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HomeMy WebLinkAboutAgenda - 03-17-2015 - 7dORANGE COUNTY BOARD OF COMMISSIONERS ACTION AGENDA ITEM ABSTRACT Meeting Date: March 17, 2015 Action Agenda Item No. 7 -d SUBJECT: System Safety Program Plan — Orange Public Transportation (OPT) DEPARTMENT: Planning and Inspections PUBLIC HEARING: (Y /N) No ATTACHMENT(S): 1) NCDOT System Safety Program Audit Assessment Report of Findings and Corrective Actions UNDER SEPARATE COVER 2) OPT System Safety Program Plan (Large 250 Page File ONLY Available at http..11oran ecountync. ov/trans ortation/ documents /OPTSafetyPlan03L5 dfl 1 INFORMATION CONTACT: Craig Benedict, Planning Director, 919 -245- 2592 Peter Murphy, Transportation Administrator, 919- 245 -2002 PURPOSE: To adopt an operational System Safety Program Plan (SSP) for Orange Public Transportation meeting the North Carolina Department of Transportation /Public Transportation Division (NCDOT /PTD) requirements. BACKGROUND: The Orange County Public Transportation Safety Program was reviewed August 26 -27, 2014 by NCDOT. A plan that was implemented in 2011 was reviewed and a number of items required updating for full compliance. OPT staff has updated the plan to eliminate deficiencies and meet all requirements under MAP -21 Moving Ahead for Progress in the 21St Century. The SSPP is implemented and reviewed annually: • To establish a safety program on a system wide basis. • To provide a medium through which Orange County can display its commitment to safety. • To provide a framework for the implementation of safety policies and the achievement of related goals and objectives. • To satisfy federal and state requirements. • To meet accepted industry standards and audit provisions. • To satisfy insurance carrier provisions. FINANCIAL IMPACT: Adoption of an SSP Plan is required for continuation of Federal and State funding for the major portion of Orange Public Transportation's programs for bus purchasing and administrative assistance. Failure to comply with NCDOT /PTD requirements would result in suspension of funding. RECOMMENDATION(S): The Manager recommends the Board adopt the staff - recommended System Safety Program Plan. NORTH CAROLINA DIVISION OF PUBLIC TRANSPORTATION Attachment 1 SYSTEM SAFETY PROGRAM AUDIT ASSESSMENT REPORT OF FINDINGS AND CORRECTIVE ACTIONS ATTACHMENT 1 System Name: Orange Public Transportation }10CTM Glp Olt 'Jr 2 - `° O V� Or TR nH1'10 L Location: 600 Hwy 86 North Auditor: Malcom D. Massenburg Date: August 26 & 27, 2014 Maintenance Performed By: Orange County Vehicle Maintenance Number of Vehicle Maintenance Records Inspected: Twelve (12) of nineteen (19) Number ofEmployees Training Records Inspected: Twelve (12) offomteen (14). Fourteen (14) includes the director and assistant director Number of Vehicles Inspected: Ten (10) ofnineteen (19) Number of Ride Check- Driver Evaluations Performed: One(1) and One(1) observation Core System Safety Program Finding Deficiency Audit Recommendation: Implementation Plan ofAction(s): OPT response /actions as of Feb 6, 2015 @ Response Date Element The implementation plan should be in sufficient March 2015 Due Closed detail to - a. Clearly demonstrate what actions have occurred General Was the SSPP revised to meet the current requirements ofNCDOT/PTD as D Plan was not revised to meet the current NCDOT/PTD Revise agencies SSPP to meet current requirements. SSPP updated November 2014. Jan 7, 2015. Noted - Copy will be provided to NCDOT/PTD. OPT November 6, 2014 addressed in the Desk Top Review Document? (Reference: PTD Standard requirements. Plan on file is from 2010 and is still in Submit plan to NC sOT/PTD for review prior to NCDOT/PTD: You will need to send a copy of your Update March 2015 - Currently on the agenda for Operating Procedure SSPP -001) draft f approval by the agencies governing board updated plan to NCDOT/PTD for review prior to Cmmty Board of Commisioners Meeting 3/17/15. sending it to your governing board for signature. General Is there a process and timeline for reviewing and updating the SSPP D Unable to verify. No documented timeline in place for Ensure plan is submitted to NCDOT for review and 0 SSPP 2011 was reviewed and approved by BOCC. Noted - Copy will be provided to NCDOT/PTD. OPT November 6, 2014 annually? Was the annual review approved by the Board of Directors or reviewing and updating plan. your agencies governing board by the required due date. SSPP was updated November 2014 and will be Update March 2015 - Plan copy sent to NCDOT for equivalent ?) (Reference: PIT) Standard Operating Procedure SSPP -001) Ensure there is a documented process to conduct annual submitted for Board approval after review by NCDOT. review. Procedures have been established 0 submitt our plan review and to document and track plan changes. Jan 7, 2015. NCDOT/PTD, you will need to submit SSP to our governing board for approval on an mount the plan to NCDOT/PTD for review prior to this finding basis. being closed. General Are any transportation services contracted? NR General Is the subreeipient providing adequate oversight of the contractor? General Are vouchers provided for transportation service? NR General Are volunteer (to include taxi cab drivers and contractors) drivers used for NR transit services. 1 Section l Driver/Employee Seleetion The deficiencies noted above until corrected indicate that your system is non - compliant with NCDOT policies. Corrective action must betaken by the given date to prevent further penalties or termination of your contract. Page 1 of 15 NORTH CAROLINA DIVISION OF PUBLIC TRANSPORTATION SYSTEM SAFETY PROGRAM AUDIT ASSESSMENT REPORT OF FINDINGS AND CORRECTIVE ACTIONS Core System Safely Program Finding Is Audit Recommendation: Implementation Plan ofAction(s): OPT response /actions as of Feb 6, 2015 @ Response Date Element Theimplementation plan shouldbein sufficient March 2015 Due Closed detail to - 7agmcies a. Clearly demonstrate what actions have occurred Has background and character checks (i.e., criminal history and motor vehicles D Criminal background checks were not conducted on d implement a process to ensure criminal The Orange County HR Department has proposed a Yes. The procedure is located within the 'Driver November 6, 2014 cords) been conducted prim to hiring new safety sensitive employees? w employees. The transit director stated he was and drivers license checks are conducted, draft policy for the County Managers and the BOCC's Selection' section. Included iWOPT Initial Hiring (Reference: NCGS 114 -19.6 Criminal History Record Check, 49 CUR, Part 391 are this process applied 0 transit because it is a d dated by the reviewer. Update the consideration which addresses the issue of conducting Procedures for Drivers' and'Procedures for selecting a and TSA/FTA Security and Emergency Management Action Items for Transit DUDS reference. This fording applies since the transit ing policies to match actua l policy criminal background checks for prospective employees mfe driver' Upon review, the supervisor will sign and Agencies; Management and Accountability) agency transports passengers on behalf of DUDS and requiems. as, mandated by federal and/or state statutes requiring date the background check document. has no other method in place to ensure transit criminal background investigations. The first step in this employees door have criminal past that would prevent process is to seek legal approval by the County them from working with children, disabled or the Attorney's Office The HR Department has provided a elderly passengers. Drivers license checks were draft to the County Attorney's Office for review and conducted but not dated and initialed by the reviewer. -it, which requires additional information. The ;;Agencies plan, pg. 3 states potential employees must Human Resource Department has an established vendor meet the follow requirements prim to hire: "Good account to conduct any required criminal background driving record with no Driving While Intoxicated check. For MVR processing, signature and review (DWI), Driving Under the Influence (DUI) or similar dates were added to the driver MVR forms on file. charges ". French Paul Trembley received a DWI 5 -16- Future MVR requests will be submitted on the 84 but was recently hired. The director stated a records established mount date or as needed through the HR review was conducted on Sane 12th and Mr. Trembley Dept. and reviewed with OPT Management. Reviewed passed the HR process. hiring policy to include minimum standards - replaced with established policy. San 7, 2015. NCDOT/PTD: Is there currently a method in place to conduct background checks on new employees or employees moving into a safety sensitive position? Will the person reviewing the record be required to Sign and Date the background check? L4 1.5 Has annual motor vehicle record review(s) been conducted of all drivers? D Three records were reviewed, Reviewed MacArthur Develop and implement a process 0 ensure drivers Establish procedure for HR to conduct records check November 6, 2014 (Reference: 49 CFR, Part 391 and TSA/FTA Security and Emergency Howard Smith, Peter Murphy and Oakley Wendy license checks are conducted, reviewed and dated by and review with OPT Management. Reviewer's Management Action Items for Transit Agencies; Management and Wilson. Records were not dated or initialed by the the reviewer. Develop an oversight process to ensure signature was added 0 the records. Electronic file with Accountability) reviewer. One operator Oakley Wilson's license expires records are updated at the required intervals. expiretca dates has been updated and a printed copy 10- 31 -14, there is no documented oversight process in has been added to the review file. place to prompt management to ensure license are updated at the required interval 2 Section Driver/Employee Training 2.1 Is a training program in place for employees (drivers, dispatchers, etc...)