Critical Topics in FDOT and FTA Program Compliance · PDF fileCritical Topics in FDOT and FTA...

6/2/2015

1

1

Critical Topics in FDOT and FTA Program Compliance

Tuesday, June 2, 20151:15 – 5:00 pm

2

Critical Topics – Outline

FDOT’s New State Management Plan and Compliance (1:15 –1:30) Triennial Oversight Reviews (Rob Gregg) (1:30 – 2:20)

Areas of compliance (Rob Gregg) Procurement and Title VI (Erin Schepers/Rob Gregg)

Triennial Bus System Safety and Security Reviews (Lisa Staes) (2:20 – 3:00) Developing a System Safety Program Plan Preparing for Triennial Bus System Safety and Security Review

BREAK (3:00 – 3:15) Triennial Maintenance Reviews (Laurie Zeruto) (3:15 – 3:55)

Developing a Maintenance Plan Preparing for Maintenance Elements in a Bus System Safety Review Preparing for Triennial Maintenance Review

FTA Drug and Alcohol (Diana Byrnes) (3:55 – 4:25)

Q & A (4:25 – 4:50) Resources and Training (Lisa Staes) (4:50 – 5:00)

6/2/2015

2

3

FDOT Triennial Review Process –Areas of Compliance

Maintenance activities

Single Agency Audit

ADA

DBE Program

Title VI

Procurement

Charter and School Bus Program

Reporting

Safety and Security

Drug and AlcoholFDOT Triennial Review Process

4

FDOT Triennial Review Process –Today’s Topics

Procurement

Title VI

Safety and Security

Maintenance activities

Drug and Alcohol Single Agency Audit

ADA

DBE Program

Charter and School Bus Program

Reporting

FDOT Triennial Review Process

6/2/2015

3

5

PROCUREMENT

FDOT Triennial Review Process

Freight, Logistics & Passenger Operations

FLORIDA DEPARTMENT OF TRANSPORTATION

PROCUREMENT GUIDANCE FOR TRANSIT AGENCIES

6/2/2015

4

PRESENTATION OVERVIEW

District Role

Funding Sources

Types of Procurements

Level of Procurement Methods

Checklists

Scenarios

District Role

Subrecipient Procurement Checklist Date:

Funding Source:

(check appropriate box)

Federal (List Type) State Local Other

Type of Procurement:

(select appropriate box – include description of procurement)

Professional

Services/Architectural Engineering Services

Operations/

Management/ Subrecipients

Rolling Stock Construction Materials & Supplies

Procurement Level:

Micro Purchase – Procurements less than $2,500

Total Amount of Procurement: $

Action Completed (Yes/No) Comments

Were Quotes Obtained?

If quotes were obtained, are they

attached?

Small Purchase – Procurement greater than $2,500 but less than $35,000



Minimum amount of Quotes Obtained?

Are the quotes attached?

Is there a Vendor Small Purchase Letter attached?

Are the applicable clauses listed on the Vendor Small Purchase Letter?

Is the appropriate Third Party

Checklist completed and attached? Checklist can be found in the Procurement Guide.

Competitive Procurement – Procurements greater than $35,000



Was the Request for Proposal (RFP) prepared and submitted for District approval prior to advertising?

Were the applicable clauses included in the prepared RFP?

After RFP process is complete, is the procurement package with selected bidder ready for district approval? Should be completed prior to final award.

Ensure subrecipient has a purchasing policy that includes federal/state purchasing rules.

Grant Application – should list estimated cost for items. Initial quotes should be obtained prior to application submittal.

Grant Award – once subrecipient is prepared to proceed with the procurement they should follow the Procurement Process and utilize the Subrecipient Procurement Checklist for step by step instruction.

6/2/2015

5

Funding Sources

Federal

State

Local

Determine what funding source will be used in the procurement Follow appropriate guidelines based on source

Third Party Guidance State Procurement Guidelines

Local Procurement Guidelines

Types of Procurement Third Party Contracts

Professional Services/Architectural Engineering Services Operations/Management/Subrecipients Rolling Stock Construction Materials and Supplies

Determine what type of procurement fits the purchase

6/2/2015

6

Level of Procurement MethodThird Party Contracts

Micro Purchases

Procurements less than $2,500

Small Purchases*

Procurements greater than $2,500 but less than $35,000

Competitive Procurements*

Procurements greater than $35,000

Other methods listed in the Procurement Guidance for Transit Agencies Manual*

Determine what level of procurement fits the purchase *Ensure that all potential vendors/contractors will accept the

applicable federal clauses – this should be done prior to completing the checklist

ChecklistsThird Party Contracts

To ensure that the applicable clauses are included in the agency’s procurement request, the appropriate checklist should be utilized.

The checklist should notate where the applicable clauses can be found in the supporting documentation.

Applicable Federal Clauses when procurement

exceeds $25,000

Location of Requirement in

Purchasing Package 22. GOVERNMENT‐WIDE DEBARMENT AND SUSPENSION

(NONPROCUREMENT)

Applicable Federal Clauses when procurement

exceeds $100,000


Purchasing Package 2. BUY AMERICA REQUIREMENTS

49 U.S.C. 5323(j) 49 CFR Part 661

25. BREACHES AND DISPUTE RESOLUTION

49 CFR Part 18

FTA Circular 4220.1E or subsequent revisions

10. LOBBYING

31 U.S.C. 1352

49 CFR Part 19

49 CFR Part 20

14. CLEAN AIR

42 U.S.C. 7401 et seq

40 CFR 15.61

49 CFR Part 18

7. CLEAN WATER REQUIREMENTS

33 U.S.C. 1251

Applicable Federal Clauses when procurements

involve property that may be transported by ocean

vessel


Purchasing Package

4. CARGO PREFERENCE REQUIREMENTS

46 U.S.C. 1241

46 CFR Part 381

Applicable Federal Clauses when procurements

involve foreign transport or travel by air


Purchasing Package 1. FLY AMERICA REQUIREMENTS

49 U.S.C. § 40118

41 CFR Part 301‐10

Applicable Federal Clauses – Contracts for items

designated by EPA, when procuring $10,000 or

more per year


Purchasing Package

15. RECYCLED PRODUCTS

42 U.S.C. 6962

40 CFR Part 247

Executive Order 12873

Approval:

Subrecipient

Date:

Approval:

Florida Department of Transportation

Date:

6/2/2015

7

Federal Funds

Materials/Supplies:Office Supplies

Micro Purchase:$2,000

Complete Procurement

ScenariosThird Party ContractsMicro Purchase

Funding Source

Types of Procurement

Level of Procurement Method

Federal Funds

Professional Services:Janitorial

Small Purchase:$32,500

Obtain two (2) or more quotes

Utilize Small Purchase Letter

Checklist:Complete

Professional Services checklist

Submit Procurement

request to District representative


ScenariosThird Party ContractsSmall Purchase

Funding Source


Level of Procurement Method Obtain quotes

Small Purchase Letter Ensure potential

vendors accept applicable clauses

Checklist

District Approval


6/2/2015

8

Useful ToolsThird Party ContractsSmall Purchase

(Date)

To: Joe’s Auto Shop

From: BBB Transit Agency

Subject: Acceptance of Federal Clauses

This purchase shall conform in all respects to the Federal Transit Administration’s Federally Required and Other Model Clauses including but not limited to: No government obligation to third parties; Program fraud and false or fraudulent statements and related acts, 31 U.S.C. 3801 et seq., 49 CFR part 31 18 U.S.C. 1001, 49 U.S.C. 5307; Access to records and reports, 49 U.S.C. 5325, 18 CFR 18.36 (i), 49 CFR 633.17; Federal changes, 49 CFR part 18; Disadvantaged Business Enterprise (DBE), 49 CFR part 26; Termination, 49 U.S.C. part 18 FTA circular 4220.1F. Date: Signature: Company Name: Title:

Federal Funds

Construction:Transit Facility

Competitive Purchase:$5.5 Million

Prepare Request for Proposal

Process (RFP) for District approval

Checklist:Complete

Construction checklist

Complete Request for Proposal

Process

Final District Approval of

Selected Bidder


ScenariosThird Party ContractsCompetitive Purchase

Funding Source


Level of Procurement Method

Prepare & Complete RFP

District Approval

Complete Checklist

Complete RFP Process

Final District Approval of Selected Bidder

6/2/2015

9

GoalsThird Party Contracts

Ensure applicable federal clauses are accepted by the vendors/contractors

Ensure checklists are completed and approved by District Representative

FAQ’s

When using local funds, should the Procurement Guidance for Transit Agencies (PGTA) be utilized?

If the local entity (county) pays for the procurement directly, the PGTA DOES NOT have to be followed. If the local entity (county) gives the funds directly to the transit agency, the PGTA must be followed. Example: The procurement is for a new parking lot for the transit agency. If the county (using local funds) pays the vendor directly for the service, the PGTA does not have to be followed. If the county (using local funds) transfers the funds to the transit agency and the transit agency pays the vendor directly for the service, the PGTA must be followed. Why? If the transit agency receives any federal funds, then any procurement made by the transit agency (regardless of funding source) must follow the PGTA.

6/2/2015

10

FAQ’s

Can the State Term Contracts (Department of Management Services) be used?

Yes. However, the vendor must acknowledge that they comply with the applicable clauses for that particular procurement. This can be done by using the Small Purchase letter. The letter would outline the applicable clauses and the vendor would acknowledge that they meet them.

FAQ’s

When using 5310 or 5311 funds, should the District Representative approve the purchase?

Yes, the District Representative should approve all 5310 and 5311 procurements.

6/2/2015

11

FAQ’s

Can the TRIPS contracts be utilized to purchase options (i.e. camera systems) when not purchasing a vehicle? Example: A transit agency would like to retrofit its’ fleet with camera systems that are listed on the TRIPS contracts. However, no vehicles would be a part of that particular procurement.

No. The options listed on the TRIPS contracts can only be utilized when placing a vehicle order. The component/option must be installed on the vehicle for that order.

FAQ’s

When using the TRIPS contract, should the Third Party Checklist for Rolling Stock be utilized?

