HomeMy WebLinkAboutAGENDA REPORT 2025 1105 CC REG ITEM 10HCITY OF MOORPARK, CALIFORNIA
City Council Meeting
of November 5, 2025
ACTION ADOPTED RESOLUTION NO.
2025-4363. (ROLL CALL VOTE:
UNANIMOUS)
BY A. Hurtado.
H. Consider Resolution Approving Updates to Moorpark City Transit’s Public
Transportation Agency Safety Plan (PTASP) and Rescinding Resolution No. 2022-
4120. Staff Recommendation: Adopt Resolution No. 2025-4363 Approving
Updates to Moorpark City Transit’s Public Transportation Agency Safety Plan and
Rescinding Resolution No. 2022-4120. (Staff: Michelle Woomer, Senior
Management Analyst) (ROLL CALL VOTE REQUIRED)
Item: 10.H.
MOORPARK CITY COUNCIL
AGENDA REPORT
TO: Honorable City Council
FROM: Daniel Kim, City Engineer/Public Works Director
BY: Michelle Woomer, Senior Management Analyst
DATE: 11/05/2025 Regular Meeting
SUBJECT: Consider Resolution Approving Updates to Moorpark City Transit’s
Public Transportation Agency Safety Plan (PTASP) and Rescinding
Resolution No. 2022-4120
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 (PTASP) as authorized by the Moving Ahead for
Progress in the 21st Century Act (MAP-21) required states and certain operators of public
transportation systems to develop PTASPs. The PTASP is based on the Safety
Management System (SMS) approach. The City approved its first PTASP on
December 2, 2020, with Resolution No. 2020-3976. The PTASP identifies best practices
and safety performance targets for fatalities, injuries, safety events, and system reliability,
and is intended to ensure that the City’s transit operations function in a safe manner. The
City is required to perform an annual review of the PTASP and update as necessary.
DISCUSSION
Staff has reviewed the PTASP previously approved on July 2 0, 2022, and made the
following updates:
• Updated Section 1: Transit Agency Information
o Name and title of Accountable Executive from previous City Manager
name to the current City Manager.
o Modes of Service to include City’s micro-transit service.
• Updated Section 3: Safety Performance Targets
o Updated the data in the Safety Performance Target chart’s System
Reliability column to reflect a rolling average of the last three years of MCT’s
safety performance data.
Item: 10.H.
257
Honorable City Council
11/05/2025 Regular Meeting
Page 2
o Included subsection on Assault on a Transit Worker/Driver regarding the
City’s zero tolerance for any assaults on transit workers/drivers and
mitigation measures in place to avoid these types of incidents.
The PTASP ensures continued eligibility for FTA funding and demonstrates the City’s
commitment to safety and compliance. The City receives an average of $400,000
annually in FTA funding for the City’s transit services. It should be noted that participating
in the PTASP is a requirement of future FTA funding.
The proposed Resolution (attached) provides approval of the updates to the City’s PTASP
and rescinds Resolution No. 2022-4120 (which approved the 2022 PTASP).
ENVIRONMENTAL DETERMINATION
This action is exempt from the California Environmental Quality Act (CEQA) as it does
not constitute a project which has a potential for resulting in a physical change to the
environment, as defined by section 15378 of the State CEQA Guidelines. Therefore, no
environmental review is required.
FISCAL IMPACT
There is no financial impact resulting from approval of this item.
COUNCIL GOAL COMPLIANCE
This action does not support a current strategic directive.
Safety Performance Targets
Mode of Fatalities Fatal iitlies Injuri es Inj uri es Safety Safety Syst em
Transit (Total) IRate {Total) Rate Events Events Rel iability
{per (per (Total) Rate (Mea n
1001k took [per distance
VRM) VIRM) took between
VRM) Maj or
Mec.-h anical
Fa ilures)
100,000-
Fiixed Route 0 0% 0 0.0 1 0 .01 0 .0 1 1 20,000
VRM
ADA/Paratira ns it 0 0% 0 0.0 1 0 .. 01 0 .0 1 80,000 V RM
1 i c ro-tr a nsi t 0 0% 0 0.01 0.01 0 ,0 1 60,000-
80,000 V RM
258
Honorable City Council
11/05/2025 Regular Meeting
Page 3
STAFF RECOMMENDATION (ROLL CALL VOTE REQUIRED)
Adopt Resolution No. 2025-_____ Approving Updates to Moorpark City Transit’s Public
Transit Agency Safety Plan and Rescinding Resolution No. 2022-4120.
Attachment: Draft Resolution No. 2025-____: 2025 Moorpark City Transit Public Transit
Agency Safety Plan
259
ATTACHMENT
RESOLUTION NO. 2025-_____
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
MOORPARK, CALIFORNIA, APPROVING UPDATES TO
MOORPARK CITY TRANSIT’S PUBLIC TRANSPORTATION
AGENCY SAFETY PLAN AND RESCINDING RESOLUTION
NO. 2022-4120
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, City Council adopted Resolution No. 2020-3976 at their regular
meeting of December 2, 2020, approving the local PTASP for purposes of compliance
with the above stated regulations; and
WHEREAS, as part of the annual review updates to the PTASP have been
provided as identified in Exhibit A to this Resolution.
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 hereby 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 annual review as 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 5th day of November, 2025.
________________________________
Chris R. Enegren, Mayor
ATTEST:
___________________________________
Ky Spangler, City Clerk
Exhibit A – Moorpark City Transit 2025 Public Transportation Agency Safety Plan
260
EXHIBIT A
Public
Transportation
Agency Safety Plan
City of Moorpark
323 Science Drive
Moorpark, CA 93021
Adopted December 2, 2020
Updated November 5, 2025
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TABLE OF CONTENTS
Definitions ................................................................................................................................ 2
Section 1: Transit Agency Information ................................................................................... 5
Section 2: Plan Development, Approval, and Updates .......................................................... 6
Section 3: Safety Performance Targets (SPTs) ...................................................................... 8
Section 4: Overview of the Agency’s Safety Management Systems (SMS) ......................... 9
Section 5: Safety Risk Management ......................................................................................10
Subsection 5.1 Safety Management Policy Statement .........................................................10
Subsection 5.2 Safety Management Policy Communication ...............................................10
Subsection 5.3 Employee Safety Reporting Program ..........................................................11
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…………………………………………………………… .................... 23
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Definitions
The City of Moorpark incorporates all of FTA’s definitions that are in 49 CFR 673.5 of the Public
Transportation Agency Safety Plan Regulation.
Accident means an Event that involves any of the following: a loss of life; a report of a serious
injury to a person; a collision of public transportation vehicles; 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 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.
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.
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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.
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.
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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.
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Section 1: Transit Agency Information
Transit Agency Name
Moorpark City Transit
Transit Agency Address
323 Science Dr., Moorpark, CA 93021
Name and Title of
Accountable Executive
PJ Gagajena, City Manager
Name of Chief Safety
Officer or SMS
Executive
Michelle Woomer, Senior Management Analyst
Mode(s) of Service
Covered by This Plan
Fixed Route, Paratransit, and
Micro-transit
List All FTA
Funding Types
9e.g., 5307,
5310, 5311)
5307, 5310
Mode(s) of Service
Provided by the Transit
Agency (Directly
operated or contracted
service)
Fixed Route and Paratransit (Operated by City of Thousand
Oaks; which has a contract with MV Transit); Micro-transit
(Operated by First Transit which was acquired by Transdev in
2023)
Does the agency
provide transit services
on behalf of another
transit agency or entity?
Yes
No Description of
Arrangement(s)
Not
Applicable
Name and Address of
Transit Agency(ies) or
Entity(ies) for Which
Service is Provided
Not Applicable
IR]
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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
11/05/2025
Relevant Documentation (Title and Location)
City of Moorpark City Council Agenda Item 10.F dated 12/02/2020 –
Resolution No. 2020-3976
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
2 Pages 6, 8, 13,
19, 20
Position Updates/System
Reliability Updates 07/21/2021
3 Pages 8, 13,
19
Position Updates/System
Reliability Updates 7/20/2022
4 Sections 1 & 3 Position Updates; updated
Safety Performance Targets 11/05/2025
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Plan Review and Updates
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.
This plan may need to be reviewed and updated more frequently based on the following:
• We determine our approach to mitigating safety deficiencies is ineffective;
• We make significant changes to service delivery;
• We introduce new processes or procedures that may impact safety;
• We change or re-prioritize resources available to support SMS;
• We significantly change our organizational structure.
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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 0.01 0.01
100,000-
120,000
VRM
ADA/Paratransit
0 0% 0 0.01 0.01 0.01 80,000 VRM
Micro-transit 0 0% 0 0.01 0.01 0.01 60,000-
80,000 VRM
Assault on a Transit Worker/Driver
The City has zero tolerance for any assaults on transit workers/drivers. The City’s transit
operators conduct an annual safety risk assessment in which the safety risk rating for this
category was green, low risk of occurring, and low severity of consequence. Several mitigating
measures are already in place, (video camera and sound, two-way radio communications,
agency works with local police, monthly safety meetings and defusing conflict
training/techniques).
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If a worker/driver experience an assault, a near miss, or unsafe act/condition, they are to
immediately report the incident to management and fill out an incident report. Management will
take appropriate action regarding: an investigation, the employee’s wellbeing and the assailant
as applicable. There is an open-door policy, and employees are encouraged to speak up
regarding any event, employees will face no negative action for voicing any concern.
MCT Transit Worker Assault Event Rate per 100,000 VRM (vehicle revenue miles)
2024 2023
Fixed Route Bus 0 0
ADA/Paratransit 0 0
Micro-transit 0 0
Safety Performance Target Coordination
FTA requires Caltrans to coordinate with FTA Region 9 and 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 and
VCTC on an annual basis.
Section 4: Overview of the Agency’s Safety Management Systems (SMS)
The City of Moorpark implements a comprehensive Safety Management System (SMS) as the
foundation of its Public Transportation Agency Safety Plan. The SMS provides a structured
framework for managing safety risk and ensuring continuous improvement across all transit
operations. It establishes clear lines of safety accountability, proactive hazard identification, and
data-driven decision-making to reduce the likelihood and severity of safety events.
Moorpark City Transit’s SMS integrates both contracted operators—MV Transportation (Fixed
Route) and Transdev Services, Inc. (Micro-transit)—under one unified safety framework. Each
contractor maintains internal safety programs consistent with the City’s SMS principles and
reports performance data, incidents, and corrective actions to the City’s Chief Safety Officer
(CSO). The Accountable Executive ensures adequate resources and leadership oversight to
implement safety initiatives, monitor performance, and promote a strong safety culture.
The SMS is built upon four key components:
• Safety Management Policy – Defines the City’s safety commitment, responsibilities, and
reporting structure.
• Safety Risk Management (SRM) – Identifies and mitigates hazards through structured
risk analysis.
• Safety Assurance (SA) – Monitors and evaluates system performance to ensure risk
mitigations remain effective.
• Safety Promotion (SP) – Builds and sustains a positive safety culture through
communication, education, and training.
Together, these elements ensure that safety is integrated into every level of decision-making
and daily operations for Moorpark City Transit and its contracted providers.
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Section 5: Safety Risk Management
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.
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.
Caltrans established safety performance targets to 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.
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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.
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.
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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.
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’s. 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; and
• 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.
• 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;
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• 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; and
• 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.
• 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 program 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.
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• 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.
• 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
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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 matter experts, is responsible for
assessing identified hazards and ratings using the safety risk matrix below. Prioritizing safety
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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
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.
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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 Serious Undesirable - With management decision required
1E, 2D, 2E, 3C, 3D, 3E,
4A, 4B, Medium 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; 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:
• 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.
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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
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.
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• 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 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 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.
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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
• 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.
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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.
• Reinforcing training concepts in the post-training work environment by giving employees
opportunities to perform what they’ve learned.
The City’s contractor, Thousand Oaks, also has a Public Transportation Agency Safety Plan.
The City’s transit service operators, MV Transit which operates fixed route and paratransit
services; and Transdev which operates the micro-transit service 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; and a copy of Transdev’s General Safety Requirements and Guidelines is included as
Appendix III.
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.
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CITY OF MOORPARK
INJURY AND ILLNESS PREVENTION PROGRAM
July 1, 2024
APPENDIX I
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TABLE OF CONTENTS
I. EMPLOYER INFORMATION ................................................................................... 3
II. SCOPE ..................................................................................................................... 3
III. EMPLOYEE ACCESS .............................................................................................. 4
IV. SAFETY PROGRAM RESPONSIBILITIES .............................................................. 6
V. SAFETY PROGRAM COMMUNICATION ................................................................ 8
VI. SAFETY PROGRAM COMPLIANCE ..................................................................... 10
VII. IDENTIFICATION, EVALUATION, AND PREVENTION OF OCCUPATIONAL
SAFETY AND HEALTH HAZARDS ....................................................................... 11
VIII. ACCIDENT INVESTIGATION ................................................................................ 13
IX. CORRECTING UNSAFE OR UNHEALTHY CONDITIONS ................................... 14
X. SAFETY TRAINING ............................................................................................... 14
XI. SAFETY COMMITTEE ........................................................................................... 16
XII. SAFETY PROGRAM RECORD KEEPING ............................................................ 16
XIII. DOCUMENTATION ................................................................................................ 17
XIV.REFERENCES ....................................................................................................... 17
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I.EMPLOYER INFORMATION
City of Moorpark
799 Moorpark Avenue
Moorpark, CA 93021
(805) 517-6200
II.SCOPE
General Industry Safety Orders Section 3203 requires all employers to develop
and implement an effective Injury and Illness Prevention Program (IIPP). Specific
elements of a safety program are required to be included in the IIPP. Currently,
violations of any California Division of Occupational Safety and Health (Cal/OSHA)
regulations may result in citations with a monetary penalty.
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 City 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.
Regard for the safety of citizens, the public, City employees, and the employees
of contractors is a responsibility at all levels of the City organization. The City
intends to prevent any human suffering in recognizing that accidents, even minor
ones, may cause both physical and mental pain. 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 this manner for all other aspects of City operations, the City will be in
a better position to control accidents and to improve the total performance of the
organization. It is, therefore, of utmost importance that all aspects of the IIPP are
strictly adhered to, and that the intent of this program is followed.
Copies of the IIPP are available at the following locations and Share drive folder:
Moorpark City Hall
799 Moorpark Avenue
Moorpark, CA 93021
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Moorpark Public Services Facility
627 Fitch Avenue
Moorpark, CA 93021
Arroyo Vista Recreation Center
4550 Tierra Rejada Road
Moorpark, CA 93021
Moorpark Share Drive Folder
N:\Risk Management\Injury & Illness Prevention Program
III. EMPLOYEE ACCESS
In addition to copies available at the various aforementioned locations, employees
have the right and opportunity to examine and receive a copy of the IIPP.
Employees may elect to grant a designated representative access to the IIPP. A
designated representative is an individual or organization to whom the employee
has given written authorization to exercise a right of access to the IIPP. For
purposes of this IIPP, a recognized or certified collective bargaining agent is
automatically a designated representative.
A. Written Authorization
Employees seeking to grant a designated representative access to the
agency’s IIPP shall submit a written request that contains the following
information:
1. The name and signature of the employee authorizing a designated
representative to access the IIPP on the employee’s behalf;
2. The date of the request;
3. The name of the designated representative (individual or
organization) authorized to receive the IIPP on the employee’s
behalf;
4. The date upon which the written authorization will expire (if less than
one (1) year).
B. Access to the Program
The agency shall provide access to the IIPP by doing one of the following:
1. Provide access in a reasonable time, place, and manner, but in no
event later than five (5) business days after the request for access is
received from an employee or designated representative.
a. Whenever an employee or designated representative
requests a copy of the IIPP, the employer shall provide the
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requester a printed copy of the IIPP, unless the employee or
designated representative agrees to receive an electronic
copy of the IIPP.
b. One printed copy of the IIPP shall be provided free of charge.
If the employee or designated representative requests
additional copies of the IIPP within one (1) year of the previous
request and the IIPP has not been updated with new
information since the prior copy was provided, the employer
may charge reasonable, non-discriminatory reproduction
costs (per Title 8 Section 3204(e)(1)(E)) for the additional
copies, or;
2. Provide unobstructed access through a company server or website,
which allows an employee to review, print, and email the current
version of the IIPP. Unobstructed access means that the employee,
as part of his or her regular work duties, predictably and routinely
uses the electronic means to communicate with management or
coworkers. If the employee does not have regular access to a
computer, a verbal request for a copy for the employee can be
submitted to the Safety Program Administrator. If the employee is
granting access to a designated representative, the written
authorization can be delivered to the office of the Safety Program
Administrator.
Employees shall have unobstructed access of the IIPP through a company server
or website, which allows an employee to review, print, and email the current
version of the IIPP. Unobstructed access means that the employee, as part of his
or her regular work duties, predictably and routinely uses the electronic means to
communicate with management or coworkers. If the employee does not have
regular access to a computer, a verbal request for a copy for the employee can be
submitted to the Safety Program Administrator. If the employee is granting access
to a designated representative, the written authorization can be delivered to the
office of the Safety Program Administrator.
The IIPP provided to the employee or designated representative need not include
any of the records of the steps taken to implement and maintain the written
document. If the agency has distinctly different and separate operations with
distinctly separate and different IIPPs, the agency may limit access to the IIPP(s)
applicable to the employee requesting it. The agency shall communicate the right
and procedure to access the IIPP to all employees. Nothing in this section is
intended to preclude employees and collective bargaining agents from collectively
bargaining to obtain access to information in addition to that available under this
section.
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IV. SAFETY PROGRAM RESPONSIBILITIES
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 Human Resources Manager as
the City’s Safety Program Administrator who has the authority and responsibility
for implementing the agency’s IIPP.
City of Moorpark Safety Program Administrator
Carolina Tijerino
Human Resources Manager
(805) 517-6238
ctijerino@moorparkca.gov
Under the agency’s safety program, all levels in the organization have a
responsibility for safety.