? Has D The transit agency doesn't have a training plan that list Develop and implement a specific training plan for each Driver training program requires improved record A training plan is included identifying training November 6, :014 specific training requirements been identified for each position? (Reference: specific training requirements for each position, at what position that list training requirement, training intervals keeping to include checklists and signatures to insure objectives and training intervals. Position Specific Mannorm Training Standards for Community and Human Service Transportation intervals training is conducted, and when training and identifies when training objectives have been completion of same. Also added to individuals' training training has been conducted for each position and added Vehicle Operators ... Records Retention and Disposition Schedule, Standard -15 objectives have been accomplished accomplished- folders. San 7, 2015. NCDOT/PTD: Has a training to the employees training record Employees records Personnel Records, Item 29...29 CFR 1627.3) plan been developed that list position specific training have been documented 0 reflect their commit and identifies training objectives and required training knowledge level and all future position specific training intervals9 and annual training will be documented in the employees training record- The deficiencies noted above until corrected indicate that your system is non - compliant with NCDOT policies. Corrective action must be taken by the given date to prevent further penalties or termination of your contract. Pa �- 2 1 c NORTH CAROLINA DIVISION OF PUBLIC TRANSPORTATION SYSTEM SAFETY PROGRAM AUDIT ASSESSMENT REPORT OF FINDINGS AND CORRECTIVE ACTIONS Core System Safely Program Finding Audit Recommendation: Implementation Plan ofAction(s): OPT response /actions as of Feb 6, 2015 @ Response Date Element The implemeotattoo plan should be in sufficient March 2015 Due Closed detail to - a. Clearly demonstrate what actions have occurred 2.2 Are ride checks conducted to assess training success and safety- related D Ride checks were not conducted at the required Develop and implement an oversight process to ensme Updated policy for Assistant Administrator to conduct November 6, 2014 performance? (Reference: Minimum Training Standards for Community and intervals. ride checks are conducted and documented at the ride checks throughout the year. Reviewed bi- monthly Human Service Transportation Vehicle Opemfrs) required intervals. with the System Administrator. 2.3 Are performance deficiencies noted during the ride check corrected and D Serious deficiencies were noted during ride checks but Conduct ride checks to assess training success and With the above established ride check standards, November 6, 2014 documented? (Reference: Minimum Training Standards for Community and courective actions were not taken. One operator safety related performance. Document the ride checks immediate re- training will be provided with signatures Human Service Transportation Vehicle Opemfrs) answered her cellular phone while driving, two others and have the operator and the evaluator sign the ride required from both trainer and operator. Missing had to be reminded to use two hands when driving and check form. Conduct and document remedial/follow -up signatures were obtained and noted items were one as speeding and had issues with wheel chair lift training to correct noted items and when required r wed with operators. The specific operators noted in operation. There was no corrective actions or redial conduct follow -up ride checks to measure training the review were directly notified of any deficiencies and training conducted/documemcd- One employee had mccess. Document all training in the employees all operators received additional safety training at a none of the same issues on ride checks in 2012 and training record scheduled Saturday training session. Laws governing 2013. I rode with the person during my audit and noted CDL operator cell phone usage was redistributed to all the person still drove with one hand, did not operate the employees. vehicle smoothly and occasionally was speeding. There were at least two operators who did not sign acknowledgement of their ride check; in addition the person conducting the ride check did not sign the form. 2.5 Are there procedures in place to decide when remedial training is necessary? D No documented process in place f determine when Develop and implement a process f determine when Updated - OPT Employee training record calendar. Sou New hire training is scheduled and conducted upon November 6, 2014 (Reference: Minimum Training Standards for Community and Human Service remedial training is required. Items identified oa ride remedial training is required. Document remedial 7, 2015. NCDOT/PTD: I am not same how the hiring. Annual training is conducted at specifc Transportation Vehicle Operators) check should have been remedially trained and training training to include success and challenges, in the employee training calendar relates to determining intervals, reflected on the employee training calendar. documented in employee record. employee training record. remedial training. What process is used to determining Remedial training is conducted oa a case-case basis when and if remedial training is required? resulting from ride check observations, preventible accident determinations, or compliants. All training is noted in Employees' Training File. 2.7 Is there documentation of all previous training classes? Does the documents D Training was not conducted at the required intervals for Develop and implement a process f ensure training is Updated - OPT Training record form. Quarterly November 6, 2014 included: the training objectives or lesson plans, trainers' names and and veteran employees. Training records were not conducted at the required intervals. Document training training was previously established and posted New qualifications, length of training, training mode (e.g., video, classroom, OJT)? updated to reflect the training that was conducted. in the employee training record and have the trainer and documentation allows sufficient crosschecking with the (Reference: Minimum Training Standards for Community and Human Service There were several folders containing training rosters trainee sign in receipt of the training. training files to indicate and ensure all operators Transportation Vehicle Operators... Records Retention and Disposition Schedule, but the information was not in an organized manner, not completed the quarterly training. Standard -15 Personnel Records, Item 29...29 CFR 1627.3) all employees attended and the information was not Below training related items (2.8 to 2.24) were updated transferred to employee training records. with similar improvements to documentation + additional noted items. 2.8 Is there training on customer relations techniques? (Reference: Minimum D No record of up -fdate customer relations techniques Develop and implement a process f emon, training is Updated OPT - Employee Training to include Customer November 6, 2014 Training Standards for Community and Human Service Transportation Vehicle training. conducted at the required intervals. Document training Relations Techniques. Operators) in the employee training record, have the trainer and trainee sign in receipt of the training. 2.9 Is there [mining on passenger assistance and sensitivity techniques for serving D Training not up to date on passenger assistance and Develop and implement a process f emon, training is Updated OPT - Employee Training Calendar included November 6, 2014 older and disabled passengers? (Reference: Minimum Training Standards fm sensitivity techniques fm serving older and disabled conducted at the required intervals. Document training in ADA training module Community and Human Service Transportation Vehicle Operators... Records passengers. in the employee training record and have the trainer and Retention and Disposition Schedule, Standard -15 Personnel Records, Item trainee sign in receipt of the training. 29...29 CFR 1627.3 ) The deficiencies noted above until corrected indicate that your system is non - compliant with NCDOT policies. Corrective action must be taken by the given date to prevent further penalties or termination of your contract. Page 3 of 15 NORTH CAROLINA DIVISION OF PUBLIC TRANSPORTATION SYSTEM SAFETY PROGRAM AUDIT ASSESSMENT REPORT OF FINDINGS AND CORRECTIVE ACTIONS Core System safely Program Finding Is Audit Recommendation: Implementation Plan ofAction(s): OPT response /actions as of Feb 6, 2015 @ Response Date Element Theimplemeutatiou plan shouldbein sufficient March 2015 Due Closed detail to - 7-mee a. Clearly demonstrate what actions have occurred 2.10 Is there training on wheelchair securement? (Reference: Minimum Training D No record of current training on wheelchair securement d implement a process to ensure training is Updated OPT - Employee Training Calendar to include November 6, 2014 Standards for Community and Human Service Transportation Vehicle Based on ride checks repetitive refresher training is at the required intervals. Document training wheelchair securement in ADA training module. Ride Operators 49 CFR, Part 37.173 Transportation Services for Individuals with required. oyee training record and have the trainer and checks to include wheelchair securement reviews Disabilities) in receipt of the training. ide ntifying any additional ADA training needs. 