It is a District decision. All TRIPS contracts have the necessary clauses. Simply locate the appropriate clauses in the contract that is being utilized and notate them on the checklist.

6/2/2015

12

FAQ’s

Should transit agencies have a procurement policy?

Yes. Any transit agency receiving federal funds should have a procurement policy. The policy should identify the method (i.e. PGTA) of ensuring federal requirements and applicable clauses are adhered to.

Freight, Logistics & Passenger Operations

FLORIDA DEPARTMENT OF TRANSPORTATION

For questions or comments, please contact:

Erin Schepers | Vehicle Procurement [email protected] | (850) 414-4526

6/2/2015

13

TITLE VI REQUIREDCOMPLIANCE

Rob Gregg, CUTR

A How‐to‐Guide

6/2/2015

14

What is Title VI?

• Title VI is a Federal statute that provides that no person shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance.o Race ‐ all races protected as defined by

U.S Censuso Color ‐ discrimination based on skin

color or complexion is prohibitedo National Origin – discrimination based

on the nation in which a person was born or where their ancestors were born is prohibited

27

Types of RecipientsAll recipients of federal financial assistance are subject to the laws of Title VI and are required to submit a Title VI Plan. However, there are different types of recipients as outlined below:

– Designated recipient – an entity designated to receive and apportion amounts to urbanized areas of 200,000 population or greater; or a state or regional authority, if the authority is responsible under the laws of a state for a capital project and for financing and directly providing public transportation. In Florida, all designated recipients except for LYNX have allowed FDOT to remain the designated recipient for Section 5310/11 funds and as such are subrecipients to the FDOT in regards to Title VI requirements.

– Direct recipient – an entity that receives funding directly from FTA. Distinguished from a primary recipient in that a direct recipient does not extend financial assistance to subrecipients. Urban and small urban systems can be direct recipients if they choose.

– Primary recipient – an FTA recipient that extends Federal financial assistance to a subrecipient. The FDOT is the primary recipient.

– Subrecipient – an entity that receives Federal financial assistance from FTA through a primary recipient. All rural systems are subrecipients to the FDOT.

28

6/2/2015

15

Title VI Florida Environment

Rural systems (demand response/route deviation only)– All rural systems are subrecipients to the FDOT.– Only required to complete the general requirements outlined in FTA

Circular 4702.1B dated October 1, 2012.

Urban/Small Urban systems– All urban/small urban systems are direct recipients.– All systems that operate fixed route service have additional

requirements as outlined in Chapter IV of the FTA Circular 4702.1B dated October 1, 2012.

– All urban/small urban systems except for LYNX have deferred the administration of Section 5310/11 funds back to the FDOT – as such, FDOT has designated recipient responsibilities of Title VI for these urbanized areas.

29

When do I have to submit a Title VI Plan?• Every three years, on a date determined by FTA, each direct and primary recipient is required to submit a Title VI Program to their FTA regional civil rights officer.

• Subrecipients (all rural systems) shall submit the information to the primary recipient (the entity from whom the subrecipient receives funds directly), on a schedule to be determined by the primary recipient (FDOT).

30

6/2/2015

16

What is required in Title VI Plans?

General Requirements

All recipients – rural, small urban and urban

Fixed Route Transit Provider Requirements

Fixed Route Transit Systems

States (If Transit Provider)

MPOs (If Transit Provider)

State Requirements

States

MPO Requirements

MPOs

31

Title VI General RequirementsALL Recipients must complete the following General Requirements for Title VI:

1. Title VI Annual Certification and Assurances2. Title VI Notice to the Public, including a list of locations where the

notice is posted3. Title VI Complaint Procedures4. Title VI Complaint Form5. List of transit‐related Title VI investigations, complaints, and

lawsuits6. Public Participation Plan7. Language Assistance Plan8. Table depicting the membership of non‐elected committees and

councils, broken down by race9. Sub‐recipient Monitoring10. Title VI equity analysis if the agency has constructed a facility

* Once the Title VI Program is completed, a copy of the board of directors meeting minutes or resolution demonstrating the board approved the Title VI Program should be included in the Title VI submission to the FTA or the primary recipient.

32

6/2/2015

17

Certifications and Assurances

GENERAL REQUIREMENT #1

Purpose: In accordance with 49 CFR Section 21.7(a), every application for financial assistance from FTA must be accompanied by an assurance that the applicant will carry out the program in compliance with DOT’s Title VI regulations. This requirement shall be fulfilled when the applicant/recipient submits its annual certifications and assurances to FTA. Primary recipients shall collect Title VI assurances from subrecipients prior to passing through FTA funds.

Reference:

The text of FTA’s annual certifications and assurances is available on FTA’s website at http://www.fta.dot.gov/documents/Appendix_A_Legal_Capacity_Documents_CAs.pdf

33

Notice to the PublicGENERAL REQUIREMENT #2

Purpose and Definition: A Title VI Notice to the Public must be displayed to inform a recipient’s customers of their rights under Title VI. At a minimum, the notice should include the statement—“If information is needed in another language, then contact [phone number]”— stated in English and in any other language(s) spoken by Limited English Proficient (LEP) populations that meet the Safe Harbor threshold.

Methods and Approaches:• At a minimum, recipients must post the Title VI notice to the public:

On the agency’s website (if your agency does not have a website, contact your district modal development manager)

In public areas of the agency’s office(s), including the reception desk, meeting rooms, etc.

• Recipients may also post the notice: In transit facilities (e.g., headquarters, transit shelters and stations, etc.) On transit vehicles (e.g., buses, rail cars, etc.)

34

6/2/2015

18

Sample Title VI Notice to the Public

35

Notifying the Public of Rights Under Title VI

Your Community Transit

Your Community Transit operates its programs and services without regard to race, color, and

national origin in accordance with Title VI of the Civil Rights Act. Any person who believes she or

he has been aggrieved by any unlawful discriminatory practice under Title VI may file a

complaint with Your Community Transit.

For more information on Your Community Transit’s civil rights program, and the procedures to file a

complaint, contact XXX‐XXX‐XXXX, (TTY XXX‐XXX‐XXXX); email

[email protected]; or visit our administrative office at 12345 Road, City,

Florida Zip Code. For more information, visit yourcommunitytransit.gov.

If information is needed in another language, contact XXX‐XXX‐XXXX

The above sentence must also be provided in any language(s) spoken by the LEP population that meet the Safe Harbor threshold.

Complaint ProceduresGENERAL REQUIREMENT #3

Purpose: to create uniformity with regard to how the agency investigates and tracks complaints.

Methods and Approaches:• The following should be stated in your complaint procedures: contact information,

description of what to include in a complaint, who will investigate complaints, timeframe for accepting complaint, describe what the investigation will entail, method of response, investigation and resolution timeframe, resolution if Title VI violation exists, method of appeal

• Other considerations: A method for tracking complaints, A list of potential reasons that a complaint may be dismissed, Language assistance measures

Requirements:The complaint procedure shall be available on the recipient’s website.

36

6/2/2015

19

Sample Title VI Complaint Procedures

37

Complaint FormGENERAL REQUIREMENT #4

Purpose: To provide customers a method in which to file a Title VI complaint.

Requirements:• The complaint form shall be available on the recipient’s website. • A recipient’s Title VI Complaint Form shall specify the three classes protected by

Title VI—race, color, and national origin—and allow the complainant to select one or more of those protected classes as the basis/bases for discrimination.

• If any of the LEP populations in your service area meet the Safe Harbor threshold,then the procedure should be provided in English and in any other language(s) spoken by LEP populations that meet the Safe Harbor Threshold.

38

6/2/2015

20

Sample Title VI Complaint Form

39

Transit‐related Investigations, Complaints, and Lawsuits


Purpose: To comply with reporting requirements of 49 CFR Section 21.9(b).

Methods and Approaches:• All recipients shall prepare and maintain a list of any of the following that allege

discrimination on the basis of race, color, or national origin: Active investigations conducted by FTA and entities other than FTA; Lawsuits; and Complaints naming the recipient

• This list shall include: The date that the transit‐related Title VI investigation, lawsuit, or complaint

was filed; A summary of the allegation(s); The status of the investigation, lawsuit, or complaint; And actions taken by the recipient in response, or final findings related to the

investigation, lawsuit, or complaint.

40

6/2/2015

21

Title VI List of Transit‐related Investigations, Complaints, and

Lawsuits Sample Form

41

Public Participation PlanGENERAL REQUIREMENT #6

Purpose: To promote inclusive public participation.

Methods and Approaches:Efforts to involve minority and LEP populations in public participation activities can include:• Placing public notices at all transit stations, stops, and

vehicles.• Schedule meetings at times and locations that are

convenient and accessible for minority and LEP communities.

• Employ different meeting sizes and formats.• Coordinate with community‐ and faith‐based

organizations, educational institutions, and other organizations to implement public engagement strategies that reach out specifically to members of affected minority and/or LEP communities.

42

6/2/2015

22

Title VI Public Participation Plan (cont.)GENERAL REQUIREMENT #6

Methods and Approaches (continued):• Consider radio, television, or newspaper ads on stations and in publications that

serve LEP populations. Outreach to LEP populations could also include audio programming available on podcasts.

• Provide opportunities for public participation through means other than written communication, such as personal interviews or use of audio or video recording devices to capture oral comments.

References:• FTA Circular, 4703.1, “Environmental Justice Policy Guidance for Federal Transit

Administration Recipients”• How to Engage Low‐Literacy and Limited English Proficiency Populations in

Transportation Decision‐making available online at http://www.fhwa.dot.gov/planning/publications/low_limited/

43

Language Assistance PlanGENERAL REQUIREMENT #7

Purpose: To provide meaningful access to benefits, service, information, and other important portions of programs and activities for individuals who are limited‐English proficient (LEP).

Requirements: The recipient shall develop an assistance plan to address the identified needs of the LEP population(s) it serves. An LEP Plan shall, at a minimum:• Include the results of the Four Factor Analysis, including a description of the LEP

population(s) served;• Describe how the recipient provides language assistance services by language;• Describe how the recipient provides notice to LEP persons about the availability of

language assistance;• Describe how the recipient monitors, evaluates and updates the language access

plan; and• Describe how the recipient trains employees to provide timely and reasonable

language assistance to LEP populations.

