exceptions to this procedure. The Chief Executive Officer, the Chief Operating Officer, the Executive Vice President of Risk Management and the Senior Vice President of Safety & Training must approve any exceptions to the Plan. The Committee will make necessary changes to the Plan in accordance with the Procedures for Plan Revision found in Section 2.2, Element 6: Control and Update Procedures. All safety rules and procedures in effect shall be reviewed and revised in accordance with any changes in all federal, state and local codes. Element 12: Training and Certification Review and Audit All MV Transportation training programs must be properly documented, regularly reviewed and updated as needed. Each training area must be reviewed a nd audited at least annually. All training will be reviewed to ensure it is being properly maintained and that employees are receiving required training. The MV Transportation Safety & Training Division oversees this function. There is more information in Section 4.3. Element 13: Emergency Response Planning, Coordination, and Training MV Transportation, in conjunction with its clients has developed emergency procedures, drill procedures and a drill schedule to conduct annual disaster and emergency response drills in each of its modes of transportation. Emergency procedures are available at each MV Transportation facility. These are covered in MV Transportation’s System Security and Emergency Preparedness Plan (SSEPP). Today’s safety and health programs must address risks beyond the organization’s walls. MV Transportation will develop contingency plans and “what-if” worst-case scenarios to plan for disasters, contractor activities and other liability exposures. These contingency plans will be practiced and modified as necessary to achieve optimum protection. MV Transportation will design and set up annual disaster and emergency training to ensure minimization of exposure. This is also covered in the SSEPP. All MV Transportation Bus Operators and Supervisors who are involved with the public must receive training in emergency operations and participate in emergency drills as part of their recurrent training. There is more information in Section 7.3. Element 14: Process for System Modification Review and Approval The SSPP was developed as a multidisciplinary document to identify, document and coordinate the safety efforts of all personnel and all business units. During the process, dozens of documents, guidelines, manuals, policies and procedures were identified that outline the specific safety activities of various work groups. These items are identified as Resource Documents and are maintained, in most cases, in the department to which they are related. Resolution No. 2020-____ Page 49 189 December 2019 14 As MV Transportation’s operations, facilities, business and legal environments change, it may be necessary to amend or add to this Plan. When such amendment or addition to the Plan is proposed, it will be presented to the Executive Safety Committee for review and analysis. Appropriate documentation, analysis and concurrence by all departments/divisions impacted by the change will be required prior to submittal to the Executive Safety Committee. If it is determined to be a necessary and prudent change, the approval of the appropriate division Vice President will be obtained before submittal to the President for final approval and adoption. Element 15: Safety Data Acquisition and Analysis MV Transportation’s safety professionals conduct proactive safety and health activities, including periodic inspections of facilities and other occupational health assessments. Other activities include record keeping, conducting injury/illness/incident investigations and performance reviews. MV Transportation safety professionals collect and analyze this data in order to identify patterns and make recommendations. Complete and accurate records are used to identify hazards as well as measure improvements in safety performance Communication of safety data is managed electronically and through commercially available software. MV Transportation continually reviews policies, procedures, standards, legislation and other activities designed to monitor and improve performance in safety. Element 16: Interdepartmental Coordination MV Transportation has continuing verbal and written communication procedures in place to ensure interdepartmental and interagency coordination is occurring. Use of the SSPP will help to achieve an open line of communication throughout the company and our clients. MV Transportation understands that its real assets are people, not machinery, and employees must recognize their stake in a safe and healthful workplace. Employees will be involved in planning, implementation and improvement. Solutions to safety and health problems will be solicited from affected employees. MV Transportation will ensure its employees contribute to safety and health objectives through safety committees and teams. The Safety & Training Group will also maintain a safety hotline on our internal website for all employees to use. Element 17: Configuration Management MV Transportation provides change control for its operations and those of its contractors through the System Design and Control Process described in Section 7.6 of this document. MV Transportation requires, as part of contract specifications, documentation in the form of operations manuals and “as-built” drawings for new acquisitions and overhauls of any owned vehicle rolling stock, system equipment and facilities. As required, certified and qualified vendor trainers also provide training to MV Transportation and its clients. There is more information in the Configuration Management Section 5.5. Resolution No. 2020-____ Page 50 190 December 2019 15 Element 18: Employee Safety Program and Training New and transferred employees must become familiar with company polic ies and client procedures and learn how to perform their jobs safely and efficiently. MV Transportation will use on-the-job, classroom and specialty training to contribute to a successful safety and health program. MV Transportation’s program will include hazard recognition, regulatory compliance and prevention. Training will be reinforced though regular follow-ups with both new and veteran employees. This document is also an integral part of the employee safety program. As part of its employee safety program, MV Transportation will use general approaches to motivate employees and stress the role that visible management leadership plays in changing unsafe or unhealthy behaviors and attitudes. MV Transportation uses three motivational techniques on a regular basis: communication, incentives/awards/recognition and employee feedback surveys. Effective communication within the organization keeps employees informed about policies, procedures, goals and progress. MV Transportation will spread the word about safety programs inside the company through the use of bulletin board notices, newsletters, meetings and other forums. Effective two-way communication between employees and managers is critical, as is publicizing safety information in the community, and these will become cornerstones of MV Transportation’s Safety and Health Programs. Safety and health considerations are also important when planning for and staffing the company’s work force. MV Transportation will research issues such as work safety rules, employee assistance programs and requirements resulting from the Americans with Disabilities Act. MV Transportation will comply with all laws and regulations, enhancing worker dignity, safety, health and productivity. Element 19: Hazardous Materials Plan MV Transportation has a Hazardous Materials Management Plan for divisions (still under development) that must use alternative fuels and hazardous materials as part of their client requirements. This information is designed to assist local area Fire Departments in the event of an emergency. This document names an emergency contact position and lists the types and locations of chemicals stored at the facility. Element 20: Drug and Alcohol Programs MV Transportation has an extensive drug and alcohol program in place. MV Transportation's program goes beyond FTA guidelines and has zero tolerance for substance misuse. There is more information in the Drug and Alcohol Section 7.8. Element 21: Contractor Safety Coordination All contractor employees working on MV Transportation property or client property must comply with all MV Transportation policies and procedures. If MV Transportation finds that the contractor is not complying with the above requirements, MV Transportation has the right to terminate contractor operations until full compliance is achieved. Resolution No. 2020-____ Page 51 191 December 2019 16 Element 22: 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 governing the specific equipment. MV Transportation’s Operations Department works closely with all parties involved in any procurement. Element 23: Alternative Fuels and Safety MV Transportation has had a successful history of using alternative fuel vehicles when required by our clients. As a result, any safety and regulatory initiatives required in the use of alternative fuels have been met and followed by MV Transportation employees in support of our client needs. We will continue to support the alternative fuel requirements of our clients on each individual contract. Element 24: Operating Environment and Environmental Compliance MV Transportation will ensure that its environmental compliance program covers compliance monitoring and contingency planning for emergencies. MV Transportation’s program will include environmental management incorporating pollution prevention, waste minimization and source reduction. MV Transportation will track and provide all necessary documentation to ensure compliance with local, state and federal guidelines. We will also meet individual client environmental requirements. Element 25: Security To emphasize the importance of security in all aspects