2.11 Is there training on wheelchair lift operation? (Reference: Minimum Training D No record of up- Iodate training on wheelchair lift Develop and implement a process to ensure training is Updated OPT - Employee Training Calendar to include November 6, 2014 Standards for Community and Human Service Transportation Vehicle operation for all employees. During pre -trip driver was conducted at the required intervals. Document training wheelchair securement in ADA training module Operators 49 CFR, Part 37.173 Transportation Services for Individuals with unnowere that lift platform lights could not be removed in the employee training record and have the trainer and Disabilities) and must work. trainee sign in receipt of the training. 2.12 Is there training on evacuation of passengers, including elders and persons with D No documentation of up-to-date training un evacuatiom Develop and implement a process to emsure training is Updated OPT - Employee Training Calendrer, added to November 6, 2014 disabilities, from transit vehicles (including simulations)? (Reference: of passengers, including elders and persons with conducted at the required interests. als. Document training Emergency Prcedures Minimum Training Standards for Community and Human Service Transportation disabilities, from transit vehicles for all employees in the employee training record and have the trainer and Vehicle Operators... OSHA 29 CUR 1910.38 - Emergency Action Plans) trainee sign in receipt of the training. 2.13 Is there training on emergency procedures and equipment use (including D No documentation of up-to-date training for all Develop and implement a process to emsure training is Updated OPT - Employee Training Gilead —, added to November 6, 2014 simulation exercises)? (Reference: Minimum Training Standards for employees un emergency procedures and equipment use conducted at the required intervals. Document training Emergency Procedures Community and Human Service Transportation Vehicle Operator, OSHA 29 (including simulation exercises) in the employee training record and have the trainer and CUR 1910.38 - Emergency Action Plans and 29 CFR 1910, Section 1910.158 (g) trainee sign in receipt of the training. (2)) 2.14 Is there training on accident and incident reporting procedures (including D No documentation of up-to-date training un accident Develop and implement a process to emsure training is Updated OPT - Employee Training Calendrer, added to Yes, it's part of Defensive Driving Training' and November 6, 2014 anagement roles and relevant checklists)? (Reference: Minimum Training and incident reporting procedures (including conducted at the required intervals. Document training Emergency Procedures San 7, 2015. NCDOT/PTD: "Accident Prevention' information. OPT March 2015 Standards for Community and Human Service Transportation Vehicle management roles and relevant checklists) for all in the employee training record and have the trainer and Will the emergency Procedures training include training update - Emergency proceedures training for both the Operators...NCDOL: A Guide to Transportation Safety) employees. trainee sign in receipt of the training. on accident and incident training? dispatcher and the drivers have been developed. Training is ongoing and docinum d in the employee training record as it is conducted. 2.15 Is there annual training on first aid? (Reference: Minimum Training Standards D No documentation of up-to-date training un first aid for Develop and implement a process to emsure training is Included in emergency procedure module; under November 6, 2014 for Community and Human Service Transportation Vehicle Operators ...NCGS all employees. conducted at the required intervals. Document training emergency equipment usage 95 -254. - Safety and Health Program... Rules) in the employee training record and have the trainer and trainee sign in receipt of the training. 2.16 Is there training on blood -borne pathogens and exposure control plaa? D No documentation of up-to-date training un blood- Develop and implement a process to ensure training is Updated Orange County training module - blood home November 6, 2014 (Reference: Minimum Training Standards for Community and Human Service home pathogens and exposure control plan for all conducted at the required intervals. Document training pathogens procedures included in SSPP Transportation Vehicle Operators... 29 CFR 1910.1030 - Bloodbome employees. in the employee training record and have the trainer and Pathogenn, NCGS 95 -254. - Safety and Health Program... Rules) trainee sign in receipt of the training. 2.17 Do drivers receive defensive driving training? (Reference: Minimum Training D No documentation of up-to-date training on defensive Develop and implement a process to ensure training is Updated OPT - Employee Training Calendar to include November 6, 2014 Standards for Community and Human Service Transportation Vehicle Operators) driving for all employees. conducted at the required intervals. Document training defensive driving module in the employee training record and have the trainer and trainee sign in receipt of the training. The deficiencies noted above until corrected indicate that your system is non - compliant with NCDOT policies. Corrective action must be taken by the given date to prevent further penalties or termination of your contract. Page 4 of 15 NORTH CAROLINA DIVISION OF PUBLIC TRANSPORTATION SYSTEM SAFETY PROGRAM AUDIT ASSESSMENT REPORT OF FINDINGS AND CORRECTIVE ACTIONS Core System Safety Program Finding Audit Recommendation: Implementation Plan ofAction(s): OPT response /actions as of Feb 6, 2015 @ Response Date Element The tmplemeotattou plan should he in sufficient March 2015 Due Closed detail to - a. Clearly demonstrate what actions have occurred 2.18 Do drivers, dispatchers and supervisory staffreceive training on the proper D No documentation of training of drivers, dispatchers Develop and implement a process to ensure training is Updated Safety Data Acquisitions (SSPP) module to Included in the training material for bus drivers is November 6, 2014 operation of communication equipment? (Reference: Minimum Training and supervisory staffreceive training on the proper conducted at the required intervals. Document training include 10 -codes radio training. Jan 7, 2015. Orange County commmiation's policy which addresses Standards for Community and Human Service Transportation Vehicle Operators operation of communication equipment for all in the employee training record and have the trainer and NCDOT/PTD: What training method(s) do you have the use of cell phones, radio use procedures including and NCGS 20- 137.4A) employees. trainee sign in receipt of the training. in place to train employees on the operation of 10 codes and NCGA 20- 137.4A regarding unlawful communication equipment to include cellular phones? uses of mobile telephones. OPT March 2015 update - Do you utilize the instruction manual, do you use Training is documented in the employee training comfy policies or have another method of training? records for new employees or when new equipment is recieved- Veteran employees have a statement placed in their record stating they were trained through OJT methods and are familiar with the use of the equipment. 2.19 Are drivers trained on operating a vehicle in winter or other inclement weather? D No documentation of up -to -date training on operating a Develop and implement a process to ensure training is Updated Safety Data Acquisitions (SSPP) module to No, the Hazardous Weather Plan does not include this November 6, 2014 ( Reference: NCDOT/DMV Commercial Driven Manual, Section 2.13 - Driving vehicle in winter or other inclement weather fir all conducted at the required intervals. Document training include Orange County - Hazardous Weather Plan Jan inf ation. See 'Employee Terming' section - " in Winter Conditions) employees. in the employee training record and have the trainer and 7, 2015. NCDOT/PTD: Does the counties Hazardous Emergency Driving Procedures" that includes trainee sign in receipt of the training. Weather Plan include information on how to operate a information on how to operate a vehicle in vehicle in wiaterhuclement weather? winter /inclement weather. 2.20 Are drivers trained on handling brake failure and rapid tire deflatim? D No documentation of training for all drivers on Develop and implement a process to ensure training is Updated Safety Data Acquisitions (SSPP) module to November 6, 2014 (Reference: NCDOT/DMV Commercial Drivers Manual, Section 2.15 - handling brake failure and rapid tire defiatim. conducted at the required intervals. Document training include emergency mechanical situations Emergencies and 49 CFR, Part 383) in the employee training record and have the trainer and trainee sign in receipt of the training. 