44

6/2/2015

23

Language Assistance Plan (cont.)


Four Factor Analysis (Factor 1) – Number of LEP persons. The number or proportion of LEP persons eligible to be served or likely to be encountered by the program or recipient. This population will be program specific. In addition to the number or proportion of LEP persons served, the recipient’s analysis should, at a minimum, identify:

• How LEP persons interact with the recipient’s agency;• Location of LEP communities, and an assessment of the number or proportion

of LEP persons from each language group to determine the appropriate language services for each language group;

• The literacy skills of LEP populations in their native languages, in order to determine whether translation of documents will be an effective practice; and

• Whether LEP persons are underserved by the recipient due to language barriers.

45



Four Factor Analysis (Factor 2) – Frequency of Contact. The frequency with which LEP persons come into contact with the program. Recipients should survey key program areas and assess major points of contact with the public, such as:

• Use of bus and rail service;• Purchase of passes and tickets through vending machines, outlets, websites,

and over the phone;• Participation in public meetings;• Customer service interactions;• Ridership surveys; and• Operator surveys.

46

6/2/2015

24

Language Assistance Plan (cont.)GENERAL REQUIREMENT #7

Four Factor Analysis (Factor 3) – Nature and Importance of Program. Generally speaking, the more important the program, the more frequent the contact and the likelihood that language services will be needed. The provision of public transportation is a vital service, especially for people without access to personal vehicles. An MPO’s regional planning activities will impact every person in a region. Development of a coordinated plan to meet the specific transportation needs of seniors and people with disabilities will often also meet the needs of LEP persons. A person who is LEP may have a disability that prevents the person from using fixed route service, thus making the person eligible for ADA complementary paratransit. Transit providers, states, and MPOs must assess their programs, activities and services to ensure they are providing meaningful access to LEP persons. Facilitated meetings with LEP persons are one method to inform the recipient on what the local LEP population considers to be an essential service, as well as the most effective means to provide language assistance.

47



Four Factor Analysis (Factor 4) – Resources and Costs. Resource and cost issues can often be reduced by technological advances, reasonable business practices, and the sharing of language assistance materials and services among and between recipients, advocacy groups, LEP populations and Federal agencies. Large entities and those entities serving a significant number of LEP persons should ensure that their resource limitations are well substantiated before using this factor as a reason to limit language assistance.

48

6/2/2015

25

Language Assistance Plan (cont.)GENERAL REQUIREMENT #7

Methods and Approaches:• Publish timetables and route maps in languages other than English• Multi‐language phone lines• Multilingual staff in information booths• Multi‐language announcements at stations and on vehicles• Language identification using “I Speak” cards• Advertisements in ethnic media• Pictograms

References:• Limited English Proficiency ‐ A Federal Interagency Website – www.lep.gov• Implementing the Department of Transportation's Policy Guidance Concerning

Recipients' Responsibilities to Limited English Proficient Persons: A Handbook for Public Transportation Providers, The Federal Transit Administration, Office of Civil Rights‐ April 13, 2007 ‐http://www.fta.dot.gov/documents/LEP_Handbook.doc

49

Minority Representation on Committees and Councils


Purpose: To ensure that minorities are adequately represented on non‐elected advisory councils.

Requirements:Recipients that have transit‐related, non‐elected planning boards, advisory councils or committees, or similar bodies, the membership of which is selected by the recipient, must provide a table depicting the membership of those committees broken down by race, and a description of efforts made to encourage the participation of minorities on such committees.

50

6/2/2015

26

Table depicting Minority Representation on Committees and Councils Selected by the Recipient

51

Body Caucasian LatinoAfrican

American

Asian

American

Native

American

Service Area

Population% % % % %

[Committee 1] % % % % %

[Committee 2] % % % % %

[Committee 3] % % % % %

Subrecipient Assistance and Monitoring


Purpose: To provide assistance to subrecipients in complying with DOT’s Title VI regulations and to monitor that compliance

Requirements:Sub‐recipient Assistance ‐ Primary recipients should provide the following:• Sample notices to the public, procedures on how to file a Title VI complaint, and the

recipient’s Title VI complaint form.• Sample procedures for tracking and investigating Title VI complaints • Demographic information on the race and English proficiency of residents served by

the subrecipient. • Any other recipient‐generated or obtained data, such as travel patterns, surveys,

etc., that will assist subrecipients in complying with Title VI.

52

6/2/2015

27

Subrecipient Assistance and Monitoring (cont.)


Requirements:Subrecipient Monitoring – The primary recipient shall undertake the following activities in regards to the subrecipient(s):• Document process for ensuring compliance• Review programs for compliance• In response to a complaint of discrimination, request verification that service is

equitable.

53

Equity Analysis for Facilities


Purpose: To ensure the location of facilities are selected without regard to race, color, or national origin. Facilities included in this provision include, but are not limited to, storage facilities, maintenance facilities, operations centers, etc. (does not include bus shelters or transit stations).

Requirements:• Compare the equity impacts of various siting alternatives• Census tract or block group level analysis• If a disparate impact is determined, location may only be used with legitimate

justification and must prove that there is not an alternative location that would have a less disparate impact.

54

6/2/2015

28

Title VI Fixed Route Requirements

Recipients who operate a fixed route system are subject to additional Title VI requirements:

1. Service Standards (for each mode) – Vehicle Load

– Vehicle Headway

– On‐time Performance

– Service Availability

2. Service Policies (for each mode) – Transit Amenities

– Vehicle Assignment

55

Title VI Fixed Route RequirementsWhat is a fixed route?As defined by the Title VI Circular, a fixed route service is defined as a public transportation service provided in vehicles operated along pre‐determined routes according to a fixed schedule.

Agencies should exercise care in determining whether a service should be considered a fixed route for the purpose of Title VI. Some service designs have attributes of fixed routes, such as route deviation or flex routes, therefore an assessment should be made if the service meets this qualification and if it does, then the agency should comply with the following Title VI requirements for fixed route services.

56

6/2/2015

29

Service StandardsFIXED ROUTE TRANSIT PROVIDER REQUIREMENT #1

Purpose: To ensure service design and operations practices do not result in discrimination on the basis of race, color, or national origin.

Requirements: All fixed route transit public transportation providers are required to develop quantitative standards for the following indicators:1. Vehicle load for each mode: Generally expressed as the ratio of passengers to the number of seats on a vehicle, relative to the vehicle’s maximum load point. For example, on a 40‐seat bus, a vehicle load of 1.3 means all seats are filled and there are approximately 12 standees. Transit providers can specify vehicle loads for peak vs. off‐peak times, and for different modes of transit.

2. Vehicle headways for each mode: The amount of time between two vehicles traveling in the same direction on a given line or combination of lines.

3. On‐time performance for each mode: A measure of runs completed as scheduled.4. Service availability for each mode: A general measure of the distribution of routes within an agency’s service area.

57

Service Standards Samples

Vehicle LoadVehicle Headways

On‐time Performance

Sample:A vehicle is considered on time if it departs a scheduled timepoint no more than 1 minute early and no more than 5 minutes late. The City of USA’s on‐time performance objective is 90% or greater. The City of USA continuously monitors on‐time performance and system results are published and posted as part of monthly performance reports covering all aspects of operations.

Service Availability

Sample: The City of USA will distribute transit service so that 90% of all residents in the service area are within a ¼ mile walk of bus service or within a ½ mile walk of rail service.

58

Vehicle Type Average Passenger Capacities

Seated Standing Total

Maximum Load

Factor15′ Mini-Bus 28 2 30 1.1

40′ Low Floor Bus 39 12 51 1.340′ Standard Bus 43 17 60 1.4Light Rail Vehicle 64 69 133 2.1

POLICY HEADWAYS AND PERIODS OF OPERATIONWEEKDAY Peak Base Evening Night

Regional Trunk 10 15 15 30

Urban Radial 15 15 30 60

Cross-Town 15 15 30 --

Secondary Radial 30 30 60 --

Feeder 30 30 60 --

Peak Express 30 -- -- --

Employer Feeder 60 -- -- --

* Peak: 7-9 am and 4-6 pm; Base 9am - 4pm; Evening: 6-9:30 pm; Night: 9:30pm-Midnight;

“--“ means no service is provided during that time period.

6/2/2015

30

Service Policies

FIXED ROUTE TRANSIT PROVIDER REQUIREMENT #2

Purpose: To ensure service design and operation’s practices do not result in discrimination on the basis of race, color, or national origin.

Requirements: All fixed route transit providers of public transportation are required to develop qualitative policies for the following procedures:1. Transit Amenities: refers to items of comfort, convenience, and safety that are

available to the general riding public. Policies in this area should address how these amenities are distributed within a transit system, and whether transit users have equal access to these amenities.

2. Vehicle Assignment: refers to the process by which transit vehicles are placed into service throughout the transit provider’s system. Policies for vehicle assignment could be based on age, the type of vehicle, the type of service offered, or the on‐board technology.

59

Service Policies Samples

Vehicle Assignment

Sample: Vehicles will be assigned to the South, North, and East depots such that the average age of the fleet serving each depot does not exceed “x” years. Low‐floor buses are deployed on frequent service and other high‐ridership lines, so these buses carry a higher share of ridership than their numerical proportion of the overall bus fleet. Low‐floor buses are also equipped with air conditioning and automated stop announcement systems. All rail cars are equipped with air conditioning, and high‐floor rail cars are always paired with a low‐floor car to provide accessibility.

Bus assignments take into account the operating characteristics of buses of various lengths, which are matched to the operating characteristics of the route. Local routes with lower ridership may be assigned 30‐foot buses rather than the 40‐foot buses. Some routes requiring tight turns on narrow streets are operated with 30‐foot ratherthan 40‐foot buses.

Transit Amenities

Sample: Installation of transit amenities along bus and rail routes are based on the number of passengerboardings at stops and stations along those routes.

