Manteca City Council
February 20, 2024

Public Transportation
Agency Safety Plan
ATTACHMENT 2
Table of Contents
I. Transit Agency Information...............................................................................................................4 II. Plan Development, Approval, and Updates.......................................................................................4 III. Safety Performance Targets...............................................................................................................6 IV. Safety Management Policy................................................................................................................ 8 V. Safety Risk Management .................................................................................................................11 VI. Safety Assurance..............................................................................................................................13 VII. Safety Promotion..............................................................................................................................14 VIII. Definitions and acronyms................................................................................................................15 IX. Attachments.....................................................................................................................................17 ATTACHMENT 2
City of Manteca- Manteca Transit
220 Moffat Blvd
Manteca, CA 95336
Agency Safety Plan
Adopted November 17, 2020
Updated February 20, 2024
Signature of Accountable Executive Date
ATTACHMENT 2
This Public Transit Agency Safety Plan (PTASP) was developed in accordance with 49 Code of Federal Regulations Part 673, which mandates safety and security procedures for public transit agencies in the United States that receive federal funding. The plan must include the agency’s strategies for minimizing the exposure of the public, personnel, and property to unsafe conditions and include safety performance targets. The agency Management, including Chief Safety Officer and staff will review this PTASP during the month of October each year. The Transit team will provide updates and input for edits as required then redraft and submit for approval to appropriate authority as directed. City of Manteca collects data through its Safety Risk Management and Safety Assurance processes, shared with California Department of Transportation (Caltrans) and San Joaquin Council of Governments (SJCOG). SJCOG and Caltrans will evaluate City of Manteca’s Safety Performance Targets (SPTs) to determine whether they need to be changed, as well.

Name of Entity That
Drafted This Plan City of Manteca, Transit Division
Signature by the
Accountable
Executive
Signature of Accountable Executive Date of Signature
Approval by the
Board of Directors
City of Manteca City Council Date of Approval
I. TRANSIT AGENCY INFORMATION
City of Manteca – Manteca Transit
220 Moffat Blvd. Manteca CA 95336
Accountable Executive, Public Works Transit Manager- Juan Portillo Chief Safety Officer, MTM Transit LLC Safety Manager.

Ciy of Manteca - Manteca Transit is a Tier II Transit Agency that operates solely within the city of Manteca, San Joaquin County, California. The City offers four local fixed routes Monday through Saturday, a shuttle connecting the Altamont Corridor Express (ACE) Station with the Manteca Transit Center on weekdays, and dial-A-ride and Americans with Disabilities Act (ADA) Paratransit services.

The Manteca City Council is the governing body for the City of Manteca- Manteca Transit. The council meets formally on the first and third Tuesday of each month at 6:00p.m. at the City’s Council Chambers, located at 1001 W. Center Street in Manteca. City of Manteca does purchase transportation services from MTM Transit. City of Manteca is a recipient of Section 5307 and Section 5339 funds. City of Manteca does not provide transportation services on behalf of another entity.

II. PLAN DEVELOPMENT, APPROVAL, AND UPDATES
ATTACHMENT 2
or an Equivalent
Authority
Relevant Documentation (title and location)
Resolution #
Certification of
Compliance
Name of Individual/Entity That
Certified This Plan Date of Certification
Relevant Documentation (title and location)
Version Number and Updates
The history of successive versions of this plan are listed below.

Version
Number
Section/Pages
Affected Reason for Change Date Issued
01 ALL First Edition 2020
02 ALL Bipartisan Infrastructure Law 2024
Safety Management System (SMS)
SMS is a management system, akin to a financial or quality management system. It ensures that a public transportation agency, regardless of its size or service environment, has the necessary organizational structures, activities and tools in place, and the necessary safety accountabilities to direct and control resources to manage safety proactively and optimally.

SMS activities proactively detect safety concerns and organizational factors, and correct them using data-driven prioritization. As such, important to its success are the:

1. Effective collection, analysis, and sharing of safety data, and

2. Active, accurate, and routine safety performance measurement.

SMS provides transit and oversight agencies with additional tools and activities, and therefore new opportunities to efficiently and effectively align safety priorities and promote continuous improvement in safety performance.

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SAFETY MANAGEMENT SYSTEM COMPONENTS
III. SAFETY PERFORMANCE TARGETS
Safety performance targets are based on the safety performance measures established under the National Public Transportation Safety Plan.