of our organization, MV Transportation has established a set of security activities, which are documented in the System Security and Emergency Preparedness Plan (SSEPP). The overall goal of the Security Program is to maximize the level of security afforded to all of our passengers, employees and other individuals who come into contact with our services, as well as vehicles and division facilities. To ensure that the SSEPP is successfully implemented, the Senior Vice President of Safety & Training and the Presidents of each MV Transportation company have the responsibility to direct and oversee MV Transportation’s Security Program for the purpose of providing safe and secure transit services. The plan complies with the Transit System Security Program Plan Guide (FTA-MA-90-7001-94-1). Element 26: Internal Safety Audit Process (Assessments, Audits, and Evaluations) MV Transportation will use a variety of evaluative tools to meet the needs of the organization, including self-assessments and voluntary regulatory assessments. Numerous resources will be accessed for conducting assessments, audits and evaluations, including the company’s own internal staff. One such example is the periodic audits con ducted by our Regional Vice Presidents of their General Managers’ Divisions. Resolution No. 2020-____ Page 52 192 December 2019 17 1.13 Paratransit Van and Bus System Service MV Transportation provides paratransit and bus service to residents of more than 100 cities across the country. There is more information about MV Transportation’s services in Section 1.2. 1.14 Operations Operations is responsible for managing and providing all MV Transportation operated paratransit and bus service across the country. Some of the aspects of Operations include:  Provides paratransit and fixed route bus service for our clients across the country;  Leads and directs our operator and maintenance workforce;  Monitors service and the performance of Bus Operators to ensure that MV Transportation provides a safe, courteous, reliable and on time service for the riding public;  Provides evaluations of dial-a-ride service, routes, schedules, and facilities to determine the effectiveness of service and condition of amenities;  Makes route changes as needed at the request of our clients;  Coordinates two-way radio communication to all revenue and non-revenue vehicles, and receives and relays information to the proper sources to provide assistance and coordination for a smooth service delivery;  Monitors bus services; and  Coordinates special events planning and services in support of our clients. Safety Road Supervisors monitor service for safety, on-time performance, efficiency and compliance with operating rules. Ride checks also are performed periodically by Supervisors to monitor operator performance. Accident / Incident Investigation Supervisors conduct the initial investigation and serve as an on-the-scene coordinator, which involves securing witness statements, documenting evidence, etc. Operations coordinates with the Safety & Training Group on classification of all incidents concerning preventability. There is more information about this in Section 4.2. Driver's Licenses – Physical Examinations – Drug & Alcohol Policy Driver’s license checks are conducted periodically. Motor vehicle reports are pulled annually for violations. Employees who have motor vehicle violations/convictions, DWIs, license suspensions or any other activity in excess of what MV Transportation policy allows are referred to appropriate managers for action. This function is now managed by Risk management’s operator qualification group out of Elk Horn, Iowa. Resolution No. 2020-____ Page 53 193 December 2019 18 All employees receive a pre-employment drug test and are subject to random, post-accident, reasonable suspicion and return-to-work testing as defined in the MV Transportation Drug & Alcohol Policy. This program complies with all federal drug and alcohol testing laws and regulations for employees in safety-sensitive positions. The program is administered by the Human Resources Department. 1.15 Maintenance The Operations Maintenance Division responsibilities focus upon the maintenance and repair of MV Transportation equipment, rolling stock, and facilities. These responsibilities include:  Performing preventive maintenance inspections, corrective repairs, troubleshooting, campaigns and modifications, body shop repairs, vehicle servicing and cleaning of MV Transportation revenue and non-revenue rolling stock.  Performing preventive and corrective maintenance of all MV Transportation mobile and portable radios, electronic fareboxes, surveillance equipment and fixed-end communications equipment for bus and paratransit operations where applicable.  Maintaining and repairing operating facilities equipment, including all installed components and systems.  Developing and implementing training programs for mechanics, supervisors and other maintenance personnel.  Processing and administering all vehicle, equipment and facility warranties.  Reviewing and monitoring consumable goods and services for contractual compliance to technical specifications and quality standards.  Developing and implementing repair and maintenance procedures to ensure performance and service quality are optimized.  Developing specifications, procedures, and requirements for the purchase, maintenance, and improvement of vehicles, equipment and facilities.  Maintaining technical information related to the vehicles, equipment and facilities to ensure that assets are maintained in accordance with the manufacturers' recommended procedures.  Developing scope of work for construction and structural modifications to operating facilities and equipment performed through contractor liaison. Conducting oversight project management for operating facility and equipment modification construction contracts to ensure work is performed in accordance with engineering design specifications. 1.16 Systems Modifications Proposed modifications often result from system observations, inspections, data analyses, hazard reports, accident investigations and internal or external audits. Modifications may be proposed as a means of improving a system’s efficiency, maintainability and performance, or in order to eliminate or control hazards. Resolution No. 2020-____ Page 54 194 December 2019 19 MV Transportation has established a formal system review and approval process to ensure that modifications do not negatively impact safety. The methodology used in addressing system modifications includes control, testing and documentation (See paragraph 2.2, Element 17: Configuration Management). Resolution No. 2020-____ Page 55 195 December 2019 20 Section 2: Safety Activities - MV Transportation Executive Safety Committee 2.1 Introduction – Control and Update Procedures The CEO and COO have delegated responsibility for implementing the SSPP to the Senior Vice President of Safety & Training and Executive Vice President of Risk Management. The Senior Vice President of Safety & Training oversees the Operations Safety & Training Group, which in conjunction with the Risk Management Department monitors SSPP implementation and maintenance. The safety-related activities of the Executive Safety Committee (ESC) are described in this section. 2.2 ESC Description The MV Transportation Executive Safety Committee (ESC) will consist of Presidents, Vice Presidents, Directors and General Managers within the various departments and divisions of MV Transportation that have been identified as having a need to serve on the committee. The areas represented on this committee include Operations, Maintenance, Safety, Information Technology and Human Resources. The committee meets quarterly and is charged with reviewing and approving all company safety changes, affected system elements (facilities, equipment, etc.) and changes to the SSPP document. The committee members also are responsible for reporting information from their division safety subcommittees. 2.3 ESC Committee Chairperson and Chairperson Elect The MV Transportation Executive Safety Committee (ESC) elects the Chairperson by general election vote from the committee members (to be approved). The Committee Chairperson will serve in the role as Chairperson Elect for the period of one year before assuming the role of Chairperson. The Committee Chairperson is responsible for scheduling Committee meetings, preparing agendas, requesting assistance from nonmembers and distributing ESC reports. The Chairperson also is responsible for maintaining complete documentation of all ESC proceedings, including system modifications reviewed by the ESC. Responsibilities include providing administrative, coordination and analysis support for ESC activities. Reports from ESC members will be reviewed by the Chairperson to ensure that required system safety activities are carried out. Reports of the committee activities will be issued quarterly to MV Transportation management. The Chairperson will reside in their position for a period of one year. The Chairperson Elect w ill provide administrative support to the Committee Chairperson in their role. 2.4 ESC Member Responsibilities All members of the ESC are responsible for participating in ESC meetings and assisting in its activities, as requested by the Chair. During the scheduled ESC meetings, each member is to apprise the Committee of any system safety issues, including proposed system modifications involving his or her department. The members will also report on the level of compliance with system safety requirements, including those pertaining to inspections, tests, maintenance, certification, procurement, training, employee communication, accident and incident investigations and procedures. Resolution No. 2020-____ Page 56 196 December 2019 21 2.5 Methodology to Achieve SSPP Goals The methodology used in achieving SSPP goals and objectives involves having all MV Transportation personnel take into consideration the safety implications of their decisions and actions. It uses a proactive approach that stresses looking at systems and proposed modifications to these systems from a safety perspective before losses occur. The SSPP attempts to accomplish this through the following five steps: 1. Gaining an understanding of system functions and interrelationships among systems. 