60

6/2/2015

31

Title VI Fixed Route Requirements

Recipients who operate a fixed route system with 50+ fixed route vehicles in peak service AND are located in UZA of 200,000 POP or greater are subject to additional Title VI requirements:1. Monitoring program for service standards and

policies2. Service profile maps/charts3. Demographic profile and travel patterns (from survey

data)4. Service equity analysis5. Fare equity analysis

61

Monitoring Program for Service Standards and Policies

FIXED ROUTE TRANSIT PROVIDER (that operate 50+ fixed route vehicles and in UZA with 200k pop or greater) REQUIREMENT #1

Purpose: To ensure service design and operations practices do not result in discrimination on the basis of race, color, or national origin.

Requirements: Transit providers are required to monitor the performance of their transit system relative to their system‐wide service standards and service policies (i.e., vehicle load, vehicle assignment, transit amenities, etc.) using the following method:• Select sample of minority and nonminority routes• Assess and compare the performance of each minority and non‐minority route for

each of the transit provider’s service standards and service policies• For cases in which the observed service for any route exceeds or fails to meet the

standard or policy, the transit provider shall analyze why the discrepancies exist, and take steps to reduce the potential effects.

• Evaluate transit amenities policy to ensure amenities are being distributed throughout the transit system in an equitable manner.

62

6/2/2015

32

Monitoring Program for Service Standards and Policies (continued)


Methods and Approaches:To determine if a route is a minority transit route:• For each individual route, calculate the percentages of all persons residing in areas

served by the line who are minority persons. • Define a unique geographic area of coverage for each line by including all census

block groups within one‐quarter mile walking distance of bus stops and/or within one‐half mile walking distance of rail stations served by that line.

• For each route, calculate the number of minority persons residing in all block groups served, and determine the percentage of minority persons among all persons served by the route.

63

Sample Vehicle Load Monitoring

The table below shows passenger capacities for buses and light rail cars as the average maximum number of persons seated and standing during the peak one‐hour in the peak direction. Maximum load factors represent the maximum achievable capacity, and are calculated by dividing the total seated and standing capacity by the seated capacity of the vehicle.

SAMPLE Passenger Capacities

64

6/2/2015

33

Sample Vehicle Load Monitoring (cont.)

The table below shows the average vehicle loads by time period for lines in each quartile, for minority lines, for non‐minority lines, and for all lines in the system. In this example the transit provider uses quartiles to identify all census block groups served by bus lines within ¼ mile walking distance from bus stops and ½ mile walking distance from rail stations. The agency calculated the percentage and number of minority and non‐minority populations served by the line. Then, staff ranked all lines by the highest percentage of minority populations and further subdivided the list into four quartiles; Q1, Q2, Q3, Q4; and Q1 being the lines with the lowest percentage of minority populations served and Q4 being the lines with the highest percentage of minority populations served. The breakpoint for Q4 and Q3 were determined by comparing the percent minority with the median percentage of these populations within the agencies service area.

Vehicle Loads for Minority and Non‐Minority Lines

65

Sample Vehicle Headway Monitoring

The table below shows the average headway in minutes for minority and non‐minority lines for AM peak, midday, PM peak, evening, and night periods, for weekday service. The average span of service in hours and tenths of hours is shown for minority and non‐minority lines. The following table should be repeated for Saturday and Sunday service.

Headways and Span of Service for Minority and Non‐Minority Lines

66

6/2/2015

34

Sample On‐time Performance MonitoringSAMPLE Assessment: The City of USA initiated a random spot check program to assess a variety of performance measures, including on‐time performance. This “Mystery Rider” program completed a total 77 observations during the past fiscal year. Of the 77 bus trips observed, approximately five (5) percent were found departing a schedule time point late (i.e., more than 5 minutes after the departure time in the printed schedule). These routes on which late departures were observed were:

– B07– R10– R24– B48

Of these four routes, three (B07, R10, and R24) have a greater‐than‐average proportion of route miles in minority Census blocks. These findings suggest that additional monitoring of on‐time performance to assess potential disparate impacts is warranted. The City of USA will initiate additional on‐time performance monitoring as part of the “Mystery Rider” spot check program.

67

Sample Service Availability Monitoring

SAMPLE Assessment: The table below shows the percentages of minority and non‐minority households served. The percentage of minority households within a ½ mile walk of stops and/or stations was 86.6%. The percentage of non‐minority households within a ½ mile walk of stops and/or stations was 76.8%.

Service Availability for Minority and Non‐Minority Residents

68

6/2/2015

35

Sample Vehicle Assignment Monitoring

SAMPLE Assessment: The table below shows the average age of buses in relation to minority population served. In this case, all rail lines are minority lines, so rail vehicle age is excluded from the calculation of average vehicle age. Buses on minority lines had an average age of 12.1 years, compared to the system bus fleet average age of 12.7 years.

Vehicle Assignment by Age

69

Sample Transit Amenities Monitoring

The overlay map below shows the locations of many of the transit agency’s amenities, including park and ride facilities, transit centers, pedestrian improvements, and bus shelters, relative to the locations of bus and rail routes and the locations of minority and non‐minority populations. Such a map is one way to demonstrate how amenities are distributed across the transit system.

70

6/2/2015

36

Demographic and Service Profile Maps and Charts


Purpose: To determine the extent to which members of minority groups are beneficiaries of programs receiving Federal financial assistance from FTA.

Requirements: • A base map of the transit provider’s service area that overlays census tract, census

block or block group, or TAZ, with the transit network (including routes and transitfacilities), major activity centers, major streets and highways, and minority population data.

• A demographic map and corresponding charts that identify those areas where the percentage of the total minority population residing in these areas exceeds the average percentage of minority populations for the service area as a whole.

• A demographic map and corresponding charts that identify that shades those areas where the percentage of the total low‐income population residing in these areas exceeds the average percentage of low‐income populations for the service area as a whole.

71

Sample Demographic and Service Profile Map

72

6/2/2015

37

Minority Population Map

73

Low‐Income Population Map

74

6/2/2015

38

Demographic Profile and Travel Patterns


Purpose: To determine the extent to which members of minority groups are beneficiaries of programs receiving Federal financial assistance from FTA.

Requirements: Demographic Ridership and Travel Patterns –• Collect Information on the following using Customer Surveys: race, color, national

origin, English proficiency, language spoken at home, household income, travel patterns, fare usage by fare type amongst minority and low‐income users and display in tabular format.

• Develop a demographic profile comparing minority riders and non‐minority riders and trips taken by minority riders versus non‐minority riders.

Methods and Approaches:• Integrate into existing passenger surveys• Translate customer surveys into languages other than English as necessary or

provide translation services

75

Sample Demographic Profile

76

6/2/2015

39

Service Equity AnalysisFIXED ROUTE TRANSIT PROVIDER (that operate 50+ fixed route vehicles and in UZA with 200k pop or greater) REQUIREMENT #4

Purpose: To determine whether any planned service changes will have a disparate impact on the basis of race, color, or national origin.

Requirements:• Define “Major Service Change”• Define and analyze Adverse Effects • Develop a Disparate Impact Policy• Engage in Public Participation to develop policies• Describe dataset and techniques to collect data • Assessing service impacts

Measuring service impacts (ridership or population): Determining disparate impacts Analysis of modifications Justification for not modifying service

• Low‐income Disproportionate Burden Analysis

77

Sample Title VI Service Equity Policies HART’s Major Service Change PolicyHART shall define a major service or fare change as any of the following:• Route elimination• New route creation• Reorganization of a route in which 25% or more revenue miles are adjusted to a different route• 25% or greater change in revenue hours and/or revenue miles• 20% or greater passengers required to transfer to make current trip• 25% or greater reduction in span of service• Any fare change

HART’s Disparate Impact PolicyHART establishes a disparate impact threshold of 15%, meaning that a disparate impact occurs when a proposed major service or fare change would have a negative impact of 15% or more on minority populations as compared to the HART service area. Should a disproportionate burden be discovered via the Title VI service change review process, HART shall take steps to avoid, minimize or mitigate impacts where practicable.

HART’s Disproportionate Burden PolicyHART establishes a disproportionate burden threshold of 15%, meaning that a disproportionate burden occurs when a proposed major service or fare change would negatively impact the affected low‐income population by 15% or more as compared with the population of the HART service area. Should a disproportionate burden be discovered via the Title VI service change review process, HART shall take steps to avoid, minimize or mitigate impacts where practicable.

78

6/2/2015

40

Sample Service Equity Analysis

In the table above, an agency has assessed how proposed reductions in service frequency (headway changes) would impact minority and low‐income passengers on a bus‐only system. Here, the cumulative proposed reduction in service frequency will impact minority and low‐income passengers slightly less than their proportion of ridership of the system.

“Impacted Ons” is calculated by taking the number of trips eliminated in a given hour times the number of passengers per trip during that hour and adding up the number of passengers impacted in a week.

79

Fare Equity Analysis


Purpose: To determine whether any proposed changes to fares will have a disparate impact on the basis of race, color, or national origin.

Requirements:• Collect and Analyze ridership survey data (by fare media or fare payment type)• Assessing service impacts

Measuring service impacts (ridership or population): Determining disparate impacts Public Participation Analysis of modifications Justification for not modifying service

• Low‐income Disproportionate Burden Analysis

80

6/2/2015

41

Sample Fare Equity Analysis

81

State Requirements

In addition to general and transit provider requirements (if applicable), a State is required to provide:

1. A demographic profile of the State2. Demographic maps that show the impacts of the distribution of State and

Federal funds in the aggregate for public transportation projects3. Analysis of the State’s transportation system investments that identifies and

addresses any disparate impacts4. A description of the Statewide planning process that identifies the

transportation needs of minority populations5. Description of the procedures the agency uses to ensure nondiscriminatory

pass through of FTA financial assistance6. Description of the procedures the agency uses to provide assistance to

potential subrecipients

To access Florida (FDOT)’s Title VI documents – visit http://www.dot.state.fl.us/equalopportunityoffice/titlevi.shtm

82

6/2/2015

42

MPO Requirements

In addition to general and transit provider requirements (if applicable), an MPO is required to provide:

1. A demographic profile of the metropolitan area

2. A description of the procedures by which the mobility needs of minority populations are identified and considered within the planning process

3. Demographic maps that show the impacts of the distribution of State and Federal funds in the aggregate for public transportation projects

4. Analysis of the MPO’s transportation system investments that identifies and addresses any disparate impacts

83

FDOT MUST COMPLY• Notice to Public

• Policy Statement

• Complaint Procedure

• Public Participation Plan

• Limited English Proficiency (LEP) Guidance

• ETC.

http://www.dot.state.fl.us/equalopportunityoffice/titlevi.shtm

6/2/2015

43

Title VI Plan

• Resources:

Video Series http://www.fta.dot.gov/12885_15107.html

NEW

• Required to submit a copy of your Title VI Plan at time of grant award.

