Transcript Safety Meeting - April 18, 2007
BRIEFING PRESENTATION Safety and Security Management Plans (SSMPs) for Major Capital Projects
U.S. DOT Federal Transit Administration
What is a Safety and Security Management Plan (SSMP)?
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U.S. DOT Federal Transit Administration
Safety and Security Management Plans (SSMPs)
• Required for major capital projects, as defined in 49 CFR Part 633.5, as a component of the Project Management Plan (PMP) • Written by recipients of federal financial assistance to describe how safety and security will be addressed in their major capital projects • Must cover initial project planning through initiation of revenue service • Must be developed and submitted to FTA for review and approval • FTA approval of SSMP must be received prior the recipient receiving approval to enter the next project phase
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U.S. DOT Federal Transit Administration
Why are SSMPs necessary?
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U.S. DOT Federal Transit Administration
Purpose of SSMP requirement is to…
• Establish a consistent baseline for the management of safety and security activities • Specify minimum safety and security management activities to be performed and documented by the recipient during each project phase • Ensure safety and security are adequately addressed in all project development phases
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U.S. DOT Federal Transit Administration
FTA Safety and Security Management Guidance Circular 5800.1
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U.S. DOT Federal Transit Administration
FTA Safety and Security Management Guidance Circular 5800.1
• Becomes effective August 1, 2007 • Cancels previous guidance • Applies to recipients of major capital projects that are initiated after, or are in the preliminary engineering or earlier phases of project development as of August 1, 2007
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U.S. DOT Federal Transit Administration
Circular 5800.1 has been developed to…
• Provide safety and security management guidance to recipients with major capital projects covered by 49 CFR Part 633 • Explain why SSMPs are necessary • Identify the specific safety and security activities that must be performed and documented by the recipient in the SSMP • Provide guidance to recipients for achieving compliance with FTA’s safety and security management requirements
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Circular 5800.1 does not apply to…
U.S. DOT Federal Transit Administration • Small Starts and Very Small Starts projects unless FTA’s Administrator determines that a PMP is necessary • Recipients with major capital projects involving the rehabilitation or modernization of existing fixed guideway with total project costs in excess of $100 million, and initiated before August 1, 2007 • Recipients with major capital projects involving construction of new fixed guideway or extensions of existing fixed guideway that are in final design or later phases as of August 1, 2007 • Recipients with major capital projects designated by the Administrator, and initiated before August 1, 2007
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U.S. DOT Federal Transit Administration
Cancellation of previous SSMP guidance is through a two phased approach…
• Recipients in the final design or later phases of project development as of August 1, 2007 will continue to follow the previous guidance • Recipients with projects in preliminary engineering or earlier phases as of August 1, 2007 will follow Circular 5800.1 guidance
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U.S. DOT Federal Transit Administration
Required Safety and Security Management Activities
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U.S. DOT Federal Transit Administration
Required Safety and Security Management Activities
• Recipients must complete the following to achieve compliance with FTA’s SSMP requirements: 1. Prepare a Policy Statement 2. Identify Safety and Security Interfaces 3. Establish a Safety and Security Organization 4. Identify Specific Safety and Security Activities by Project Phase 5. Ensure Construction Safety and Security 6. Ensure Coordination with External Agencies
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U.S. DOT Federal Transit Administration
Identification of SSMP Sections that may not be applicable to the Major Capital Project
• Recipients should contact their FTA Regional Office with questions regarding applicability • Recipients must provide a clear explanation as to why the SSMP activity, section, or sub-section is not applicable • FTA determines applicability and whether or not it must be address in the recipient’s SSMP • Sections that are not applicable must still be included in the SSMP immediately followed by the phrase “not applicable”
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U.S. DOT Federal Transit Administration
Preparation of Policy Statement
• Recipients must develop a signed statement, issued by their executive management, endorsing the SSMP and stating the project’s commitment to safety and security • Policy statement provides the overall intentions and direction of the recipient’s organization regarding safety and security for the project • Policy statement should be in letter or memorandum format and signed by the recipient’s chief executive officer
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U.S. DOT Federal Transit Administration
Sample Policy Statement
Sample Safety and Security Policy Statement
It is the policy of [insert name of grant recipient] that [insert name of project] be designed and constructed in full compliance with requirements for safety and security established by the Federal Transit Administration (FTA), [insert name of grant recipient], and other local, State and Federal agencies. Safety and security are to be priorities in conducting all work on the [insert name of project] to ensure the safety and security of employees, the public, and emergency responders during the design, construction, and operation of the project.