2. Identifying the critical elements and steps necessary to ensure that existing or planned systems achieve the desired level of safety. 3. Establishing a process in which management controls are used to ensure these safety critical elements and steps are consistently carried out. 4. Monitoring systems to ensure compliance with these requirements. 5. Improving the process by reviewing the effectiveness of management controls in achieving the desired level of safety, and modifying safety critical elements and steps on a continuing basis. While these five steps describe the methodology of the SSPP, they also can be used at any level of the organization as a means of maximizing the safety of all systems. The ESC has a role in executing the functions necessary to carry out this methodology, as do all departments and divisions. Specific safety-related tasks of the ESC are as follows:  Coordinate system safety activities of the company.  Meet to evaluate and resolve system safety issues that have not been resolved at the department level.  Conduct special meetings as necessary at the request of Executive Management.  Compile pertinent system safety data and perform analysis to identify and assess operational risk.  Assign its members, as well as other departments, tasks as necessary to address system safety issues.  Request other entities within the agency to provide system safety support, such as data acquisition and analyses, field and laboratory testing, experimentation, etc.  Assist in the investigation of accidents and incidents as appropriate or requested by Executive Management or an ESC member.  Review maintenance records and failure reports and analyses to identify safety problems related to maintenance activities.  Perform analyses to identify safety problems related to maintenance activities.  Evaluate proposed system modifications from a safety perspective.  Upon request, evaluate hazard resolutions proposed by other organizational units.  Use Committee consensus to develop hazard resolutions.  Bring feedback from department subcommittees back to ESC.  Report activities of the ESC to the MV Transportation Board as needed. Resolution No. 2020-____ Page 57 197 December 2019 22 2.6 Hazard Identification and Resolution Process (MIL - 882D) The process of identifying and resolving hazards in the system is based on the FTA and APTA’s adaptation of U.S. Military Standard MIL-882D. It involves three stages: Hazard Identification, Hazard Assessment and Hazard Resolution. A description of this process follows: 1. Hazard Identification Hazard identification is a process whereby an attempt is made to discover conditions in the system which, if not altered have the potential to cause accidents, injuries or other losses. All employees are charged with the responsibility of identifying and reporting conditions that have the potential to cause accidents, injuries or other losses. These conditions may be found in the form of physical hazards, unsafe actions, and policies that create or fail to recognize hazards. There also may be certain employees who, through periodic field observations, review of incident and complaint data, and performance and complaint records, are identified as needing special counseling, retraining or re-assignment. Potentially hazardous conditions also may be identified through other means, including those listed below: Reports from passengers and other individuals through contact with our client customer service, field personnel or management personnel.  Reports from operators and other field personnel regarding hazards associated with agency vehicles, schedules, routes, policies and procedures.  Reports from maintenance personnel regarding equipment and facilities maintenance hazards.  Investigation and review of accidents and incidents by safety personnel.  Collection and analysis of accident statistics and Risk Management information systems data regarding safety, accident rates and claims reports.  Safety audits performed by knowledgeable system personnel.  Information, experiences and ideas from support departments.  Observations of facilities and operations in the workplace, including offices, by agency personnel. Conditions that have been identified as hazardous or potentially hazardous are reported to the department head and the MV Transportation Executive Safety Committee (ESC). The report may be made verbally or by use of a Hazard ID Form. If the department has not been able to correct the condition within 30 days of receipt of the verbal or written report, the item is placed on the agenda of the next meeting of the ESC. 2. Hazard Assessment Hazard assessment involves determining whether assuming some or all of the risk associated with a particular hazard would be acceptable and whether corrective action is called for. It involves hazard severity, hazard probability and risk assessment. Resolution No. 2020-____ Page 58 198 December 2019 23 Hazard Severity Hazard severity is a subjective measure of the worst credible mishap that could be expected to result from human error, environmental conditions, design inadequacies, subsystem or component failure or malfunction, and/or procedural deficiencies. Using U.S. Military Standard MIL-882D, the ESC assigns one of four severity categories: Hazard Severity Table Category Description 1 – Catastrophic Death or system loss 2 – Critical Severe injury, severe occupational illness or major system damage 3 – Marginal Minor injury, occupational illness or system damage 4 – Negligible Less than minor injury, occupational illness or system damage Hazard Probability The likelihood that a hazard will be experienced during the planned life expectancy of the system can be estimated in potential occurrences per unit of time, events, population, items or activity. The probability may be derived from research, analysis and evaluation of historical safety data. Hazard probabilities are ranked as shown in the following table: Hazard Probability Table Probability Level Description A – Frequent Likely to occur frequently. Continually experienced in the fleet/inventory. B – Probable Likely to occur several times in life of an item. Likely to occur frequently in the fleet/inventory. C – Occasional Likely to occur sometime in life of an item. Likely to occur several times in the fleet/inventory. D – Remote Unlikely, but possible to occur in the life of an item. Reasonably expected in the fleet/inventory. E – Improbable So unlikely, occurrence is not expected. Unlikely to occur, but possible in the fleet/inventory. 2.7 Risk Assessment After assessment of the severity and probability of a hazard, key departments and the ESC will use a standard analysis. A determination will be made regarding acceptance of the risk or taking corrective action. Risk assessment issues of significant impact will be submitted to the CEO and the COO. This procedure also will be followed if there are issues where there is a lack of consensus by the department involved and the ESC. Resolution No. 2020-____ Page 59 199 December 2019 24 Risk Assessment Frequency/Severity Matrix Severity Frequency 1 Catastrophic 2 Critical 3 Marginal 4 Negligible A – Frequent 1/A 2/A 3/A 4/A B – Probable 1/B 2/B 3/B 4/B C – Occasional 1/C 2/C 3/C 4/C D – Remote 1/D 2/D 3/D 4/D E – Improbable 1/E 2/E 3/E 4/E Hazard Resolution After the risks are assessed, a plan is developed for resolution. There are essentially four choices in the hazard resolution process, as shown in the Hazard Resolution Table below. Hazard Resolution Table Severity / Frequency Resolution 1/A | 1/B | 1/C | 2/A | 2/B | 3/A | Unacceptable—correction required. 1/D | 2/C | 2/D | 3/B | 3/C | Unacceptable—correction may be required after review by CEO. 1/E | 2/E | 3/D | 3/E | 4/A | 4/B | Acceptable—with review by CEO. 4/C | 4/D | 4/E | Acceptable—without review. The following hierarchy is used to eliminate or control hazards in the system: Design for Minimum Risk. Provisions are made in all designs for the identification and elimination of hazards through appropriate safety design concepts, such as fail-safe designs and redundancy. If the identified hazards cannot be eliminated, they are controlled through reducing the risk to an acceptable level. Use of Safety Devices. Hazards that cannot be eliminated through design selection are reduced to an acceptable level of risk through the use of fixed, automatic or other protective safety design features or devices. The design provides for periodic functional checks of safety devices. Use of Warning Devices. When neither design nor safety devices can effectively control an identified hazard, devices are used to provide timely detection of the hazard and to generate adequate warning signals. The application of these devices shall be designed to minimize the probability of incorrect reaction to the warning by employees or other individuals. Provide Special Procedures. Where it is impossible to eliminate or adequately control hazards through design, safety devices or use of warning devices, procedures and training are used to control the hazard. Precautionary notation is standardized and safety -critical tasks require certification through completion of MV Transportation-approved training courses. Resolution No. 2020-____ Page 60 200 December 2019 25 When the ESC has reached a consensus, a recommendation is first presented to the Chief Operating Officer. After approval, it is presented to the CEO. The CEO may accept, modify or reject the recommendation. If modified or rejected, the ESC is called into session for further review and recommendation. Upon final approval of the CEO, the resolution is placed into the hands of the responsible department for implementation. 