• This provides you time to complete your Title VI Plan if you don’t already have one.

Technical Assistance/Resources

86

605 Suwannee Street MS 26Tallahassee, Florida 32399‐0450

Program Manager: Liz StuttsPhone: 850‐414‐4530Fax: 850‐922‐4942

Email:[email protected]

Florida Department of Transportation

Center for Urban Transportation

Research

4202 E. Fowler Avenue, CUT 100Tampa, Florida 33620‐5375

Program Director: Rob GreggPhone: 813‐974‐8383Fax: 813‐974‐5168

Email:[email protected]

6/2/2015

44

87

DEVELOPING A SYSTEM SAFEY PROGRAM PLAN

AND

PREPARING FOR A TRIENNIAL BUS SYSTEM SAFETY AND SECURITY REVIEW

88

System Safety Program Plan - Goal

To identify, eliminate, minimize and control safety hazards and their risks by:

Demonstrating the agency’s safety culture and established policies, procedures, and programs that ensure compliance with Chapter 14‐90, FAC

Specifying lines of authority

Defining levels of responsibility and accountability within the agency

Establishing methods of documentation for the agencySy

stem

Safety Program

Plan

6/2/2015

45

89

Developing a System Safety Program Plan

The SSPP must be adopted, dated and signed by the Chief Executive Officer/General Manager of the Bus Transit System and must clearly comply with or exceed the established standards outlined in Rule 14‐90, F.A.C.

Annual safety certification:

Adoption of SSPP that meets or exceeds

Compliance with the SSPP, including annual safety inspections on all buses operated

System

Safety Program

Plan

90

SSPP Required Elements (Section 14-90.004(1)(a), FAC)1. Safety policies and responsibilities

2. Vehicle and equipment standards and procurement criteria

3. Operational standards and procedures

4. Bus driver and employee selection

5. Driving requirements

6. Bus driver and employee training

7. Vehicle maintenance

8. Investigations of events

9. Hazard identification and resolution

10. Equipment for transporting wheelchairs

11. Safety data acquisition and analysis

12. Wireless communication plan and procedure

13. Policy on the use of agency issued wireless communication devices

14. Driver education program

15. Safety standards for private contractors

System

Safety Program

Plan

6/2/2015

46

91

SSPP Required Elements (Section 14-90.004(1)(a), FAC)

1. Safety policies and responsibilities Policies should clearly explain the authority and responsibility of

the organization unit(s) to execute each safety and/or security task.

The system description should briefly describe the system’s characteristics in such a way that non‐technical persons understand the system and its operations.

An organizational chart should show the title of each position from General Manager/Director to operating employees.

A diagram of the structure of the transit system’s safety unit should identify the key positions, including the relationship and lines of communications between the safety unit and other units of the agency.

The relationship of the system to local political jurisdictions should be displayed in a chart, diagram, or explanation.

System

Safety Program

Plan

92

POLICIES, PROCEDURES, and OTHER DOCUMENTS

While you do not have to discuss in great detail all policies and procedures related to the required SSPP elements, you must:

1. Indicate that you do have a policy/procedure

2. Specifically identify the source document (specific policy or procedure and location in operator or employee manual) – in the SSPP

3. Present that document for reviewSystem

Safety Program

Plan

6/2/2015

47

93


2. Vehicle and equipment standards and procurement criteria (Section 14‐90.007, FAC)

Every procured and operated bus must:

Have the strength and capability to carry the maximum allowed load and not exceed the gross vehicle weight rating, gross axle weighting, or tire rating.

Have structural integrity that mitigates or minimizes the adverse effects of collisions.

Follow Federal Motor Vehicle Safety Standards.

Proof of strength and structural integrity tests on new buses must be submitted to the department.

System

Safety Program

Plan

94


Every bus shall be equipped as follows:

1. Mirrors

2. Wiring and batteries

3. Brake interlock system

4. Standee line and warning

5. Handrail and stanchions

6. Flooring

7. Doors

8. Emergency exits

9. Tires and wheels

10. Suspension

11. Steering and front axle12. Seat Belts13. Safety equipment14. Wheelchair lift/ramp safely

installed to accommodate persons with disabilities

15. Maintained wheelchair lifts/ ramps, securement devices, and restraints, including instructions for normal and emergency operation

System

Safety Program

Plan

6/2/2015

48

95


3. Operational standards and procedures (Section 14‐90.006(9‐16), FAC) No passenger door shall be open while the bus is operated

and doors must not be opened until the bus comes to a complete stop. A bus with any inoperable passenger door shall not be operated, except to move to a safe location.

Interior lighting and lighting in stepwells shall be sufficient for passengers to enter and exit safely during darkness.

Passengers must not be permitted in stepwells or forward of the standee line while bus is in motion.

Passengers shall not be permitted to stand on buses not designed for that purpose.Sy

stem

Safety Program

Plan

96


Buses shall not be refueled in a closed building and the refueling of buses while passengers are aboard shall be minimized.

The driver is required to be properly secured to the driver’s seat with a restraining belt at all times while the bus is in motion.

Drivers shall not leave the bus unattended with passengers aboard for more than 15 minutes, and the parking or holding brake must device must be set if the bus is left unattended.

Buses shall not be left unattended in an “unsafe condition” with passengers aboard at any time.

Unsafe condition – anything which endangers human life or property.

System

Safety Program

Plan

6/2/2015

49

97


4. Bus driver and employee selection

Policies must clearly outline job duties, qualifications, and procedure for driver selection

Policy should indicate the education, experience, and licensing requirements in addition to required medical qualifications

Policy shall dictate the levels and type of driving and criminal background checks required for new drivers, and include levels, types and frequency of checks for current drivers

Policy should specify the type of license needed for each specific job and/or vehicle in addition to verification and documentation needed for all employees. Policy should also include frequency for current drivers.

System

Safety Program

Plan

98

SSPP Required Elements (Section 14-90.004(1)(a), FAC)5. Driving Requirements

Must ensure that no bus driver is permitted to drive if their license has been suspended, cancelled, or revoked

Must ensure that:

Drivers will not be permitted or required to drive more than 12 hours or drive after having been on duty 16 hours in a 24‐hour period

Drivers will not be permitted to drive until the requirement of 8 consecutive hours off‐duty.

Drivers will not be permitted or required to be on duty more than 72 hours in any period of 7 consecutive days.

Must state that vehicles will be operated at all times in compliance with applicable traffic regulations, ordinances, and laws of the jurisdiction within which they operate.

System

Safety Program

Plan

6/2/2015

50

99


6. Bus driver and employee training

Must detail the training, tracking, length, and testing of bus operators to ensure adequate capabilities to safely operate each type of bus prior to permission to drive unsupervised.

Must include a copy of initial training and refresher course syllabuses for training materials that show training and testing for the minimum required training elements identified in Rule Chapter 14‐90, as well as additional new bus operator and refresher training that is required beyond these minimum topics.

System

Safety Program

Plan

100

SSPP Required Elements (Section 14-90.004(1)(a), FAC)Bus driver and employee training – minimum requirements Bus transit system safety and operational policies and

procedures

Operational bus and equipment inspections

Bus equipment familiarization

Basic operations and maneuvering

Boarding and alighting passengers

Operation of wheelchair lifts and other special equipment

Defensive driving

Passenger assistance and securement

Handling and awareness of emergencies and security threats

Driving conditions

Hazards associated with wireless communication devices

System

Safety Program

Plan

6/2/2015

51

101


7. Vehicle maintenance

Rule 14‐90.004(4), FAC: Bus transit systems shall establish a maintenance plan including procedures for preventative and routine maintenance for all operated buses.

Rule 14‐90.009(1), FAC: Each bus transit system shall require that all buses operated by such bus transit system and all buses operated by a private contract transit provider, be inspected at least annually in accordance with bus inspection procedures set forth in this rule.

System

Safety Program

Plan

102


8. Investigations of events (Rule 14‐90.004(5)(6)(7), FAC)

The system must have a formal policy understood by all personnel, explaining which events will be investigated, including predetermination of details such as:

Internal notifications

Thresholds for automatic activation of investigation

Guidelines on the timeline of investigation

Who is in charge of each specific level of investigation

Thresholds for external notifications to all necessary agencies such as FDOT, NTSB, and local regulatory agencies

If agency has an accident review board or similar functioning unit, must identify the role of this body, membership, and authority

System

Safety Program

Plan

6/2/2015

52

103

SSPP Required Elements (Section 14-90.004(1)(a), FAC) The system must have a policy or procedure that describes the

process that will be used to investigate any event involving a bus or taking place on agency controlled property resulting in a fatality, injury, or property damage as follows:

A fatality (within 30 days of related event), excluding suicides and deaths from illnesses.

Injuries requiring immediate medical attention away from the scene for two or more individuals

Property damage to system buses, non‐system vehicles, other system property or facilities, or any other property at the discretion of agency in regards to any property damage less than $1000

Evacuation of a bus due to imminent danger to passengers on the bus, excluding operational issues.