2.21 Are drivers trained on crossing railroad tracks? (Reference: NCDOT/DMV D No documentation of training for all drivers on crossing Develop and implement a process to ensure training is Updated Safety Data Acquisitions (SSPP) module to November 6, 2014 Commercial Drivers Manual, Section 4.3 On the Road...NCGS 20 -142.3 - railroad tracks. conducted at the required intervals. Document training include crossing railroad tracks procedures Certain vehicles most stop at railroad Crossings... 49 CFR 392.10 - Driving of in the employee training record and have the trainer and Vehicles) trainee sign in receipt of the training. 2.22 Is training conducted at the required intervals for new and veteran employees? D Documentation on on file to validate training was Develop and implement a process to ensure training is Updated - OPT Employee Training Calendar and November 6, 2014 (Reference: Minimum Training Standards for Community and Human Service conducted at the required intervals for new and veteran conducted at the required intervals. Document training Employee Training Record to reflect training record and Transportation Vehicle Operators) employees. in the employee training record and have the trainer and training frequency trainee sign in receipt of the training. 2.24 Have employees received training on the proper use of personal protective D Documentation on on file to validate employees Develop and implement a process to ensure training is Updated OPT - Employee Training Calemb er, added to Included in'Bloodbome Pathogens' training; PPE November 6, 2014 equipment? (Reference: 29 CFR, Section 1910.132) received training on the proper use of personal conducted at the required intervals. Document training Emergency Procedures Jan 7, 2015. NCDOT/PTD: equipment provided in blood -spill kits at no cost to the protective equipment. in the employee training record and have the trainer and Has PPE requirements been identified and equipment employee. Training has been provided and acted is the trainee sign in receipt of the training. purchased fir the required task. Has training take place training files. in accordance with the manufactures requirements and training documented in the employees OJT records? 3 iSection 3 Safety Data Acquisition /Analysis 3.1 Has a safety officer been identified? Are his/her required responsibilities D A Safety officer has not been identified in writing the Identify a safety officer in writing and establish a Orange County - OPT Assistant Transportation No—her 6. 2014 identified in the posimmajob description? (Reference: MAP -21 - Section 5329) director stated the Transportation Assistant written description of the person's responsibilities. Administrator is the Safety Officer. Documents have Administrator is has this f mctim. The job description been updated to reflect the same. for this position was last updated April, 16, 2010 and doesn't list safety officer as a job requirement. The deficiencies noted above until corrected indicate that your system is non - compliant with NCDOT policies. Corrective action must be taken by the given date to prevent further penalties or termination of your contract. Page 5 of 15 NORTH CAROLINA DIVISION OF PUBLIC TRANSPORTATION SYSTEM SAFETY PROGRAM AUDIT ASSESSMENT REPORT OF FINDINGS AND CORRECTIVE ACTIONS Core System Safety Program Finding Audit Recommendation: Implementation Plan ofAction(s): OPT response /actions as of Feb 6, 2015 @ Response Date Element Theimplemeutatiou plan shouldhein sufficient March 2015 Due Closed detail to - 7mf—at,-. a. Clearly demonstrate what actions have occurred 32 Is there a program to raise safety awareness among drivers and other personnel? D Safety items are discussed at the quarterly training and nd implement a method to ensure all Updated Employee Training files to reflect most recent November 6, 2014 Has the transit system implemented a safety program that focus on providing a documentation is maintained on file, however based on either attend safety meetings or material or training date. Employee training calendar has been safe environment for customers and employees? (Reference: NCGS 95 -251 and sign in sheets, not all employees attend the training. on information and sign acknowledge of updated to ensure timely training sessions. 252 - Safety and Health Programs and Safety and Health Committees Required) Conduct a complete documented safety review of the transit agency and brief employees em the results. Post known hazards in a common area accessible by employees. 3.4 Is there a method for identifying and evaluating safety risks throughout all D There is a risk management process on file but no Review /update the agencies risk assessment process. Risk Management process added to employee binder for November 6, 2014 elements of the recipient's public transportation system? (Reference: MAP -21 - documentation on file to indicate the process was Turin employees on how to use the process and re rew Section 5329) trained or used to document risk. The transit system document the training in their employee training record has been in the current facility since December 2013 Conduct an assessment of transit operations document but did not conduct a risk assessment prior to moving risk and post accepted risk in a common location into the facility . accessible by employees. 3.5 What are the strategies to minimize the exposure of the public, personnel and D The transit agency doesn't have a documented process Develop a and implement methods to minimize the Wires have been covered with an appropriate cover to The current estimation is February 20 to address options November 6, 2014 property to hazards and unsafe conditioms? (Reference: MAP -21 - Section in place. There were several safety items identified exposure of public, personnel and property to unsafe prevent tripping hazards. Flammable items have been for the Ditch erosion area and steps. OPT March update 5329) during the audit. (1). The director has tape covering conditions. Document and post known hazard until renowed from the facility and vehicles. Employees have - A thorough review and hazard assessment of the electrical wires in his office but the tape is peeling in they are eliminated. Train employees on the process been trained regarding potential hazards and pull their facility and vehicle parking area has been conducted. several places causing a tripping hazard (2). The front and document the training in their employee training vehicles forward before performing the walk around of Obvious hazards have been removed and work orders steps into the facility are a slick brick and is not coated record the vehicle. Facilities Management is assessing the long have been opened with the county facility maimmusnced with any non -skid material or anything to prevent slips term improvements to the building and landscape. San department fir the long term hazards. Outlook calendar or falls. (3). Flammable items are stored inside the 7, 2015. NCDOT/PTD: Did facility maintenance entries have been established to follow -up em the known custodial closet in the buildings hallway, (4). provide a timeline on when they will have a fix for the hazards until they are resolved. Flammable items (deicer) in aerosol caul are stored in noted items9 the vehicles this poses an flammable hazard and a p jectile hazard and explosion hazard from the can sitting in the son, getting too hot and exploding (5). The steps leading to the vehicle parking area are in disrepair, employees are walking down the steep grass covered hill rather using the steps (6). The ditch behind the vehicle parking area is eroding. This prevents drivers from getting behind some vehicles to check lights. The deficiencies noted above until corrected indicate that your system is non - compliant with NCDOT policies. Corrective action must be taken by the given date to prevent further penalties or termination of your contract. Page 6 of 15 NORTH CAROLINA DIVISION OF PUBLIC TRANSPORTATION SYSTEM SAFETY PROGRAM AUDIT ASSESSMENT REPORT OF FINDINGS AND CORRECTIVE ACTIONS Core system safely Program Finding Audit Recommendation: Implementation Plan ofAction(s): OPT response /actions as of Feb 6, 2015 @ Response Date Element The implemeotattoo plan should be in sufficient March 2015 Due Closed detail to - a. Clearly demonstrate what actions have occurred 3.6 Is there a process in place to investigate or study accidents and incidents to D The transit agency doesn't have a documented process Develop a and implement a process to study accidents OPT management reviews all accidents and incidents A completed Orange County accident or incident report November 6, 2014 determine if they were "avoidable" or "unavoidable "? (Reference: NCGS 95- in place to investigate or study accidents and incidents and incidents to determine if they were avoidable or for preventability. After determination, the review will is completed. Photos, videos, and completed reports me 252 - Safety and HealW Committees Required) to determine if they were "avoidable" or "unavoidable". unavoidable. Train employees on the process and be noted for the record and training will be provided as forwarded to the Transportation Administrator or document the training in their employee training record indicated. San 7, 2015. NCDOT/PTD: What is the designee for review and determination of cause. For documented process OPT uses to review all accidents accidents, a preventibihty letter is generated indicating and arrive at the determination if an accident was the determination and maintained in the file. vendable/unavendable? 