2.8 Follow-Up Follow-up of implemented resolutions is the responsibility of both the ESC and the involved department(s). Two primary methods are used:  Statistical Analyses. Careful review of safety data, such as accident reports, claims, customer complaints, etc., should continue for an acceptable time period after the implementation of a hazard resolution. Comparison of “before-and-after” statistics also can provide confirmation.  Audits. Auditing of the implementation resolution, including selective interviewing of involved parties, surveillance, blind studies and use of inspectors. If the resolution is not fulfilling the original objective or if implementation is inadequate, the ESC will be responsible for taking appropriate action. Resolution No. 2020-____ Page 61 201 December 2019 26 Section 3: Safety Activities: Risk Management, Safety & Training 3.1 Risk Management Department The Risk Management Department is responsible for the insurance program, claim management and third party contracts in MV Transportation. The Risk Management Department also oversees the company’s operator qualification files and maintains a file copy in Elk Horn, Iowa. 1. Insurance Program The purchase of commercial insurance is one of the risk-financing methods used by MV Transportation. The Risk Management Department is responsible for protecting the assets of the company through a systematic process of risk identification, assessment and evaluation of exposures and hazards that adversely affect members of the public, our employees and the company's property. 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. Risks that cannot be eliminated or reduced to an acceptable level require financing through one of the following Risk Management techniques:  Transfer of risk to third parties through contractual language and indemnification agreements;  Transfer of risk through the purchase of commercial insurance; or  Retention of risk through funded self-insurance programs. Inspections of MV Transportation division facilities and fleet are carried out periodically by representatives of Risk Management and/or the Safety & Training Group. 2. Claims Management The information developed during the administration of self-insured claims and their management provides information to MV Transportation on the causes and contributing factors as well as the frequency and severity of accidents. This information is used by Maintenance and Operations personnel to identify areas of focus for safety education and training. The Risk Management data analyst enters safety and loss information into the RM Information System (Risk Management), which provides accessible and understandable loss data useful in the hazard identification process. This data is transferred over to MV’s internal website for company management viewing. Liability and workers’ compensation reports are used in pinpointing critical safety concerns and areas in need of specific attention. Examples include losses by location/frequency, claims by type of injury, losses ranked by total cost, losses identified by cause and losses by division, department, location, route, etc. Resolution No. 2020-____ Page 62 202 December 2019 27 Reports are distributed to management for use in determining problem areas or to identify certain individuals in need of specialized training. The Systems Safety Section uses the reports to assist in analyzing safety trends and to monitor ongoing safety programs. 3. Employee Related Work Injuries Employees involved in a work-related accident are required to report the accident to a department supervisor, who documents the accident using state-approved reporting forms. The Claims Adjuster classifies the type of accident before incorporating the claim into the administrative process. MV Transportation has a formal return-to-work program, which encourages employees to return to work with restrictions in a modified duty assignment. Reducing the frequency and severity of industrial accidents, through training programs, procedural changes or implementation of safety devices, is the joint responsibility of Risk Management and the affected division. 4. Third Party Contracts The Risk Management Department reviews all contracts between MV Transportation and third parties to ensure that sub contractors have appropriate and adequate insurance coverage to protect the interests of MV Transportation, our employees and property, and members of our client that may be affected by the services provided by the sub contractor. Insurance requirements include, but are not limited to, general liability, workers’ compensation, auto liability and professional liability. MV Transportation requires Certificates of Insurance naming MV Transportation as additional insured be received and approved prior to the beginning of sub contracted work. 3.2 Operations Safety & Training Group The Operations Safety & Training Group is responsible for all safety and training activities in Bus and Paratransit Operations. Safety & Training is involved in Operations training program design and program implementation. Safety & Training is responsible for ensuring all training program needs in Operations are met and addressed. All new-hire bus operators are trained under Safety & Training’s tutelage. Safety & Training also works in partnership with Human Resources to ensure all special needs training is met for all Operations employees. Safety & Training also is responsible for all safety activities as they relate to Operations. This includes incident and injury reduction, employee health and welfare, and all safety- related aspects of public transportation. The Senior Vice President of Safety & Training is tasked with leading the MV Transportation Executive Safety Committee (ESC) and shares the SSPP oversight responsibilities with the Executive Vice President of Risk Management. Elections will occur in the future for new chairs of the committee. The committee chair position changes annually. There is more information about this in Section 3.2. Resolution No. 2020-____ Page 63 203 December 2019 28 1. Safety & Training Compliance Procedures The following outlines the policies and procedures of the Safety & Training Group, which reports through Operations. Operations Vehicle Incident Investigation Employees are required to immediately report and document incidents and injuries, no matter how slight. Bus Operators complete a written report on incidents and/or injuries occurring on or near the bus. These reports are to be filled out before leaving the incident scene. Supervisors from the division location involved are called to every incident and assist in controlling the incident scene, securing witness statements and performing the initial investigation. All incidents are reported to the company’s 24 hour hotline telephone number within a few minutes of occurring. If needed, an independent adjuster will be dispatched to the scene. Division Location Safety & Training Managers are notified of all incidents. Depending upon the severity of the incident, a Safety & Training Manager may be dispatched to the scene. Upon arrival, the Safety & Training Manager serves as the lead investigator at the incident scene. The Safety & Training Managers are trained and certified in Bus Accident Investigation by the Transportation Safety Institute (TSI). The Area Safety Managers are responsible for determining the classification of incidents as preventable or non preventable. This is done with the help and support of the division Safety & Training Manager. If the division location General Manager disagrees with the Area Safety Manager’s ruling, it is brought before the Senior Vice President of Safety & Training for the final determination. The final decision may be appealed by Bus Operators. The Vice Presidents of Safety & Training and Senior Vice President of Safety & Training review all appeals. If the incident is classified as preventable, the employee’s General Manager or his/her designee will conduct an evaluation and make a decision regarding the appropriate corrective or disciplinary action. Such decision will be made within 10 working days of rec eipt of notification on preventability. Guidelines for making these decisions are outlined in the MV Transportation Employee Handbook and Safety Culture Guide. Additional Incident Investigation Process for Operations The Road Supervisor is the first responder to investigate all reported incidents/accidents. Additional personnel may respond to provide investigative assistance depending on the severity, including an assigned independent adjuster. The on-duty claims adjuster will be notified of all incidents classified as major events through the 24 hour hotline. All incidents, no matter how minor, will be called in to the hotline immediately. A representative of senior management will respond to all fatality accidents and other catastrophic events. Emergency medical services will be requested for any injured parties via the division or client Dispatcher. The investigative team will coordinate its investigation with the investigating police agency and other MV Transportation personnel responding to the sce ne. The Resolution No. 2020-____ Page 64 204 December 2019 29 Supervisor also will ensure that all parties directly involved will be identified (including potential witnesses) and contact information secured. The Supervisor also will ensure that courtesy cards will be distributed and collected. The Supervisor will ensure that comprehensive scene photographs are taken and that a scene diagram is prepared. Key measurements also are to be recorded. If a Road Supervisor is unable to respond, the operator must use the supplied incident kit that he or she carries. The operator will also be responsible for taking pictures at the scene with the supplied camera in the kit. All MV Transportation personnel will be subject to a drug/alcohol screen in accordance with MV Transportation’s Zero Tolerance Policy. All MV Transportation vehicle operators involved in an incident will complete an Incident Report form while still at the scene. Documents, courtesy cards, photographic film, scene diagram and any other investigative material will be sent to MV Transportation’s Risk Management Claims Department. Copies also will be kept and held at the location division. The Risk Management Division will archive the file on any Incident Reports on all fatality incidents. The National Transportation Safety Board (NSTB) will be notified on all MV Transportation incidents meeting the reporting criteria. Safety Ride Checks Safety ride checks are used to monitor Bus and Van Operator safety-related performance, including speed, compliance with traffic regulations, vehicle handling and other safety- related factors. MV Transportation requires a ride check on each operator twice a year. Operators will be selected for targeted ride checks based on DriveCam history, customer complaints, accident history, disciplinary history, or at the request of management or client. 