[Insert name of grant recipient] is committed to ensure that [insert name of project] fully complies with the safety and security requirements contained in the design criteria and standards established for [insert name of project]. The [insert name of project] will not be placed into passenger service until it can be certified be safe and secure as specified in the [insert name of grant recipient]’s Safety and Security Certification Program and Plan.
All persons assigned to conduct work on the [insert name of project] are required to comply with the requirements of this Safety and Security Management Plan as well as the Plans, Procedures, and Instructions referenced by this Plan. The [insert title of grant recipient manager assigned to safety and security] has been assigned the authority to ensure that the requirements of this Plan are implemented properly by all project participants.
The [insert name of grant recipient manager assigned to safety and security] will bring any safety and security issues on the project that are not being resolved in a timely or acceptable manner to the attention of the [insert name of grant recipient] Project Director for resolution.
Signed:________________________________ Agency Name Chief Executive Officer Date:___________
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U.S. DOT Federal Transit Administration
Identification of Safety and Security Interfaces
• Recipients must identify who among the project team leadership has ultimate decision-making responsibilities for safety and security issues • These individuals must be identified by name, title, and department or affiliation • The recipient must also explain how these individuals interface with other project team functions regarding safety and security issues
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Establishing a Safety and Security Organization
U.S. DOT Federal Transit Administration • Recipients must establish a specific organization to manage safety and security for the project • All recipient staff and contractors assigned to the this organization must be identified by name, title, and department or affiliation • Committees established to support this organization must be identified along with their participants by name, title and affiliation • For all contractors, recipients must identify a recipient staff member or committee responsible for overseeing the contractor • The safety and security management organization must be illustrated by the recipient in the form of an organizational chart in the SSMP
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U.S. DOT Federal Transit Administration
Identifying Specific Safety and Security Activities by Project Phase
• At a minimum, recipients must perform the following: – – – – Identify and assess safety hazards and security vulnerabilities, using formal safety and security analysis techniques Establish safety and security requirements for the project Establish a process for verifying that contractors and recipient staff and committees build, install, inspect, and test all facilities, systems, and equipment comprising the project Develop documentation through which the recipient conveys the safety, security, and emergency rules and procedures it establishes for the project to employees, contractors, and oversight agencies
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U.S. DOT Federal Transit Administration
Identifying Specific Safety and Security Activities by Project Phase (continued)
• At a minimum, recipients must perform the following: – – – – – Establish qualifications and training programs for all personnel who will operate and maintain the project in revenue service Ensure that documented verification is available to show how it trained and qualified its personnel and/or contractors to operate and maintain the project and to respond to emergencies Maintain a process to manage open safety and security items, resulting from design deviations, change orders, non-conformances, and other sources Conduct emergency exercises or drills prior to placing the project into revenue service Make final safety and security certification prior to the placement of the project into revenue service
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U.S. DOT Federal Transit Administration
Identifying Specific Safety and Security Activities by Project Phase – Sample Matrix
*
Sample Safety and Security Activities Matrix TASK Task Type
Develop Safety and Security Policy Statement Establish Designated Function (DF) for Safety and Security throughout the Project Develop Safety and Security Management Plan MGT MGT Establish Safety and Security Committees Create Safety and Security Responsibilities Matrix Develop Safety and Security Certification Program Plan Develop and Implement Hazard and Vulnerability Resolution and Tracking System Prepare Preliminary Hazard and Vulnerability List Identify Safety and Security Certifiable Elements Establish Safety and Security Certifiable Items List Establish Safety and Security Configuration Management Create Safety and Security Certification Project Folders Perform Preliminary Hazard Analysis and Threat and Vulnerability Analysis Prepare Safety and Security Design Criteria Perform Safety and Security Review of Preliminary Operations and Maintenance Procedures Perform Safety and Security Design Reviews & Additional Hazard and Vulnerability Analysis MGT MGT MGT MGT/ENG MGT/ENG MGT/ENG ENG/MGT ENG ENG MGT ENG ENG MGT ENG/MGT *Partial Matrix Shown