3.9 Do vehicle operators (drivers) wear reflective vests will performing job D 26 Aug 1:05 p.m., the driver of vehicle 35 was observed Implement a process to ensure employees have and All OPT operators wear reflective safety vests while on November 6, 2014 fimctioos? ( Refereace: Minimum Training Standards for Community and by NCDOT/PTD auditor as she walked to vehicle got in ware reflective vest. Train employees on the requires duty. The operator noted had removed vest while on Human Service Transportation Vehicle Operators) and drove off with out a safety vest. and document the training in their employee training meal break and was observed wearing vest while on record Conduct random spot checks to ensure duty. OPT will continue to enforce use of safety vests compliance. through training and observation. 3.11 Has the transit agency adopted an exposure control plan that eliminates or D The current agency exposure control plan doesn't Update the plan to ensure all the required portions of 29 Blood -Borne pathogens policy updated in SSPP and on November 6, 2014 minimizes employees' exposure to blood -bome pathogens? (Reference: 29 CFR address all the required items. There are no procedures CUR 1910.1030 are addressed Train employees on the OC website 1910, Section 1910.10309 in place to deal with contaminated waste. requirements and document the training in their employee training record. 3.12 Are there written procedures detailing the required actions to clean contaminated D There are no written procedures in the place for Develop written procedures cleaning contaminated Blood -Borne pathogens policy updated in SSPP and on Yes, the Bloodbome Pathogens training includes step- November 6, 2014 vehicles/equipment? Has training been provided to the employees identified to cleaning contaminated vehicles /equipment beyond the vehicles and equipment. Train employees on the OC website San 7, 2015. NCDOT/PTD: Dose the by -step instructions including ontsourced interior decontaminate and clean the vehicle/equipment? ( Refereace: 29 CFR 1910, capabilities of a single exposure control kit. requirements and document the training in their updated policy contain instructions on how to clean vehicle cleaning. Section 1910.120 (d) (e)) employee training record. contaminated vehicles /equipment? 3.17 Is there a written Fire Prevention Plan for the workplace? Does the plan meet D A fire prevention plan has not been developed or Develop a fire prevention plan that includes removing Fire prevention Plan updated in 2014 SSPP and added Drivers were trained in Sept 2014 regarding the storage November 6, 2014 OSHA requirements? (Reference: 29 CFR 1910, Section 1910.39) established for the transit agency. flammable items stared in vehicles and the transit to employee training binder San 7, 2015. of flammible materials. Items were removed from building. Train employees on the Fire Prevent Plan and NCDOT/PTD: Have employees been trained on the vehicles and stured appropriately. The updated Fire document the training in their employee training record updated plan? Prevention Plan will be reviewed at an upcoming safety meeting. The deficiencies noted above until corrected indicate that your system is non - compliant with NCDOT policies. Corrective action must be taken by the given date to prevent further penalties or termination of your contract. Page 7 of 15 NORTH CAROLINA DIVISION OF PUBLIC TRANSPORTATION SYSTEM SAFETY PROGRAM AUDIT ASSESSMENT REPORT OF FINDINGS AND CORRECTIVE ACTIONS Core System Safety Program Finding Audit Recommendation: Implementation Plan ofAction(s): OPT response /actions as of Feb 6, 2015 Et Response Date Element The implemeotattoo plan should he in sufficient March 2015 Due Closed detail to - a. Clearly demonstrate what actions have occurred 3.19 Has a workplace hazard assessment been accomplished to determine if hazards D The transit agency moved into this facility in Dec 2013, Conduct a workplace assessment on the transit agency Facilities maintenance personnel removed florescent Yes, an assessment was conducted. November 6, 2014 me present or likely to be present? Is there a written certification documenting a workplace hazard assessment was not accomplished to to determine hazards accept in writing hazards that bulb and other flammable items from the building. Jan the hazard assessment? (Reference: 29 CFR 1910, Section 1910.132) determine if hazards are present or likely to be present. can't be eliminated. Brief employees on known 7, 2015. NCDOT/PTD: Has an assessment been The transit agency stored a used long tube style hazards document the hazards and post those hazards conducted of the entire operation to determine what if florescent bulb stored in the HVAC area. Storing in a common location. Remove used light from HVAC any hazards are present? florescent bulbs in an HVAC area poses an inhalation me and prevent the future storage of florescent bulbs hazard to building occupants. in this area. 3.20 If hazards are present, has the required employee protective equipment (PPE) D PPE is required for the use of some chemicals used by Identify PPE requirements and issue required items. Documentation has been updated and is included in the Yes, PPE training is included in 'Emergency November 6, 2014 been identified? (Reference: 29 CFR 1910, Section 1910.132) the transit agency but PPE requirements have not been Train employees on proper use of equipment and risk management process. Jan 7, 2015. Procedures" training identified, issued and trained. document the training in the employee training record NCDOT/PTD: Have PPE requirenames been identified? 5 Section 5 Vehicle Maintenance 5.2 Is there a written maintenance plan? (Reference: PIT) Standard Operating D The agency doesn't have an approved maintenance plan. Develop and update the transit agencies maintenance Updated and added to SSPP 2014; AssetWorks Vovemher 6, 2014 Procedure SSPP -00I and ETA Circular 5010.0 and 9030.1C) The information presented for review was a 2010 draft plan. Ensure the plan contains all of the required information included in documentation. plan that did not contain the required AssetWorks information. information. 5.3 Does the maintenance plan meet the minimum manufacturer's requirements? D The maintenance plan only showed service Update the vehicle maintenance plan to include the Updated and added to SSPP 2014; AssetWorks training November 6, 2014 (Reference: PTD Standard Operating Procedure SSPP -001 and ETA Circular requirements for an A preventive maintenance (PM) required inf atioo. Include the plan as part of the has been scheduled with ITRE. OPT is working with 5010.0 and 9030. IC) inspection. The PM A doesn't meet all the requirements agencies SSPP and submit the plan for NCDOT/PTD ITRE personnel to update AssetWorks initial setup to established by the manufacturer. The a service does not review prior to adoption by you governing board. reflect the current program designed to meet cover all of the service elements required by the manuffacturoms recommendations. manufacture. The maintenance plan doesn't list the required AssetWorks information. 5.5 Are the vehicle emergency exits inspected at the required intervals? (Reference: D Emergency exit inspections is listed w the pre -trip Incorporate the emergency exit inspection as part of an Emergency exit inspections are included in the Yes. Emergency exit inspections are included in the November 6, 2014 Manufacturers mount and 49 CFR, Part 396) inspection but the information is not maintained as part Asset Works process. Establish documented procedures preventive maintenance scheduling and will be service records. of the vehicle record. There is no listing of items to ensure operators consistently check the require items. maintained in the AssetWorks software. Jan 7, 2015. operators are required to check and it was observed not Maintain the checks in the vehicle maioteoaoce file. NCDOT/PTD: Are the preventive maintenance all operators check the same items during pre -trip checks/services conducted every 90 days? Is there a inspections. specific entry m the vehicle service record that list emergency exit inspections? 5.6 Is the ADA signage properly displayed? (Reference: 49 CFR, Part 38) D Several wheel chair equipped vehicles are not marked Conduct a review of the entire vehicle fleet for overall New ADA signs were purchased. Signs have been November 6, 2014 with an external wheelchair symbol. condition and signage. Ensure vehicles contain all the installed by Motor Pool as needed- required signs and markings. 5.7 Does the equipment show signs of neglect, mechanical or physical deficiencies D The vehicle fleet is not maintained in a state of good Ensure vehicles are maintained in a good state of repair Detailed cleaning (exterior and interior) was scheduled All safety related items were immediately repaired. November 6, 2014 (fluid leaks, engine damage, etc...)