SAFETY PERFORMANCE MEASURE: FATALITIES (total number of reportable fatalities and rate per total vehicle revenue miles by mode)
Reducing the number of fatalities is a top priority for the entire Department of Transportation. As an industry, we must try to understand the factors involved in each fatality in order to prevent further occurrences. Measuring the number of fatalities over vehicle revenue miles, by mode, provides a fatality rate from which to assess future performance.

SAFETY PERFORMANCE MEASURE: INJURIES (total number of reportable injuries and rate per total vehicle revenue miles by mode)
Many transit agencies have never had a fatality, and continued safe operation is exactly what is desired.

However, injuries occur much more frequently, and are due to a wide variety of circumstances. Analyzing the factors that relate to injuries is a significant step in developing actions to prevent them. Again, measuring the number of injuries by mode, over vehicle revenue miles provides an injury rate from which to assess future performance.

SAFETY PERFORMANCE MEASURE: SAFETY EVENTS (total number of reportable events and rate per total vehicle revenue miles by mode)
The safety events measure captures all reported safety events that occur during transit operations and the performance of regular supervisory or maintenance activities. A reduction in safety events will support efforts to reduce fatalities and injuries, as well as damages to transit assets. Measuring the number of safety events by mode over vehicle revenue miles provides a safety event rate from which future performance can be compared.

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SAFETY PERFORMANCE MEASURE: SYSTEM RELIABILITY (mean distance between major mechanical failures by mode)
The system reliability measure expresses the relationship between safety and asset condition. The rate of vehicle failures in service, defined as mean distance between major mechanical failures, is measured as revenue miles operated divided by the number of major mechanical failures. This is a measure of how well a fleet of transit vehicles is maintained and operated. FTA recognizes the diversity of the transit industry, and that agencies have varied equipment types, with varied rates of performance, so this measure allows agencies to develop safety performance targets that are specific to their own fleet type, age, operating characteristics, and mode of operation.

As part of this Safety Plan, the City of Manteca – Manteca Transit has developed Safety Performance Targets (SPTs) that it will review and update annually. The specific safety performance targets are based on the safety performance measures established under the National Public Transportation Safety Plan.

FTA has adopted four initial safety performance measures: (1) Fatalities, (2) Injuries, (3) Safety events, and (4) System Reliability. The safety performance targets set by City of Manteca – Manteca Transit are based on the past two (2) calendar years of data. These targets for the year 2024 are expected to stay within +/- 1% of the previous two years’ data pertaining to fatalities, injuries, safety events, and system reliability. Table 1 below displays the mode of transit service, the annual goal for Fatalities, Injuries and Safety Events including the target rates for Fatalities, Injuries and Safety Events. In addition, System Reliability targets are measured by number of mechanical failures per 100,000 miles.

Table 1
Mode of Transit
Service
Fatalities
(Total #
of
Reportabl
e
Fatalities)
Injuries
(Total #
of
Reporta
ble
Injuries
)
Safety
Events
(Total #
of
Reporta
ble
Events)
System
Reliability
Fatality Rate
(Rate per
100K VRM)
Injury Rate
(Rate per
100K VRM)
Safety
Event Rate
(Rate per
100K VRM)
Motor Bus (MB) 0 1 1 88,995 0 0 0.6
Demand
Response/ (DR)
Paratransit
0 1 1 16,210 0 3.1 3.1
To calculate SPTs, the City of Manteca referred to system safety data, including:
• Near miss information
• Accident investigation reports (with casual factor analysis) • Internal safety audits (or reviews)
• Injury reports
• Safety event reports (including accidents, incidents, and occurrences) • System monitoring (including monthly reports, and testing and inspection records) Safety Performance Target Coordination
The coordination with the State and Metropolitan Planning Organization(s) (MPO) in the selection of State and MPO safety performance targets are listed below.

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City of Manteca- Manteca Transit Staff will contact Caltrans and SJCOG to advise of intended Safety Performance Targets in Manteca Transit PTASP.

Targets
Transmitted to the
State
State Entity Name Date Targets Transmitted
Cal Trans
Targets Metropolitan Planning Organization Name Date Targets Transmitted Transmitted to the Metropolitan
Planning
Organization(s)
San Joaquin Council Of Governments
IV. SAFETY MANAGEMENT POLICY
Safety Management Policy Statement
The management of safety is one of our core business functions. Manteca Transit is committed to developing, implementing, maintaining, and constantly improving processes to ensure that all our transit service delivery activities take place under a balanced allocation of organizational resources, aimed at achieving the highest level of safety performance and meeting established standards.

All levels of management and all employees are accountable for the delivery of this highest level of safety performance, starting with the City of Manteca, City Manager.