A. Employee safety responsibilities include:
1. Becoming familiar and complying with the Code of Safe Practices
(Exhibit A) and specific work procedures or rules as they apply to
their work activity.
2. Attending training sessions as scheduled.
3. Knowing the job and always apply safe work practices.
4. Recognizing the hazards of the job and taking precautions to ensure
the safety of themselves and others.
5. Immediately advising their supervisor if the working conditions, tools
or equipment are unsafe.
6. Actively participating and cooperating in the overall safety program.
7. Using all personal protective equipment as required.
8. Complying with all safety instructions from supervisors.
9. Obeying all health and safety warning signs and standards.
10. Immediately reporting all accidents (vehicular or personal)
regardless of severity to the supervisor.
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11. Not jumping from truck beds, platforms, fences, or other elevated
places.
12. Not taking shortcuts in or over dangerous places.
13. Paying strict attention to their work and not participating in practical
jokes and horseplay.
14. Not wearing loose clothing and jewelry while working on or near
equipment and machines.
B. Supervisory safety responsibilities include:
1. Becoming familiar and complying with the Code of Safe Practices
(Exhibit B) and specific work procedures or rules as they apply to
their area of authority.
2. Attending training sessions as scheduled.
3. Ensuring that employees and sub-contractors under their direction
are aware of and comply with the Code of Safe Practices and specific
work procedures or rules as they apply.
4. Disciplining employees, per the agency’s disciplinary action policy,
for violations of the Code of Safe Practices and specific work
procedures or rules as they apply.
5. Investigating accidents and near miss incidents in a timely manner,
including documenting all aspects of the incident, identifying the
cause and implementing the corrective actions to prevent
reoccurrence.
6. Correcting any unsafe conditions or work practices observed during
a site safety inspection in a timely manner.
7. Preparing a job safety analysis for specific jobs and reviewing it with
management and employees. [if used]
C. Managerial safety responsibilities include:
1. Becoming familiar and complying with the Code of Safe Practices
(Exhibit B) and specific work procedures or rules as they apply to
their area of authority.
2. Attending training sessions as scheduled.
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3. Ensuring that employees and contractors are aware of and comply
with the Code of Safe Practices, and specific work procedures or
rules and Cal/OSHA regulations.
4. Disciplining employees, per the agency’s disciplinary action policy,
for violations of the Code of Safe Practices and specific work
procedures or rules as they apply.
5. Reviewing accident investigations in a timely manner, ensuring that
all aspects of the incident are documented and implementing
corrective actions to prevent reoccurrence.
6. Correcting in a timely manner any unsafe conditions or work
practices observed during a site safety inspection.
7. Designating an employee within their department to act as the
department safety coordinator.
D. Safety Program Administrator responsibilities include:
1. Developing, distributing, and updating the centralized safety manual.
2. Ensuring safety training as required by the centralized safety manual
has been conducted.
3. Conducting audits of the agency safety programs to evaluate
compliance with Cal/OSHA requirements.
4. Reporting to agency management regarding safety compliance
status, new or upcoming regulations and other safety issues that
require their attention.
5. Assisting in reviewing new chemicals and/or equipment as required.
E. Department safety coordinator responsibilities include:
1. Conducting facility safety inspections.
2. Conducting and documenting safety meetings and training with
employees.
V. SAFETY PROGRAM COMMUNICATION
A. Initial Training:
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Upon implementation, all employees will have the IIPP reviewed with them.
The IIPP will be reviewed as an element of the new employee orientation
and for contract employees working under the agency’s direction and
control. The IIPP will also be reviewed for each new job assignment,
procedure, substance, or equipment that creates a new hazard.
B. Safety Meetings:
1. The Human Resources Manager (Safety Program Administrator) will
conduct safety meetings. All meetings will include information on the
following subjects as applicable.
a. Review of Code of Safe Practices, policies or procedures.
b. On-the-job or off-the-job safety information.
c. Feedback from employees on hazards, safety suggestions, or
concerns.
d. Review of previous accidents, causes, and corrective actions.
e. Recognition for compliance, good safety performance or
attitude.
C. Attendance at safety meetings is considered a part of every employee’s job
duties. All meetings will be documented in writing with the following
information included: date, safety topic, discussion items, and employee
attendance records. The Human Resources Manager will retain completed
safety meeting documentation forms.
D. Safety meetings will be conducted as follows:
1. City Manager’s Office – Quarterly
2. Community Development – Quarterly
3. Finance – Quarterly
4. Parks, Recreation and Community Services – Monthly (Field);
Quarterly (All other staff)
5. Public Works – Monthly (Field); Quarterly (All other staff)
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E. Employee Suggestions:
Employees will be afforded an opportunity to make safety suggestions
and/or express their concerns. This opportunity will be by means of an
employee safety suggestion. Employee suggestions may be made
anonymously, but in any case no employee shall be disciplined, demoted,
or otherwise discriminated against for making a suggestion. Response to
suggestions will be documented on the suggestion form and the employee
notified as to the outcome. Anonymous suggestions will be considered as
seriously as non-anonymous suggestions; responses shall also be
documented on the suggestion form and posted for all employees to review.
Suggestions may be made to the department safety coordinator and/or
Safety Program Administrator.
Employees who have complaints pertaining to job safety should first discuss
them with their immediate supervisor for review and investigation. If the
supervisor and the employee cannot reach a resolution, the immediate
supervisor should refer the employee to the second level supervisor or
director.
The second level supervisor or director should discuss the complaint with
the immediate supervisor and the employee. If an agreement still cannot be
reached after further investigation, the second level supervisor or director
should refer the complaint to the Human Resources Department for final
resolution. Supervisory personnel may consult with the safety officer or risk
manager for technical advice or other pertinent information.
When a resolution of the complaint is established, a written notice of the
outcome should be provided to the employee and all supervisory personnel
involved.
F. Written Communications:
A regular area where written safety communications will be posted shall be
established. Postings will contain information on: off-the-job or on-the-job
safety topic, changes in safety procedures, accident causes, employee
safety suggestions or other information as appropriate.
VI. SAFETY PROGRAM COMPLIANCE
A. Disciplinary Action:
The agency’s policy states that non-compliance and/or willful violation of the
Code of Safe Practices and specific work procedures or rules will result in
disciplinary action and/or termination. Disciplinary action will be
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administered and documented per the agency’s policy and procedure
and/or contracts.
B. Educational Program:
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.
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.
Supervisors are responsible for observing and providing safety training to
the employees under their supervision. Basic safety training will be provided
to all new employees and to current employees when given new or different
job assignments. Observations will be conducted after initial orientation and
training have been completed and establishing a period for evaluating
employee safe work habits to ensure compliance with safety standards.
Supervisors should also periodically review safety training topics with
employees under their supervision.
Completed observations will be monitored with the findings condensed to
further identify areas for additional training, maintenance, or procedural
improvement. Additional elements may be included to not only meet but
exceed the IIPP requirements of California Code of Regulations, Title 8,
Chapter 4, section 3203.
C. Accountability Program:
Central to maintaining safety program compliance is establishing
accountability for safety. The City has identified specific safety activities that
managers and supervisors are responsible for. These activities include
conducting safety meetings, observation audits, and accident
investigations; attending training sessions; and overseeing accident rate
performance. Performance in these and additional safety activities will be
maintained and included for discussion and appropriate action in the annual
performance appraisal review.
VII. IDENTIFICATION, EVALUATION, AND PREVENTION OF OCCUPATIONAL
SAFETY AND HEALTH HAZARDS
A. Job Hazard Analysis:
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Selected departments shall develop a job hazard analysis (JHA). The
employee and the supervisor can complete the JHA as work activities are
developed. Upon completion of the JHA, it is to be reviewed with the
department safety coordinator.
Review with affected employees, including a discussion of hazards, safety
equipment required, procedures or practices to reduce or eliminate hazards
and special training requirements.
The JHA is to be maintained on file by the department safety coordinator
for documentation purposes.
B. Facility Safety Inspections:
The department safety coordinator will conduct a formal, documented
facility safety inspection monthly. This inspection shall be documented on a
facility inspection form. The inspection will include an evaluation of work
areas, machine guarding, exits, fire extinguishers, eyewashes,
housekeeping and other specific Cal/OSHA requirements.
Correction of unsafe conditions will be documented on the inspection form
and the form shall be maintained on file in the department.
It will be the responsibility of the department manager to:
1. Monitor progress on corrective actions that remain to be completed
and conduct follow-up survey to verify completion of corrective
actions as required.
2. Inform employees and agency management of any serious finding or
incomplete corrective action that may pose a serious injury risk to
employees or the public or the environment in general.
C. Hazard Information and Inspections:
Information as to job or site hazards will be extracted from accident
investigations and site safety inspections/audits. This information will be
used to improve training programs, safety meetings, etc.
Inspections shall be conducted whenever the employer is made aware of a
new or previously unrecognized hazard.
D. Equipment Inspections:
Material handling equipment such as forklifts, hoists, or other equipment will
be inspected and maintained per the legal requirements. It will be the
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responsibility of the employee using the equipment to ensure these
inspections are conducted and documented.
E. Insurance Company Inspections and Surveys:
The agency’s workers’ compensation or property carrier may conduct
surveys of agency facilities. The findings of these inspections are submitted
to the agency in writing along with recommendations for corrective action.
Findings and recommendations will be submitted in writing and will be
tracked until fully implemented.
F. Chemical/Equipment/Procedure Inspection, Review and Approval:
Chemicals, equipment, and procedures not currently in use or operation
must be reviewed and approved by the department safety coordinator prior
to their being purchased and/or implemented. The purchasing department
shall not purchase non-approved chemicals or equipment. Replacement in
kind is not considered as a “new” chemical, equipment, or procedure.
Inspections shall be conducted when new substances, processes,
procedures, or equipment are introduced to the workplace that represent a
new occupational safety and health hazard.
VIII. ACCIDENT INVESTIGATION
A. Reporting:
Employees will report all accidents, industrial injuries, or illnesses or
incidents that could have resulted in an injury, illness, or property damage
(including near miss incidents) to their supervisor immediately. In the event
that the supervisor is unavailable, accidents or injuries shall be reported to
the department manager.
B. Investigation:
After ensuring the injured employee has received appropriate medical
treatment, the supervisor shall conduct an accident investigation. The
investigation shall include the factual details surrounding the event (e.g.,
who, what, when, where, witnesses, etc.), the probable cause of the event
and corrective actions to prevent a reoccurrence of the incident. The
investigation shall be documented on the agency’s accident report form. A
sample form by the State of California Department of Industrial Relations
has been included (Exhibit C). The supervisor will forward the completed
report to the department manager for review and concurrence. A copy of an
“Injury or Illness Event Report” form shall be sent to the human
resources/risk management department.
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The facility manager will review the report and follow up with the supervisor
to ensure that the corrective actions have been implemented.
Within 24 hours of the incident, the supervisor or his designee will provide
the injured employee with an “Injury or Illness Event Report” form and
document it.
The Safety Program Administrator or their designee shall complete the
“Employer’s Report of Occupational Injury or Illness” (Form 5020, also
known as “Employer’s First Report of Injury”) and send it to the workers’
compensation carrier if required.
IX. CORRECTING UNSAFE OR UNHEALTHY CONDITIONS
Methods of correcting unsafe or unhealthy conditions will vary depending upon the
degree of hazard and control of the work site. Minor hazardous situations, such as
housekeeping, storage, or other items shall be corrected without additional
documentation. Hazardous conditions of a more serious nature will require a work
order/request, work to be stopped, or the equipment tagged and taken out of
service until the proper corrective action can be taken. Hazards of an imminent
nature will require emergency notifications and evacuation.
Hazard correction shall be documented on an individual basis using an
investigation/corrective action report, in companion with a facility safety inspection
form. On a cumulative basis, hazard correction shall be documented using an
identified hazards and correction record form.
Should an emergency situation arise which creates an imminent hazard, which
cannot be immediately abated, all employees will be evacuated from the facility to
a safe location until the situation is corrected. The evacuation will be carried out
per the site’s evacuation procedures.
X. SAFETY TRAINING
A. New Hire Orientation:
Prior to reporting for work, all employees will receive an agency orientation
and a job safety orientation, if applicable to their job description and
responsibilities.
1. The agency orientation will include training on:
a. Code of Safe Practices.
b. Injury/incident reporting.
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c. Employee access to medical/exposure information.
d. Hazard communication and chemical safety.
e. Review of the injury and illness prevention program.
f. Emergency response/evacuation duties.
2. The job orientation will include training on:
a. Specific chemicals and handling procedures used as part of
the job.
b. Use of equipment as required.
3. Additional specialized training will be conducted as necessary. This
may include:
a. Forklift/manlift operator certification.
b. Respiratory refresher and fit test.
c. Confined space entry.
d. Hearing conservation.
e. Ergonomics.
f. Police department personnel shall be P.O.S.T. certified as
required (the City of Moorpark contracts police services with
the County of Ventura so this will be separately verified with
the County).
g. Fire department personnel shall be trained per the state’s
fire marshal requirements (the City of Moorpark contracts fire
services with the County of Ventura so this will be separately
verified with the County).
B. Training and instruction shall also be provided in the following situations:
1. Whenever new substances, processes, procedures, or equipment
are introduced to the workplace and represent a new hazard. Any
new substances or equipment shall include training that follows the
manufacturer’s guidelines.
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2. Whenever management becomes aware of a new or previously
unrecognized hazard.
C. Contract Employees:
Contract employees who are under the direction and control of an agency
employee will attend the job safety orientation and safety meetings. They
will receive any specialized training as required by their job assignment, as
would an employee.
D. Supervisor Training:
Supervisors will attend scheduled training sessions designed to familiarize
them with the safety and health hazards to which their employees are
exposed and to assist them in implementing the safety program.
XI. SAFETY COMMITTEE
The agency has established a safety committee made up of Competitive Service
and Non-Competitive Service employees and other representatives as
appropriate. This committee shall meet at least quarterly and maintain written
minutes. The minutes shall be posted for all employees to review. The purpose of
this committee is to review action items from internal/external inspections, safety
activity performance, new or revised safety policies or procedures, accident
investigations, new equipment, recognition program, and other items relating to
the safety program.
XII. SAFETY PROGRAM RECORD KEEPING
As a local governmental entity, the City of Moorpark is not required to keep written
records of the steps taken to implement the IIPP.
The Safety Program Administrator shall maintain record keeping and program
documentation. Safety program documentation will include copies of:
A. Accident reports.
B. OSHA log.
C. Insurance company surveys and recommendations.
Departmental safety coordinators shall maintain the records for:
A. Site inspections.
B. Accident reports.
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C. Employee training records.
D. Completed safety meetings.
XIII. DOCUMENTATION
A. Training documentation shall include the employee’s name (and ID number,
if applicable), training date, type of training, instructor’s name, and an
outline of what was presented. The departmental safety coordinators will
maintain the training records per the agency’s records retention policy.
B. Records of surveys will include the date of the survey, area surveyed,
survey findings, and who conducted the survey. The departmental safety
coordinators will maintain these records per the agency’s records retention
policy.
C. Copies of insurance company surveys and all other records. The Safety
Program Administrator will maintain these records per the agency’s records
retention policy.
D. Medical and exposure records will be maintained per legal requirements
and the agency’s records retention policy.
XIV. REFERENCES
California Code of Regulations, Title 8, Division 1, Chapter 4, Subchapter 7,
Introduction, section 3203
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EXHIBIT A
CODE OF SAFE WORK PRACTICES
EMPLOYEE SAFETY RESPONSIBILITIES
GUIDELINES AND RESPONSIBILITIES
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. Immediately advise their supervisor if the working conditions, tools or
equipment are unsafe.
D. Actively participate and cooperate in the overall safety program.
E. Use all personal protective equipment as required.
F. Comply with all safety instructions from supervisors.
G. Obey all health and safety warning signs and standards.
H. Immediately report all accidents (vehicular or personal) regardless of
severity to the supervisor.
I. Do not jump from truck beds, platforms, fences, or other elevated places.
J. Do not take shortcuts in or over dangerous places.
K. Pay strict attention to their work and do not participate in practical jokes
and horseplay.
L. Do not wear loose clothing and jewelry while working on or near
equipment and machines.
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EXHIBIT B
CODE OF SAFE WORK PRACTICES
SUPERVISORY SAFETY RESPONSIBILITIES
GUIDELINES AND RESPONSIBILITIES
A. Give sincere, active, and constant support to all safety activities and
procedures.
B. Instill safety awareness in each employee.
C. Be responsible for familiarizing employees with the hazards of the job to
which they are assigned, and instruct their personnel in the safe methods
of performing the job.
D. Ensure that each worker is provided with the needed safety equipment
and protective devices.
E. Take prompt corrective action whenever unsafe conditions or acts are
noted.
F. Periodically review the work practices of subordinate employees to ensure
they continue to work in a safe manner.
G. Make regular safety appraisals of their assigned area.
H. Investigate and find the cause of accidents and take corrective action to
prevent recurrences.
I. Be responsible for the enforcement of safety rules among employees.
J. At the end of each workday, inspect work areas for proper housekeeping
or other hazards.