System

Safety Program

Plan

104

SSPP Required Elements (Section 14-90.004(1)(a), FAC) Each investigation shall be documented in a final report

which shall include a description of activities, causal factors, and any corrective action plan (CAP)

Each CAP shall identify the action to be taken and the schedule for its implementation

The agency shall track and monitor the implementation of each CAP

Investigation reports, CAPs, and related supportive documentation must be maintained my the system for a minimum of four years from the date of investigation completion.Sy

stem

Safety Program

Plan

6/2/2015

53

105

SSPP Required Elements (Section 14-90.004(1)(a), FAC)9. Hazard identification and resolution

Hazard identification procedureDescribes the methods used to ensure as many hazards as possible are entered into a hazard resolution process prior to causing any problems

Hazard categorizationA formal procedure should be in place with prior determinations as to which types of hazards must have which types of resolutions

Hazards are categorized in terms of severity and probability of occurrence

Hazard resolutionThe analysis and following actions taken by the bus transit system to reduce to the lowest practical level of risk associated with an identified hazard

System

Safety Program

Plan

106


11. Safety data acquisition and analysis

This section should explain the collection, maintenance, and distribution of safety data relative to operation

Trend analyses of data should be used to identify areas of concern and develop mitigation measures/policies and procedures to correct and monitor the effectiveness of these programs

The responsibilities for providing, receiving, processing, and analyzing data should be listed here

BTS should be clear pertaining to where this section is located in their safety and security plans

Parts of this section may be contained in the investigation of events and the hazard identification and resolution sections

System

Safety Program

Plan

6/2/2015

54

107


12. Wireless communication plan and procedure

The BTS must have a formal plan that addresses the requirements in Rule 14‐90.004(1)(a) 12, 13, 14

Policy must state that the use of personal wireless communication devices are prohibited while the transit vehicle is in motion

Policy must require all personal wireless communication devices be turned off with any earpieces removed from operator’s ear while occupying the driver’s seat

System

Safety Program

Plan

108


13. Policy on the use of wireless communication devices issued to the operator by the system

Policy must address use of wireless communication device issued to the operator by the BTS for business related purposes

Must explain how and when the agency issued device can be used in emergency situations

Must ensure that the use of the agency issued wireless communications device does not interfere with the operator’s safety related duties

System

Safety Program

Plan

6/2/2015

55

109


14. Driver education program – Wireless Communication Devices

The driver educational training program must include:

A section discussing the hazards associated with using a wireless communications device while driving

A section explaining the proper use of a wireless communications device issued by the BTS while in the performance of their safety related duties

System

Safety Program

Plan

110


15. Safety standards for private contractors

In accordance with Rule 14‐90.004(1)(a) 15:

Must outline the established standards for private transportation operators that provide(s) continuous or recurring transportation services for compensation as a result of a contractual agreement with the bus transit system.

System

Safety Program

Plan

6/2/2015

56

111

Preparing for a Triennial Bus System Safety/Security Review

AuthoritySection 14‐90.012, FAC: “The Department or its contractors shall conduct inspections of bus transit systems to ascertain compliance with the provisions of this rule chapter.”

FDOT Procedure 725‐303‐009‐j, Section 6.1: “The Department or its designee is authorized to conduct inspections of bus transit systems to verify compliance with the provisions of Rule Chapter 14‐90, FAC.”

FrequencyAt least once every three years

Bus System

Safety/Security Reviews

112


Purpose Verify compliance with the provisions of Rule Chapter 14‐90, Florida Administrative Code

Verify compliance with the bus transit system’s approved System Safety Program Plan, Security Program Plan, and other applicable policies

Verify that adequate safety management controls are in place and functioning to meet the minimum standards in Chapter 14‐90.

Who?

“Bus Transit Systems”

Bus System


6/2/2015

57

113

Preparing for a Triennial Bus System Safety/Security ReviewBus Transit System means

A community transportation coordinator

A public transit provider

A private contract transit provider which owns, operates, leases, or controls buses or taxicabs where such transportation consists of continuous or recurring transportation under the same contract

A privately owned or operated transit provider that receives operational or capital funding from the Department and owns, operates, leases, or controls buses, other than nonpublic sector buses that provide transportation services available for use by the general riding public

Bus System


114


Bus System


Notice

You will be notified by your district FDOT office in writing at least three weeks prior to the review.

District FDOT offices will coordinate scheduling with review team.

Notice will establish what will be expected of you and the various documents that will need to be accessed by the review team – including those items that must be provided to the team prior to the scheduled review.

6/2/2015

58

115

Pre-Review DocumentationBus System


The current approved System Safety Program Plan

Safety policy and procedure documents

Organizational chart

Employee/Driver handbook(s)

Dispatch policies and procedures

Routes and service schedules

Wireless communications policy/plan

Vehicle inventory

116

Pre-Review Documentation

Bus System


Driver hours of service policies/procedures

Bus driver selection policies/procedures

Background check policies/procedures

License check/MVR policies/procedures

Bus driver and employee training manuals, policies/procedures, and manuals (include list of required courses for new hires and refresher and coordinated syllabi)

Accident/incident policies and procedures

Hazard identification and resolution process

Maintenance plan

6/2/2015

59

117

Onsite ReviewBus System


What to expect during onsite review:

Entrance meeting

Record checks

Bus inspections

Route reviews

Driver performance checks

Exit briefing

118

Onsite Review

Bus System


Entrance meeting Finalize review schedule and answer preliminary

questions

Introduce review team and agency personnel

Review and adjust agenda, if needed

Outline review areas and process

6/2/2015

60

119



Record checks Records are selected at random and cover 30% (30 driver minimum) of all BTS drivers over the past three years.

Driver licenses – ensuring they are current and the process identified in SSPP and policies/procedures is being followed

Medical certification – Verify expiration date and completion of form including signatures. Ensure agency is following standard identified in SSPP.

120

Onsite Review

Bus System


Record checks Hours of service – Rule 14‐90.006(3), FAC: Drivers are not permitted to drive more than 12‐hours in a 24‐hour period, or drive following 16‐hours of duty in a 24‐hour period. A driver must have 8 consecutive hours off duty prior to resuming driver duties once these limits are met.

Driver event investigation records

Hazard investigation records

6/2/2015

61

121



Bus inspectionsEach bus shall be inspected for operable equipment and devices including, but not limited to:

1. Horn

2. Windshield wipers

3. Mirrors

4. Wiring and batteries

5. Service and parking brakes

6. Warning devices

7. Directional signals

8. Hazzard and warning signals

9. Lighting systems and signaling devices

10. Handrails and stanchions

122

Onsite Review

Bus System


11. Standee line and warning

12. Doors and brake interlock devices

13. Stepwells and flooring

14. Emergency exits

15. Tires and wheels

16. Suspension system

17. Steering system

18. Exhaust system

19. Seat belts

20. Safety equipment

21. Equipment for transporting wheelchairs

22. Working speedometer

6/2/2015

62

123



One of the most important components of the review process is riding the bus route (one‐hour minimum) to review route and driver performance

Route Checks include, but not limited to:

Coverage area

Bus stop locations – safe/accessible

Driver observations

124

Onsite Review – Driver Observations

Bus System


Prior to first run of the day, a pre‐trip inspection form should be completed checking each of the items outlined in Rule 14‐90.006(8)(a)FAC:

1. Parking brakes2. Tires and wheels3. Service brakes4. Steering5. Horn6. Lighting devices7. Windshield wipers8. Rear vision mirrors9. Passenger doors10. Exhaust system11. Equipment for transporting wheelchairs12. Safety, security, and emergency equipment

6/2/2015

63

125

Onsite Review – Driver ObservationsBus System


Not impaired, fatigued or ill

Adjusts mirrors prior to starting their route

Wears seat belt correctly and is not slouching in seat

Drives with both hands on the steering wheel

Appears observant of road conditions continuously

Drives with caution including using signals, not speeding or stomping on brakes, keeping proper distance, etc.

When required, driver safely attaches tie down straps into floor tracks, and use the four‐point tie down on wheelchairs.

Removes tie downs after each use and stores straps in their proper place

126

Onsite Review – Driver Observations

Bus System


Uses correct language under ADA guidelines and acts courteously

Attends to all passengers requesting or requiring assistance

Does not use personal wireless communications devices

Answers radio properly, using proper language and 10‐codes, where applicable

Ensures bus is at a complete stop before doors are opened and does not operate bus with any passenger doors open

Makes sure passengers are seated or properly positioned behind the standee line before proceeding

Monitors passengers and reports misbehavior

6/2/2015

64

127

Onsite Review – Exit BriefingBus System


Ensure system is presented with all results, both positive and negative

Provide a summary of deficiencies or any areas of concern

128

Categorization of Findings

Bus System


Deficiency:

Does not comply with Rule 14‐90, FAC

If it is determined that the bus transit system has a deficiency that is considered an area of non‐compliance, the bus transit system is required to develop and submit to the District a CAP and implementation schedule to correct the deficiency.

Areas of Concern:

Weakness in implementation of SSP or SPP and/or weakness in conformance with Rule 14‐90, FAC

The bus transit system is required to develop and submit to the District a CAP and implementation schedule for each area of concern.

Observation/ Recommendation:

An offered suggestion, view, or comment regarding safety and security performance, even when no deficiency or area of concern exists

6/2/2015

65

129

Review ReportBus System


Final report is issued within 30‐calendar days of completion of the onsite review and submitted to the person directly responsible for management of the bus transit system

Final review report:

Will describe the review process

Will identify findings (deficiencies, areas of concern, and observations/recommendations)

Will require the bus transit system to develop and submit a corrective action plan (CAP) and implementation schedule for identified deficiencies and areas of concern within 30‐calendar days from date of the final report.

130

Review Report – Corrective Actions

Bus System


District must notify bus transit system of approval or rejection of each corrective action and implementation schedule within 15‐calendar days of receiving the plan

District office must submit a Corrective Action Plan (CAP) close‐out letter within 30‐calendar days of completion and implementation of all corrective actions resulting from the review

6/2/2015

66

131

Review Report – Corrective ActionsBus System


Rule 14‐90.012, FAC: If the district finds any unsafe condition which poses an immediate danger or threat to public safety they are required to:Immediately notify BTS of the condition (the normal 30‐day window is not required)Immediately notify the transit system of the immediate corrective action requiredConduct an onsite review of the system to verify the correctionSuspend affected passenger service operations if the bus transit system fails to correct the deficiency

132

Common Bus System Safety and Security Review Findings

Bus System


The execution of minimum training standards identified in SSPP cannot be confirmed through the examination of driver files.