? (Reference: FTA Circular 5010.0 and repair. All vehicles had damage and the exterior of to include required maintenance and repair. Vehicle and performed OPT is working with Motor Pool and Outside body repairs were scheduled and completed. To 90301C 49 CFR Part 37 and 38) eleven (11) of the in- service vehicles were extoarely need to be washed to remove excessive dirt and fuel with assistance of other outside vendors fir detailed minimize down -time for route coverage, oar -safety, dirty and most were dirty inside also. See Attached spills. Interior of vehicles need to be cleaned. Conduct cleaning. Equipment has been made available fir items (install decal, tom seat, one cracked gill) are 1&dni, and document periodic random audits to ensure regular cleanings as needed. Noted defects were scheduled with the vehicle's next preventive compliance. scheduled for appropriate repair. Jan 7, 2015. maintmarace appointment and/or as ordered parts are NCDOT/PTD: What is the timetrarme to have all repairs received - estimated completion is February 13, 2015. completed? OPT March 2015 update - all vehicle repairs have been completed. The deficiencies noted above until corrected indicate that your system is non - compliant with NCDOT policies. Corrective action must be taken by the given date to prevent further penalties or termination of your contract. Page 8 of 15 NORTH CAROLINA DIVISION OF PUBLIC TRANSPORTATION SYSTEM SAFETY PROGRAM AUDIT ASSESSMENT REPORT OF FINDINGS AND CORRECTIVE ACTIONS 10 Core system safely Program Finding Audi[ Recommendation: Implementation Plan ofAction(s): OPT response /actions as of Feb 6, 2015 & Response Dale Element EM The implemeotatiou plan should he in sufficient March 2015 Due Closed detail to - a. Clearly demonstrate what actions have occurred 5.8 Are wheelchair lifts, secmement devices and other accessibility features of the D Operators did not check securement devices when Develop a process requiring operators check all the Included in updated pre/post trip checklist added to Spot checks have been conducted to ensure compliance. November 6, 2014 transit vehicles tested /inspected on a daily basis? (Reference: Manufacturers preforming pre -trip inspections. Three vehicles had required items during pre /post -trip inspections. Train SSPP; additional training is scheduled as needed. Jan 7, OPT March 2015 update - Employees have received Manual, 49 CFR Parts 37, 38 and 383) emeut devices left in the floor, this is a tripping employees on the requirement and document the 2015. NCDOT/PTD: Have random spot checks been remedial training on the importance of conducting a hazard. training in the employee training record Conduct conducted to ensure compliance? pre/post trip inspection. random spot checks 0 ensure compliance. 5.9 Is there a process in place fir the drivers and maintenance (management) D Pre/post -hip inspections showed drivers documented Train staff members on agency requirements, document OPT and Motor Pool have reviewed their combined November 6, 2014 personnel to communicate vehicle issues? (Refereace: FTA Circular 5010.0 and vehicle deficiencies repeatedly, in some case for weeks training in the employee training record and conduct procedures fir timely vehicle mainteuauce/safety. 9030.1C) with no corrective actions. spat checks to ensure compliance. Additional scheduling using outside vendors has been added to ensure appropriate response time as needed. All maintenance will be recorded appropriately. OPT office staff review pre/post trip inspections daily. 5.10 Do drivers perform pre - and post -trip inspections? (Reference: FTD Standard D Drivers complete pre-trips however only one operator Develop written pre/post -trip inspection procedures. Included in updated pre/post trip checklist added to Spot checks and obervations are conducted to ensure November 6, 2014 Operating Procedure SSPP -001, ETA Circular 5010. C and 9030.1C... 49 CFR open the hood and checked fluids prior to starting Train operators on procedures and document the SSPP, additional training is scheduled as needed Jan compliance. Parts 383 and 396) vehicles. One vehicle had a slight knocking sound when training in the employee training record Cnnduct spot 7, 2015. NCDOT/PTD: Are spat checks conducted to it was started indicating possible low oil level. checks to ensure compliance. ensaire compliance? 5.11 Are deficiencies noted in pre/post -trip inspections repaired in a timely maaaer? D Drivers noted ADA and safety items on their pre-hip Develop and implement a process 0 ensure deficiencies Motor Pool has reviewed its procedures fir timely November 6, 2014 Are the Pre/Post -Trip Checklists reviewed by management? (Refereace: FTA inspections repeatedly before vehicle was taken to the noted in pre/post -trip inspections repaired in a timely vehicle mainteuance/safety. Additional use of outside Circular 5010.0 and 9030.1C) shop. (Headlight out, Lifts with issues, electrical nommer and pre/post -trip inspections are reviewed and vendors has been added to ensure appropriate response problems) Vehicle 20 had a lift issue that was not initialed by management. time. All maiateaance will be recorded appropriately. addressed OPT office staff review documentation daily. 5.12 Is a process in place fir drivers to report critical (safety) vehicle defects that D Several vehicles had repeated safety related items with Develop and implement a process 0 ensure there is a Included in review to improve timely repairs. November 6, 2014 occur after the pre trip inspection has been performed? (Refereace: FTA no corrective action. method to report critical (safety) vehicle defects that Additional training provided to drivers to ensure Circular 5010.0 and 9030.1C...49 CFR Part 396) ur after the pre trip inspection has been performed. compliance. Train employees on the process and document the training in the employee training record- 5A3 Are preventive maintenance entries accurate, documented in appropriate files and D AssetWorks is not used by transit agency. Ensure AssetWorks is used to document scheduled and After completing scheduled AssetWorks training with We have worked with ITRE to create the template for November 6, 2014 me they conducted at the required mileage? (Reference: FTA Circular 5010.0 unscheduled vehicle maintenance. ITRE December 10. OPT will work with FIRE the corrected PM schedules. Final completion is and 9030.1C) personnel to update AssetWorks initial setup to reflect pending. OPT March 2015 update - Separate vehicle and capone the OPT program that is designed to meet lift preveutive maiuteuance schedules have been manufacturers recommendations. Changes will include established in Asset Works and vehicle preveutive a separation of preventative maintenance levels for notintimence has been updated to reflect the county's vehicle and lift maintenance. Jan 7, 2015. procedures meeting the manufacturers NCDOT/PTD: Has AssetWorks been updated with the recommendaticas. required inf ation? 6 Section 6 erurity The deficiencies noted above until corrected indicate that your system is non - compliant with NCDOT policies. Corrective action must be taken by the given date to prevent further penalties or termination of your contract. Page 9 of 15 NORTH CAROLINA DIVISION OF PUBLIC TRANSPORTATION SYSTEM SAFETY PROGRAM AUDIT ASSESSMENT REPORT OF FINDINGS AND CORRECTIVE ACTIONS 11 Core System Safely Program Finding Audit Recommendation: Implementation Plan ofAction(s): OPT response /actions as of Feb 6, 2015 @ Response Date Element The implementation plan should he in sufficient March 2015 Due Closed detail to - a. Clearly demonstrate what actions have occurred 6.1 Does the transit system have a security plan, appropriate to the size, location and D The transit agency does not have a security plan Develop a security plan appropriate to the size, Updated Security/Emergency Plan added to 2014 -SSPP Yes, an OPT policy information binder is located in the November 6, 2014 scope of its operations, in place? (Reference: PTD Standard Operating appropriate to the size, location and scope of it's location and scope of its operations. Train employees Jan 7, 2015. NCDOT/PTD: Is the plan available to the breakroom for employee review. Procedures SSPP -001) operations in place. on the plan, document the training in the employee transit staff, can they access it without having to ask training record and make the plan available for permission from a manager9 employees to review. 6.2 Are security responsibilities defined? (Reference: PTD Standard Operating D No process in place. Develop written procedures to define security Updated Smurity/Emergemcy Plan added to 2014 -SSPP November 6, 2014 Procedures SSPP -001 and FTA Circular 5010. ID) responsibilities. 