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EXHIBIT C
INVESTIGATION / CORRECTIVE ACTION REPORT SAMPLE FORM
Date and Time
of Incident I
Exposure
!INVESTI GAT ION / CORRECT IVE ACT ION REPORT
Location
EMPLOYEES INVOLVED
DETAILED INCIDENT / EXPOSURE DESCRIPTION
ri~•~'i,~T~l
~tr ~
KRVlcz
ULTIMATE CAUSE OF INCIDENT /EXPOSURE (I.E. "WHO, WHAT, WHEN, WHERE, HOW" AND THE "5 WAYS"
... THE ROOT CAUSE)
OPT ONS FOR ELIMINATION OR CONTROL OF THE ROOT CAUSE(S)
CORRECT VE ACTIONS TAKEN / DATE / NAME OF PERSON(S) MAKING CORRECTIONS
W ilinesses :
Investiga ted by: __________________ _ Date: -------
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System Security &
Emergency Preparedness
Plan
Division 077
July / 2021
www.mvtransit.com
APPENDIX II
We Provide Freedom '"
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Section 1. Table of Contents
Section 1. Table of Contents......................................................................................................................1
Section 2. Foreward...................................................................................................................................3
2.1. Policy Statement 3
2.2. SSEPP Program Plan Revision History 4
2.3. Reference Documents 4
2.4. Glossary of Terms 6
Section 3. Introduction..............................................................................................................................9
3.1. Background 9
3.2. Authority 9
3.3. Purpose, Goals and Objectives of SSEPP Program 10
3.3.1 Purpose 10
3.3.2 Goals 11
3.3.3 Objectives 11
3.4. Scope 12
Section 4. Transit System Description.....................................................................................................13
4.1. Organizational Structure 13
4.2. Operating Characteristics and Service 13
4.2.1 Service Area 13
4.2.2 Service Design 13
4.3. Services and Facilities 14
4.4. Measures of Service 14
4.4.1 Methodology to Achieve SSEPP Goals 15
4.5. Hazard Identification and Resolution Process (MIL - 882D) 16
4.5.1 Hazard Identification 16
4.5.2 Hazard Assessment 17
4.5.3 Risk Assessment 18
4.6. Follow-Up 19
Section 5. SSEPP Program Roles and Responsibilities.............................................................................20
5.1. Philosophy 20
5.2. Division of Responsibilities 20
5.2.1 All Personnel 20
5.2.2 Senior Vice President of Safety & Training 21
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5.2.3 SSEPP Program Point of Contact (POC) 21
5.2.4 Location Safety Committee (LSC) 22
5.2.5 Supervisors 23
5.2.6 Bus Operators 24
5.2.7 Other Personnel 24
5.3. Responsibility Matrices 25
5.4. Existing SSEPP Capabilities and Practices26
5.5. Training and Exercising 27
5.6. Coordination with Local Public Safety Agencies 28
5.7. Coordination with Other Transit Providers 28
5.8. Security Incidents Trend Analysis 29
5.8.1 Facility Security 30
5.8.2 Vehicle Security31
5.8.3 Management Information Systems Security 32
5.9. Internal Security Practices 32
5.10. External Security Component 33
Section 6. Threat and Vulnerability Resolution Process..........................................................................34
6.1. Threat, Vulnerability and Consequence Identification and Resoulution 34
6.2. Threat and Vulnerability Identification 34
6.3. Threat and Vulnerability Assessment 35
6.4. All Hazards Threat and Vulnerability Identification and Analysis 36
Section 7. Evaluation and Modification of the SSEPP..............................................................................38
7.1. Evaluation 38
7.1.1 Internal38
7.2. Modification and Update 38
Section 8. Threat Levels and Alerts .........................................................................................................39
8.1. Homeland Security Advisory System (HSAS) for Transit 39
8.1.1 Low Condition (Green) 39
8.1.2 Guarded Condition (Blue) 40
8.1.3 Elevated Condition (Yellow) 40
8.1.4 High Condition (Orange) 41
8.1.5 Severe Condition (Red) 41
8.1.6 Active Incident 41
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8.1.7 Recovery Phase42
8.2. Federal Bureau of Investigation Alerts 42
8.3. Public Transit Information Sharing and Analysis Center (PT-ISAC)42
8.4. Homeland Security Information Network – Public Transit (HSIN-PT) 43
Section 9. Appendices .............................................................................................................................44
9.1. Appendix A Vehicle Safety Program Implications44
9.2. Appendix B: Security Baseline Planning Worksheet 47
9.3. Appendix C: Emergency Response Planning, Coordination, and Training Considerations 50
9.4. Appendix D: Bomb Threat Checklist and Procedures 52
9.5. Appendix E : Types of Preparation Exercises 62
9.6. Appendix F: Reporting Criminal Activity 63
9.7. Appendix G: Emergency Action Plan 64
9.7.1 Elements 65
i. Emergency Escape Procedures and Routes 65
ii. Employee Accountability Procedures after Evacuations 65
iii. Rescue and Medical Duties 65
iv. Alarm System 66
v. Training 66
9.7.2 Emergency Shutdown Procedures 66
9.8. Appendix H – Chemical Hazard Communication Program Plan 69
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Section 2. Foreward
2.1. Policy Statement
It is the objective of MV Transportation, Inc. (“MV”)to provide safe, secure and reliable service for its
passengers and employees. To demonstrate this commitment, MV has developed this Security and
Emergency Preparedness Program Plan.
MV has a sincere concern for the welfare and safety of its employees, contractors, and public safety
partners, as well as the public it serves. The operation of MV requires a continual emphasis on security,
from the procurement of new systems and equipment, through the hiring and training of employees, to
the management of the agency and the provision of service. The security function must be supported by
an effective capability for emergency response, both to support resolution of those incidents that occur
on transit property and those events that affect the surrounding community served by MV.
This plan describes the policies, procedures and requirements to be followed by management,
maintenance and operating personnel in order to provide a secure environment for agency employees,
volunteers, and contractors, and to support effective emergency response. All personnel are expected
and required to adhere to the policies, procedures, and requirements established herein and to properly
and diligently perform security-related functions as a condition of employment or support for MV.
The security function must be supported by effective emergency response capabilities to ensure that
security related incidents involving operations and services are responded to, resolved and recovered
from quickly, safely and efficiently. To this end, MV management will provide leadership in promoting
safety, security and emergency preparedness throughout the organization. The general manager and
the management staff will be continually and directly involved in formulating, reviewing and revising
security and emergency preparedness policies, goals and objectives.
All of MV’semployees are governed by the requirements and terms of this plan, and must
conscientiously learn and follow prescribed security and emergency rules and procedures. Employees
shall make safety a first concern when using equipment, tools and materials.They shall be properly
trained in the work rules and procedures for their area(s) of responsibility, including contingency plans
for abnormal and emergency conditions. Each employee shall take an active part in the identification
and resolution of security concerns.
Supervisors shall actively participate in all activities regarding security and emergency preparedness;
shall fully cooperate with the policies and objectives specified in this plan; and shall receive the full
cooperation and support of executive management in their activities for improved security and
emergency preparedness.
Note: The references herein to “MV” or “MV Transportation” describe MV Transportation, Inc., to
include all its subsidiaries, joint ventures, partnerships, and affiliates.
2.2. SSEPP Program Plan Revision History
Date Revision Description of Change
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Names
This Plan must be updated annually.
2.3. Reference Documents
The following are resources used to develop the policies and procedures documented in
this SSEPP :
Title: Transit System Security Program Planning Guide
Author(s): John Balog and Anne Schwarz
Year: 1994
Sponsoring Agency: Federal Transit Administration (FTA)
Volpe Report #: DOT-VNTSC-FTA-94-01
DOT Number: FTA-MA-90-7001-94-1
NTIS Number: PB94-161973
Available: http://www.transit-safety.dot.gov
Title: Transit Security Handbook
Author(s): Annabelle Boyd and James Caton
Year: 1998
Sponsoring Agency: Federal Transit Administration (FTA)
Volpe Report #: DOT-VNTSC-FTA-98-03
DOT Number: FTA-MA-90-9007-98-1
NTIS Number: PB98-157761
Available: http://www.transit-safety.dot.gov
Title: Critical Incident Management Guidelines
Authors: Annabelle Boyd and James Caton
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Year: 1998
Sponsoring Agency: Federal Transit Administration (FTA)
Volpe Report #: DOT-VNTSC-FTA-98-05
DOT Number: FTA-MA-26-7009-98-1
Available: http://www.transit-safety.dot.gov
Title: Transit Security Procedures Guide
Author(s): John Balog and Anne Schwarz
Year: 1996
Sponsoring Agency: Federal Transit Administration (FTA)
Volpe Report #: DOT-VNTSC-FTA-94-08
DOT Number: FTA-MA-90-7001-94-2 9
Available: http://www.transit-safety.dot.gov
Title: Emergency Preparedness for Transit Terrorism
Authors: Annabelle Boyd and John P. Sullivan
Year: 1997
Sponsoring Agency: Transportation Research Board
Report Number Transit Cooperative Research Program Synthesis Number 27
Web site: http://nationalacademies.org/trb/publications/tcrp/tsyn27.pdf
Title: Perspectives on Transit Security in the 1990s: Strategies for Success
Author(s): Annabelle Boyd and Patricia Maier
Year: 1996
Sponsoring Agency: Federal Transit Administration (FTA)
Volpe Report #: DOT-VNTSC-FTA-96-02
DOT Number: FTA-MA-90-7006-96-01
NTIS Number: PB96-185871
Available: http://www.transit-safety.dot.gov
Title: Transit Security in the 90's
Author(s): Kathryn Powell and Annabelle Boyd
Year: 1996
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Sponsoring Agency: Federal Transit Administration (FTA)
Keywords: Local transit-Security measures
Volpe Report #: DOT-VNTSC-FTA-96-11
DOT Number: FTA-MA-26-9009-97-01
NTIS Number: PB97-146989
Available: http://www.transit-safety.dot.gov
Title: Protecting Surface Transportation Systems and Patrons from Terrorist Activities
– Volume One
Author: Brian Michael Jenkins
Year: January 1997
Sponsoring Agency: San Jose University, Mineta International Institute for Surface
Transportation Policy Studies
Report Number: IISTPS 97-4
Full text available at: http://www.transweb.sjsu.edu/publications/terrorism/Protect.htm
Title: Protecting Surface Transportation Systems Against Terrorism and Serious Crime
– 2001 Update
Author: Brian Michael Jenkins
Year: October 2001
Sponsoring Agency: San Jose University, Mineta International Institute for Surface
Transportation Policy Studies
Report Number: IISTPS 01-7
Full text available at: http://www.transweb.sjsu.edu/publications/terrorism/Protect.htm
Title: Improving Transit Security
Authors: Jerome A. Needle and Renee M. Cobb, J.D,
Year: 1997
Sponsoring Agency: Transportation Research Board
Report Number Transit Cooperative Research Program Synthesis Number 21
Web site: http://nationalacademies.org/trb/publications/tcrp/tsyn21.pdf
2.4. Glossary of Terms
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Emergency: A situation which is life threatening to passengers,
employees, or others, or which causes damage to any
transit vehicle or facility or results in the significant
theft of services and reduces the ability of the system
to fulfill its mission.
Safety Committee: A group of MV Transportation employees, including
senior safety manager, division safety and
maintenance managers, division managers and
supervisors, and union representatives.
Fatality:A transit-caused death that occurs within 30 days of
the transit incident.
Injury:Any physical damage or harm to a person that requires
immediate medical attention and hospitalization.
Safety:Freedom from danger.
Security:Freedom from intentional danger.
Security Breach: An unforeseen event or occurrence that endangers life
or property and may result in the loss of services or
system equipment.
Security Incident: An unforeseen event or occurrence that does not
necessarily result in death, injury, or significant
property damage but may result in a minor loss of
revenue.
Security Threat: Any source that may result in a security breach, such
as vandal or disgruntled employee; or an activity, such
as an assault, intrusion, fire, etc.
System:A composite of people (employees, passengers,
others), property (facilities and equipment),
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environment (physical, social, institutional), and
procedures (standard operating, emergency operating,
and training) which are integrated to perform a
specific operational function in a specific
environment.
System Security: The application of operating, technical, and
management techniques and principles to the security
aspects of a system throughout its life to reduce
threats and vulnerabilities at the most practical level
and through the most effective use of available
resources.
Management:
An element of management that defines the system
security requirements and ensures the planning,
implementation, and accomplishments of system
security tasks and activities.
System Security
Program:
The combined tasks and activities of system security
management and system security analysis that
enhance operational effectiveness by satisfying the
security requirements in a timely and cost-effective
manner through all phases of a system life cycle.
Threat:Any real or potential condition that can cause injury or
death to passengers or employees or damage to or loss
of transit equipment, property, and/or facilities.
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Threat analysis: A systematic analysis of a system operation designed
to identify threats and make recommendations for
their elimination or mitigation during all revenue and
non-revenue operation.
Threat Probability: The probability a threat will occur. Threat probability
may be expressed in quantitative or qualitative terms.
An example of a threat-probability ranking system is
as follows: (a)frequent, (b) probable, (c) occasional,
(d) remote, (e) improbable, and (f) impossible.
Threat Resolution: The analysis and subsequent action taken to reduce
the risks associated with an identified threat to the
lowest practical level.
Threat Severity: A qualitative measure of the worst possible
consequences of a specific threat:
Category 1 - Catastrophic. May cause death or loss of
a significant component of the transit system, or
significant financial loss.
Category 2 - Critical. May cause severe injury, severe
illness, major transit system damage, or major
financial loss.
Category 3 - Marginal. May cause minor injury or
transit system damage, or financial loss.
Category 4 - Negligible. Will not result in injury,
system damage, or financial loss.
Unsafe Condition
or Act:Any condition or act that endangers life or property.
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Vulnerability: Characteristics of passengers, employees, vehicles,
and/or facilities that increase the probability of a
security breach.
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Section 3. Introduction
3.1. Background
Vulnerabilities of public agencies, and the communities they serve, to acts of terrorism and extreme
violence have increased over time. Threat assessments issued by the Federal Bureau of Investigation
(FBI) have consistently placed public transportation at the top of the critical infrastructure protection
agenda, along with airports, nuclear power plants, and major utility exchanges on the national power
grid.
To establish the importance of security and emergency preparedness in all aspects of our organization,
MV has developed this System Security and Emergency Preparedness (SSEPP) Plan. This SSEPP outlines
the process to be used by MV to make informed decisions that are appropriate for our operations,
passengers, employees and communities regarding the development and implementation of a
comprehensive security and emergency preparedness plan.
As a result of this plan, MV hopes to achieve not only an effective physical security program, but also to
enhance coordination with the local public safety agencies. Better communication will increase
awareness of MV’s resources and capabilities, and improve the company’s readiness to support efforts
to manage community-wide emergencies.
In order to be effective, the activities documented in this SSEPP focus on establishing responsibilities for
security and emergency preparedness, identifying our methodology for documenting and analyzing
potential security and emergency preparedness issues, and developing the management system through
which it can track and monitor progress in resolving these issues.
3.2. Authority
The authority for implementing the SSEPP resides with MV Transportation’s CEO and/or COO, MV
employees, and the client.
This SSEPP has been developed in cooperation with the United States Department of Transportation’s
Federal Transit Administration (FTA) and the FTA’sSystem Security and Emergency Preparedness
Training and Technical Assistance Program. This Program supports efforts to address requests from the
Department of Homeland Security and the administrator of the FTA to review the current levels of
protection and to integrate security and emergency preparedness more fully into MV’s operations.
3.3. Purpose, Goals and Objectives of SSEPP
This plan demonstrates the process for addressing system security and emergency preparedness:
System Security – The application of operating, technical, and management techniques and principles to
the security aspects of a system throughout its life to reduce threats and vulnerabilities at the most
practical level and through the most effective use of available resources.
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Emergency Preparedness – A uniform basis for operating policies and procedures for mobilizing transit
agency and other public safety resources to assure rapid, controlled, and predictable responses to
various types of transit and community emergencies.
The SSEPP will support MV’sefforts to address and resolve critical incidents on its property and within
its community.
Critical Incidents – may include accidents, natural disasters, crimes, terrorism, sabotage, civil unrest,
hazardous materials spills and other events that require emergency response. Critical incidents require
swift, decisive action from multiple organizations, often under stressful conditions. Critical incidents
must be stabilized prior to the resumption of regular service or activities.
Critical incidents often result from emergencies and disasters, but can be caused by any number of
circumstances or events. Successful resolution of critical incidents requires the cooperative efforts of
both public transportation and community emergency planning and public safety agencies.
MV has established criteria for a critical incident:
Element of Definition Agency Threshold
Service Interruption Inability to provide service
Duration of Interruption 2 hours (system wide)
24 hours (single route)
Injuries and Fatalities
2 or more injuries requiring
hospitalization
1 or more fatalities
Dollar Amount of Property
Damage $25,000
3.3.1Purpose
The purpose of the SSEPP is to establish formal mechanisms to be used by all MV employees, and
contractors in all departments to:
Identify hazards associated with MV Transportation systems.
Eliminate, minimize or control these hazards.
Coordinate and establish system safety throughout the company.
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Provide a leadership safety document that is fluid and changing with our
operating environments.
The SSEPP will be used as a means of preventing injuries, accidents and other losses. It demonstrates
MV’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 SSEPP standards of the American Public Transportation Association (APTA) and the
Federal Transit Administration (FTA).
3.3.2Goals
The overall goal of MV’s SSEPP is to establish the highest reasonable level of security that can be
afforded to all passengers, contractors, employees, equipment and facilities. Specific goals of the SSEPP
are as follows:
Identify, eliminate, minimize and/or control safety hazards and their
associated risks.
Provide a superior level of safety in our transit operations.
Support the safety efforts of the FCDOT.
Achieve and maintain a superior level of safety in the company’s work
environment.
Comply with the applicable requirements of regulatory agencies.
Develop relations and coordination with local law enforcement agencies
and local and state government agencies.
3.3.3Objectives
Although every threat cannot be identified and resolved, MV can take steps to improve awareness, to
better protect passengers, employees, facilities and equipment, and to stand ready to support
community needs in response to a major event. To this end, the SSEPP has the following objectives:
Establish safety policies, procedures and requirements that integrate
safety into decision-making and operations.
Define roles and 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.
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Meet or exceed safety requirements in specifications, equipment
installation, system testing, and 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 offering suggestions and information during the
design and build 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.
Develop a management structure to maintain, evaluate and modify the
plan.
Enable employees, contractors, passengers and other personnel to
identify criminal acts, suspicious activities and occurrences, or other
security concerns within MV’s operations and to properly report and
address such events.
Solicit security concerns from employees, contractors and passengers.