2. Training and Certification Programs Training programs designed to increase safety awareness are developed and taught by Safety & Training personnel. Training is used as a regular part of recurrent training as well as in response to specific problems identified in audits, safety check rides and statistical analyses. Types of training experiences include:  LLLC Defensive Driving Program: Mandatory training for all Bus and Van Operators that teaches defensive driving concepts behind-the-wheel.  Monthly Safety Meetings: Mandatory meetings attended by driving personnel where instruction is offered on safe driving techniques, accident avoidance, customer relations, radio usage and other safety-related topics.  Monthly Small Group Location Safety Meetings (LSC): In this version of the safety meeting, employees are invited in small groups for discussion and problem resolution with topics selected by the supervisor. An example of this is tool box safety meetings for mechanics.  Personal Emphasis Safety Training (PET): This training is custom-designed to address specific deficits in performance of employees. PET is accomplished with small groups of individuals, depending on the nature and severity of the identified safety problem(s). Resolution No. 2020-____ Page 65 205 December 2019 30 Identification is accomplished through audits, customer complaints, observation, or incident frequency.  Train-the-Trainer Behind-the-Wheel Instruction Courses: The Safety & Training Group teaches a train-the-trainer course for all company BTW instructors. All BTW instructors must be certified to instruct operators.  TSI Bus and Van Training Certification: All California BTW trainers must be certified by TSI’s train-the-trainer instruction course. This is a four day course taught by TSI certified instructors.  Other instructional events may include the use of safety videos played continuously in the ready rooms, DriveCam video counseling sessions, individual counseling during and after Safety Rides and Check Rides, and the following mandatory classes taught on an on-going basis to employees. Some of the classes currently taught to Bus Operators are Customer Relations & Conflict Resolution and the Ergometrics Passenger and Customer (START) Program. 3. Employee Safety Programs and Training The following outlines the Safety & Training Group’s responsibilities regarding employee safety programs and training:  Oversee Operations safety programs and activities;  Oversee MV Transportation safety training program;  Submit recommendations to Operations management to improve safety procedures and practices;  Review training programs and documentation to ensure personnel receive comprehensive training and testing in safety areas;  Ensure safety training for contractors and other non-MV Transportation personnel interfacing with sections of right of way in revenue service;  Conduct safety studies as directed by the Chief Operating Officer and Company Presidents;  Investigate reported hazards;  Review safety rules and procedures;  Develop and maintain statistical database for all Operations safety records;   Liaison with public safety agencies; and  Liaison with our clients we serve. 4. Maintenance Safety Committee The Maintenance Safety Committee, a management/worker group, will meet regularly to discuss bus and bus maintenance safety issues. Issues that cannot be resolved are elevated to the MV Transportation Executive Safety Committee. (This committee has not yet been established but will be in the near future.) Resolution No. 2020-____ Page 66 206 December 2019 31 Section 4: Safety Activities: Bus/van Transportation and Maintenance 4.1 Introduction Service at MV Transportation is controlled by the Operations Department, which provides both bus/van and vehicle maintenance service facilities. 4.2 Operations Department The Operations Department is responsible for providing all MV Transportation operated bus and van maintenance services. The functional areas of the department responsibilities are Bus Operations and Maintenance. 1. Safety Rules and Procedures The MV Transportation Employee Handbook defines rules and standard operating procedures and serves as the official handbook of MV Transportation for Bus and Van Operators. Safety rules in procedures are covered in complete detail in the new MV Transportation Safety Culture Guide (under development). 2. Safety Monitoring Operations Supervisors monitor bus and paratransit operations for safety, performance, efficiency and compliance with operating rules. Ride checks and on board evaluations are performed periodically by Road Supervisors and Safety & Training Managers to monitor operator performance. All operators must have at least two ride checks a year. 3. Accident / Incident Investigation A Road Supervisor conducts the initial investigation and serves as an On-Scene Coordinator to secure witness statements, document evidence, etc. The Division Safety Manager coordinates with the Area Safety Manager for investigation of preventability. Our Incident Reporting Policy insures consistency in reporting and follow through company wide. 4. Safety Awards The Operations Department conducts several award programs to encourage safe operating practices, including a National, Regional and Division Safe Operator Award consistent with the National Safety Council Safe Driver Award Program. Awards are given for 1, 5, 10, 15, 20, 25 years' safety record completion. A Professional Operator of the Year Award is also given at the division, region and national levels. A major criterion for this award is the avoidance of preventable accidents. MV Transportation is developing a short term Safety Award Program for Bus and Paratransit Operators. This short-term awards program recognizes operators that complete a quarter and year without preventable incidents. Resolution No. 2020-____ Page 67 207 December 2019 32 5. Drivers Licenses MVR checks are performed annually. Driver’s licenses’ are checked when operators check in with dispatch. 6. Substance Abuse Program Bus and Paratransit Van Operators receive a pre-employment drug test and are subject to random, probable cause and post-accident tests as defined in MV Transportation’s Drug and Alcohol Policy and Procedures and in compliance with federal drug and alcohol testing laws and regulations for transportation workers in safety-sensitive positions. 7. Maintenance Inspections State Safety Inspections – Some MV Transportation maintenance facilities have technicians who are certified as State Safety Inspectors where this is required by state law. These individuals carefully monitor the expiration dates of the safety inspection stickers throughout their respective fleets and assure that all safety inspections are performed and documented in a timely fashion. Preventive Maintenance Inspections (PMI) – All revenue, non-revenue and off-road support equipment is subject to scheduled Preventive Maintenance Inspection processes in accordance with the manufacturers’ guidelines. The inspection processes afford the opportunity to proactively assure that MV Transportation fleets are safe and well maintained. This is done to meet our client contractual guidelines. Post-Accident Quality Assurance Inspections – The Maintenance Division conducts formal post-accident inspections on MV Transportation vehicles when there is an indication that parts or vehicle system failure may have contributed to the accident. This is also supported by the Safety & Training Group. Damage estimates are reported to the Risk Management Department. 8. Safety-Related SOPs Maintenance personnel work with established safety-related SOPs, including Lock-Out/Tag- Out hazards materials and confined space procedures. Safety-related SOPs are developed by the Safety & Training Group in cooperation with the maintenance division and must be approved by management. 9. Safety Manual All maintenance employees will be issued our industrial safety manual (currently under development) applicable to the division to which they are assigned, through which they are instructed on the rules and regulations of MV Transportation shops that reflect the overall safety policies of the SSPP. The manual addresses the following concerns: personal injury, hazardous material handling, personal protective equipment, housekeeping, tools fire prevention, electrical (batteries) safety, welding, steam cleaning, painting, road calls and material handling. Resolution No. 2020-____ Page 68 208 December 2019 33 Employees must adhere to all standard procedures and posted signs and understand the safe practices and conditions of each job prior to starting the assignment. Questions regarding safety of maintenance personnel or MV Transportation property are referred to the employee’s immediate supervisor. 10. First Aid Supplies are maintained in all MV Transportation shops. Shift Supervisors are trained to follow specific procedures in case of employee injuries. Depending on the condition of the employees, the Shift Supervisor may either allow them to return to work after receiving on - site medical attention or have them transported to a medical facility. 