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U.S. DOT Federal Transit Administration
Ensuring Construction Safety and Security
• Recipients must establish requirements for construction safety and security – This must include requirements for contractors at construction sites – Requirements must meet OSHA standards • Recipients must ensure that contractor oversight is provided • Safety and security analyses that contractors must perform for the construction site must be identified • If appropriate for the project, incentives must also be identified
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• U.S. DOT Federal Transit Administration
Ensuring Coordination with External Agencies
Recipient’s must identify required activities and develop schedules to ensure compliance with requirements specified by local, State and Federal agencies • This includes: – State Safety Oversight Agencies – – – – – Federal Railroad Administration Department of Homeland Security Transportation Security Administration Office of Grants and Training Other DHS agencies as appropriate • Recipients must document coordination with metropolitan planning organizations (MPOs)
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Required SSMP Contents
U.S. DOT Federal Transit Administration
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U.S. DOT Federal Transit Administration •
Required SSMP Contents
Recipient’s must develop and implement an SSMP that contains the following 11 sections: 1. Management Commitment and Philosophy 2. Integration of Safety and Security into Project Development Process 3. Assignment of Safety and Security Responsibilities 4. Safety and Security Analysis 5. Development of Safety and Security Design Criteria 6. Process for Ensuring Qualified Operations and Maintenance Personnel 7. Safety and Security Verification Process (Including Final Safety Security Certification) 8. Construction Safety and Security 9. Requirements for 49 CFR Part 659, Rail Fixed Guideway Systems, State Safety Oversight 10. FRA Coordination 11. DHS Coordination
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U.S. DOT Federal Transit Administration
Section 1: Management Commitment and Philosophy
• Must explain how the recipient’s leadership is committed to safety and security throughout the project • Section 1 must include: – Safety and Security Policy Statement – – – Purpose of SSMP Applicability and Scope SSMP Goal
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U.S. DOT Federal Transit Administration
Section 2: Integration of Safety and Security Into Project Development Process
• Safety and Security Activities: Must identify the safety and security tasks the recipient must perform through all project phases. Must include: – Both text description and matrix listing of activities and corresponding project phase • Procedures and Resources: Must identify the procedures and resources that will support performance of safety and security tasks. Must include: – – – – Project budget and schedule Procedures for managing safety and security contractors Procedures for coordinating safety and security activities with other recipient staff and contractors Procedures for managing Sensitive Security Information (SSI)
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U.S. DOT Federal Transit Administration
Section 2: Integration of Safety and Security Into Project Development Process (continued)
• Interface with Management: Must identify the process and lines of communication through which recipient’s will communicate safety and security issues to project leadership • Organizational Chart must be provided with supporting text to: – Identify, by name, title, and department or affiliation, individuals who have ultimate decision-making responsibility for safety and security – – Explain how these individuals interface with project team functions Identify relationships between project leadership and construction contractors and subcontractors
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U.S. DOT Federal Transit Administration
Section 3: Assignment of Safety and Security Responsibilities
• Responsibility and Authority: Must establish a specific organization to perform safety and security tasks – All staff and contractors assigned must be identified by name, title, and department/affiliation – – All committees and committee members must be identified by name, title, and affiliation Organizational chart must be provided • Committee Structure: Describes the organization and responsibilities of committees used by the recipient during the project • Safety and Security Responsibility Matrix: Presents responsibilities and reporting relationships established for staff, committees, and contractors performing safety and security activities –
For all contractors, the recipient must identify a recipient staff member or committee responsible for overseeing the contractor
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U.S. DOT Federal Transit Administration
Section 3: Assignment of Safety and Security Responsibilities – Sample Matrix *Project Safety and Security Tasks
Legend:
P – Primarily or lead S – Secondary function or assistance A – Approval authority C – Comment only
Program Management and Control