Implement an annual security review and assessment process and verify
adherence to MV’s security policies, procedures and requirements.
Administer security-related training courses to address security threats
and emergency response.
Limit security breaches and effectively resolve those that do occur.
Thoroughly investigate all incidents involving security breaches or other
security-related threats or vulnerabilities.
Thoroughly evaluate the security implications of all proposed system
modifications before implementation and ensure that system
modifications do not create new security risks.
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Address items covered by the TSA/FTA Security and Emergency
Management Action Items for Transit Agencies.
Address items covered by the BASE, as applicable that are not already
included above.
3.4. Scope
MV’s SSEPP is applicable to all aspects of our current service, ensuring that our operations, training,
coordination with local public safety agencies, and general security and emergency preparedness
planning address concerns resulting from heightened threat levels. Key elements of theSSEPP include:
An evaluation of our current capabilities to identify and prevent security
incidents that may occur on our property.
Development of a vulnerability assessment program to identify our
weaknesses and guide planning activities.
Improved physical security.
Review and expansion of our training program for security and
emergency response.
Enhanced emergency planning and procedures development.
Improved coordination with the public safety agencies in our service
area.
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Section 4. Transit System Description
4.1. Organizational Structure
The following individuals are responsible for leading security initiatives in the company and for
placement within the organization to support the security and emergency preparedness structure of MV
Transportation, Inc.; including all employees, volunteers, and subcontractors:
CEO
COO
Group Presidents
Vice President
Maintenance Vice President of Safety & Training
Directors of Safety
Safety Manager
Managers
Location Safety
Committees (LSC)
4.2. Operating Characteristics and Service
4.2.1Service Area
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. MV has become one of the largest transportation management firms
in the United States.
4.2.2Service Design
MV provides the following types of services:
Fixed Route
Paratransit
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Shuttle Services (corporate and airport)
Demand Response
Route Deviation
Checkpoint Service
Zone Service
Vanpools
4.3. Services and Facilities
MV has been providing transit services since its inception in 1975; and has grown into one of the largest
transportation contracting firms in the United States. The company is a professional and innovative
contractor who supplies top quality, safe, and reliable transit service toour clients at a reasonable price.
Paratranist
MV has provided paratransit services since its company’s founding in 1975,
predating theAmericans with Disabilities Act. MV’s experience in
paratransit operations range from countywide ADA paratransit services to
door-to-door stair-assist ADA paratransit services. Included in the scope
of many of these services, MV operates reservations and dispatch call
centers using a variety of different reservation and dispatch systems.
Fixed Route
MV’s fixed route services range from small employee shuttle bus services to
large transit operations in major US cities. MV has helped its customers
establish new services and expandexisting fixed route systems to further
meet passenger demand.
Fleet Services
Most MV locations have a dedicated on-site maintenance shop. The shops
are either owned by our clients or leased by MV.
4.4. Measures of Service
Typical Modes of Service: Demand Response and fixed route
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Measure ofService Indicator Exposure
Fixed route Public bus stops, shelters, transit centers
Paratransit Door-to-door, curb-to-curb, other
Special trip requests Outside public domain
Charter Outside public domain
Other Outside public domain
Multi-modal services Outside public domain
4.4.1Methodology to Achieve SSEPP Goals
The methodology used in achieving SSEPP goals and objectives involves having all of MV’s 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 SSEPP attempts to accomplish this through the following five steps:
1. Gaining an understanding of system functions and the interrelationships among
them.
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 SSEPP, they also can be used at any level of the
organization as a means of maximizing the safety of all systems. The safety committee 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 safety committee are as follows:
Coordinate safety activities of the company.
Meet to evaluate and resolve system safety issues that have not been
resolved at the department level.
Conduct monthly meetings.
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Assign its members, as well as other departments, tasks as necessary to
address system safety issues.
Assist in the investigation of accidents and incidents as appropriate or
requested by management or asafety committee member.
Review maintenance records and failure reports 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 to the safety committee.
Report activities of the safety committee to MV senior management, and
the FCDOT as needed.
4.5. 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:
4.5.1Hazard 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.
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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 safety committee. 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 safety committee.
4.5.2Hazard 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.
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,
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and/or procedural deficiencies. Using U.S. Military Standard MIL-882D,
the safety committee 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.
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Unlikely to occur, but possible in the
fleet/inventory.
4.5.3Risk Assessment
After assessment of the severity and probability of a hazard, key
departments and the safety committeewill 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 thevice president of safety. This procedure also will be
followed if there are issues where there is a lack of consensus by the
department involved and the safety committee.
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 General Manager.
1/E | 2/E | 3/D | 3/E | 4/A | 4/B
|
Acceptable - with review by Project Manager
4/C | 4/D | 4/E |Acceptable - without review.
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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-approved training courses.
4.6. Follow-Up
Follow-up of implemented resolutions is the responsibility of both the safety department, 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 safety department will be responsible
for taking appropriate action.
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Section 5. SSEPP Program Roles and
Responsibilities
5.1. Philosophy
MV hopes to ensure that, if confronted with a security event or major emergency, personnel will
respond effectively, using good judgment, ensuring due diligence, and building on best practices,
identified in drills, training, rules and procedures.
This level of proficiency requires the establishment of formal mechanisms to be used by all personnel to
identify security threats and vulnerabilities associated with MV Transportation operations, and to
develop controls to eliminate or minimize them. SSEPP also requires MV Transportation process for:
Coordinating with local law enforcement and other public safety agencies
to manage response to an incident that occurs on a transit vehicle or
affects transit operations, and
Identifying a process for integrating MV Transportation resources and
capabilities into the community response effort to support management
of a major event affecting the community.
Management expects all employees, and contractors, especially those
working directly with passengers, to support the SSEPP.
5.2. Division of Responsibilities
5.2.1All Personnel
MV personnel must understand and adopt their specific roles and
responsibilities, as identified in the SSEPP, thereby increasing their own
personal safety and the safety of their passengers, during normal
operations and in emergency conditions.
To ensure the success of the SSEPP, the following functions must be
performed by MV Transportationpersonnel:
Immediately reporting all suspicious activity, no matter how insignificant
it may seem, to the general manager or his/her designee.
Immediately reporting all security incidents.
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Using proper judgment when managing disruptive passengers and
potentially volatile situations.
Participation in all security and emergency preparedness training,
including drills and exercises; with at least one drill performed annually
at each division.
Becoming familiar with, and operating within all security and emergency
preparedness procedures for the assigned work activity.
Notifying the general manager or his/her designee when a physical or
mental condition, or required medications or therapies, may impair an
individual’s ability to perform security or emergency preparedness
functions.
Accurately completing “employee statements” on appropriate reports.
5.2.2Senior Vice President of Safety & Training
Under the authority of the MV’s Board of Directors and the chief operating
officer (COO), the senior vice president safety has the overall authority to
develop and execute the agency’s SSEPP . Ultimate accountability for
implementation of the SSEPP rests with the MV’sgeneral managers at the
divisions. In addition, the general manager is responsible for the following
specific activities at their division:
Ensuring that sufficient resources and attention are devoted to the
SSEPP, including:
―Implementation of standard localized operating procedures
related to employee security duties.
―Enforcement of company safety and security regulations at their
division.
―Implementation of emergency operating procedures to maximize
transit response effectiveness and minimizing system
interruptions during emergencies and security incidents.
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―Provision of proper training and equipment to division employees
to allow an effective response to security incidents and
emergencies.
―Ensuring all employees receive security awareness training.
―Annual drills to measure effectiveness.
Development of a localized effective notification and reporting system
for security incidents and emergencies.
Designating a point of contact (POC) to manage the SSEPP (this could
be the operations manager or location safety manager).
Communicating security and emergency preparedness as top priorities
to all employees.
Developing relations with outside organizations that contribute to the
SSEPP, including local public safety and emergency planning agencies.
Establishing and implementing a voluntary location safety committee
(LSC).
5.2.3SSEPP Program Point of Contact (POC)
To ensure coordinated development and implementation of the SSEPP,
thesenior vice president of safety and general manager has designated
Safety Manager as the Security and Emergency Preparedness Point of
Contact (POC) for development and implementation of the SSEPP. The
POC, who reports directly to the general manager has been granted the
authority to use MV’sresources to develop the SSEPP, and to monitor its
implementation, and to ensure attainment of security and emergency
preparedness goals and objectives.
The POC has the responsibility for overseeing the SSEPP on a daily basis.
The POC will be the direct liaison with the division’s operators and
dispatchers, regarding the plan. The POC will also serve as the TO Transit
primary contact with MV. To the extent that liaison is necessary with state
and federal agencies, the POC will serve as the lead liaison for the agency.
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The POC will also be responsible for the security-related agenda items for
location safety committee meetings and actions. In managing the program,
in concurrence with the client, the POC will:
Be responsible for successfully administering the SSEPP and
establishing, monitoring, and reporting on the system’s security and
emergency preparedness objectives.
Review current agency safety, security and emergency policies,
procedures, and plans, and identifying needed improvements.
Develop and implement plans for addressing identified improvements.
Coordinate with local public safety agencies, local community emergency
planning agencies, and local human services agencies to address security
and emergency preparedness; including participation in formal meetings
and committees.
Develop, publish, and enforce reasonable procedures pertinent to agency
activities for security and emergency preparedness.
Provide adequate driver training and continuing instruction for all
employees,and contractors regarding security and emergency
preparedness.
Review new agency purchases to identify security related impacts.
Ensure performance of at least one (1) emergency exercise annually.
5.2.4Location Safety Committee (LSC)
Given the nature and scope of the MV’s operations, it has been determined
that a separate security committee is unnecessary. As a continuing
responsibility of the LSC, there will be a permanent agenda oriented
toward security and emergency preparedness matters, ranging from
comments on the management of the SSEPP to liaison with public
agencies and feedback from employees. It will also be an ongoing part of
the security agenda to determine the level of compliance with agency
policies, rules, regulations, standards, codes, procedures, and to identify
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changes or new challenges as a result of incidents or other operating
experience.
The POC will be responsible for managing the security agenda during the
LSC meetings. When appropriate, members of local fire and police
departments will be invited to participate in the security portion of the
safety committee meetings.
The LSC provides the primary mechanism through which the division:
Identifies security conditions and problems at the agency.
Organizes incident investigations and develops and evaluates corrective
actions to address findings.
Obtains data on agency security performance.
Develops strategies for addressing agency security problems.
Coordinates the sharing of security responsibilities and information.
Manages the integration of security initiatives and policies in agency
operations.
Evaluates the effectiveness of the security program.
Ensures document reviews and configuration management.
Manages the development and revising of agency policies, procedures,
and rulebook.
Coordinates interaction with external agencies.
The LSC also ensures that all agency employees, and contractors:
Have a full knowledge of the security program and emergency
preparedness programs.
Make security and emergency preparedness a primary concern while on
the job.
Cooperate fully with the agency regarding any incident investigation.
Raise security and emergency preparedness concerns.
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5.2.5Supervisors
Supervisors are responsible for communicating the transit agency’s security policies to all employees,
and contractors. For this reason, supervisors must have full knowledge of all security rules and policies.
Supervisors must communicate those policies to MV operations personnel in a manner that encourages
them to incorporate SSEPP practices into their everyday work. The specific responsibilities of
supervisors include the following:
Ensuring that drivers make security and emergency preparedness a
primary concern when on the job.
Cooperating fully with the SSEPP regarding any accident investigations
as well as listening and acting upon any security concerns raised by the
drivers.
Immediately reporting security concerns to the general manager.
Having full knowledge of all standard and emergency operating
procedures.
In addition, when responding to an incident, supervisors are expected to:
Provide leadership and direction to employees during security incidents.
Handle minor non-threatening rule violations.
Defuse minor arguments.
Determine when to call for assistance.
Make decisions regarding the continuance of operations.
Respond to fare disputes and service complaints.
Respond to security related calls with police officers when required,
rendering assistance with crowd control, victim/witness information
gathering, and general on-scene assistance.
Complete necessary security related reports.
Take photographs of damage and injuries.
Coordinate with all outside agencies at incident scenes.
5.2.6Bus Operators
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In addition to the general responsibilities identified for all personnel, bus
operators are responsible for exercising maximum care and good judgment
in identifying and reporting suspicious activities, in managing security
incidents, and in responding to emergencies. Each operator will:
Take charge of a security incident scene until the arrival of supervisory
or emergency personnel.
Collect fares in accordance withcontract and/or divisionpolicy.
Attempt to handle minor non-threatening rule violations.
Respond verbally to complaints.
Attempt to defuse minor arguments.
Determine when to call for assistance.
Maintain control of the vehicle.
Report all security incidents to agency dispatch.
Complete all necessary safety-related reports support community
emergency response activities as directed by MV policies and
procedures.
5.2.7Other Personnel
Other personnel who support MV also have responsibilities for the SSEPP
Program.
Dispatchers are expected to:
Receive calls for assistance.
Dispatch supervisors and emergency response personnel.
Coordinate with law enforcement and emergency medical service
communications centers.
Notify supervisory and management staff of incidents.
Establish on-scene communication.
Complete any required safety-related reports.
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Provide direction to on-scene personnel.
Mechanics (including contractors) are expected to:
Report vandalism.
Report threats and vulnerabilities of vehicle storage facilities.
Provide priority response to safety and security critical items such as
lighting.
Maintain facility alarm systems.
Human Resources personnel are responsible for:
Ensuring all pre-employment screening processes are carried out
effectively.
Notifying the executive director of employee disciplinary action that may
result in the affected employee becoming a risk to MV facilities, systems,
passengers, employees, or other assets.
Educating employees on employee identification policy and procedure.
Communications (Marketing-Customer Service-Community Relations) are
responsible for:
Requesting assistance from transit public safety resources as needed for
special events, usually from our client(s).
Providing insight into potential threats and vulnerabilities through
feedback from customer focus groups and other information sources.
Designating a public information officer (PIO) for media contact
regarding security incidents and issues.
Coordinating community oriented policing efforts and programs with
officers assigned to community oriented policing duties by the public
safety and security administrator.
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5.3. Responsibility Matrices
The operation of MV’s servicesrequires a continual emphasis on security,
this includes: procurement of new systems and equipment, hiring and
training of employees, management of the agency and the provision of
service, and the rehabilitation and disposal of existing equipment and
facilities. The security function must be supported by an effective
capability for emergency response, both to support resolution of incidents
which occur on transit property and events which affect the surrounding
community served by MV.
Tasks have been identified to provide direction in implementation of this
SSEPP. These tasks are on-going and are considered minimum
requirements. Tasks are identified in the matrices below. Also identified
is the organizational/participant responsibilities for each task, as
designated by the following code:
P Primary Task Responsibility. The identified participant(s) is (are)
responsible for the preparation of the specified documentation.
S Secondary or Support Responsibility. The identified participant(s)
is (are) to provide the necessary support to accomplish and
document the task.
R Review/Comment Responsibility. The identified participant(s) is
(are) to review and provide comment on the task or requirement.
A Approval Responsibility. The identified participant is to review,
comment and subsequently approve the task or requirement.
A security task matrix should be presented showing interfaces with other
units and the key activities required, including the frequency of those
activities
System Security
System Security Tasks GM POC Safety
Committee
Ops &
Maint.
Supervisor Dispatch Frequency
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Emergency Preparedness
5.4. Existing SSEPP Capabilities and Practices
A summary of the existing proactive methods, procedures, and actions to prevent, deter, or minimize
security incidents include:
Emphasis on agency personnel awareness.
Participation in security awareness training.
Host annual meeting with local law enforcement.
Annual meeting with local emergency management agency.
Analysis of security incidences and suspicious activity to determine a
proper course of action including:
―Identifying potential and existing problem areas.
―Developing action plans.
―Implementing the plans.
―Measuring results.
Conduct criminal
background investigatgions
of employment applicants
X
Conduct facility walk around
inspections
X X X
Check division security
equipment such as cameras,
fences, gates, lighting, etc.
X
Check and challenge unkn
own personnel on property
X
Emergency Preparedness GM POC Safety
Committee
Ops &
Maint.
Supervisor Dispatch Frequency
Meet and look at security /
emergency plan
X Quart.
Conduct division security /
Emergency awareness drill
X X Y, AR
Update and maintain
emergency response plan
X X
Check emergency
preparedness inventory
items
X X X
Investigate any suspicious
activities or unusual events
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Review of transit agency emergency plans.
Review of MV documentation on system security and emergency
preparedness.
Evaluation of security/emergency response procedures for completeness
and accuracy.
A summary of other existing proactive actions and systems to prevent, deter or minimize security
incidences includes:
Conducting security surveys with local law enforcement as a formal
threat and vulnerability analysis process.
Local police notification/participation in employee discharge and/or
discipline process as needed.
Evaluation of security/emergency response procedures for completeness
and accuracy.
Participation by local law enforcement in training of new drivers as
requested to increase awareness in security matters.
Presentations by local police and transit agency personnel to employees,
the public or other groups interested in transit security matters.
Development and distribution of crime prevention information on
agency brochure for passengers and the public.
5.5. Training and Exercising
The division should formulate SSEPP training and exercising plan, taking into account the considerations
identified below:
This section should describe basic and refresher security and emergency
related training programs for personnel with associated responsibilities
Description of all security-related training including refresher for non-
security staff provided, including content, duration, grading standards,
and maintaining course content for each training class.
Description of the process used to identify security-related training
needs, to develop and present training classes, and to determine
qualifications for instructors.
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This section should explain how MV determines what training to offer
and ensures that all individuals are trained appropriately. This should
include a discussion of the required qualifications for instructors
5.6. Coordination with Local Public Safety Agencies
Identify (by name and contact number) the local law enforcement, fire services, emergency medical
services, and emergency planning agencies within the transit agency’s service area
To support improved emergency and incident preparedness and response, MV Transportation, Inc. will
participate in, at a minimum, one exercise or drill with local public safety organizations in order to:
Review current plans and policies.
Identify current security and emergency considerations.