11. Industrial Incident Investigation The Safety & Training Group investigates and reviews industrial incidents. When necessary, changes or additions to procedures, special communications or supplemental training are initiated to prevent future incidents. If identified hazards from this process are beyond the control of routine procedures, they are referred to the MV Transportation Executive Safety Committee (ESC). Any major incidents are also reported to the Chief Operating Officer, Region Presidents, RVPs, Vice Presidents of Safety & Training and the Senior Vice President of Safety & Training. 12. Equipment and Facility Inspection Daily inspections include equipment rooms, air compressors and AC units. Safety equipment, such as sprinkler systems, fire extinguishers and security alarms also are checked on schedules. Reports of hazards and inoperative equipment generate specific, prioritized work orders. Safety-related items are always top priority. If a safety-related, top-priority hazard requires a special order for parts or tools to correct the situation, special privileges exist for obtaining these items. 4.3 Interdepartmental Coordination as it Pertains to Operations This program plan formalizes the establishment of lines of safety communications between the Operations Safety & Training Group, the Risk Management Department and individuals designated as Safety Coordinators, or focal points in MV Transportation’s Divisions/Departments. The Safety Coordinators will be formally appointed and charged with the authority and responsibility to interface with on-site management. The person typically is the location or division Safety Manager. In each facility, a safety-trained and qualified employee will be assigned safety responsibilities including but not limited to:  Conducting and monitoring maintenance Toolbox Safety Meetings;  Assisting to verify adherence to safety policy and procedures;  Assisting the Safety Department in audits; Resolution No. 2020-____ Page 69 209 December 2019 34  Completing the MV Transportation hazard forms;  Functioning as a motivational safety force and an example for other employees in their department; and  Reporting findings to the MV Operations Safety Committee. 4.4 Configuration Management Configuration control procedures will be followed to assure that changes to facilities, hardware, and operating and support systems are not made without the review of the new configuration to ensure the modified system meets all approved safety standards. The Safety & Training Group of Operations will include elements of configuration control in the safety audits and reviews they conduct through the MV Transportation departments. The MV Transportation Maintenance Division also plays a key role in configuration management. It is responsible for all aspects of configuration management for revenue and non-revenue rolling stock. These responsibilities include:  New Bus Purchases – A Project Manager (PM) is assigned to each new bus procurement with a client. This is typically the GM assigned to that contract. The PM is responsible for coordinating, monitoring and controlling all aspects of the new contract and the ultimate equipment configuration. A formal review of MV Transportation’s technical specifications (usually provided by our client) is conducted in the manufacturing plant of each new bus contract to promote and assure full understanding of the required vehicular configuration. This is usually done in support of the client we serve. A first article vehicle is then produced, reviewed and approved as representative of all production vehicles to be built under the terms and conditions of the bus contract. MV Transportation Maintenance Inspectors may visit the manufacturing plant to monitor the contractor’s in-plant inspection and configuration management. Upon final inspection, release and acceptance by MV Transportation’s Maintenance division includes a post- delivery audit of the bus equipment and records to assure that the agreed-upon equipment configuration standards have been satisfied. MV Transportation’s Maintenance Team conducts formal audits of the pre- and post-delivery processes. Resolution No. 2020-____ Page 70 210 December 2019 35 Section 5: Other Organizational Units 5.1 Safety Activities: Other Organizational Units - Introduction General safety-related responsibilities for all MV Transportation personnel are as follows: 1. Department and Division Heads (Vice Presidents and Directors) Responsible for the safety of their departments and divisions, including employees, facilities, equipment, operations and services provided. 2. Operations General Managers Responsible for the safety of their divisions, including employees, facilities, equipment, operations and service provided. They are also responsible for evaluating and correcting hazards. 3. Supervisors This position is responsible for the safety of their units, including employees, facilities, equipment, operations and services under their supervision. 4. Employees All MV Transportation employees are responsible for working safely and following established rules, procedures, policies and safe work practices. All organizational units are responsible for Hazard Resolution as follows:  Maintain a hazard identification and reporting system in each division that encourages employees to communicate unsafe conditions to management;  Resolve hazards reported or identified through inspections, analyses, incident investigations, etc;  Use the process described in Chapter 3 for hazards and proposed system modifications as appropriate; and  Follow up to ensure corrective actions are completed in a timely manner. 5.2 Human Resources Department The Human Resources Department is responsible for recruiting, compensation, benefits, employee relations, equal employment opportunity, training and development. In addition, the department is responsible for:  Maintaining the drug and alcohol program;  Labor relations;  Uniform employee guidelines;  Conducting training courses to promote professional development and safety; and  Managing MV Transportation’s Drug and Alcohol Policy and Procedures, including the administration of the drug/alcohol testing program listed in Section 7.8. Resolution No. 2020-____ Page 71 211 December 2019 36 5.3 Business Development Department The Business Development Department is responsible for customer service, sales, advertising and marketing, audio/visual graphics, the Internet, promotional events and external communications. They are charged with finding and building new business for the company. The Department also plays a key role in providing safety-related information to our clients through advertising, fliers, posters and the news media. Dissemination of information to the news media includes providing details regarding accidents or safety-related incidents. The safety aspects of MV Transportation’s operations are a major part of the Business Development Department’s advertising and public information materials. The availability of MV Transportation’s services and how to use them are topics explained in fliers, brochures and other publications. The Department helps coordinate public education efforts regarding safety around MV Transportation’s services for the clients we serve. 5.4 Legal Issues The Risk Management department works with our insurers to defend MV Transportation against all tort and workers’ compensation claims and defends MV Transportation in other areas. Some of Risk Management’s legal coverage issues include:  Monitoring legislation, regulatory and case information in order to ensure that MV Transportation’s procedures are compliant.  Notifying department Vice Presidents, Directors and Managers when liability or safety issues are identified in the course of case investigation or litigation.  Reviewing contract language in the use of subcontractors for our clients. 5.5 Procurement Handled by the Operations Department Operational and passenger safety are the highest priorities when defining vehicle 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 governing the specific equipment in effect at the time. 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 purchasing process begins with the preparation of a request that is submitted to Operations management. Advance planning includes considering safety, technical, business, management, and other issues in controlling acquisition from inception to completion. The Procurement area of Operations works in conjunction with the Operations Safety & Training Group when purchasing personal protective equipment for employees, controlling chemicals and other hazards in the workplace, mandating safety requirements in speci fic Resolution No. 2020-____ Page 72 212 December 2019 37 contracts and requiring compliance from specific vendors and clients with MV Transportation’s safety requirements. Operations requires the vendor to attach a Material Safety Data Sheet (MSDS) with each hazardous chemical shipment in order for it to be accepted into our shops. Each maintenance facility must have an approved chemical inventory list available for employees with the Hazard Communication information containing MSDS sheets. The Maintenance Division of Operations has a process of visually inspecting select parts, components and materials. Some of the responsibilities include:  Ensuring procurement process complies with established procedures for evaluating materials and products for use by MV Transportation;  Developing, maintaining, and utilizing a list of hazardous materials and equipment;  Enforcing procurement restrictions and other procurement procedures;  Adhering to safety procedures related to hazardous substance acquisition, handling, labeling, storage, disposal and record keeping; and  Ensuring that sub contractors meet requirements related to the safety of MV Transportation employees and property, and the public. Safety-Related Procurement Tasks Include:  Establishing and maintaining a standard procedure for evaluation of all potentially hazardous materials with safety department personnel;  Including safety performance standards on equipment specifications;  Establishing procedures that require safety department coordination for identification and purchase of safety-critical/hazardous materials;  Annually reviewing inventory requirements for defined safety-critical items;  Reviewing and coordinating with Risk Management and Operations Safety & Training as required for each proposed contract to determine any safety implications, including whether safety performance standards should be specified;  Assigning responsibility for monitoring the safety provisions of each contract to the project manager/contracting officer, who will coordinate with Operations Safety & Training Group;  Assigning responsibility for monitoring storage safety by inspecting housekeeping standards to identify slip, trip and fall hazards to improve the work environment. 