Establish Safety and Security Policy Statement Set safety and security policies, goals and objectives Develop safety and security task list Establish safety organization (DF, committees, contractor support, etc.) Establish security organization (DF, committees, contractor support, etc.) Assign roles and responsibilities for safety activities Assign roles and responsibilities for security activities Develop Safety and Security Management Plan Develop Safety and Security Milestone Schedule Develop and disseminate Safety and Security Certification Program Plan Develop and disseminate procedures to direct safety activities Develop and disseminate procedures to direct security activities Provide assistance on safety and security issues Provide centralized procurement of safety and security contractors and consultants Perform program reviews and audits for safety and security activities Establish system for hazard and vulnerability tracking and resolution Require hazard/vulnerability analysis to assess impacts of deviations from design criteria/design standards and project technical baseline specifications *Partial Matrix Shown P P P P S P P P P P S P P P P P P S P P S P P P P P S P P P P S S P S S S S S S C C S S S S S S S S S C C C C C C C C C C C C C C C C C A A A A A A A C A A A A A A A A A C C C C C C C S S C C C C C C C S C C C C C C C S S C C C C C C C S C C C C C C C P S C C C C C C C S C C C C C C C S S C C C C C C C S C C C C C C C C C C C C C C C C C
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U.S. DOT Federal Transit Administration
Section 4: Safety and Security Analysis
• Approach to Safety and Security Analysis: Must describe recipients process for identifying, documenting, analyzing, controlling, eliminating, and tracking safety hazards and security vulnerabilities – Must also identify the level of hazards and vulnerabilities acceptable to project management • Requirements for Safety and Security Analysis: Must specify distinct types of analysis the recipient will perform during the project – Must identify who will perform analyses and when – – Must describe how results of analyses will be communicated to and incorporated into project Must include a process for assuring resolution of identified hazards and vulnerabilities establish a specific organization to perform safety and security tasks
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U.S. DOT Federal Transit Administration
Section 4: Safety and Security Analysis (continued)
• • • • Safety and security analysis systematically identifies, evaluates, and resolves hazards and vulnerabilities during each project phase Recipients’ approach to hazard and vulnerability identification, analysis, and resolution is the basis of their risk management system Risk management, when applied to safety and security, means – “a structured system for measuring uncertainty in safety and security loss and evaluating corresponding impacts on project cost, schedule and performance to support sound decisions.” In general: – – – Greater probability of occurrence = Greater Risk and greater need for resolution Greater severity of consequences = Greater Risk and greater need for resolution Probability + Severity = Risk Assessment
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U.S. DOT Federal Transit Administration •
Section 4: Safety and Security Analysis (continued)
Safety and security analysis is used during the design process to help identify design requirements and criteria Project Definition and General Requirements DESIGN Preliminary Project Description and Component Identification Identification of Safety and Security Codes, Standards, Requirements Preliminary Hazard and Vulnerability List and Supporting Analysis SAFETY AND SECURITY DESIGN CRITERIA Preliminary Specifications and Drawings Final Project Specifications and Drawings Design Approval Safety and Security Certifiable Elements and Items System Safety and Security Analysis Design Reviews
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U.S. DOT Federal Transit Administration
Section 4: Safety and Security Analysis (continued)
• • MIL-STD-882 is the most frequently used approach for hazard analysis in transit Degrees of Hazard Severity are defined as follows: – –
Category I, Catastrophic
– could result in death, permanent total disability, loss exceeding $1 million, or irreversible environmental damage
Category II, Critical
– could result in permanent total disability, injuries or occupational illnesses resulting in hospitalization of 2 or more persons, loss exceeding $200,000, but less than $1 million, or reversible environmental damage – –
Category III, Marginal
- could result in injury or occupational illness resulting in one or more lost workdays, loss exceeding $10,000, but less than $200,000, or mitigatible environmental damage without violation of law or regulation where restoration activities can be accomplished
Category IV, Negligible
- could result in injury or illness not resulting in a lost work day, loss exceeding $2,000, but less than $10,000, or minimal environmental damage not violating law or regulation
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U.S. DOT Federal Transit Administration •
Section 4: Safety and Security Analysis (continued)
Degrees of Hazard Probability are defined as follows: – – – – –
A, Frequent
- Likely to occur often in the life of an item, with a probability of occurrence greater than 10 -1 in that life. Continuously experienced in fleet.