Develop procedures, if necessary.
Establish and maintain ongoing communication.
5.7. Coordination with Other Transit Providers
Identify (by name and contact number) transit agencies or other contract providers within your county
or neighboring counties that may need to be contacted in the event of a critical incident.
Security Incident Recording
The safety manager records all criminal activity that takes place on the system. Much of what the
agency records is also reported to the National Transit Database (NTD) on a periodic basis. The NTD’s
guidelines for what activities to report and when are found at
http://www.ntdprogram.gov/ntdprogram/safety.htm. The safety manager completes a
standardized report that identifies all significant security incidents involving transit agency staff,
contractors, patrons, equipment or facilities. This standardized form including the crime results from the
previous calendar year is shown on the Reported Transit Crimes form below.
Reported Transit Crimes
Security Incident Number of Occurrences
Bomb threat 0
Bombing 0
Terrorism-related
incidents
Chemical/biological/radiological/nuclear (CBRN)
release
0
Other system security
incidents
Arson 0
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Security Incident Number of Occurrences
Sabotage 0
Hijacking 0
Cyber security event 0
Aggravated assault 0
Burglary 0
Fare evasion1 0
Forcible rape 0
Larceny/theft 0
Homicide 0
Motor vehicle theft 0
Robbery 0
Suicide 0
Trespassing1 0
Other personal
incidents
Vandalism1 0
5.8. Security Incidents Trend Analysis
MV has developed internal metrics to facilitate trend analysis. The results of the analysis can assist the
division in allocating resources and supporting security enhancements and fixed site improvements.
Using the annual standardized form, the safety manager records all significant security incidents on a
year-by-year basis to identify trends in criminal activity. The results of the analysis are contained in
Transit Crime Trends form below.
1Report only those incidents that result in arrests.
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Transit Crime Trends
Number of Occurrences
Security Incident
2019 2020 2021
Percentage
Change
Bomb threat 0 0 0
Bombing 0 0 0
Terrorism-
related
incidents
CBRN release 0 0 0
Arson 0 0 1
Sabotage 0 0 0
Hijacking 0 0 0
Other system
security
incidents
Cyber security 0 0 0
Aggravated
assault
0 0 0
Burglary 0 0 0
Fare evasion1 0 0 0
Forcible rape 0 0 0
Larceny/theft 0 0 0
Homicide 0 0 0
Vehicle theft 0 0 0
Robbery 0 0 0
Suicide 0 0 0
Trespassing2 0 0 0
Other
personal
incidents
Vandalism2
2Report only those incidents that result in arrests.
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5.8.1Facility Security
Crime and terrorism prevention in the transit environment begins with the
securing of facilities where passengers are present, where personnel work
and where vehicles are stored. This requires a keen awareness of security
issues and close cooperation among all levels of transit personnel. MV’s
facilities have security features to limit the chances of a security breach or
attack on the system. For a more detailed description of the security
functions, capabilities and provisions that are common at each facility, see
the Facility Security Features form below.
Facility Security Features
External
Fencing X
Lighting X
Sensors
Guard post
Gate arms X
Motion detectors
Burglar systems
Intrusion alarms
Closed-circuit TV (CCTV)X
Public address systems
Panic button (to police or security)
Card or controlled access X
Law enforcement presence (24/7)
Security guard presence (off-hours)
Law enforcement patrol X
Law enforcement canine patrol
Internal
Intrusion alarms
Motion detectors
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Closed-circuit TV (CCTV)
Card or controlled access X
Public address systems
5.8.2Vehicle Security
MV has implemented some security features and practices for increasing the
safety and security of its vehicles. In addition to security equipment,
vehicle operators are currently required to perform inspections on their
assigned vehicles at the beginning and end of each work shift. The
inspection checklists are tailored for each vehicle and reviewed daily by
maintenance personnel who are responsible for correcting problems. The
inspections include but are not limited to identification of suspicious
packages.
Vehicle Security Features
Security features Rail cars Buses Support
Vehicles
Automatic vehicle location (AVL)
system X
Global positioning system (GPS) X
Radios X
Direct phone
Covert or silent alarms X
Radio speakers X
Driver’s only speakers
Onboard cameras (audio
capable)X
Audio microphones X
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5.8.3Management Information Systems Security(MISS)
MV’s information technology (IT) team maintains a firewall-protected
intranet system for management and other personnel. MV has procured
standard virus protection software and firewalls to protect its information
technology infrastructure. For security purposes, the MISS team maintains
a list of the users who have access to the system. Additionally, the system
requires each employee to enter a username and password at log-in.
5.9. Internal Security Practices
This SSEPP includes internal security practices and procedures that are adhered to by all employees and
contractors. Specific components deal with the personnel hiring and termination process, personnel
identification and access control, and security awareness. Most requirements are directed toward the
agency’s employees and its contractor staff; however, some of these requirements apply to
subcontractors, vendors, building tenants, visitors and patrons. The Security Procedures form below
identifies which security procedures MV has in place.
Security Procedures
Security Procedures Security Procedures
Exist?Source Document
Background investigation3 X
Badging and uniforms3 X
Communication with passengers X
Identifying suspicious behavior X
Passenger and baggage screening4
Safe mail package handling
3Refer to TSA guidance document titled “Additional Guidance on Background Checks, Redress and Immigration Status”
(http://www.tsa.gov/assets/pdf/guidance_employee_background_checks.pdf)
4Ensure that procedures are ADA compliant and therefore consider and include passengers with disabilities, the elderly and
their baggage.
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Sensitive security information
Security procurement language checklist
Termination
Trash container procurement and
placement
Unattended items
Vehicle security sweeps
5.10. External Security Component
The interface between MV and other local, state and federal governmental
agencies exists on all levels. These interfaces and relationships ensure that
communications are ongoing and that the development and
implementation of various security-related activities occur, including
exercises, simulations, drills and training.
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Section 6. Threat and Vulnerability Resolution
Process
6.1. Threat, Vulnerability and Consequence
Identification and Resoulution
The inherently open nature of transit systems can be exploited by criminals, terrorists or other
adversaries to commit crimes, acts of violence and other malicious and destructive acts. The greatest
vulnerability and challenge faced by most transit systems with regard to security is how to maintain an
open and inviting environment that is easily accessible to all members of the public while concurrently
maintaining a level of security that prevents or minimizes, to the greatest extent possible, the
occurrence of such acts throughout the system. Key steps to prevent, minimize and prepare for criminal
and/or terrorist acts within or directed toward the agency’s operations and services are designed to do
the following:
Identify potential threats facing the agency.
Identify vulnerabilities within transit operations and services that may be
exploited to carry out these threats.
Analyze the potential impacts of each threat and vulnerability scenario.
Develop and implement corrective actions and countermeasures to
eliminate, minimize or otherwise prepare for attacks.
Protect against identified threats and vulnerabilities.
6.2. Threat and Vulnerability Identification
Threat and vulnerability assessment offers MV the ability to identify critical assets and their
vulnerabilities to threats, to develop and implement countermeasures, and to monitor and improve
program effectiveness. This analysis is guided by clear investigation of three critical questions:
Which assets can we least afford to lose?
What is our responsibility to protect these assets?
Where do we assume total liability for risk, and where do we transfer risk
to local public responders, technical specialists, insurance companies,
and the Federal Government?
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The primary method used by MV to identify the threats to the transit system and the vulnerabilities of
the system is the collection of incident reports submitted by drivers and supervisors and information
provided by local law enforcement and contractors.
Information resources include the following:
Operator incident reports.
Risk management reports.
Bus maintenance reports.
Marketing surveys.
Passengers’letters and telephone calls.
Management's written concerns.
Staff meeting notes.
Statistical reports.
Special requests.
Type of incidents.
―Crimes against persons.
―Crimes against property.
―General incidents.
Disposition of incidents (same as disposition of call for service).
The safety manager will review security information resources and determine if additional methods
should be used to identify system threats and vulnerabilities such as a formal evaluation of the program
to ensure that security procedures are maintained and that security systems are operable.
Security testing and inspections may be conducted to assess the vulnerability of the transit system.
Testing and inspection includes the following three-phase approach:
Equipment preparedness:To ensure that security equipment is operable
and in the location where it belongs.
Employee proficiency: To ensure that employees know how and when to
use security equipment.
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System effectiveness: To evaluate security by employing security system
exercises.
6.3. Threat and Vulnerability Assessment
The threats which are most likely to occur include the following disruptive incidents:
Drunkenness.
Disorderly conduct.
Disputes.
Minor assaults.
Vandalism.
Inclement weather.
Other potential occurrences include:
Fare evasion.
Loud radios/behavior.
Smoking.
Littering.
Eating/drinking.
Using the table below, the safety manager can make an assessment concerning how susceptible each
system element of MV is to each listed threat.
The safety manager uses a scale of 1 to 4 for ranking each system element’s vulnerability, one being the
lowest (or not vulnerable), to four being the most vulnerable.
Threats
System
Elements
Eating &
Drinking
Disputes Intoxication Minor
Assaults
Vandalism Inclement
Weather
Smoking
Vehicles 1 1 1 1 1 1 1
Office
Personnel 1 1 1 1 1 1 1
Drivers 1 1 1 1 1 1 1
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When considering threat and vulnerability resolutions and the prevention of incidents,the safety
manager will review current methods to determine if additional means can be identified to address
security risks through three possible alternative approaches:
Eliminate.
Mitigate.
Accept.
Each approach will be investigated by the safety manager to determine and develop a course of action
acceptable by MV’s management.
6.4. All Hazards Threat and Vulnerability Identification
and Analysis
Threat analysis is a process that enables transit systems to “define the level or degree of the threats
against a facility by evaluating the intent, motivation, and possible tactics of those who may carry them
out.” Vulnerability analysis is described by the FTA as a process that can be used by transit systems to
identify “specific weaknesses with respect to how they may invite and permit a threat to be
accomplished.”
Through these forms of analysis, transit systems are able to better identify and evaluate the security-
related risks that exist not only within their systems, but also within the operating environments and
surrounding communities through which their services are provided. This can be a complex process that
may require the involvement of outside parties, including local, state or federal law enforcement and
emergency response agency representatives, and/or security experts.
The analysis process involves gathering and evaluating relevant information, including but not limited to
the following:
Security practices, protocols, crime deterrents and other
countermeasures currently in place within the system, including an
evaluation of their effectiveness.
Historical data pertaining to past security breaches and other security-
related incidents directed toward the system or toward other similar
systems.
Crime rate data in the communities and areas surrounding the system.
Site layout information, such as the ease of accessibility, location of
incoming utilities, hazardous storage materials locations, types of
building construction, levels of lighting, etc.
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Existing criminal or terrorist threats that may be present within the
system’s operating environment or that may be directed toward the
surrounding communities, state or nation as a whole and may impact the
system.
The response capabilities of the transit system and local emergency
responders, such as police and fire.
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Section 7. Evaluation and Modification of the SSEPP
7.1. Evaluation
7.1.1Internal
The SSEPP is a “living document” and needs to address issues associated
with system security and emergency preparedness on a timely and
proactive basis. It is incumbent upon all appropriate MV personnel to
constantly evaluate the effectiveness of the SSEPP as well as its
implementation. The safety manager and/or the POC ensures that the
SSEPP is evaluated for effectiveness.
7.2. Modification and Update
MV will revise the SSEPP, supporting documentation, and training to
reflect new practices, policies, and procedures on annual basis. The safety
manageris responsible for screening changes and modifications to facilitate
ongoing revisions to keep the SSEPP current. Safety manager is
responsible to see that the LSC meets and conducts security/emergency
preparedness meetings on a regular or quarterly basis. The Plan should be
updated every year by July 1st.
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Section 8. Threat Levels and Alerts
MV recognizes the threat condition designations as defined by the Homeland Security Presidential
Directive-3, which pertain primarily to federal departments and agencies. MV’s role and application of
the federal threat models are identified herein and will be dependent upon the nature and extent of the
security threats to both the transit operating system and the nation as a whole. MV’s preparedness and
response actions for each threat condition designation have been developed in accordance with FTA’s
recommended protective measures. Additionally, MV keeps current of the federal threat level in
addition to regularly receiving and monitoring alerts distributed by other organizations, including the
FBI.
8.1. Homeland Security Advisory
System (HSAS) for Transit
The FTA, through its Transit Agency Security and Emergency
Management Protective Measures guidance document (November
2006) provides a set of suggested protective measures and a
systematic approach for its application to enhance transit security and
emergency management. The protectivemeasures align with the
color-coded threat conditions used in the DHS Homeland Security
Advisory System (HSAS). HSAS for Transit consists of five threat level
designations: Low (green), Guarded (blue), Elevated (yellow), High
(orange) and Severe (red).
In addition, the FTA provides two (2) additional threat levels and
associated protective measures. They are the active incident (an
actual emergency, which might include a terrorist attack, accident or
natural disaster) and the recovery phase following an incident. MV
uses the HSAS for Transit as a guide for its own preparation and response to threat conditions.
8.1.1Low Condition (Green)
This condition is declared when there is a low risk of terrorist attacks.
MV’s activities at green include the following:
Preparing security and emergency preparedness-related plans, including
emergency operating procedures, emergency response procedures,
contingency planning, communications planning, information
technology/disaster recovery planning and others as needed.
Completing inventory of each department’s supplies, equipment and
other resources that may be needed to execute any portion of the plans.
HSAS
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Refining and exercising as appropriate preplanned protective measures.
Ensuring that personnel receive proper training on the Homeland
Security Advisory System.
Institutionalizing a process to ensure that all facilities and regulated
sectors are regularly assessed for vulnerabilities to terrorist attacks and
that all reasonable measures are taken to mitigate these vulnerabilities.
8.1.2Guarded Condition (Blue)
This condition is declared when there is a general risk of terrorist attacks.
MV’s activities at blue include the following:
Practicing all of the security and emergency preparedness plans and
procedures and determining what steps should be undertaken in
managing an incident.
Testing equipment and systems.
Rechecking inventories of supplies, maintenance logs and new supplies
ordered.
Designing new drills and exercises and executing emergency, disaster
recovery, and contingency operations capabilities.
Developing and disseminating as appropriate public awareness
information for security and emergency preparedness.
Reviewing all security and emergency preparedness plans, and on a
regular basis identifying any problems, shortcomings or issues through
drills and exercise after-action reports.
Checking communications with designated emergency response or
command locations.
Reviewing and updating emergency response procedures.
8.1.3Elevated Condition (Yellow)
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This condition is declared when there is an elevated risk of terrorist
attacks. MV’s activities at yellow include the following:
Increasing surveillance of critical locations.
Coordinating emergency plans and procedures, and checking to see if
other protective measures need to be put in place based on the threat
information.
Initiating contingency activities as appropriate (such as checking that
equipment and alternate operating locations are available and equipment
processes and procedures are operating properly).
Coordinating emergency plans as appropriate with nearby jurisdictions.
Assessing whether the precise characteristics of the threat require further
refinement of preplanned protective measures.
Implementing, as appropriate, contingency and emergency response
plans.
8.1.4High Condition (Orange)
This condition is declared when there is a high risk of terrorist attacks.
MV’s activities at orange include the following:
Coordinating necessary security efforts with federal, state and local law
enforcement agencies.
Preparing for the activation of emergency and contingency plans.
Restricting access to agency facilities and limiting access to threatened
facilities to essential personnel only.
Taking additional precautions at public events and possibly considering
alternative venues or even cancellation.
Preparing to execute contingency procedures, such as moving command
and control to an alternate site or dispersing the work force.
8.1.5Severe Condition (Red)
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This condition is declared when there is a severe risk of terrorist attacks.
Under most circumstances, the protective measures for a severe condition
are not intended to be sustained for substantial periods of time. In
addition, this threat condition indicates that a severe risk of terrorist
activity or an incident or emergency is imminent. However, this does not
mean that MV’s is under attack or has an active emergency ongoing. MV’s
activities at red include the following:
Increasing or redirecting personnel to address critical emergency needs.
Assigning emergency response personnel and pre-positioning and
mobilizing specially trained teams or resources.
Monitoring, redirecting or constraining transportation systems.
Closing public transit and government facilities.
8.1.6Active Incident
At this phase, an attack against the transit agency or an agency’s service
area is occurring or has occurred.
MV’s activities at this phase include the following:
Responding to casualties.
Assisting in evacuations.
Reporting incident (see Section 5.4)
Inspecting and securing transit facilities.
Helping with other tasks directed by local emergency management
personnel.
8.1.7Recovery Phase
At this phase, the recovery of transit service after an attack has occurred. It
follows the previous phase (active incident) and may also exist for short
time periods when the agency is transitioning from a higher threat
condition to a lower threat condition. This phase coexists with the
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prevailing threat condition. In other words, business recovery will be
accomplished while maintaining the prevailing readiness status. MV’s
activities at this phase include the following:
Restoring service, routes and schedules.
Repairing or reopening facilities.
Adjusting staff work schedules and duty assignments.
Responding to customer inquiries about services.
Undertaking other activities necessary to restore transit service.
8.2. Federal Bureau of Investigation Alerts
MV regularly monitors, examines and evaluates the security alerts distributed by the FBI. These alerts
help identify current security issues and threats affecting the nation as a whole. MV distributes the list
to selected individuals of the agency. Any questions or concerns relating to the FBI security alerts should
be addressed directly to the local field office of the FBI.
Address:_8002 Kew Gardens Rd Kew Gardens, NY 11415 (718)286-7100
8.3. Public Transit- Information Sharing and Analysis
Center (PT-ISAC)
MV regularly reviews information disseminated by the PT-ISAC. In January 2003, the U.S. Department of
Transportation designated the American Public Transportation Association (APTA) as the sector
coordinator in the creation of a Public Transit ISAC to further promote security for the public
transportation industry. Through this role, APTA serves as the primary contact to organize and bring the
public transportation community together to work cooperatively on physical and cyber-security issues.