5.6 Information Technology Department The Information Technology (IT) Department is responsible for Application Development and Maintenance, Database Administration, Computer Operations, Local and Wide Area Networks, Office Automation, Telecommunications, Budgets and Procurement, Data Security, and Computer Inventory and Asset Management. Also, the IT Department is responsible for maintaining and updating the IT Recovery Plan that provides procedures and instructions for dealing with emergency computer failure situations affecting MV Transportation data center operations. Resolution No. 2020-____ Page 73 213 December 2019 38 Section 6: Required Safety Doctrines 6.1 Understanding The creation and maintenance of a safe and healthy working environment and the use of safe methods, practices and procedures are important objectives of MV Transportation. It is management’s aim to see that our operations are conducted in a manner that will not endanger the well being of our employees, patrons, community or the public. Several written programs address safety requirements for all MV Transportation employees. The following section outlines the major safety initiatives and the referenced documents used to manage and maintain safe MV Transportation operations. A majority of the safety requirements for all employees can be found in the Industrial Safety Program (still being developed) and Employee Handbook. 6.2 Safety Training This is listed throughout the SSPP under the various departments and divisions. 6.3 Fire Protection Auditing of compliance to fire protection requirements will be accomplished through the use of emergency drills, inspections, incident investigations and periodic testing of fire protection and fire suppression systems. Training activities will be monitored for content and accomplishment. Fire protection and life safety requirements for MV Transportation Operations in all modes of Transportation will be coordinated with the jurisdictional Fire Departments and County Fire Marshall’s Office, emergency medical services and disaster preparedness groups. This will be in support of our division locations’ client needs. Agreements/Arrangements Arrangements on fire and life safety equipment and procedures will be prepared by MV Transportation and approved by jurisdictional fire departments. This is also covered in our SSEPP (see below). 6.4 System Security and Emergency Preparedness Plan (SSEPP) MV Transportation’s System Security and Emergency Preparedness Plan provides a source of information outlining the overall policies to be used in implementing emergency operating procedures to ensure the safety of passengers, employees and fire/rescue personnel during emergencies involving MV Transportation client systems. The System Security and Emergency Preparedness Plan (SSEP) covers MV Transportation facilities, employees, sub contractors and guests. The SSEPP also covers issues associated with the public, terrorist activities and other bus emergencies. These plans ensure:  Notification by MV Transportation of an emergency condition;  Response of fire/rescue emergency services; and  On-scene command and control and specific actions in an emergency situation. This information is contained in more detail in the MV Transportation System Security and Emergency Preparedness Plan (SSEPP). Resolution No. 2020-____ Page 74 214 December 2019 39 Inspections and Investigations All new facilities will undergo pre-acceptance inspection by the Safety & Training Group to ensure compliance with applicable codes and ordinances. This is typically performed by an Area Safety Manager (ASM). Current operational facilities and systems receive a formal fire and safety inspection once a year by MV Transportation Safety personnel through our annual facility audits. Incidents involving equipment, vehicles and facilities will be investigated in conjunction with local fire departments and other appropriate agencies. The Risk Management Department also coordinates and schedules annual loss-control inspections by insurance company representatives. All fire suppression systems undergo annual maintenance with the support of our clients. 6.5 Hazard Communication (HAZCOM) MV Transportation has an ongoing Hazard Communication Program, which is taught to all new employees who work with or could be exposed to chemicals in their work environment. All affected employees also receive annual training. The program is designed to inform employees about the following: 1. The “Right to Know” Laws; 2. Workplace chemical lists; 3. How to read and interpret information on Labeling systems; 4. How to read and interpret information on Material Safety Data Sheets (MSDSs); 5. Physical and health hazards in the workplace; 6. Protective measures, specific work procedures and personal protective equipment; and 7. Methods and observations to detect the presence or release of a hazardous material. 6.6 Lock-out/Tag-out MV Transportation has developed Energy Control Procedures also known as Lock- out/Tag-out Procedures. Training for these procedures is conducted initially for new employees and annually for existing employees. The written procedures outline the following: Basic rules for using lockout and tag-out procedures; 1. Sequence of lock-out and tag-out system procedures; 2. Restoring machines or equipment to normal production operations; and 3. Procedures involving more than one person. Details of the Energy Control Procedures can be found in the Maintenance Safety Work Rules of the Industrial Safety Maintenance Manual (still in development). 6.7 Environmental Management Program From the identification of a transit need through the stages of project design, initiation and operation, environmental safety and compliance are primary considerations. MV Transportation uses a multidisciplinary approach to environmental safety and compliance that supports all aspects of existing operations as well as the future. MV Transportation is Resolution No. 2020-____ Page 75 215 December 2019 40 committed to the principles and practices of environmental responsibility and strives to make decisions that are based on an understanding of environmental consequences and to take actions that protect, restore and enhance the environment. 6.8 Drug and Alcohol Program MV Transportation has adopted a comprehensive drug and alcohol policy. As mentioned in the Human Resources Section 6.2, the Human Resources Drug & Alcohol Manager is responsible for administering this program. MV Transportation developed its drug and alcohol misuse program to promote the safety of its patrons and employees by encouraging a drug-free workplace and by undertaking affirmative measures to deter and detect the use of illegal drugs and alcohol misuse in the workplace. 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 are intended to accomplish the objectives of those regulations. The policy identifies employees subject to testing, testing requirements, prohibited behavior, consequences of positive results and resources for employee assistance and rehabilitation. MV Transportation also has extended the policy beyond FTA guidelines to Zero Tolerance. 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. Covered Employees All employees who perform safety-sensitive functions for MV Transportation are subject to the drug and alcohol testing provisions set forth in the FTA regulations. The four categories of safety-sensitive functions are as follows: Brief Description 1. Revenue Vehicle Operations (in or out of service) 2. Revenue Vehicle & Equipment Maintenance 3. Revenue Vehicle Control/Dispatch 4. CDL/Non-Revenue Vehicle Operations Resolution No. 2020-____ Page 76 216 December 2019 41 Circumstances for Testing FTA requires that drug tests be given to safety-sensitive employees in the following circumstances: 1. Pre-employment (new hires/employees transferring from non-safety-sensitive functions to safety-sensitive functions and employees who have not performed a safety-sensitive function for 90 consecutive days (regardless of reason) 2. Reasonable suspicion 3. Post-accident 4. Random 6.9 New Systems Design and Control Safety Procedures Verification of compliance with safety requirements contained in the specifications is accomplished by using coordinated reviews of contractual documentation, system design reviews, assessment of failure modes and criticality analyses, fault-free analysis and preparation of test results. During this verification effort, adherence to configuration control and other appropriate management procedures also are assessed. Procurement of new systems such as facilities, equipment, buses, vans and non-revenue vehicles will include safety requirements in specifications, design reviews, testing, configuration control and periodic safety evaluations. Most of the time, MV Transportation will procure equipment at the request of our clients we serve. 