B, Probable
- Likely to occur several times in the life of an item, with a probability of occurrence less than 10 -1 by greater than 10 -2 in that life. Will occur frequently in fleet.
C, Occasional
- Likely to occur some time in the life of an item, with a probability of occurrence less than 10 -2 but greater than 10 -3 in that life. Will occur several times in the life of the fleet.
D, Remote
- Unlikely but possible to occur in the life of an item, with a probability of occurrence less than 10 -3 but greater than 10 -6 in that life. Unlikely, but can reasonably be expected to occur in the fleet.
E, Unlikely
- So unlikely to occur in the lifetime of an item, it can be assumed occurrence will not be experienced, with a probability of occurrence less than 10 -6 in that life. Unlikely to occur in the fleet, but possible
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U.S. DOT Federal Transit Administration
Section 4: Safety and Security Analysis (continued)
• Hazard risk classification combines the hazard severity and probability characteristics into a single hazard risk index
Probability of Occurrence A
Frequent
B
Probable
C
Occasional
D
Remote
E
Unlikely
Catastrophic 1 2 4 8 12 Severity of Occurrence Critical Marginal 3 7 5 6 10 15 9 11 14 17 Negligible 13 16 18 19 20
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U.S. DOT Federal Transit Administration
Section 4: Safety and Security Analysis (continued)
• Hazard risk classification combines the hazard severity and probability characteristics into a single hazard risk index
Priority Hazard Risk Assessment Value
1-5 6-9 10-17 18-20 1 2 3 4
Hazard Risk Category
High Serious Medium Low
Hazard Risk Acceptance/Approval Level
Project Chief Executive Safety Organization Project Engineering and Safety Organization Project Engineering
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U.S. DOT Federal Transit Administration
Section 4: Safety and Security Analysis (continued)
• FTA’s threat and vulnerability analysis approach may also be employed
Very Easy Relatively Easy Difficult Very Difficult Too Difficult Vulnerability A B C D E Impact I II III IV Loss of life Serious injuries, major service impact, >$250k damage Minor injuries, minor service impact, <$250k damage No injuries, no service impact
Audit Approach ...