The PT-ISAC collects, analyzes, and distributes critical cyber and physical security and threat information
from government and numerous other sources. These sources include law enforcement, government
operations centers, the intelligence community, the U.S. military, academia, IT vendors, the
International Computer Emergency Response Team (CERT) and others. The PT-ISAC is full-service,
responding to incidents and warnings on a 24-hour basis, seven days a week. Any questions concerning
the service should be directed to:
PT-ISAC
1-866-PT-ISAC-1 (784-7221)
www.surfacetransportationisac.org
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8.4. Homeland Security Information Network – Public
Transit (HSIN-PT)
MVregularly reviews information disseminated by TSA through DHS’s HSIN-PT. HSIN-PT is a security
information sharing resource for the public transit community to share unclassified security and threat
information and establish relationships and network with both private and public transportation security
officials. HSIN-PT provides the transit security community a “one-stop shop” to aid in its efforts to
maintain vigilance and readiness to prevent terrorism in the mass transit and passenger rail
environment. TSA also uses its emergency notification system, called TSAalerts, sometimes in
conjunction with HSIN-PT, to advise transit agencies of significant threats or terrorist attacks.
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Section 9. Appendices
9.1. Appendix A Vehicle Safety Program Implications
Vehicle Safety Program Plan
Section Title
Covered Policies And Procedures Additional Issues In SSEPP
Program
1 Management
Commitment safety policy statement
memorandum authorizing system
security and emergency
preparedness (SSEPP)
2 Compliance
Responsibilities
general manager
drivers, mechanics and others
operating agency vehicles
safety incentive program(s)
expanded to address SSEPP
creation of SSEPPpoint of contact
(POC)
Drivers – Initial Hire qualifications
initial training
commitment to address
SSEPPissues in hiring
3
Qualifications
application
interviews
physical requirements
age
knowledge of English
driver licensing
operating skills
criminal /dmv records check
ability to perform simple math
reasonable knowledge of the service
area and ability to read basic maps
a road test given by a designated mv
supervisor is required
expansion of new hire background
check
expansion of new hire application
process to emphasize the
importance of safety, security and
emergency procedures
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Vehicle Safety Program Plan
Section Title
Covered Policies And Procedures Additional Issues In SSEPP
Program
Initital Training
agency policies and procedures
federal and state guidelines and
regulations
pre and post trip inspections
vehicle familiarization
basic operations and maneuvering
special driving conditions
backing
bad weather
boarding and alighting passengers
defensive driving course (LLLC)
passenger assistance training
training on road
additional training to address
security awareness, reporting
suspicious activity, reports and
documentation, and pre and post
trip inspections
4
Drivers – Ongoing
Supervision And
Training
training – refresher/retraining
evaluation and supervision
motor vehicle record checks
annual physical examination
safety meetings
discipline/recognition
preventable accidents/injuries
additional refersher training for
knowledge of emergency
procedures
additional responsiblities for
supervision
5 Emergency Driving
Procedures
emergency driving procedures
accident causes
slippery road surfaces
driving with poor visibility
driving through water
vehicle breakdowns and unavoidable
stops
vehicle fire/evacuation
hold up/robbery
natural disasters
tornado
flood
expansion of emergency
procedures to include additional
security and emergency
conditions
expansion of emergency
procedures to include support of
community response to a major
event or emergency
emergency training and exercising
6 Passenger Safety
general guidelines
mobility device securement and
passenger restraint systems
expansion of procedures for
managing difficult passengers
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Vehicle Safety Program Plan
Section Title
Covered Policies And Procedures Additional Issues In SSEPP
Program
difficult passengers
medical condition
bloodborne pathogens/infection
control
clarifications regarding first aid
and bloodborne
pathogens/infection control
7 Vehicles &
Equipment
vehicles & equipment
preventive maintenance
program development
preventive maintenance program
format for preventive maintenance
program for transit vehicles
master vehicle service and repair
record – maintenance history
preventive maintenance intervals
pre & post trip inspections
emergency equipment on vehicles and
usage
use of emergency equipment on
vehicles
vehicle security
vehicle safety in and around the shop
or yard
expansion of vehicle security
procedures
expansion of maintenance
procedures for identifying and
reporting vandalism, suspicious
substances, or vehicle tampering
8 Accident
Management
accident documentation packet
accident notification procedures –
driver responsibility
accident investigation – management
responsibility
accident investigation kit
reconstruction & analysis
drug and alcohol tests
additional tools for accident
document packet to address
security
9
Insurance Claims
and Litigation
Management
VTLP
10
Day-To-Day
Operations –
Monitoring For
Safety
record keeping additional reports for security-
related incidents
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9.2. AppendixB: Security Baseline Planning Worksheet
SECURITY BASELINE
PLANNING WORKSHEET
Yes No Notes
Has management accepted responsibility for the
management of security vulnerabilities during the start-up
and operation of the transit system?
X
Has management endorsed a policy to ensure that security
vulnerabilities are identified, communicated, and resolved (or
accepted) through a process that promotes accountability for
decision-making?
L
Does your division have clear and unambiguous lines of
authority and responsibility for ensuring that security is
addressed at all organizational levels within the operation
(including contractors)?
X
Does your division have access to personnel with security
management experience, knowledge, skills, and abilities?
X
Does your division ensure that resources are effectively
allocated to address security considerations?
X
Is the protection of passengers, employees, contractors,
emergency responders, and the general public a priority
whenever activities are planned and performed at the
division ?
Does your division routinely evaluate its capabilities to
provide adequate assurance that the public and employees
are protected from adverse consequences?
Has your division committed to developing security
mitigation measures to prevent and manage security
vulnerabilities?
Has your division appropriately documented its security
measures in plans, procedures, training, and in project
requirements, specifications and contracts?
Does your division have a formal system security program,
documented in a system security program plan.
If “yes,” is the security plan current, reflecting current
security operations and system configuration?
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SECURITY BASELINE
PLANNING WORKSHEET
Yes No Notes
If “no,” does your division have plans in place to develop a
security plan?
If “no,” prepare a brief list of all activities performed at your
division that address security concerns (for example, include
facility access control; procedures for handling difficult
people; workplace violence program; bomb threat
management plan; procedures for identifying and reporting
suspicious activity; facility and vehicle evacuation and search
procedures; coordination with local law enforcement, etc.)
Whenever possible, does your division guidedesign,
engineering, and procurement activity with an agreed-upon
set of security standards and requirements (including design
criteria manuals, vehicle specifications, and contracting
guidelines)?
GENERAL EMERGENCY RESPONSE CAPABILITIES Yes No Notes
Does your division have an emergency plan?
Does your division have emergency operating procedures?
Does your division have an incident response plan for
terrorism, as an appendix to the emergency plan or as a
separate plan?
Does your divisioncoordinate with local public safety
organizations on the development, implementation and
review of the emergency plan and procedures?
Does your emergency plan specify use of the incident
command system?
Have your employees been trained in the emergency plan
and procedures?
Does your division conduct routine drills, table-tops and
refresher training?
Does your divisioncoordinate its drilling and training for
emergency response with local public safety organizations?
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Does your division conduct briefings of after-action reports to
assess performance during the drill or exercise and identify
areas in need of improvement?
Have members of your divisionparticipated in domestic
preparedness training programs?
PREVIOUS EXPERIENCE Yes No Notes
Has your divisionexperienced an emergency in the last 12
months?
If” yes,” were you satisfied with the division’s level of
response?
Has your divisionreceived a bomb threat in the last 12
months?
Has your division evacuated in its facilities in the last 12
months as the result of a bomb threats?
Has your division conducted a physical search of a facility in
response to a bomb threat?
Points of Emphasis
Awareness - Train all security and maintenance personnel to spot suspicious-looking or unfamiliar
people or objects.
Communication - Teach employees and/or tenants the importance of awareness; encourage them to
identify and report anything that appears out-of-the-ordinary.
Screening - Develop and implement systems for identifying and controlling visitor access to the building.
Inspection - Establish strict procedures for the control and inspection of packages and materials
delivered to the building, particularly those intended for critical areas.
Procedures - Instruct all personnel, particularly telephone switchboard or reception personnel, on what
to do if a bomb threat is received.
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Surveillance - Instruct security and maintenance personnel to routinely check unattended public or open
areas, such as rest rooms, stairways, parking garages and elevators.
Lighting - Make sure that all of the facility's access points are well-lit.
Systems Awareness - Unexpected interruptions in the building's fire or security systems may not be
coincidental; train personnel to identify and address them immediately.
Local Authorities - Contact local government agencies to determine their procedures for dealing with
bomb threats, search, removal and disposal.
Contingency - Assure adequate protection and off-site backup for classified documents, proprietary
information, critical records and activities essential to the operation of business.
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9.3. Appendix C:Emergency Response Planning,
Coordination, and Training Considerations
Emergency response planning, coordination, and training is formalized
and documented, and identifies responsibilities of employees by
function.
Service continuation, restoration, and recovery plan developed.
Emergency drills and table-top exercises scheduled on a regular basis.
Coordination and training with outside agencies, including fire and
rescue units,hospitals, police, hazardous materials and environmental
agencies, and regional Office of Emergency Management.
Media relations, information control procedures, and policies established
(internal and external to agency).
Documentation of drills maintained, drill critiques held, and
recommendations recorded with follow-up.
Emergency procedures reviewed by management on a regular basis and
updated as needed.
Procedure revisions and updates incorporated into evacuation
procedures and SOPs developed for signature(s) and distribution.
Regular assessments of employee proficiency conducted.
Emergency contacts list developed, currentand responsibility for call-
outs identified.
Emergency evacuation routing for transit vehicles developed.
Employees issued quick reference guidelines for emergency situations.
Support systems developed to provide post-incident support to
customers and employees.
Regular functional testing and inspection of emergency support
equipment and systems.
Pre-determination of factors that would require partial or full service
shut-down.
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Contingencyplans for loss of electrical power and radio or phone
communications.
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System Security Considerations
Security plan established, which addresses all operations modes and
contracted services.
System security responsibilities and duties established.
Personal safety awareness and education programs for passengers and
employees and community outreach.
Security equipment regularly inspected, maintained and functionally
tested.
Contingency SOPs developed, drills, and table-top exercises conducted
for extraordinary circumstances:
―Terrorism (including chemical, biological agents, and weapons of
mass destruction);riot and domestic unrest; catastrophic natural
events; and system-wide communications failure.
Security SOPs reviewed on a regular basis and updates made as needed
to security plan.
Data collection established for all security issues and incidents, analysis
performed and recommendations made, document control established
including follow-up.
Security risk and vulnerability assessments conducted, documented and
reviewed.
Contingency plans for loss of electrical power and radio or phone
communications.
Standard operating procedures for critical incident command, control,
and service continuation and restoration.
Security training provided to all staff levels (from front-line "eyes and
ears" concept to professional level security training).
Background checks on employees and contractors (where applicable).
Regular assessments of employee security proficiencies conducted.
Employees issued quick reference guidelines for security situations.
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Emergency contacts list developed and kept current, and responsibilities
for call-outs identified.
Visitor, deliveries and contractor facility access procedures developed
and visible identification required.
Concepts of crime prevention through environmental design (CPTED)
applied in reviews of facilities and in new design and modifications.
Security checklists developed and regularly used for verifying status of
physical infrastructure and security procedures.
Agency employees identifiable by visible identification and/or uniform.
Policy and procedures in place for facilities key control.
Planning, coordination, training and mutualaid agreements with external
agencies (state, local police,FBI and other federal agencies.
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9.4. Appendix D: Bomb Threat Checklist and
Procedures
Bomb Threat Checklist
Exact time and date of call:
Exact words of caller:
Voice Accent Manner Background Noise
Loud Local Calm Factory Machines
High Pitched Foreign Rational Bedlam
Raspy Race Coherent Music
Intoxicated Not Local Deliberate Office Machines
Soft Region Righteous Mixed
Deep Local Angry Street Traffic
Pleasant Foreign Irrational Trains
Other Race Incoherent Animals
Raspy Not Local Emotional Quiet
High Pitched Region Laughing Voices
Loud Airplanes
Party Atmosphere
Language Speech Familiarity with Threatened Facility
Excellent Fast Much
Fair Distinct Some
Foul Stutter None
Good Slurred
Poor Slow
Other
Distorted
Pleasant Nasal
Other Lisp
Raspy Other
Questions to Ask the Caller
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Where is the bomb?
What does it look like?
What kind of bomb is it?
What will cause it to explode?
Did you place the bomb?
Why did you place the bomb?
Where are you calling from?
What is your address?
What is your name?
Observations
If the voice is familiar, whom did it sound like?
Were there any background noises?
Telephone number call received at.
Person receiving call.
Any additional remarks.
Bomb Threat Procedures
In recent years the use and threatened use of explosives in society has
increased at an alarming rate. Organizations must prepare a plan of action
to respond effectively. This brief provides guidelines that will assist transit
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agencies in developing a procedure specific to their particular
environment.
Steps to Be Considered
When faced with a bomb threat, the primary concern must always be the
safety of passengers, employees, and emergency responders. Many transit
agencies already have a disaster or emergency procedure for responding to
smoke, fire, or medical emergencies in stations, administrative facilities,
shops, and yards. Several aspects of these procedures remain viable in a
bomb threat procedure.
However, new problems must be addressed when a bomb threat is
received. For example, in the instance of a fire, effort is directed at
evacuating the occupants in a quick and orderly manner. In the case of a
bomb threat, if evacuation is initiated, the exit routes and assembly areas
should be searched prior to vacating the premises. The potential hazard
remains when a building is evacuated before a search has been made.
Personnel cannot safely re-occupy the building and resume normal
activities until a search has been conducted. Such problems require a
procedure with 7 logical steps:
Step 1: Threat Reception
Step 2: Threat Evaluation
Step 3: Search Procedure
Step 4: Locating Unidentified Suspicious Objects
Step 5: Evacuation Procedure
Step 6: Re-occupation of Building
Step 7: Training of Essential Personnel
Each of these steps is discussed below:
Step 1: Threat Reception
Threats are transmitted in several ways:
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Telephone Threats (threat to detonate explosive is phoned into system)
Caller is the person who placed the device.
Caller has knowledge of who placed the device.
Caller wants to disrupt system operation.
Written Threats (threat to detonate explosive is written into system).
May be more serious than phoned-in threats.
Written threats are generally more difficult to trace than phoned-in
threats.
Letter and Package Threats (suspicious package or letter is delivered to
agency).
These threats serve a variety of purposes, but, generally, they are directed
at specific system personnel rather than at the system as a whole.
The personal motivations of the criminal may be more important in these
types of threats.
Bomb threats are normally transmitted by phone. The person receiving the call should be prepared to
obtain precise information, including:
The time the call was received and on which telephone number or
extension.
The exact words of the person making the threat should be recorded.
Indicate whether it was a male or female voice and an approximate age.
Note any accent or speech impediment or slurring of speech which could
indicate intoxication or an unbalanced condition.
Listen for the presence of any background noises such as traffic, music,
or other voices.
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Decide if the voice is familiar.
The person receiving the threatening call should be prepared to ask the
caller certain questions if the information has not been volunteered.
Where is the bomb?
When is it going to explode?
What does it look like?
What kind of bomb is it?
Why did you place the bomb?
What is your name?
The caller may provide specific information by answering these questions. Often the type of person
making a threat of this nature becomes so involved that they will answer questions impulsively. Any
additional information obtained will be helpful to police and explosive technicians. To assist the person
receiving the call, it is suggested a printed form be readily available. A sample is provided in Appendix D.
Typically, this checklist is kept readily available to the transit dispatcher or administrative personnel
most likely to receive such a threat.
Written and letter/package threats should be treated as “suspicious objects” (see Step 4).
Step 2: Threat Evaluation
Two basic descriptions of threats can be identified:
Non-specific threat: This is the most common type of threat, usually with
little information given other than, "There is a bomb in your building."
Specific threat: This threat is given in more detail. Reference is often
made to the exact location of the device, or the time it will detonate.
Specific threats should be considered more serious in nature, requiring a
more concerted effort in the response. The non-specific threat, however,
cannot be ignored. A policy must be developed to respond effectively to
both threat levels.
Certain actions should be taken regardless of the threat category:
Notify law enforcement (whether internal transit police and/or security
or local law enforcement).
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Notify management personnel.
Initiate the search procedure.
Search before evacuation of personnel (employee search).
Search after evacuation of personnel (volunteer search).
Notification to internal and/or external law enforcement, security and management personnel should
be prompt, and include as much detail as possible. The person who received the threatening call should
be available immediately for interviewing. Copies of the completed threat checklist should be readily
available to all who may need it.
The appropriate search procedure should be initiated. Searches in the transit environment – as in many
other environments – have two major constraints:
Radio communication cannot be used (it may detonate the device).
The environment is specialized, therefore, it cannot be searched
effectively by outsiders.
To address these concerns, personnel who work in a particular area, or who are responsible for an area,
should be used. Not only will these personnel provide a much more thorough search than outside
responders, but they are knowledgeable concerning station or facility emergency communication
systems, and can access “land line” telephones to manage communications more effectively during the
search. A system that utilizes the employees – after evacuations have been ordered -- should always
and only use volunteers.
The following criteria help determine what immediate action to take:
Factors favoring a search before the movement of personnel (occupant
search):
―There is a high incidence of hoax telephone threats.
―Effective security arrangements have been established.
―Information in the warning is imprecise or incorrect.
―The caller sounded intoxicated, amused, or very young.
―The prevailing threat of terrorist activity is low.
Factors favoring movement of personnel before searching (volunteer
search):
―The area is comparatively open.
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―Information in the warning is precise as to the matters of location,
a description of the device, the timing, and the motive for the
attack.
―A prevailing threat of terrorist activity is high.
