Safety Information and Safety Management System (SMS)
SMS is a formal approach that enables organizations like the MBTA to proactively manage and mitigate safety risks. It has the following components:
- Safety management policy aligns organizations under an SMS to prioritize safety in management decision making.
- Safety Risk Management (SRM) identifies, evaluates, resolves, and tracks risk mitigations in a timely manner.
- Safety Assurance (SA) collects, assesses, and acts on data to meet safety objectives and effectively mitigate risk.
- Safety promotion supports workplace and public safety through engagement, communication of key safety information, and personnel training.
FTA Safety Management Inspection Response
FTA Special Directive 22-10
During their Safety Management Inspection (SMI), the Federal Transit Administration (FTA) issued Special Directive (SD) 22-10 and found that the MBTA:
- Does not have structures to support effective SMS operation
- Executive leadership needs prioritized, actionable information about safety risk mitigations
- Executive management does not consistently make decisions about safety risks based on safety data analysis or documented facts
- Does not consistently collect and analyze information on precursor factors during safety investigations and SA activities
- Does not clearly communicate safety risk assessment responsibilities to participants, which delays safety risk assessment activities
- Safety information management tools, such as hazard logs and safety risk mitigation logs, do not fully support resource prioritization to address safety risks and safety performance monitoring
Corrective Action Plans (CAPs)
The MBTA developed CAPs to address SD 22-10 findings. CAPs are made up of action items at different stages of progress:
- Not yet submitted: The action item has not been completed.
- Under FTA review: The MBTA completed the action item and submitted documentation to the FTA. The FTA is reviewing the MBTA's submission.
- Resubmissions in progress: The MBTA completed the action item and submitted documentation to the FTA. The FTA requested additional information from the MBTA.
- Submissions accepted by the FTA: The MBTA completed the action item and submitted documentation to the FTA. The FTA accepted the MBTA’s submission.
The MBTA completed procurement for SMS implementation and safety information technical support. We also launched a strategy and mapping effort for all safety and operational data to inform safety decisions across the organization.
SD 22-10 work informs rules compliance and review initiatives in response to SD 22-12: Policies, Procedures, and Training.
On October 13, 2023, the FTA approved the MBTA’s revisions to SD 22-10 CAPs 1–6, which are now SD 23-10 CAPs 1, 2R, and 4–6.
| CAP | Status | ||
|---|---|---|---|
| CAP | SD 23-10 CAP 1 reviews and updates SMS planning, implementation, and operations. | Status | In progress |
| CAP | SD 23-10 CAP 2R enables safety data sharing between the field and management, ensuring that safety risk decisions are based on data analysis or documented facts. | Status | In progress |
| CAP | SD 23-10 CAP 4 develops policies and procedures that ensure proactive safety risk monitoring, mitigations, and corrective actions. | Status | In progress |
| CAP | SD 23-10 CAP 5 defines and assigns roles, responsibilities, and thresholds of authority in carrying out safety risk assessments. | Status | In progress |
| CAP | SD 23-10 CAP 6 ensures that safety information management tools effectively prioritize resources to address safety risk and safety performance monitoring. | Status | In progress |