Asset Assets
Terminals Multi-modal Stations Maintenance Facilities Vessels Slips, Docks, and Bridges
Threat Threats
Bombs Chemical Agents Biological Agents Guns/Knives Hijacking
Scenario A B C D E Criticality Matrix I II III IV H H H S S H H S L L S S L L L S L L L L
• • •
H = High S = Serious L = Low
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• U.S. DOT Federal Transit Administration
Section 4: Safety and Security Analysis (continued)
Similar vulnerability classifications can be made using a modified approach
RISK LEVEL Critical
ASSETS/IMPACTS
Loss of Life
THREAT
Definite threat exists Both the capability and intent exist Similar assets are targeted on a frequent or reoccurring basis
VULNERABILITY
Few effective countermeasures exist Known adversaries would exploit the asset
High Medium
Low
Serious injuries Major service impact >$250K damage Minor injuries Minor service impact <$250K damage No injuries No service impact Credible threat exists Plausible capability and intent exists Related incidents exist on similar assets in the past Potential threat exists Adversary’s desire to gain capability and intent exists Capability could exist through a third party Little or no credible evidence of capability or intent exists No history of actual or planned threats Some countermeasures exist, but multiple weaknesses still exist Many adversaries could exploit the asset Effective countermeasures exist, but at least one weakness still exists Some known adversaries could exploit the asset Multiple levels of effective countermeasures exist Few or no known adversaries would be capable of exploiting asset
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U.S. DOT Federal Transit Administration
Section 4: Safety and Security Analysis (continued)
• Hazard and vulnerability resolution is performed through the following methods, listed in order of precedence: – Design for Minimum Risk – – – Incorporate Safety Devices Provide Warning Devices Develop Special Procedures and Training
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U.S. DOT Federal Transit Administration
Section 4: Safety and Security Analysis (continued)
Preliminary Engineering Final Design Construction Operations
Safety & Security Analysis Concepts PHVL Safety & Security Analysis Systems and Subsystems Safety & Security Analysis Personnel, Procedures And Equipment PHA and TVA Inputs to Specifications Revise PHA/TVA SSHA, FMEA, FMECA, FTA, TRA & SSSA Inputs to Design, Procedures, Test, Training, Manufacturing & Assembly SHA, Updated FEMA, FMECA, FTA, TRA & SSSA O&SHA, HHA Inputs to Design, Changes, Training & Procedures
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U.S. DOT Federal Transit Administration
Section 4: Safety and Security Analysis (continued)
Hazard and Vulnerability Analysis Process
HAZARD OR VULNERABILITY IS IDENTIFIED
HAZARDS OR VULNERABILITY CAN BE IDENTIFIED BY ANY PROJECT MEMBER, INCLUDING CONTRACTORS AND SUBCONTRACTORS
HAZARD OR VULNERABILITY REPORTED
HAZARDS AND VULNERABILITIES ARE REPORTED TO PROJECT SAFETY ORGANIZATION AND DOCUMENTED
HAZARD AND VULNERABLITY ASSESSMENT MADE
DETERMINE HAZARD AND VULNERABILITY CAUSES; ANALYZE SEVERITY AND PROBABILITY FACTORS; DETERMINE CORRECTIVE ACTIONS; COMMUNICATE TO PROJECT PERSONNEL
RESOLVE HAZARDS
ASSUME RISK OR IMPLEMENT CORRECTIVE ACTION TO ELIMINATE OR CONTROL HAZARD OR VULNERABILITY; DOCUMENT ACTIONS TAKEN
FOLLOW-UP
MONITOR CORRECTIVE ACTIONS FOR EFFECTIVENESS
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U.S. DOT Federal Transit Administration
Section 5: Development of Safety and Security Design Criteria
• Approach to Development of Safety and Security Requirements and Design Criteria: Must describe recipients approach to creating suitable safety and security requirements and design criteria. Recipient must: – – – – Describe resources that will be used to develop requirements Describe how requirements will be used to develop design criteria Describe how requirements and criteria will be used to identify safety and security certifiable elements Explain approach for ensuring requirements and criteria are included in final specifications and contract documents • Design Reviews: Recipient must explain how safety and security will be addressed during design reviews • Deviations and Changes: Must identify process for ensuring all proposed changes are appropriately reviewed and approved prior to adoption
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U.S. DOT Federal Transit Administration
Section 6: Process for Ensuring Qualified Operations and Maintenance Personnel
• Operations and Maintenance Personnel Requirements: Must identify quantity and job classifications of personnel needed to operate and maintain the completed project – – Must specify qualifications and core competencies Must place special emphasis on front-line personnel • Plans, Rules and Procedures: Must identify, by name, specific safety, security, and emergency plans, rules, procedures, and manuals that will be developed by the recipient for the project – Must include a schedule for development
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U.S. DOT Federal Transit Administration
Section 6: Process for Ensuring Qualified Operations and Maintenance Personnel (continued)