6.3 Is the security plan available to transit agency staff? (Reference: PTD Standard D The transit agency does not have a security plan. Develop and implement a written security plan. Train Updated Security/Emergency Plan added to 2014 -SSPP Yes, an OPT policy information binder is located in the November 6, 2014 Operating Procedures SSPP -001 and FTA 5310.ID) employees on the plan and document the training in the . Jan 7, 2015. NCDOT/PTD: Is the plan available to breakroom for employee review. employee traimiag record. the transit staff, can they access it without having to ask permission from a manager 6.5 Is a process in place to identify security problems and resolve security D No documented process in place. Develop and implement a method to identify security Updated Security/Emergency Plan added to 2014- Yes, a'Workplace Security Assessment' f is used November 6, 2014 vulnerabilities as they may develop? (Reference: PTD Standard Operating problems and resolve security vulnerabilities as they SSPPJaa 7, 2015. NCDOT/PTD: What method is used for the purpose. OPT March 2015 Update - Procedures SSPP -001 and FTA Circular 5010. ID) may develop. Train employees on security procedures to identify security vulnerabilities? Proceedures have been established th identify security and document the training in the employee training vulnerabilities these include mamagememt conducting record assessments of the entire operation. Incident reporting sheets have also been developed and operaters trued on their use. These sheets are generic and can be used th report multipul types of incidents to included security. Have procedures been established for vehicle and facility security? (Reference: D No documented process in place. Develop and implement a written security plan. Train Updated Smurity/Emergency Plan added to 2014 -SSPP. Yes, a'Workplace Security Assessment' procedure and November 6, 2014 PTD Standard Operating Procedures SSPP -001 and FTA Circular 5010. ID) employees on the plan and document the training in the Jan 7, 2015. NCDOT/PTD: Have procedures for form are used for this purpose. OPT March 2015 employee traimiag record. facility security been established? Update - Facility opening and closing procedures have been developed. The early morning dispatcher parks in e of the slots closet to the front door and has been instructed not to exit their vehicle if the see anyone or anything that looks suspicious. The front door will remain locked until the first driver reports to work. All drivers have been instructed to lock transit vehicle doors and verify the doors are locked at the end of the day or when the vehicles are not in use.. Lift doors have been am med and deemed not a security concern due to their height. The deficiencies noted above until corrected indicate that your system is non - compliant with NCDOT policies. Corrective action must be taken by the given date to prevent further penalties or termination of your contract. Page 10 of 15 NORTH CAROLINA DIVISION OF PUBLIC TRANSPORTATION SYSTEM SAFETY PROGRAM AUDIT ASSESSMENT REPORT OF FINDINGS AND CORRECTIVE ACTIONS 12 Core System Safely Program Finding Audit Recommendation: Implementation Plan ofAction(s): OPT response /actions as of Feb 6, 2015 @ Response Date Element Theimplemeutatiou plan shouldhein sufficient March 2015 Due Closed detail to - a. Clearly demonstrate what actions have occurred 6.6 Are procedures established to control access to secure transit areas including D No documented process in place. Develop and implement a written security plan. Train Updated Security/Emergency Plan added to 2014 -SSPP OPT March 2015 update - A dispatcher now sits in November 6, 2014 vehicle operation? (Reference: Standard Operating Procedures SSPP -001 and employees on the plan and document the training in the Jan 7, 2015. NCDOT/PTD: Have procedures been the foyer area with a direct line of sight of anyone FTA 5310.1D) employee training record. established to control access to the facility? eatering /exiting the building. When that persco is away from their desk, the other offices can see when a person enters/exits the building. The rear door to the building remains locked. 6.8 Are the facilities and/or transit vehicles monitored for security? (Refereace: D No documented process in place. Develop and implement a written security plan that Updated Security/Emergeicy Plan added to 2014 -SSPP Vehicles are located in parking lot adjacent to OC- November 6, 2014 Standard Operating Procedures SSPP -001 and FTA 5310.1D) includes procedures to monitor transit facilities and . Jan 7, 2015. NCDOT/PTD: Are facilities and /or Maintenance Facility. OPT March 2015 update - All vehicles. Train employees oa the plan and document transit vehicles monitored for security? transit vehicles have cameras installed. Drivers the training in the employee training record. instructed to immediately contact dispatch if they have any type of security issue. Procedures have been established to monitor who enterers and exits the facility. 6.11 Is there a process in place for employees to identify and report suspicious people, D No documented process in place. Develop and implement a written security plan that Updated Security/Emergeicy Plan added to 2014 -SSPP yes, 'Security Incident Report' is used for this purpose. November 6, 2014 activities, packages, devices, substances or vehicles? (Reference: FTD Standard includes methods to identify and report suspicious Jan 7, 2015. NCDOT/PTD: Has a method been This fora is located in Safety DaWAcquisitioa/ Operating Procedures SSPP -001 and FTA Circular 5010. ID) people, activities, packages, devices, substances or established to identify and report suspicious people, Analysis section. OPT March 2015 Update - Incident vehicles. Train employees on the plan and document the activities, packages, devices, substances or vehicles. reporting sheets have also been developed and operators training in the employee training record Have employees been trained oa the process and the trained on their use. These sheets are generic and can training documented in the employee training record? be used to report multiple types of incidents to included security. 6.12 Are procedures in -place for employees to react to best protect th emselves aid D No documented process in place. Develop and implement a written security plan that Updated Security/Emergeicy Plan added to 2014 -SSPP Included in 'Emergency Procedures' aniiiig. OPT November 6, 2014 their passengers in the case of an incident involving potential terrorist includes procedures for employees to react to best Jan 7, 2015. NCDOT/PTD: Have procedures for March 2015 update - When drivers face any type of activity/disruptive passengers? (Reference: Standard Operating Procedures SSPP protect themselves and their passengers in the case of an employees to react to best protect themselves and their lineation activity they are to call the authorities and 001 and FTA Circular 5010.11y, incident involving potential terrorist activity/disruptive passengers been developed and employees trained. Has then notify the dispatch office. If a passenger displayed passengers. Train employees oa the plan and document the training been documented in the employee training disruptive behavior depending oa the offense they the training in the employee training record. record? receive a verbal warning the first time, they along with the sponsoring agency receive a written notice and it they are disruptive a third time within a 12 month period they will be suspended for a mimmum of two weeks. If they become disruptive again within a three month period they are suspended for three months. Passengers displaying disruptive behavior after the three month suspension may receive a longer suspension or be barred from riding transit vehicles indefinitely. Passengers committing physical assault, commuiicating threats or damaging property maybe permanently suspended The deficiencies noted above until corrected indicate that your system is non - compliant with NCDOT policies. Corrective action must be taken by the given date to prevent further penalties or termination of your contract. Page 11 of 15 NORTH CAROLINA DIVISION OF PUBLIC TRANSPORTATION SYSTEM SAFETY PROGRAM AUDIT ASSESSMENT REPORT OF FINDINGS AND CORRECTIVE ACTIONS 13 Core System Safely Program Finding Audit Recommendation: Implementation Plan ofAction(s): OPT response /actions as of Feb 6, 2015 @ Response Date Element The implemeotattoo plan should he in sufficient March 2015 Due Closed detail to - a. Clearly demonstrate what actions have occurred 6.14 Are there procedures in place to respond to bomb threats and other types of D There is no bomb threat checklist in place. Develop and implement procedures to respond to bomb Updated Security/Emergency Plan added to 2014 -SSPP A'Bomb Threat Checklist' form exists for this purpose. November 6, 2014 threats including threat evaluation, evacuation procedure and contacting threats and other types of threats including threat Jan 7, 2015. NCDOT/PTD: Have bomb threat OPT March 2015 update - Bomb threat check lists have appropriate authorities? Note: Procedures must be in -place for vehicles and evaluation, evacuation procedure and contactiug procedures been established and employees trained on been located by each phone and employees have been facilities (Reference: Standard Opemting Procedures SSPP -001, NCDOL and appropriate authorities. Train employees on the plan the updated procedures. Is the [mining documented in instructed on their use. Employees have also been 29 CFR 1910.38) and document the training in the employee training the employee training record? instructed on responding to other types of threats that record. may occur. 6.16 Is law enforcement and emergency response personnel regularly informed of D Scheduled changes are not published or provided to Develop a written process to ensure law enforcement Updated Security/Emergency Plan added to 2014 -SSPP A Public Transportation Emergency Response November 6, 2014 changes to system facilities, operations, etc., so that they may respond quickly to law enforcement or emergency respoose personnel. and emergency response perm mel regularly informed Jan 7, 2015. NCDOT/PTD: Has a process been Agreement exists for this purpose. OPT March 2015 emergencies? (Reference: PTD Standard Operating Procedures SSPP -001 and of changes to system facilities, operations, etc., so that developed to notify law enforcement and emergency Update - Procedures have been established to emare 29 CFR 1910.38) they may respond quickly to emergencies. response perm mel to changes to system operations? law enforcement is informed of opera iumal / facility changes. Outlook calendar entries will be used as a reminder to send notification emails to the appropriate agencies. 