Manteca Transit’ commitment is to:
• Support the management of safety through the provision of appropriate resources, that will result in an organizational culture that fosters safe practices, encourages effective employee safety reporting and communication, and actively manages safety with the same attention to results as the attention to the results of the other management systems of the organization; • Integrate the management of safety among the primary responsibilities of all managers and employees; • Clearly define for all staff, managers and employees alike, their accountabilities and responsibilities for the delivery of the organization’s safety performance and the performance of our safety management system;
• Establish and operate hazard identification and analysis, and safety risk evaluation activities, including an employee safety reporting program as a fundamental source for safety concerns and hazard identification, in order to eliminate or mitigate the safety risks of the consequences of hazards resulting from our operations or activities to a point which is consistent with our acceptable level of safety performance;
• Ensure that no action will be taken against any employee who discloses a safety concern through the employee safety reporting program, unless disclosure indicates, beyond any reasonable doubt, an illegal act, gross negligence, or a deliberate or willful disregard of regulations or procedures; ATTACHMENT 2
• Comply with, and wherever possible exceed, legislative and regulatory requirements and • Ensure that sufficient skilled and trained human resources are available to implement safety management processes;
• Ensure that all staff are provided with adequate and appropriate safety-related information and training, are competent in safety management matters, and are allocated only tasks commensurate with their skills; • Establish and measure our safety performance against realistic and data-driven safety performance indicators and safety performance targets;
• Continually improve our safety performance through management processes that ensure that appropriate safety management action is taken and is effective; and • Ensure externally supplied systems and services to support our operations are delivered meeting our safety performance standards.

Juan Portillo, Transit Manager Date
General Manager/Safety Manager Date
Safety Management Policy Communication
All matters concerning occupational safety, health or security will be communicated to employees by written documentation, staff meetings, formal and informal training and posting in work areas.

Employee Safety Reporting Program
Herein is the process and protections for employees to report safety conditions to senior management, including employee behaviors that may result in disciplinary action and therefore, are excluded from protection.

Communication from employees to supervisors and/or the safety representatives about unsafe, unhealthy or insecure conditions is encouraged and may be verbal or written, as the employee chooses. The employee may use the “Report of Unsafe Condition or Hazard” form and remain anonymous.

Although the employer and management have the primary responsibility in providing employees with a safe and healthy workplace, employees are ultimately responsible for their own safety.

If any employee fails to follow the City of Manteca’s and MTM Transit’s safety procedures, the employee’s supervisor should:

I. Inform the employee of the violation.

II. Inform or remind the employee of the correct procedure.

III. Ask the employee to comply and correct the violation(s).

IV. Remind the employee of the City of Manteca’s and MTM Transit disciplinary policy.

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No employee will be retaliated against for reporting hazards or potential hazards or for making suggestions related to safety or security. In addition, employees submitting frivolous or false reports of hazards or potential hazards will be subject to progressive discipline up to and including termination.

Authorities, Accountabilities, and Responsibilities
The authorities, accountabilities, and responsibilities of the following individuals for the development and management of the transit agency’s Safety Management System (SMS) are identified by title.

Accountable Executive: Ultimate authority over SMS development and implementation, accountable for agency safety performance, responsible for agency to carry out the Agency Safety Plan, and promotes safety.
a. Authority: The AE has ultimate control and direction over PTASP and TAM Plans b. Accountability: The AE must ensure that agency SMS is effectively implemented throughout the agency’s public transportation system. To ensure that action is taken as necessary to address substandard performance in the agency’s SMS. The AE may delegate specific responsibilities but is ultimately accountable.
c. Responsibility: The AE is responsible to carry out the PTASP of the agency as well as the TAM Plan including control and direction over human and capital resources needed to develop and maintain the PTASP and the TAM Plan.

Chief Safety Officer: Reports SMS activities to AE and agency governing body when required, implements and operationalizes agency SMS, manages SMS documentation, oversee processes are in place, monitors Safety Risk mitigations, and develops performance Reports a. Authority: The CSO have authority over the day-to-day implementation and operation of the agency’s SMS. The CSO are partners with the agency leaders and staff to execute the agency SMS.
b. Accountability: The CSO are accountable to report to the AE and communicate AE decisions and directives as well as briefing the AE and Council Members. c. Responsibility: The CSO are responsible to implement and operate the agency SMS processes and activities including:

1. Develop and maintain SMS documentation

2. Directing hazard identification and risk assessment

3. Monitor safety risk mitigation activities

4. Planning safety management training

5. Ensure that Safety Suggestion forms are reviewed and addressed promptly Agency Leadership and Executive Management:

Manteca Transit Leadership and Executive Management is comprised of Public Works Director, Transit Manager, General Manager, Safety Manager, and Maintenance Manager. The Executive team provides input, guidance and support to develop the Agency Safety Plan and implement SMS processes, review and act on safety performance reports to mitigate risks in areas of responsibility ATTACHMENT 2
a. Authority: To direct subordinate staff and ensure SMS compliance b. Accountability: To ensure that SMS activities are being carried out and followed in each of their respective areas of operation
c. Responsibility: To support the day to day operation and implementation of the agency SMS Key Staff: Manteca Transit Key staff is comprised of City Staff, Administrative Analyst along with Front line Employees that consist of: Road Supervisor, Dispatch, Drivers and Safety committee.