• Training Program: Must identify training elements provided to employees, by job classification, to ensure capabilities to provide safe and secure service and to respond to emergencies – – Must provide development and training schedule including completion dates for employee qualifications and certifications Must document and retain personnel training records, qualifications, and certifications • Emergency Preparedness: Must identify exercises, drills, tabletops, or other activities used to ensure project readiness – Must explain how exercise results will be assessed, documented, and incorporated into project (i.e., after action reports or equivalent document) • Public Awareness: Must identify public outreach and education programs
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U.S. DOT Federal Transit Administration
Section 7: Safety and Security Verification Process
• Design Criteria Verification Process: Must describe process used to verify specifications, drawings, and contract documents conform to safety and security requirements and design criteria – Must explain approach to ensuring required inspections and tests are incorporated into project test plans • Construction Specification Conformance Process: Must describe process used to verify project elements conform to safety and security components of specifications, drawings, and contract documents • Testing/Inspection Verification: Must describe process used to verify as-built or delivered configuration contains/meets safety and security requirements of specifications, drawings, and contract documents – Includes contractual testing, system integration testing, and pre-revenue testing
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U.S. DOT Federal Transit Administration
Section 7: Safety and Security Verification Process (continued)
• Hazard and Vulnerability Resolution Verification Process: Must describe process used to verify hazards and vulnerabilities have been appropriately identified, analyzed, and resolved to acceptable levels • Operational Readiness Verification: Must describe process used to verify plans, procedures, rules, manuals, and training/qualification programs conforming to safety and security requirements – Must explain process for ensuring qualification and readiness of operations and maintenance personnel • Safety and Security Certification Requirements: Must describe process used to deliver final certification that project is safety and secure for revenue operation – Includes individual certificates of compliance for safety and security certifiable elements
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U.S. DOT Federal Transit Administration
Section 7: Safety and Security Verification Process (continued)
• Final Safety and Security Certification is the responsibility of the recipient • Includes a signed statement by the Project’s Chief Executive that the project has met established safety and security requirements and is ready for revenue operations • Failure to administer safety and security certification program can delay the start or revenue operation
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U.S. DOT Federal Transit Administration
Section 8: Construction Safety and Security
• Construction Safety and Security Program Elements: Must describe recipient’s program for construction safety and security – – Including contractor requirements for plans and reports that must be submitted by the contractor to the recipient Must describe activities recipient will perform to track and manage contractor construction safety and security programs and plans • Construction Phase Hazard and Vulnerability Analysis: Must describe recipient’s requirements for safety and security analysis at construction sites – Including approach to identifying and mitigating hazards and threats unique to the construction site • Safety and Security Incentives: Must describe incentives (if any) the recipient may provide for construction safety and security program
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U.S. DOT Federal Transit Administration
Section 9: Requirements for 49 CFR Part 659, Rail Fixed Guideway Systems: State Safety Oversight
•
Only required for recipients with major capital projects undertaken for rail transit agencies as defined by 49 CFR Part 659.5
• These recipients must describe activities performed to coordinate with its State Safety Oversight Agency • Must identify State Oversight Agency requirements and activities to be performed to address these requirements – Must provide a schedule for the activities the recipient will perform to ensure compliance with these requirements
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U.S. DOT Federal Transit Administration
Section 10: FRA Coordination
•
Only required for recipients that propose to share track with one or more FRA regulated railroads or that will operate on the general railroad system
• Activities that will be performed to comply with FRA regulations must be identified with a schedule for there completion • Recipients with commuter or passenger railroads, regulated by FRA, must also describe their process for developing or updating an SSPP and submitting it to FRA for review and approval – The SSPP must conform to APTA “Guidelines for the Development of Commuter Rail System Safety Program Plans” • These recipients must also submit for FRA review and approval, plans for the completion of a collision/derailment hazard analysis that conforms to the hazard management process in the approved SSPP or the “Draft FRA Guide to Collision/ Derailment Hazard Analysis.”