6.20 Does the agency have an emergency management plan, appropriate to the size, D The agency doesn't have an emergency management Develop and implement a written emergency Updated Security/Emergency Plan added to 2014 -SSPP Emergency Procedures training is noted on the November 6, 2014 location and scope of its operations, that is integrated with regional emergency plan management plan. Train employees on the plan and Jan 7, 2015. NCDOT/PTD: Has an emergency Employee Training Calendar and in Employees training management plans? (Reference: PTD Standard Operating Procedures SSPP -001 document the training in the employee training record management plan appropriate to OPT been developed record and 29 CFR 1910.38) and employees trained on the plan? Has the training been documented in the employee training record? 1 Section Driver /Employee Selection 1.1 Is there a system in place for monitoring employees' current employment status, N/D licenses, and other driver qualifications? (Reference: 49 CFR, Parts 383 and 391, Records Remotion and Disposition Schedule, Standard -15 Personnel Records, Item 29 and 29 CFR 1627.3) 1.2 Are driver licenses and CDL medical cards current? (Reference: Minimum N/D Training Standards for Community and Human Service Transportation Vehicle Operators) 1.3 Does the driver and employer posses valid copies of the CDL medical N/A certificate? (Reference: 49 CFR, Part 391.41) Section 2 Driver/Employee Training 2.4 Is there a schedule in place for refresher training courses? (Reference: N/D Minimum Training Standards for Community and Human Service Transportation Vehicle Operators) 2.6 Is there a system in place to maintain and track training qualifications? N/D (Reference: Minimum Training Standards for Community and Human Service Transportation Vehicle Operators... Records Remotion and Disposition Schedule, Standard -15 Personnel Records, Item 29...29 CFR 1627.3 ) The deficiencies noted above until corrected indicate that your system is non - compliant with NCDOT policies. Corrective action must be taken by the given date to prevent further penalties or termination of your contract. Fz �- I2 r I E NORTH CAROLINA DIVISION OF PUBLIC TRANSPORTATION SYSTEM SAFETY PROGRAM AUDIT ASSESSMENT REPORT OF FINDINGS AND CORRECTIVE ACTIONS 14 Core System Safety Program Audi[ Recommendation: Implementation Plan ofAction(s): OPT response /actions as of Feb 6, 2015 @ Response Date Element Theimplementatiou plan should bein sufficient March 2015 Due Closed detail to - a. Clearly demonstrate what actions have occurred 223 Have employees been trained on the inspection requirements and proper N/A operation of specialized equipment? (Reference: 29 CUR, Section 1910. General Duty Clause 5 (a) (1) (2)) 2.25 Have employees received lockont/tagout program training? (Reference: 29 CUR, N/D Section 1910.146 (7)) 3 Section 3 Safety Data Acquisition /Analysis 3.3 Does the organization conduct regularly scheduled safety meeting? (Reference N/D NCGS 95 -252) 3.7 Are there procedures in -place for employees to relay /communicate safety related N/D ues? (Reference: Minimum Training Standards for Community and Human Service Transportation Vehicle Operators) 3.8 Are all vehicles equipped with the required emergency equipment: reflective N/D triangles, a fire extinguisher, a web cutter, a first aid kit and a blood -home Pathogen kit? Is the equipment serviceable and accessible? (Reference: Minimum Truman Standards for Community and Human Service Transportation Vehicle Operators) 3.10 Are passenger complaints related to safety and security identified, tracked and N/D readily available? Are follow -up /closure procedures monitored? (Reference: Records Retention and Disposition Schedule, Standard -1 Administration and Management, Item 14) 3.13 Is employee accident/injuries information recorded on the required OSHA N/D documents (300 Log, 300 -A Summary of Work - Related Injuries/Illnesses and 301 Incident Report Log)? (Reference: 29 CUR 1910, Section 1904.4) lathe information properly maintained? (Reference: 29 CUR 1910, Section 1904.33) 3.14 Are romns, hallways and stairways maintained in an orderly condition? N/D (Reference: 29 CUR 1910, Section 1910.22) 3.15 Is there a written Emergency Action Plan for the workplace? Does the plan meet N/D OSHA requirements? (Reference: 29 CUR 1910, Section 1910.38) 3.16 Are emergency exit routes properly identified, free of obstructions and hazardous N/D materials? (Reference: 29 CUR 1910, Section 1910.37) 3.18 Has periodic maintenance inspections and required tests been performed on N/A vehicle lifts and/or hoisting equipment? Is there documentation of the inspections? (Reference: Equipment owner's manual, 29 CUR 1910 General Duty Clause 5 (a) (1) (2), and ANSI /ALI ALIS -2009) 3.21 Is personal protective equipment available and in serviceable condition? N/D (Reference: 29 CUR 1910, Section 1910.132 and 29 CUR, Section Subpart 1 Appendix B 12) 3.22 Is there a written lackout/tagout program? Does the plan meet OSHA N/A requirements? (Reference: 29 CUR 1910, Section 1910.(3) (i)) 3.23 Was an annual inspection performed of the energy control procedures fir the N/A lockout/tagont program? (Reference: 29 CUR 1910, Section 1910.147 (6) (i) (ii)) 4 Section 4 Drug and Alcohol Abuse Programs (Safety and Training Unit does not audit section 4 The deficiencies noted above until corrected indicate that your system is non - compliant with NCDOT policies. Corrective action must be taken by the given date to prevent further penalties or termination of your contract. Page 13 of 15 NORTH CAROLINA DIVISION OF PUBLIC TRANSPORTATION SYSTEM SAFETY PROGRAM AUDIT ASSESSMENT REPORT OF FINDINGS AND CORRECTIVE ACTIONS 15 Core Element System Safely Program Audi[ Recommendation: Implementation Plan ofAction(s): Theimplemeotatiou plan should heirs sufficient detail to - a. Clearly demonstrate what actions have occurred OPT response /actions as of Feb 6, 2015 @ March 2015 Response Due Date Closed 4.1 Is there a Drug and Alcohol Policy? NR 4.2 Is the policy signed by the Top Official? Note: Provide current hard copy of policy to Safety and Training Specialist. NR The drug forms printed 2109 and maintained in the Drug and Alcohol plan are out of date and don't contain all the required information. FTA as the testing 5 Section 5 Vehicle Motor enance 5.1 Is there a written statement of policy governing maintenance? (Reference: PTE) Standard Operating Procedure SSPP -001 and FTA Circular 5010.0 and 9030.1C) NOD 5.4 Are there procedures in place to identify and track warranty claims? Have claims been follow up and closed? (FTA C 9030. 1D, Ch. IV, Section 8.c) N/D 6 iSection 6 Security 6.4 Have there been any security related issues? Have security awareness briefings coaducted? (Reference: PTD Standard Operating Procedures SSPP -001 and FTA Circular 5010.11y) NOD 6.9 Is there adequate lighting for the facility grounds? (Reference: Standard Operating Procedures SSPP -001 and FTA 53 10. 1 )) NR 6.10 Is there a fence or similar barrier aromd the perimeter of the facility and vehicle storage area? ( Refercnce: PTE) Standard Operating Procedures SSPP -001 and FTA Circular 5010.11y) NR 6.13 Have managers and supervisors received formal training? (Reference: Standard Operating Procedures SSPP -001 and FTA Circular 5010. 1 )) NR 6.15 Are procedures in place to respond to passenger, vehicle or traffic emergencies that can occur (including simulation)? (Reference: PTO Standard Operating Procedures SSPP -001 and 29 CFR 1910.38) N/D 6.17 Have mock training exercises in cooperation with law enforcement and emergency service personnel been developed and coaducted? (Reference: PTO Standard Operating Procedures SSPP -001) NR 6.18 Does the agency have an emergency management plan, appropriate to the size, location and scope of its operations, that is integrated with regional emergency management plans? (Reference: PTE) Standard Operating Procedures SSPP -001 and 29 CFR 1910.38) N/D Findings Key: ND = No Deficiencies; D = Deficient, NA = Not Applicable, NR Not Rated Listed of attendees E -mail Address Name Title/Organization Phone Number Peter Murphy Transportation Administrator j pmurphy (morangecounry —gov (919) 245 -2002, Ext. 2000 The deficiencies noted above until corrected indicate that your system is non - compliant with NCDOT policies. Corrective action must be taken by the given date to prevent further penalties or termination of your contract. Page 14 of 15 NORTH CAROLINA DIVISION OF PUBLIC TRANSPORTATION SYSTEM SAFETY PROGRAM AUDIT ASSESSMENT REPORT OF FINDINGS AND CORRECTIVE ACTIONS 16 Core system safely Program Finding Audit Recommendation: Implementation Plan ofAction(s): OPT response /actions as of Feb 6, 2015 @ Response Date Element The implementation plan shouldhein sufficient March 2015 Doe Closed detail to - a. Clearly demonstrate what actions have occurred The deficiencies noted above until corrected indicate that your system is non - compliant with NCDOT policies. Corrective action must be taken by the given date to prevent further penalties or termination of your contract. Page 15 of 15