Medical Examination Certificates (MECs) are not current, completed or signed by medical examiner

The medical examination standard identified in the SSPP (FDOT form versus USDOT form) is not consistently observed in the driver files.

Drivers’ licenses are not current. No demonstrated tracking or analysis of incidents. SSPP and/or SPP are out of date. Drivers are not consistently completing pre‐trip

inspection forms or are not following pre‐trip inspection procedure.

Drug/alcohol documentation found in common driver personnel files.

6/2/2015

67

133

DEVELOPING A MAINTENANCE PLAN

AND

PREPARING FOR A TRIENNIAL MAINTENANCE REVIEW

134

Developing a Maintenance Plan

Maintenance Plan

A Maintenance Plan is a “living document” that describes the agency’s current maintenance practices and procedures.

Maintenance Plans should include the following:

• Preventative maintenance inspection practices

• Pre/post‐trip inspection practices

• Annual safety inspection practices

• Wheel chair lift maintenance activities

• Road call procedures

• Vehicle cleaning procedures

• Accident procedures

• Warranty procedures

• Parts inventory procedures & practices, when applicable

• On‐site fueling practices, when applicable

6/2/2015

68

135


4 Types of Maintenance Plan Templates:

In‐house Maintenance Plan Template‐ used for agencies who perform most or all maintenance activities in‐house.

Combination Maintenance Plan Template‐ used for agencies who perform preventative maintenance inspections in‐house, but outsource some repairs.

Outsource Maintenance Plan Template‐ used for agencies that outsource all maintenance activities.

Transportation Operating Procedure Template (TOP)‐ used for 5310 only agencies.

Maintenance Plan

136


Maintenance Plan Requirements:

Maintenance plans should be comprehensive and detailed to provide the reviewer with a clear understanding of how the maintenance department operates on a daily basis.

Maintenance plans need to be customized to the agency’s specific maintenance process and all actual practices.

Maintenance Plan

6/2/2015

69

137

Maintenance Elements in Bus System Safety Reviews Maintenance Plans are requested before the on‐site maintenance review to gain an understanding of the agency’s vehicle fleet, maintenance procedures & practices.

Maintenance plans are analyzed to ensure they accurately describe all required maintenance practices & procedures.

Maintenance plan findings include, but are not limited to, the following:

• It is a finding if the agency does not have a maintenance plan.

• It is a finding if the maintenance plan does not accurately describe current maintenance practices.

• It is a finding if the agency does not follow the maintenance plan’s described maintenance activities.

• It is a finding if the maintenance plan does not include all of the required maintenance procedures & practices.

Maintenance Reviews

138

Maintenance Elements in Bus System Safety Reviews

Equipment records (vehicle history files) are examined to ensure they include required elements from Ch. 14‐90.004(h)(4)(d) such as:

Identification of the vehicle, including make, model, license number or other means of positive identification and ownership;

Date, mileage, and description of each inspection, maintenance, repair or lubrication performed;

If not owned by the transit agency, the name of the person or company furnishing service for this vehicle; and

The name and address of any business firm performing an inspection, maintenance, lubrication or repair.

It is a finding if the vehicle history files do not include preventative maintenance inspections and repairs.

Maintenance Reviews

6/2/2015

70

139


Asset Management Plans are requested. Although it is not a finding if your agency does not have an asset management plan in place, it will be a finding in the future.

Asset Management Plans assist agencies with assessing the current condition of agency inventory items and establishing a procurement plan for purchasing new inventory items

Asset Management Plans list all agency inventory items (vehicles, equipment, computers, furniture, chairs, etc.) as well as the following additional information:

Current condition score for each inventory item Original purchase price/date for each inventory item Anticipated purchase price/date for each inventory item Procurement plan for replacing each inventory item

(internal process, grants to be used, etc.)

Maintenance Reviews

140

Maintenance Elements in Bus System Safety Reviews Parts Department procedures and practices are examined

to determine how parts inventory is managed.

If parts are kept on‐site, the process for requesting and reordering parts is examined.

Parts inventory should be balanced at least annually to determine parts usage and cost efficiency.

No findings issued for Parts Inventory. Recommendations are made to improve Parts Department functionality if needed.

Maintenance Reviews

6/2/2015

71

141

Maintenance Elements in Bus System Safety Reviews Vehicle Safety Inspections – a minimum of 10% of vehicle

fleet will be randomly selected for a visual safety inspection.

Additional visual bus safety inspections may be performed if there are any indicators in the maintenance records of poor vehicle safety. The total number of vehicles inspected at each agency will ultimately be determined by the Maintenance Consultant performing the review.

Defects found during the Vehicle Safety Inspection will be considered a finding. Vehicles with safety defects may be recommended to be removed from service until the defects are repaired. However, if the identified defects are repaired and documentation of the repairs are provided to the Maintenance Consultants prior to the maintenance review report being finalized, the finding will be removed from the report.

Maintenance Reviews

142

Maintenance Elements in Bus System Safety ReviewsThe following items will be inspected during the Vehicle Safety Inspection:

• General Exterior Condition

• General Interior Condition

• All Windows and Glass

• Exterior Lights & Operation

• Interior Lights & Operation

• Exterior & Interior Mirrors

• Emergency Exits & Identification

• All Interior Signage

• Dash Gauges and Indicators

• Check Air System

• Service & Emergency Brake

• Interlock Systems

• Steering & Horn

• Windshield Wipers & Washers

• First Aid Kit

• Fire Extinguisher

• Fire Suppression System

• Safety Triangles

• Handrails & Stanchions

• Floor, Steps, Thresholds

• All Seats & Belts

• Undercarriage

• Suspension System

• Wheels/Lugs & Tires

• Batteries, Wiring & Signage

• Fuel & Exhaust System

• Engine Compartment & All Fluids

• Backup Alarm

• Exterior Reflectors

• Wheelchair Belts & Tie Downs

• Lift Operation & Instructions

• Wheelchair Lift Pad Kits/ Wiring/ Leaks

• Wheelchair Lift Identification

Maintenance Reviews

6/2/2015

72

143

Maintenance Elements in Bus System Safety Reviews Preventative Maintenance File Review – a minimum of 20% of

the vehicle records will be randomly selected for review

Maintenance activities are reviewed for a minimum of one year. If there is limited information available, multiple years may be examined to determine maintenance procedures and practices

Preventative maintenance inspections and repairs conducted between inspections are examined to determine the following:

• Preventative maintenance inspection intervals ‐ an “on‐time” preventative maintenance inspection must occur within 10% of the targeted mileage interval (for example: to be considered “on time”) if using 6,000 mile intervals, the inspection must occur within 6,600 miles

• Repeat repairs

• Unscheduled repairs that occur shortly after preventative maintenance inspections are performed

• Wheelchair lift inspections

Maintenance Reviews

144

Maintenance Elements in Bus System Safety ReviewsPreventative Maintenance File Review Findings:

• It is a finding if less than 80% of the preventative maintenance inspection intervals examined are conducted on time

• It is a finding if the preventative maintenance inspection target mileage used in practice does not match the target mileage indicated in the agency’s maintenance plan

• It is a finding if the agency’s preventative maintenance inspection target mileage exceeds the FDOT recommended 6,000 mile target without proper justification and prior approval by FDOT

• It is a finding if the preventative maintenance inspections are not being performed in the sequence indicated in the agency’s maintenance plan

• It is a finding if the Preventative Maintenance Inspection checklist does not meet all of the minimum maintenance requirements listed in the FDOT Preventative Maintenance Standards Manual

• It is a finding if there is missing documentation for preventative maintenance inspections and repairs. Missing documentation includes dates, mileage, inspection items (whether the items are checked appropriately on the form), corresponding work orders for defects noted on the inspection form, etc.

Maintenance Reviews

6/2/2015

73

145

Maintenance Elements in Bus System Safety Reviews Annual safety inspections must be completed at least

once annually per Chapter 14‐90.009(1).

“C” level preventative maintenance inspections, as described in the FDOT Preventative Maintenance Standards Manual, may serve as an annual inspection as long as it is performed once a year and is documented as an annual inspection on the form.

It is a finding if annual inspections are not completed at least once annually

It is a finding if the annual inspection does not meet all of the requirements listed in Chapter 14‐90.009(3)(a‐u).

Maintenance Reviews

146

Maintenance Elements in Bus System Safety Reviews Pre‐trip inspections must be performed before a vehicle

begins revenue service according to Chapter 14‐90.006(7).

All pre‐trip inspection forms with defects noted must be reviewed before the vehicle begins revenue service to determine if the defect is safety related. The following are considered safety defects by FDOT: Steering system

Service & parking brake

Suspension & undercarriage

Tires, wheels & wheel end components

Fuel & exhaust systems

All lights, mirrors, wipers & warning devices

Interlock systems

Interior controls, gauges & safety equipment

Wheelchair lifts

Air system

Emergency exits (doors, windows, etc)

Maintenance Reviews

6/2/2015

74

147

Maintenance Elements in Bus System Safety Reviews Vehicles with safety related defects must be removed

from service until all repairs have been made.

All pre‐trip inspection forms must be retained for a minimum of 14 days according to Chapter 14‐90.006(7)(c).

All pre‐trip inspection forms with defects noted must show a corresponding repair in one of the following ways: Pre‐trip inspection form is signed and dated by the mechanic conducting the repair with a note describing the repair made, or

A work order showing the appropriate repair is attached to the pre‐trip inspection form.

Pre‐trip inspection forms with defects noted and the corresponding repair must be filed in the vehicle history file for the life of the vehicle.

Drivers are observed performing pre‐trip inspections by the Maintenance Consultant during the maintenance review.

Maintenance Reviews

148

Maintenance Elements in Bus System Safety ReviewsPre‐trip inspection findings:

It is a finding if pre‐trip inspections are not being performed.

It is a finding if a pre‐trip inspection is not thorough.