Step 3: Search Procedure
Pre-planning and coordination of employees are essential in implementing an effective search of transit
premises, particularly for large stations and facilities. A central control mechanism is necessary to
ensure a thorough and complete response. A printed station and/or facility schematic should be
identified for each major transit facility. Wherever possible, stations should be divided into zones or
sections (prior to the actual conduct of the search), and volunteer personnel – familiar with the zone or
section – identified to support the search, by shift or position. Back-ups and supporting volunteers
should also be identified for each zone or segment. A compendium of station/facility schematics should
be available to those responsible for managing bomb threats and searches. Not only will these
schematics support identification and assembly of the volunteer search team, but also, as the search is
conducted, each area can be “crossed off” the plan as it is searched.
Areas that are accessible to the public require special attention during a search, and may be vitally
important if an evacuation is to be conducted. The level of the search should be commiserating with the
perceived threat level:
An occupant search is used when the threat's credibility is low.
Occupants search their own areas. The search is completed quickly
because occupants know their area and are most likely to notice anything
unusual.
The volunteer team search is used when the threat's credibility is high.
The search is very thorough and places the minimum number of
personnel at risk. Evacuate the area completely, and ensure that it
remains evacuated until the search is complete. Search teams will make
a slow, thorough, systematic search of the area.
During the search procedure the question often arises, "What am I looking for?" The basic rule is: Look
for something that does not belong, or is out of the ordinary, or out of place. Conduct the search
quickly, yet thoroughly, keeping the search time to a maximum of 15 to 20 minutes. Both the interior
and exterior of the station or facility should be searched.
Historically, the following areas have been used to conceal explosive or hoax devices in the transit
environment:
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Outside Station Areas Inside Stations
Trash cans
Dumpsters
Mailboxes
Bushes
Street drainage systems
Storage areas
Parked cars
Shrubbery
Newspaper Stands
Ceilings with removable panels
Overhead nooks
Areas behind artwork, sculptures and benches
Recently repaired/patched segments of walls, floors, or
ceilings
Elevator shafts
Restrooms
Behind access doors
In crawl spaces
Behind electrical fixtures
In storage areas and utility rooms
Trash receptacles
Mail rooms
Fire hose racks
Depending on the nature of the threat, searches may expand to include transit vehicles. In extremely
rare instances, dispatchers have instructed operators on certain bus routes or rail lines to immediately
bring their vehicles to a safe location, deboard passengers, and walk-through the vehicle – looking for
unidentified packages. In other instances, evacuated vehicles have been met by law enforcement
officers, who actually conduct the search, including the vehicle undercarriage and rooftop areas.
Step 4: Locating an Unidentified Suspicious Package
If an unidentified or suspicious object is found, all personnel should be instructed (1) not to move it and
(2) to report it to central dispatch or the search team leader immediately. The following information is
essential:
Location of the object.
Reason(s) suspected.
Description of the object.
Any other useful information – how difficult to secure area, evacuate,
nearest emergency exits, etc.
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Based on this information, decisions will be made regarding the following:
Removal of persons at risk.
Establishment of perimeter control of the area to ensure that no one
approaches or attempts to move the object.
Activities to establish ownership of the object. (In the event that
legitimate property has been left behind in error prior to the bomb threat
being received).
Assignment of someone familiar with the building and the area where the
object is located to meet the explosives disposal unit personnel on their
arrival (in the event that they have been called).
Continue implementation of search procedure until all areas have
reported to the central control, as there may be more than one
unidentified object.
While volunteers and public safety personnel are conducting the search, and particularly while they are
managing response to a suspicious package, they should keep in mind the following information:
Improvised explosive devices (IEDs) and other types of bombs inflict
casualties in a variety of ways, including the following:
―Blast over pressure (a crushing action on vital components of the
body, eardrums are the most vulnerable).
―Falling structural material.
―Flying debris (especially glass).
―Asphyxiation (lack of oxygen).
―Sudden body translation against rigid barriers or objects (being
picked up and thrown by a pressure wave).
―Bomb fragments.
―Burns from incendiary devices or fires resulting from blast
damage.
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―Inhalation of toxic fumes resulting from fires.
The following are four general rules to follow to avoid injury from an IED:
1. Move as far from a suspicious object as possible without being in further danger from
other hazards such as traffic or secondary sources of explosion.
2. Stay out of the object's line-of-sight, thereby reducing the hazard of injury because of
direct fragmentation.
3. Keep away from glass windows or other materials that could become flying debris.
4. Remain alert for additional or secondary explosive devices in the immediate area,
especially if the existence of a bomb-threat evacuation assembly area has been highly
publicized.
Historically, perpetrators of bombings in the transit environment (in
foreign countries such as Israel, France, India, and England) have used
two tactics that intensify the magnitude of casualties inflicted by
detonation of an explosive device:
―Perpetrators have detonated a small device to bring public safety
personnel to the site; a larger, more deadly device has detonated
some time after the first device, thereby inflicting a large number
of casualties on the first responder community.
―Perpetrators have used a real or simulated device to force the
evacuation of a facility only to detonate a much more substantial
device in identified bomb-threat evacuation assembly areas.
These attacks are especially harmful because the evacuation
assembly areas often concentrate transit personnel and
passengers more densely than would otherwise be the case.
Step 5: Evacuation Procedure
If an unidentified object is found, a quiet and systematic evacuation from the area should be conducted.
Prior to evacuation, all areas used in the evacuation route must be searched: stairwells, corridors,
elevators, and doorways. When these areas have been checked, volunteer personnel should be
assigned to direct other personnel along the searched exit routes.
As a general guideline, evacuation should be to a minimum distance of 300 feet in all directions from the
suspicious package, including the area above and below the site, giving regard to the type of building
construction (thin walls, glass) and the size of the suspicious package. Elevators should not be used to
evacuate people under normal circumstances. A power failure could leave them trapped in a hazardous
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area. Attention should be paid to the need for special transportation requirements of persons with
disabilities.
The essential task in evacuation procedures is to direct people to quietly leave the premises, using tact
and power of suggestion, in an effort to maintain control and avoid panic. Once a complete or partial
evacuation has taken place, there must be some form of accounting for all personnel. This may be a
difficult task, but a necessary one to ensure the safety of all personnel.
Assembly areas should be pre-selected and well known to personnel. Establish a clearly defined
procedure for controlling, marshalling, and checking personnel within the assembly area. If possible, for
major transit stations, assembly areas should be coordinated with local police in advance. Assembly
areas are selected using the following criteria:
Locate assembly areas at least 300 feet from the likely target or building
(if possible).
Locate assembly areas in areas where there is little chance of an IED
being hidden. Open spaces are best. Avoid parking areas because IEDs
can be easily hidden in vehicles.
Select alternate assembly areas to reduce the likelihood of ambush with
a second device or small-arms fire. If possible, search the assembly area
before personnel occupy the space.
Avoid locating assembly areas near expanses of plate glass or windows.
Blast effects can cause windows to be sucked outward rather than blown
inward.
Select multiple assembly areas, if possible, to reduce the concentration
of key personnel. Drill and exercise personnel to go to different assembly
areas to avoid developing an evacuation and emergency pattern that can
be used by perpetrators to attack identifiable key personnel.
Step 6: Re-Occupation of Station/Facility
Re-occupation of the building is a decision that must be made by an appropriate transit agency or law
enforcement official. If the evacuation was made without a search, the premises should be searched
before re-occupation.
Step 7: Training
Any effective threat procedure must be accompanied with an adequate training program. Training the
essential personnel should encompass both the preventative and operational aspects of the procedure.
Prevention can be accomplished through employee awareness, developing good housekeeping habits,
and being on the alert for suspicious items and persons.
Operational training may include lectures by transit police and security instructional staff or guest
speakers, in-service training classes, and practical training exercises. Evacuation and search drills should
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be performed periodically under the supervision of transit police or local law enforcement. Coordination
with local law enforcement is particularly important for those small agencies with no internal security.
Conclusion
Considering recent events, it is advisable to consider all threats serious. A well-prepared and rehearsed
plan will ensure an effective, quick search with minimal disruption of normal operation. Panic and
possible tragedy can be avoided. Appropriate security, heightened employee and passenger awareness,
and good housekeeping controls will identify many potential problems.
9.5. Appendix E: Types of Preparation Exercises
Experience shows that exercises are the most practical, efficient, and cost effective way to prepare for
disasters and crises. The aim for any transit agency should be to develop a progressive exercise program,
a long-term approach in which exercises are planned, conducted, and evaluated as building blocks to
competency in crisis management.
There are two principal benefits of such a program. First, people practice their role and gain proficiency
in crisis management. Second, the coordination among transit providers and local emergency response
agencies is improved. These benefits arise not from exercising alone, but from evaluating the exercise
and acting upon those results. An exercise has value only when it leads to individual and/or collective
improvement.
Key terms used in the development of exercises include the following:
Progressive Exercise Program: A commitment from the transit provider
and community public safety agencies to plan and conduct increasingly
more challenging exercises over a period of time, to achieve and maintain
competency in executing the local crisis management plan.
Objective: A goal expressed in simple, clear, specific, and measurable
terms. Serves as the foundation of all exercise planning.
Scenario: The overall outline of how an exercise will be conducted.
Includes the narrative, majordetailed sequence of events, problems or
messages, and expected actions. Often used interchangeably with the
term narrative.
Narrative: A word “picture” that includes all essential elements of
information concerning the incident used to initiate an exercise.
Types of exercises include the following:
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Drill: Supervised activities that test, develop, or maintain skills in a single
response procedure (such as: communications, notification, lockdown,
fire) and the possible or probable interaction with local government
agency functions (such as: incident command posts, rescue squad entry,
police perimeter control) which will involve actual field response. Helps
prepare for more complex exercises in which several functions are
coordinated and tested.
Exercise: An activity designed to promote emergency preparedness, test
or evaluate emergency operations, policies, plans, procedures or
facilities, train personnel in emergency duties, and demonstrate
operational capabilities.
Full-Scale Exercise: Evaluates the operational capability of emergency
response management systems in an interactive manner. Includes the
mobilization of emergency personnel and resources required to
demonstrate coordination and response capability. Tests total response
capability as close to a real emergency as possible.
Functional Exercise: A fully simulated interactive exercise which tests
one or more functions in a time-pressured realistic simulation and
focuses on policies, procedures, roles, and responsibilities.
Orientation Seminar: An informal discussion designed to familiarize
participants with roles, plans, procedures, and resolve questions of
coordination and assignment of responsibilities.
Tabletop Exercise: Simulates an emergency situation in an informal,
stress-free environment. Designed to elicit discussion as participants
examine and resolve problems based on existing crisis management
plans.
9.6. Appendix F: Reporting Criminal Activity
If you observe a crime in progress or behavior that you suspect is criminal, immediately notify [dispatch
or local police]. Report as much information as possible including:
Activity: What is happening? (In plain language and with as few assumptions as possible)
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Description of involved people: For each involved person, provide:
Height.
Weight.
Gender.
Clothing.
Weapons.
Distinguishing characteristics.
Location: Describe exactly where the criminal activity is occurring. If the activity is “moving,” describe
the direction of travel.
Vehicle: If a vehicle is involved, please provide the following:
Color.
Year.
Make.
Model.
License.
DO NOT APPROACH OR ATTEMPT TO APPREHEND THE PERSON(S) INVOLVED.
Stay on the telephone with the police dispatcher and provide additional information as changes in the
situation occur, until the first police officer arrives at your location.
9.7.Appendix G: Emergency Action Plan
MV facility sites will utilize the emergency action plan template from the
MV Safety Policy Manual to develop a site specific emergency action plan.
COMPANY: MV Transportation Inc.
ADDRESS: 1993 Rancho Conejo Blvd Thousand Oaks, CA
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Emergency Plan Coordinator
Name:
Title:Safety Manager
Department:Transportation
Telephone No:805-231-8761
Preferred Means of Reporting Fires And Other Emergencies
Type of
Emergency:
Reported By:
Fire:911
Explosion:911
Tornado/Weather:911
Bomb Threat:911
Chemical
Spill/Leak:911
Violence:911
Medical:911
Gas:911
Electric:
9.7.1Elements
i. Emergency Escape Procedures and Routes
Emergency escape procedures and route assignments have been
posted in each work area, and all employees have been trained by
designated supervisors in the correct procedures to follow. New
employees are trained when assigned to a work area. A sample
escape procedure and escape route sheet of the type posted in work
areas should be developed. (Identify and attach floor plan and
escape route).
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Procedure for Employees Who Remain to Operate Critical
Operations Before They Evacuate
A single procedure should be developed that describes operations,
procedures, and personnel required in order for critical operations
to be performed before the assigned personnel evacuate during
emergency situations. A description of the special training provided
should also be included.
ii. Employee Accountability Procedures after
Evacuations
Each supervisor is responsible for accounting for all assigned
employees, personally or through a designee, by having all such
employees report to a predetermined designated rally point and
conducting a head count. Each assigned employee must be
accounted for by name. All supervisors are required to report their
head count (by name) to the emergency evacuation coordinator.
iii. Rescue and Medical Duties
Specific rescue and medical duties have been assigned to designated
individuals. These personnel have received special training and
instructions for properly carrying out these assignments.
iv. Alarm System
Alarm systems for notifying all employees in case of an emergency
are:
When so required by specific OSHA Standards, the organization will
comply with OSHA Standard 1910.165, Employee Alarm Systems.
v. Training
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The following personnel have been trained to assist in the safe and
orderly emergency evacuation of other employees. (See also
Appendix B-identify)
Name Title Work Area Special
Assignment
Todd Painter Safety Manager MSC
George Saldana Road Supervisor MSC
Jennifer Singer GM MSC
Training is provided for employees when:
―The plan was initiated.
―Responsibilities change.
―New employees are hired or transferred.
9.7.2Emergency Shutdown Procedures
During some emergency situations, it will be necessary for some
specifically assigned and properly trained employees to remain in work
areas that are being evacuated long enough to perform critical operations.
These assignments are necessary to ensure proper emergency control.
Assignments
Work Area Name Job Title Description of Assignment
Maintenance
Area
Kevin
Hayes Supervisor Maintenance Facility
Manager
Special Training
The preceding individuals have received special instructions and training
by their immediate supervisors to ensure their safety in carrying out the
designated assignments. A training record describing the instructions
I I
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provided and the detailed procedures to be followed is maintained in the
Emergency Action Plan and Fire Protection Plan coordinator’s office.
Emergency and Fire Protection Plan Coordinator:
Name Date
Employee Accountability Procedures Following
An Emergency Evacuation
Each supervisor is responsible for accounting for each assigned employee
following an emergency evacuation. This will be accomplished by
performing the procedures established for such an eventuality.
Employee Accountability
Rally points have been established for all evacuation routes and
procedures. These points are designated on each posted work area
escape route.
All work area supervisors and employees must report to their designated
rally points immediately following an evacuation.
Each employee is responsible for reporting to his or her supervisor so
that an accurate head count can be made. Supervisors will check off the
names of all those reporting and will report those not checked off as
missing to the emergency evacuation coordinator.
The emergency evacuation coordinator will be located at one of the
following locations:
―Primary location.
―Secondary location.
The emergency evacuation coordinator will determine the method to be
utilized to locate missing personnel.
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Rescue and Medical Duties
It may become necessary in an emergency to rescue personnel and perform some specified medical
duties, including first-aid treatment. All employees assigned to perform such duties will have been
properly trained and equipped to carry out their assigned responsibilities properly and safely.
Assignments
Name Location Special
Assignment
Special Training
Provided
Todd Painter MSC First Aid Basic First Aid
George Saldana
Special Instructions and Procedures
All personnel performing emergency rescue and medical duties must follow
these instructions:
9.8. Appendix H –ChemicalHazard Communication
Program Plan
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MV sites will utilize the Hazardous Communication Plan contained within the MV Safety Policy Manual.
An overview of the plan is as follows:
Company Policy – 29 CFR 1910.1200(e)
MV is committed to the prevention of exposures that result in injury and/or illness; and to comply with
29 CFR 1910.1200, OSHA’s Hazard Communication Standard and all applicable state health and safety
rules.
All employees of MV are included under the hazard communication program. This written program will
be available for review by any employee during work hours. It is located in the MV Safety Policy and
Procedures Manual.
Container Labeling – 29 CFR 1910.1200(f)
The safety manager and maintenance manager are jointly responsible for ensuring that all container
labeling procedure are reviewed and updated as needed.
Description of labeling system used:
Original containers received for use will be labeled to indicate at a minimum:
―Warning labels that are legible and in English.
―The name of the chemical.
―Items found on the SDS
―Pertinent physical and health hazards, including the organs that
would be affected.
―The name, address, and phone number of the manufacturer,
importer or responsible party.
Secondary containers will be labeled with at a minimum:
The name of the chemical as it appears on the SDS.
Appropriate hazard warnings.
Material Safety Data Sheets (SDS) – 29 CFR 1910.1200(g)
The safety manager and maintenance manager(s) at each garage are responsible for obtaining and
maintaining the SDSs.
The maintenance manager will review incoming SDS to make sure that they contain all required
information, and for changes in health and safety information. The maintenance manager will make sure
that any new information is passed on to affected employees.
When toxic or hazardous substances are received without the SDS, the maintenance manager will either
call or send a letter to the supplier requesting the SDS. A written record of all SDS requests, whether by
phone or formal letter, will be placed in a special file.
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Employees are not permitted to use any chemicals for which the company does not have the SDS.
SDS will be accessible to all employees during each work shift. Copies of the SDS will be kept in the
maintenance shop at each garage.
Employee Information and Training – 29 CFR 1910.1200(e) (1) (i)
The safety manager and maintenance manager are responsible for the employee training program. They
will ensure that all elements specified below are carried out.
The maintenance managers are responsible for assuring that before starting work, each affected
employee of MV will attend a health and safety orientation that includes information and training on
the following:
An overview of the requirements contained in the OSHA Hazard
Communication Standard.
Hazardous chemicals present at his or her workplace.
Physical and health risks of the hazardous chemical.
The symptoms of overexposure.
How to determine the presence or release of hazardous chemicals in the
workplace.
How to reduce or prevent exposure to hazardous chemicals through use
of control procedures, work practices and (PPE) personal protective
equipment.