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U.S. DOT Federal Transit Administration
Section 11: DHS Coordination
• Must address how the project will meet DHS requirements including security directives issued by TSA and OGT • Recipients must identify activities to be performed with a schedule for completion • Concerns regarding potential conflicts between DHS/TSA/OGT and FTA/PMOCs must be documented
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U.S. DOT Federal Transit Administration
Referencing Other Documentation
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U.S. DOT Federal Transit Administration
Referencing Other Documentation
• If references to existing programs, plans or other documentation are used by a recipient in the SSMP, the reference must include: – – – – Document name Chapter or Title Appropriate page numbers A brief statement regarding how the referenced document addresses the applicable SSMP requirement • All referenced material must be made available to FTA and the PMOC for review • Materials appropriate for referencing include: – Other sections of the PMP – – Other Plans (e.g., SSPP, System Security Plan, Safety and Security Certification Plan, Construction Safety Plans, Emergency Plans, etc.) Contract Specifications and Project Documents
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U.S. DOT Federal Transit Administration
Sensitive Security Information (SSI) Management
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U.S. DOT Federal Transit Administration •
Sensitive Security Information (SSI) Management
In accordance with 49 CFR Part 15, each recipient is required to control the release of SSI • DOT policies and procedures for the control of SSI apply to all DOT employees, contractors, recipients, consultants, licensees, and regulated entities that have access to or receive SSI • All recipients must document or reference their procedures for managing SSI materials in the SSMP • FTA and its PMOCs will follow the recipients SSI management policies when reviewing SSI materials • Any SSI submitted to the FTA or its PMOCs by the recipient will be exempted from being available under the Freedom of Information Act (FOIA)
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U.S. DOT Federal Transit Administration
FTA Evaluation of Recipient SSMP Development and Implementation
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FTA Evaluation of Recipient SSMP Development and Implementation
U.S. DOT Federal Transit Administration • SSMP development and implementation is an on-going process that will be reviewed by the FTA through its PMOCs • SSMP review procedures have been developed and will be provided to recipients prior to the review • Recipients are strongly encouraged to
use Appendix A of Circular 5800.1 to prepare for review
• Review results will be documented in a report that will be provided to the recipient • PMOCs will work with recipients to close outstanding issues
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U.S. DOT Federal Transit Administration •
FTA Evaluation of Recipient SSMP Development and Implementation (continued)
Evaluation is based on 12, equally weighted criteria: 1.
2.
3.
4.
5.
6.
7.
8.
Recipients assignment of safety and security responsibilities Effectiveness of recipient’s process for identifying, communicating, and resolving safety hazards and security vulnerabilities Recipient’s technical capacity to support and maintain identified duties and responsibilities Recipient’s safety and security budget and schedule Extent to which safety and security requirements are incorporated into technical specifications and contract documents Extent to which SSMP activities and requirements are incorporated into technical direction given to contractors and recipient personnel Effectiveness of recipient’s management of contractor safety and security activities Extent to which recipients take documented action to address safety and security concerns
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U.S. DOT Federal Transit Administration •
FTA Evaluation of Recipient SSMP Development and Implementation (continued)
Evaluation is based on 12, equally weighted criteria: 9.
10.
11.
12.
Effectiveness of recipient’s verification that contractors, staff and committees built, installed, inspected and tested facilities, systems, and equipment according to safety and security requirements Effectiveness of recipient’s process for verifying contractors, recipient staff, and committees ensure the readiness of operations and maintenance personnel for revenue service Effectiveness of recipient’s process for providing safety and security certification, issuing Final Verification Report, and managing identified work-arounds or restrictions to full safety and security certification Effectiveness of recipient’s process for ensuring compliance with requirements specified by other agencies (e.g., State Oversight Agency, FRA, DHS, TSA, OGT, etc.)
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