It is a finding if the pre‐trip inspection checklist does meet the requirements listed in Chapter 14‐90.006(7)(a)(1‐12).

It is a finding if all pre‐trip inspections are not retained for 14 days, according to Chapter 14‐90.006(7)(c).

It is a finding if the defects identified on the pre‐trip inspection form do not show a corresponding repair.

Maintenance Reviews

6/2/2015

75

149


During the maintenance review process the Maintenance Consultant performs a walk through of the maintenance shop to determine:

If the maintenance shop has a Facility & Equipment Maintenance Plan and if the equipment is being maintained according to the plan.

If Material Safety Data Sheets (MSDS) are maintained according to Florida’s Right To Know Law.

If the shop is equipped with the equipment and tools necessary for maintaining the vehicle fleet.

If the shop is properly equipped with the appropriate safety equipment (fire extinguishers, eye wash stations, etc).

If the floors are free of spills and debris and if the work stations are organized and free of clutter.

How waste materials are stored and disposed.

Maintenance Reviews

150


Maintenance shop findings:

It is a finding if the agency does not have a Facility & Equipment Maintenance Plan in place and if the plan is not being followed.

It is a finding if the MSDS is not being maintained according to Florida’s Right To Know Law.

It is a finding if the shop is not properly equipped with the appropriate safety equipment (fire extinguishers, eye wash stations, etc).

It is a finding if maintenance shop conditions are not safe for the maintenance technicians.

It is a finding if waste materials are not stored and disposed safely.

Maintenance Reviews

6/2/2015

76

151

Maintenance Elements in Bus System Safety Reviews Warranty repairs should be pursued for applicable

vehicles.

Warranty repairs and timelines should be tracked.

Vehicles not maintained according to OEM recommendations jeopardize warranty coverage.

Road calls should be documented

Road calls should be tracked and analyzed regularly to determine the root cause of failure.

When trends are identified through analysis, it may indicate changes needed in the preventative maintenance program.

During the maintenance review process the Maintenance Consultant observes overall vehicle appearance to determine exterior and interior cleanliness.

Maintenance Reviews

152

Maintenance Elements in Bus System Safety Reviews Each finding in the Maintenance Review Report has a

corresponding recommendation to assist with State and Federal compliance.

Additional recommendations may be provided throughout the report to improve maintenance program practices.

Tools, resources and technical assistance are provided during and after the maintenance review process.

The Maintenance Consultant provides technical assistance to eliminate findings during the maintenance review process, if possible.

Maintenance Reviews

6/2/2015

77

153

Maintenance Elements in Bus System Safety Reviews Agencies that receive only 5307 funding (not 5311 funding)

have a condensed maintenance review process. The following are areas that ARE reviewed for maintenance practices: Maintenance plans Preventative maintenance Annual safety inspections Pre‐trip inspections Road calls Vehicles files

Accident procedures are an additional area that is reviewed for 5307 agencies. Maintenance is responsible for two areas regarding accidents. The

maintenance department must determine whether a mechanical failure contributed to an accident that has occurred. The maintenance department must also determine the severity and the amount of damage that occurred during the accident, since the amount of damage determines the required level of reporting to FDOT.

Maintenance Reviews

154

Maintenance Elements in Bus System Safety Reviews Agencies that receive only 5310 funding (no other FDOT

funding) also have a condensed maintenance review process. The following are areas that ARE reviewed for maintenance practices:

Transportation Operations Procedure

Preventative maintenance

Pre‐trip inspections

Warranty

Vehicle appearance

Vehicle history files

Maintenance Reviews

6/2/2015

78

155

Preparing for Triennial Maintenance Review Agencies preparing for an FTA Triennial Maintenance Review should use the full maintenance review process described in today’s presentation that include the following areas: Maintenance plans Equipment records (vehicle history files) Asset management Parts inventory Vehicle safety inspections Preventative maintenance Annual inspections Pre‐trip inspections Maintenance Shop and Facilities Warranty Road calls Vehicle appearance

Maintenance Reviews

156

Preparing for Triennial Maintenance Review The following resources are provided on the zip drive handouts: Maintenance plan templates

In‐house

Combination

Outsourced

Transportation Operations Procedure (TOP)

Maintenance Review workbook (5311)

Maintenance Review Process (5311)

FDOT Preventative Maintenance Standards Manual

Facility & Equipment Maintenance Plan template

Preventative Maintenance Agreement

Sample forms: Preventative maintenance inspection form

Pre‐trip inspection form

Annual safety inspection form

Road call information form

Work order form

Scheduled Maintenance article

Maintenance Reviews

6/2/2015

79

157

Substance Abuse Management Oversight and Technical Assistance Program

Drug and Alcohol Testing

158

Background & History

• Jan. 1987‐Marijuana use determined as causal factor for fatal rail accident

• August 1991‐ Alcohol misuse determined as causal factor for fatal transit accident


6/2/2015

80

159

Regulatory History

• October 1991 Omnibus Transportation Employee Testing Act

– Required each DOT modal administration to develop industry specific rules concerning which employees will be covered and the testing circumstances (pre‐employment, random, etc.)

– Required DOT to prepare rules concerning “how” testing will be performedD

rug and Alcohol Testing

160


6/2/2015

81

161

Non-ComplianceDrug and Alcohol Testing

• Sub‐recipient agencies: FDOT has the authority to withhold funding based on non‐compliance to FTA regulations

• Direct grantees: MAP‐21 gives FTA even more “teeth” than ever before; non‐compliance may result in loss of funding

• Non compliant programs also:– Are ineffective at deterring employees from using prohibited drugs or misusing alcohol

– Make it difficult to produce “defendable” test results when litigation or labor union grievances are brought against the agency

162

Substance Abuse Management Oversight Reviews

• Performed on behalf of the District Office

• Annual review of each 5311 sub‐recipient agency’s drug and alcohol testing program

– Electronic review of testing program performed in advance (statistical data only)

– An on‐site records review is performed

– Inspection of record maintenance and retention

– Inspection of service providers (collection sites, alcohol test technicians)


6/2/2015

82

163


• Review Reports: Areas of Concern/Deficiencies– Written reports are developed within 10 days of the on‐site review

– Reports are submitted in draft form, to the appropriate District Official

– The District reviews, comments and/or approves the draft report

– The draft report is revised (if needed) and then finalized

– The District forwards the final report directly to the agency


164


• Technical Assistance– The final report that the agency receives will outline any corrective action that is needed, and timeline for corrective actions.

– Reviewer is available to assist the agency is implementing any of the corrective action

– Documentation of corrective action may be required to be submitted to the District

– Training in areas of concern may also be required


6/2/2015

83

165

Substance Abuse Management Training: Instructor Led

• Training for Program Management Staff

– FDOT Certificate Program

– One‐on‐one training, on request

• New program manager

• Refresher training for “seasoned” program managers

• Training for Employees and Supervisors

– Employee drug awareness

– Reasonable Suspicion for Supervisors and other designated officials


166

Substance Abuse Management Training: In-house

• FDOT Substance Abuse Management Website

– FDOT Employee D &A Handbook

– Computer Based Training (CBT)

• Employee Drug Awareness

• Supervisor Refresher

– Video training package with workbooks

– Short videos for safety meetings (topics such as: post accident testing criteria, medication awareness)

www.sam.cutr.usf.edu


6/2/2015

84

167

FTA Resources

• FTA Website

– Transit Safety Oversight

• Regulation Updates

Newsletters

There will be no manacles or thumb screws.

There are:

Resources available Technical assistance Training

6/2/2015

85

169

Resources

Maintenance compliance Rule Chapter 14‐90, Florida Administrative Code Assistance provided through the Preventive Maintenance Planning, Training and Technical Assistance Program – contact Bob Westbrook at 850‐414‐4533

Title VI compliance Training is available – contact Liz Stutts at 850‐414‐4530

Procurement compliance Procurement Handbook and Procurement Policy template Training and technical assistance is available –contact Erin Schepers at 850‐414‐4526

170

Resources Safety and security compliance System Safety Program Plan and Security Plan templates available System Safety Review Process (SSP 100) Rule Chapter 14‐90, Florida Administrative Code Technical assistance and oversight monitoring assistance is available – contact Victor Wiley at 850‐414‐4525

Drug and alcohol program compliance Training and technical assistance is available through the Substance Abuse Management Oversight and Technical Assistance Program –contact Victor Wiley at 850‐414‐4525 or Diana Byrnes at 813‐426‐6980

6/2/2015

86

171

FDOT Technical Assistance and Training

Initial regional training on requirements

New training curriculum and delivery along priority transit safety issue areas as identified during Triennial Reviews

On‐site technical assistance when needed

172

Contact information - FDOT

Bob WestbrookTransit Operations [email protected]‐414‐4533

Victor WileyTransit Safety Programs [email protected]‐414‐4525

Liz StuttsGrant Programs [email protected]‐414‐4530

Erin SchepersProcurement Program [email protected]‐414‐4526

6/2/2015

87

173

Contact information – Supporting Cast

Rob Gregg, DirectorTransit Management and Innovation Program – [email protected]‐974‐8383

Laurie Revell ZerutoAssistant Director Applied Business Research – [email protected]‐644‐2509

Lisa Staes, DirectorTransit Safety/Workforce Development Programs ‐ [email protected]‐426‐6982

Diana ByrnesSubstance Abuse Management Specialist ‐ [email protected] 813‐426‐6980

174

Resource websites FDOT Transit Office:

http://www.dot.state.fl.us/transit/navigation/aboutus.shtm

Preventive Maintenance Planning, Training and Technical Assistance (PrMPT): www.prmpt.org

Substance Abuse Management Oversight Program: http://sam.cutr.usf.edu

Transit Safety Network: www.floridatsn.org

Transit Research Inspection Procurement Services

www.tripsflorida.org

Transit Operator Training Program: www.transitoperations.org

Critical Topics in FDOT and FTA Program Compliance · PDF fileCritical Topics in FDOT and FTA...

Documents

Transcript of Critical Topics in FDOT and FTA Program Compliance · PDF fileCritical Topics in FDOT and FTA...