Steps MV has taken to reduce or prevent exposure to hazardous
chemicals.
Procedures to follow if employees are overexposed to hazardous
chemicals.
How to read labels and review SDS to obtain hazard information.
Location of the SDS file and written hazard communication program.
Hazardous Non-Routine Tasks– 29 CFR 1910.1200(e) (1) (ii)
Periodically, employees may be required to perform non-routine tasks that involve the use of hazardous
chemicals.
The maintenance manager will provide information about hazardous chemicals to which employees may
be exposed during non-routine tasks prior to employees starting such tasks.
This information will include:
Specific hazards involved.
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Protective measures the employee should take.
Measures the company has taken to lessen the hazard, including
ventilation, respirators, presence of another employee and emergency
procedures.
Informing Contractors – 29 CFR 1910.1200(e) (2)
The safety manager and maintenance manager will provide contractors who have employees at any
maintenance facility the following information:
Toxic and hazardous substances to which the contractor’s employees
may be exposed.
Precautions the employees can take to lessen the possibility of exposure.
Location of the SDS
Before work is started, the maintenance manager will contact each contractor to gather and
disseminate any information concerning chemical hazards that the contractor is bringing into MV’s
workplace. They are also responsible for ensuring that any employees of MVwho is exposed to these
hazards are properly trained and protected.
List of Hazardous Chemicals – 29 CFR 1910.1200(e) (1) (i)
The safety manager and maintenance manager are responsible for preparing and updating the list of all
chemicals in the workplace that are potentially hazardous.
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GENERAL SAFETY REQUIREMENTS & GUIDELINES
SCOPE:
These safety requirements and guidelines apply to all employees and contractors of Transdev
North America, Inc. (Transdev). The general procedures in this section do not address specific
situations or programs in any depth. Other safety policies address individual topics in more
specific details. The intent of this document is to provide a general overview. If there are any
conflicts with specific safety policies, the specific policy will take precedence. Please refer to
those policies for further guidance relevant to your operation
POLICY:
Transdev will make every reasonable effort to provide employees with a workplace that is free
from safety and health hazards. The Transdev General Safety Guidelines and Requirements
establish standards of conduct and specify work conditions that are necessary to help achieve
an incident-free workplace.
ROLES AND RESPONSIBILITIES:
Vice President of Safety: Responsible for the Company’s safety programs and the
development of appropriate safety procedures, programs and protocols.
Regional / Division Safety Director: Leads the safety function in the Region or business
Division. Assists the VP of Safety in the development of appropriate safety programs, policies
and procedures. Provides functional support to the Regional Vice President / Division
President in their safety program implementation and execution efforts. Responsibilities
include:
•Monitor safety performance at each property and provide guidance to General
Managers and Safety Managers as needed to address emerging trends and areas of
concern.
•Provide proactive support and serve as a safety resource for General Managers, Safety
Managers and others in their area of operations.
•Conduct, review and document facility audits and assist in and confirm the correction of
deficiencies.
•Schedule and present safety training programs.
Regional Vice President: Responsible for the implementation and execution of the Company’s
safety programs in his/her area of operations.
General Manager: General Managers at Transdev hold primary responsibility for Transdev’s
safety programs. They are primarily responsible for ensuring that day-to-day activities in their
operations are conducted safely. The General Manager is responsible for the execution of the
APPENDA APPENDIX III
APPENDIX III(#transc:lew
the mobility company
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safety programs activities and ensuring the operational safety of their property’ daily
functions/tasks. They are responsible for maintaining maintenance, environmental and safety-
related records. They schedule training, coordinate with contractors on en vironmental and
safety matters, and serve as the facility liaison with OSHA, fire departments, and other entities
concerned with environmental and safety practices. Training will be provided by management
at least monthly on a variety of relevant topics. All training will be documented in writing and
kept on file at the property/location/facility. Safety programs at each facility consist of but are
not limited to:
• Promote safety awareness and injury/incident prevention with their managers,
supervisors, employees and contractors.
• Ensure all property employees and contractors conduct their day-to-day activities in a
safe manner in accordance with company safe-work practices and policies.
• Perform appropriate inspections of equipment, storage and work practices
• Conduct safety audits and random facility operations inspections.
• Maintain liaison with local agencies.
• Cultivate a thorough knowledge of safety programs, as well as any applicable Federal,
State, or local safety requirements.
• Ensure that work safety records are correctly maintained.
• Select company authorized physicians and clinics with assistance from the Human
Resource, Procurement and Safety Departments
• Investigate collisions, injuries and follow-up on all incident reports, verifying the
accuracy of filed reports, and determining appropriate corrective action.
Property Safety Director/Manager: Assists the General Manager in the implementation and
execution of the safety program requirements and development of appropriate local sa fety
initiatives. Activities include but not limited to:
• Provide support and serve as resource for General Managers and others in their area of
operations toward implementation of safety program requirements.
• Conduct, review and document facility safety inspections and assist in the correction of
deficiencies.
• Schedule and present training programs.
Operations Managers/Supervisor: Supervisors need to be constantly aware of unsafe acts
and conditions capable of causing injury or property damage by:
• Performing daily inspections of the work areas, ensuring that all are in order.
• Frequently checking the tools of employees, both those provided by Transdev, and
those furnished by the employee.
• Checking all fire extinguishers to ensure they are properly located, charged, and
accessible.
• Observing the behavior of employees/contractors, and correcting any unsafe conditions
or practices.
• Ensuring that all posters, warning signs and bulletin s in his or her area are properly
posted.
• Completing injury investigation forms. Supervisors need to assure that both their report
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and that of the employee/contractors are of sufficient detail and clarity to explain the
nature and cause as well as the outcome of the injury causing incident.
• Answering all health and safety questions raised by employees, refer them to an
appropriate source or find out the answer and get back to them. The supervisor should
also be able to inform the employee/contractor of his rights under the Health and Safety
Program and OSHA laws.
• Requiring each employee to attend and complete any scheduled training courses. They
should also make certain that the employee/contractor is comfortable with any on-the-
job training they have been given.
• Ensure employee/contrctor’s compliance with company safety policies & procedures
• Document all training
Employees/Contractors: All Transdev employees and contractors are expected to work in a
safe manner and in compliance with their training and the provisions, requirements and
recommendations of Transdev’s safety policies and safety principles. A copy of the safety
policies/requirements will be available for review at all times in the facility offices. Employees
and contractors are also expected to follow the instructions of their managers/supervisors, and
to exercise common sense and safety awareness in their daily activities.
Employees/contractors are expected to notify, in a timely manner, their supervisors and/or
managers of any unsafe conditions or other safety concerns noted or encountered during work
operations.
SAFETY MANAGEMENT SYSTEM (SMS)
All Transdev North America operations/entities shall implement the Transdev North America
Safety Management System (SMS) and maintain an SMS Binder with TDNA Safety Policies
and Procedures, Local policies/client requirements and Training requirements (see below for
binder’s minimum content). The Transdev SMS is based on the continuous improvement
approach “Plan, Do, Check, Act” and allows coping with internal and external changes in the
environment of our activities. Being in compliance with the safety req uirements imposed by
this SMS also ensures compliance with the national Safety Policy.
• Strategy
• Health and Safety po licy
• Safety Management
System {SMS)
• Risk analysis
• Emergency plan
• Processes review
• Health and Safety
• Implementation of processes
and action plans
• Creation of performance
indicators
• Training
• SMS audits
• Operations safety visits
• Performance monitoring
and ana lysis
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SMS Binder - Minimum Content:
• System Safety Program Plan (SSPP)
• Emergency Response Plan / Hazards Plan
• Transit System Security & Emergency Preparedness Program Plan
• Injury & Illness Prevention Program (IIPP)
• National Safety Manager / Safety Org Chart
• Hazard Assessments
• TD Policies & Procedures / Employee Handbook
• Maintenance Manual / Shop Safety Procedures
• Safety Manager Training / Certificates
• BTW Training / Certificates
• Substance Abuse Policy, Reasonable Suspicion Training Certificates
• ASE Certificates
• Certification of violations & Annual Review of MVR/Driving Record
• Fire Drill Summaries
• Safety Meeting schedules and minutes
• Staff Meeting Agenda
• Internal & External Audits
• Facility Inspections
• Incident, Accident & Injury Reporting Procedures
• Safety Notification Procedures / Critical Incident Notification Procedures
• Vision KPIs and Task Manager
• TOM PRM
• Maintenance
SAFETY VIOLATIONS:
Supervisors shall investigate and handle each incident fairly and completely with the goal of
understanding the safety rule or safe work expectation that was violated.
If a safety violation is found, employees/contractors shall be counseled and made aware of the
consequences of noncompliance with company or other safety rules and retrained as
appropriate or necessary. Emphasis must be stressed that unsafe work behaviors or unsafe
work habits will not be tolerated. All counseling and refresher training sessions shall be
documented and a record kept in the employee's file.
Supervisors shall ensure that all employees/contractors are treated equitably and that patterns
of unsafe practices or behaviors indicate a need to remove the employee/contractors from
service, in accordance with company safe work expectations and policies.
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GENERAL RULES:
Operation of Motor Vehicles:
• Only drivers that meet Transdev’s minimum qualification requirements and that have
successfully completed the Transdev Operator Development Program shall be allowed
to operate a motor vehicle in revenue service.
• Drivers operating any motor vehicle for business-related purposes (whether in revenue
service or not) shall operate motor vehicles in accordance with applicable laws and
regulations. Only Company employees and individuals authorized by the Company may
drive Company vehicles.
• Use of mobile communication devices, whether hand-held or hands-free, is strictly
prohibited while operating a revenue vehicle. Operators must comply with the directives
outlined in Transdev’s Cellular Telephone and Other Electronic Devices Policy.
Operators may not wear portable headphones, Bluetooth devices, earphones, or other
such devices while operating company owned or leased vehicles.
• Operators will abide by Transdev defensive driving standards/requirements and
applicable traffic laws, signs and signals at all times.
• The posted speed limits must be observed at all times. Vehicle speed must never
exceed that which is safe for current driving conditions, regardless of posted limits.
• Seatbelts must be properly worn at all times when operating a Company vehicle.
• Operators are not permitted to eat or drink while operating a Company vehicle.
• Smoking or the use of tobacco or e-cigarettes/vaping devices is not permitted inside
Company vehicles or when otherwise representing the Company.
• Transdev Operators are required to be in proper uniform while on duty. Operator attire
must not interfere with safe driving or peripheral vision.
• No unauthorized passengers are allowed in the vehicle
Aisles and Passageways:
• Where mechanical handling equipment is used, sufficient safe clearance must be
allowed for turning or passing.
• Aisles and passageways will be kept clear of obstructions and in good repair.
• Permanent aisles and passageways will be clearly marked.
• Covers or guardrails will be installed to protect personnel from the hazards of open pits,
tanks, vats, ditches, etc.
Boilers:
• Boilers should be inspected on an annual basis.
• A valid boiler inspection certificate bearing the signature of inspector and date of
inspection should be posted.
• Boilers should be equipped with approved-type water column, gauges and glass
indicators.
• An emergency shutdown procedure recommended by the boiler manufacturer or
insurance underwriter will be implemented when such shutdown is required.
Chipguards: Effective chip guarding shall be provided in operations involving compressed air,
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to protect employees against flying chips and other such hazards.
Dockboards: Dockboards shall be strong enough to carry the load imposed on them, and be
firmly anchored to prevent slipping and shifting.
Drinking Water:
• Potable drinking water will be provided in all Transdev facilities.
• Drinking dispensers shall be kept clean and sanitary and will be serviced regularly.
Eye and Face Protection:
• Protective eye and face equipment, when required, shall be used and maintained in a
sanitary and reliable condition.
• Safety glasses are mandatory in all Transdev Maintenance facilities
• Such equipment shall meet the requirements of ANSI Z89.1 1989, Practice for
Occupational and Educational Eye and Face Protection.
Fire Doors: Fire doors will be clearly labeled as such and will not be blocked or tied in an
open or closed position.
Floors:
• All floor surfaces will be kept clean, dry, and free from protruding nails, splinters, loose
boards, holes, or projections.
• Where wet processes are used, drainage shall be adequately maintained. False floors,
platforms, mats, or other dry standing places shall be provided where appropriate.
Floor Loading Limits (Especially over offices and secondary deck storage): Floors will
be posted to show maximum safe floor loads.
Floor Openings and Open Sides:
• Every stairway and ladder way floor opening must be guarded by a standard railing toe
board on all exposed sides except the entrance. Entrances will be guarded to prevent a
person from walking directly into the opening.
• All hatchways, floor holes, pits and chute floor openings must be guarded with
covers/netting or standard railings to leave only one entrance.
• Regardless of height, open-sided floors, walkways, platforms, or runways above or
adjacent to dangerous equipment shall be guarded with a standard railing toe board.
Foot Protection: Adequate foot protection should be worn whenever there is a reasonable
probability that it can prevent injuries.
Hand Tools:
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• Management is responsible for monitoring the safe condition of tools and equipment
used by employees, including tools which employees may furnish themselves.
• Employees will use their own tools for general assignments after they are approved by
the department supervisor.
• Hand tools must be kept in a safe condition (e.g. mushroomed top strikes on chisels,
etc. not permitted).
• Wrenches will not be used when sprung to the point that slippage occurs.
• The frames of portable electric tools will be properly grou nded, unless they are double-
insulated.
• Any equipment showing excessive deterioration, frayed wiring, or other dangerous
conditions will be removed from service until repaired.
Head Protection:
• Head protection (hard hats) will be worn when there is a p ossibility of head injuries from
impact, falling or flying objects, electrical shock, or burns.
• Helmets for protection against impact and penetration of falling objects shall meet the
requirements of ANSI Z89.1 1989, or an equally effective standard.
• Helmets for protection against electrical shock must meet the requirements of ANSI
Z89.2 1971.
Lighting: Adequate lighting will be provided at all times.
Personal Protective Equipment: Transdev shall furnish employees with proper personal
protective equipment as necessary except safety shoes (for which we will offer a yearly
allowance). All equipment will be maintained in a sanitary and reliable condition.
Railings:
• A standard railing will consist of a top rail, intermediate rail and posts, and will have a
vertical height of 42 inches from the upper surface to the top rail. Railing will be
equipped with toeboards, and be capable of withstanding a load of at least 200 pounds
in any direction.
• Stair railings are similar, but are 30-34 inches in height.
Scaffolds:
• All scaffolds and supports used by Transdev facilities must be capable of supporting the
load they are designed to carry.
• All planking shall be of scaffold grade, 2"x 9" or wider.
• Scaffold planks shall extend over their end supports not less than 6 inches nor more
than 18 inches.
• Railings and toeboards will be installed on all open sides and ends of platforms more
than 10 feet above the floor.
• If persons must pass or work under the scaffold, a screen with openings no greater than
1/2 inch must be placed between the guardrail and toeboard.
Fixed Industrial Stairs:
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• Every flight of stairs having four or more risers shall be provided with a standard railing
on all open sides. Handrails shall be provided on at least one side of closed stairways,
preferably on the right side descending.
• Risers must be of uniform height and tread.
• Fixed stairs must be at least 22 inches wide.
• Spiral stairs are not permitted except for special situations which would prohibit the use
or installation of conventional stairs.
Storage:
• All stored materials in tiers must be stacked, blocked, interlocked, and limited in height,
to secure against sliding or collapse.
• Storage areas will be kept free from accumulation of materials that constitute hazards
from tripping, fire, explosion, or pest infestation.
Smoking Policy:
• NO SMOKING signs will be posted in areas where smoking presents a hazard.
• Smoking shall not be permitted within 50 feet of fueling facilities, tanks and compressed
gasses
• Smoking is not allowed in any Transdev vehicle or facility.
Sprinkler Systems:
• Automatic systems must be checked annually for proper water flow through the test
valve. This action must be documented.
• Pipes must be protected against freezing or rupture.
• Sprinkler heads must not be arranged so as to throw water on electrical boards and
equipment. They must be protected by paper bags where subject to paint and other
elements.
NOTE: The Maintenance Department’s “Shop Safety Manual” and “Maintenance
Procedures Manual” contain additional safety guidelines and requirements applicable
to maintenance operations.
INSPECTIONS: Inspections will be performed annually, monthly, and daily on routine matters
and as required on others. Problems identified will be corrected and documented.
Types of Inspections:
A. Daily Safety “Walk-Throughs”: The property’s General Manager conducts these daily
“safety walk-through” of the facility for the purpose of proactively identifying work hazards
and unsafe conditions. These are NOT formal inspections, but just an informal safety
observation of the facility in order to be aware of unsafe conditions that could cause
injury/mishaps.
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B. Monthly Self-Inspections: The property’s General Manager conducts the monthly self-
inspection and documents it on the Facility Inspection Form. The purpose of this inspection
is to conduct a general facility safety assessment and to ensure the safe working conditions
of the facility. If the monthly safety audit indicates the need to repair or address an item,
the General Manager will take steps to do so as soon as possible.
C. Annual General Safety Audit: The General Safety Audit (GSA) is a comprehensive
safety review of all facility operations. These audits are performed at least once each year.
The Regional Safety Director or external third-party auditor(s) shall conduct the GSA, in
coordination with the General Manager. This process ensures that the General Manager is
aware of the results of the inspection, and to highlight areas where supervisors may need
additional training or advice.
D. "Spot/Focused Inspections" concentrate on a particular program or area such as
regulatory/policy compliance, training, hoists, respirators, fire extinguishers, tools, etc.
They should be performed as often as deemed necessary, daily in some instances. The
General Manager should perform random spot inspections for quality assurance, as he
deems necessary.
Performing Inspections: The General Manager and Supervisors should make a strong effort
not to allow inspections to be a negative experience. It should be stressed that the inspection
is simply to document the overall safety status of the facility. The only objective is to gather
information that can help make the workplace safer and to take steps to repair/remediate as
needed. Problems that are observed should be pointed out in a friendly, factual way. Safety
must involve all personnel at all levels to be effective.
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