1. New Systems User Requirements It is the responsibility of the department drafting the specifications for the equipment, system or facility to assure that safety requirements are included in procurement specifications. Requirements for safety review of new systems or system modifications are included in a subsection of this plan. Consideration is given to the following:  Compatibility with the safety features, design and procedures of existing MV Transportation systems usually taken over at the request of our clients;  Initial staff training for new systems and new divisions;  Avoidance, elimination or reduction of identified safety hazards by design change, safety devices and parts or materials selection;  Location of equipment components so that access by personnel during operation, maintenance, repair or adjustment activities do not require exposure to hazards such as electrical shocks, burns, sharp edges or points and dangerous or toxic materials;  Design to minimize severe damage to equipment or injury to personnel in the event of an incident; and  Provision of suitable warning and caution notes in instruction for operation, assembly, maintenance and repair, and distinctive markings for personnel protection on hazardous components, equipment and facilities. Resolution No. 2020-____ Page 77 217 December 2019 42 2. New Systems Safety Design Review Safety design reviews are an integral part of all acquisition processes for MV Transportation facilities, systems and equipment. Safety design reviews must be conducted to assess the compliance of facility or equipment design with specified safety requirements and to ensure that the safety of existing MV Transportation equipment is not degraded by the addition of new divisions, facilities or equipment. Safety reviews are normally carried out as an integral part of MV Transportation’s Operations pre service inspections. 3. New Systems Specifications Basic safety and user requirements will be included in procurement specifications and coordinated with appropriate staff. As a new facility, new division, system or equipment change specifications are proposed, responding sub contractors will be required to resolve hazards in accordance with MV Transportation-established order of precedence:  Design for minimum hazard. The major effort during the design phase of a contract is to select appropriate safety design features such as fail-safe and redundancy.  Safety Devices. Hazards that cannot be eliminated through design must be reduced to an acceptable level through the use of appropriate safety devices.  Warning Devices. Where it is not possible to preclude the existence or occurrence of a hazard, devices must be employed for the timely detection of the condition and the generation of an adequate warning signal.  Special Procedure. Wherever it is not possible to reduce the magnitude of an existing or potential hazard through design or the use of safety and warning devices, the development of special procedures to control the hazard is required. Subcontractors who provide systems, subsystems or equipment that affect safe movement of vehicles (Bus, Van, and other services) or passenger/employee safety are requir ed to establish and maintain a Safety Program in accordance with MV Transportation that defines objectives, tasks, procedures, schedules and data submittals for the safety activities that will be performed by the subcontractor. Acceptance testing must include procedures that assess compliance with the safety requirements of the procurement specification during Substantial Completion. 4. New Systems Acceptance Testing and Inspection Inspections of new facilities and installation of equipment upon completion of acceptance testing and inspection. 5. New Systems Configuration Management Configuration Management requirements will be included in major contracts to assure that changes to the design of equipment and facilities are adequately documented and approved by MV Transportation. Resolution No. 2020-____ Page 78 218 December 2019 43 6. Construction Safety Plan This defines construction safety functions and responsibilities and other construction safety requirements such as safety equipment, documentation and safety personnel. All subcontractors working for MV Transportation employees should comply by submitting and having a Construction Safety Plan. 7. Drug-free and Alcohol-free Workplace Policy All MV Transportation sub contractor personnel in safety-sensitive positions must comply with this policy. Resolution No. 2020-____ Page 79 219 December 2019 44 Section 7: Updates, Audits and Regulatory Agencies 7.1 Implementation / Revisions 1. Updates The SSPP will be updated every two years or upon demand if warranted. The MV Transportation Executive Safety Committee (ESC) will take prime responsibility for implementation of any revisions. The ESC also will assess the effectiveness of the SSPP, develop and propose changes and solicit internal and external review. Events which may require revision include the following:  Service changes;  New or retrofitted equipment or vehicles;  New facilities;  Organizational changes and reassignment of functions; and/or  Changes in safety policies, goals and objectives. The assigned Document Control person of the Executive Committee will distribute controlled copies of revised pages, and recipients will return confirmation of receipt. Revision pages will include a revision number and date of applicability. 2. Audits An Internal Safety and Audit Program will be established and audits performed by the Systems Safety Section to measure the effectiveness of the SSPP in achieving the objectives of the plan and compliance with its requirements. Program activities include the following:  Ensuring adequate on-the-job safety surveillance during system maintenance, operation and modification;  Determining compliance with management safety policies as contained in the SSPP;  Determining compliance with operating rules, regulations, standards, codes and procedures;  Recommending specific corrective action plans to eliminate or minimize the effects of any deviations from compliance. 3. Audit Responsibilities Regional Vice Presidents (RVP) and General Managers will be responsible for conducting the audits with the help of the Operations Safety & Training Group. Safety & Training help provide the independent nature of the audit process as other organizational units are primarily involved with implementation of the audit items. Other organizational units are required to cooperate with the audit. Resolution No. 2020-____ Page 80 220 December 2019 45 4. Audit Schedule Audits will be announced in advance by the CEO or COO to ensure the full support and participation of each department. An audit of a division will be conducted at a minimum of every two years. The audit may include the use of unannounced inspections and spot audits as determined by the CEO or COO, Region Presidents, RVP’s and the MV Transportation Executive Safety Committee. 5. Audit Content The following functions will be addressed in the audit:  Facility inspections;  Maintenance audits and inspections;  Manpower and staffing;  Rules and procedures;  Training and certification;  Emergency response planning, coordination and training;  Safety data acquisition and analysis;  Interdepartmental and interagency coordination;  Configuration management;  Employee safety programs;  Hazard materials programs;  Drug and alcohol abuse programs; and  Procurement. A list of specific items to be audited will be developed in advance, including checklists that address both quantitative and qualitative aspects of performance. Organizational units will be given time to produce documentation related to checklist terms. 6. Follow-Up/Action Plans Departments and other organizational units are responsible for implementing their respective approved recommendations and action plans within the established time frames. 7. Documentation The Safety & Training Group, Operations and IT through MV’s internal website will maintain audit documentation, including reports to the CEO, COO, Region Presidents and Region Vice Presidents and to individual divisions or departments. 8. External Safety Audits Periodic external audits may be required by local, state and federal agencies. The General Manager of the corresponding division will coordinate the scheduling of such audits. Resolution No. 2020-____ Page 81 221 December 2019 46 7.2 Regulatory Agencies The following are the major local, state and federal agency interfaces that affect safety for MV Transportation: 1. Local Regulatory Agencies The local interfaces are specified with all member clients and cites regarding operations, maintenance, and emergency planning and response activities. 2. State Regulatory Agencies The individual states are responsible for developing and enforcing environmental regulations regarding air, water and noise pollution and hazardous materials regulations. MV Transportation will comply with each states needs. 3. Federal Regulatory Agencies The Department of Transportation (DOT) issues regulations affecting transit operations including those related to the Americans with Disabilities Act (ADA) and drug/alcohol testing of employees. The Federal Transit Authority (FTA), an agency of DOT that is responsible for federal funding (capital and operating) of transit authorities and oversight of those expenditures. The FTA also compiles safety data on all transit agencies. The Occupational Safety and Health Administration (OSHA) is responsible for developing and enforcing federal regulations related to workplace safety, including maintenance shops, offices and field activities which serve as guidelines to the MV Transportation operations. MV Transportation is regulated by OSHA and is required to follow OSHA guidelines and all standards incorporated by reference in the Code of Federal Regulations. The Environmental Protection Agency (EPA) is responsible for developing and enforcing federal regulation related to air, water and noise pollution and hazardous materials regulation. The National Transportation Safety Board (NTSB) is an independent federal agency responsible for investigating transportation accidents and making recommendations to prevent similar accidents from occurring. Resolution No. 2020-____ Page 82 222