Draftsafety management system policy and procedures, are subject matter experts in development of realworld SMS strategies and processes, Execute SMS activities and promote best practices:
a. Authority: The key staff have the authority as assigned by the leadership and management to assist in the development of agency SMS processes and activities as they are the subject matter experts.
b. Accountability: The key staff assigned are accountable to endorse the agency SMS and promote it at all levels.
c. Responsibility: Key staff members are responsible to draft the agency SMS policies and procedures. In addition to develop, implement and operate the agency safety plan action elements.

The City of Manteca identifies mitigations & strategies to minimize exposure to infectious diseases, consistent with Centers for Disease Control and Prevention or State health authority guidelines to exposure of infectious diseases through the Safety Risk Management process (Section 7 of this document). These mitigations & strategies include:
• Clear driver protection barriers on all buses and at the lobby counter to separate staff and customers;
• Sanitation stations (e.g. hand sanitizer dispensers) at the following entrances: (1) Driver Breakroom, (2) All Lobby entrances at the Transit Center. • Mask recommendation for all passengers and staff;
• Available personal protection equipment (PPE) for all staff; • Enhanced bus cleaning protocols;
• Implementation of any other emerging best-practice, as recommended by health authorities.” Safety Risk Identification
The Agency will apply risks of loss to the Risk Management Process which includes a systematic and continuous identification of loss exposures, the analysis of these exposures in terms of frequency and severity probabilities, the application of sound risk control procedures and the financing of risk consistent with the Agency’s financial resources. The Safety Risk Management practices include a comprehensive hazard identification and analysis data collection process from various sources such as:
the employee safety reporting program, observations of operations, inspections, internal safety investigations, accident reports, compliance programs, safety committee reviews, industry data, governmental sources (FTA, NTSB, CHP), customer and public feedback or complaints.

V. SAFETY RISK MANAGEMENT
ATTACHMENT 2
Safety Risk Assessment
Safety risk assessment defines the level or degree of the safety risk by assessing the likelihood and severity of the consequences of hazards and prioritizes hazards based on the safety risk. The Chief Safety Officer, with assistance from key staff subject matter experts, is responsible for assessing identified hazards and ratings using the safety risk matrix below. Prioritizing safety risk provides the Accountable Executive with the information needed to make decisions about resource application.

The following matrix, adopted from the TSI Participation Guide – SMS Principles for Transit, facilitates the ranking of hazards based on their probability of occurrence and severity of their outcome.

Probability Levels
Description Level Specific Individual Item Fleet Inventory The measuring goes from A to F with A being frequent or likely to occur frequently and E being improbable or expected that this event will most likely never occur. The designation F is used when potential hazards are identified and later eliminated.

The Safety Risk Severity Table presents a typical safety risk. It includes four categories to denote the level of severity of the occurrence of a consequence, the meaning of each category, and the assignment of a value to each category using numbers. In this table, 1 is considered catastrophic meaning possible deaths and equipment destroyed and 4 is considered negligible or of little consequence with two levels in between.

Frequent A Likely to occur often in the life of an item. Continuously experienced.

Probable B Will occur several times in the life of an item. Will occur frequently.

Occasional C Likely to occur sometime in the life of an item. Will occur several times.

Remote D Unlikely, but possible to occur in the life of an item.

Unlikely, but can reasonably be expected to
occur.

Improbable E So unlikely, it can be assumed occurrence man not be experienced in the life of an item. Unlikely to occur, but possible.

Eliminated F
Incapable of occurrence. This level is used when
potential hazards are identified and later
eliminated.

Incapable of occurrence. This level is used when
potential hazards are identified and later
eliminated.

Severity Levels
Description Level Mishap Result Criteria
Catastrophic 1 Could Result in one or more of the following: death, permanent total disability, irreversible significant environmental impact, or monetary loss equal to or exceeding $10M ATTACHMENT 2

Safety Risk Probability and Safety Risk Severity are combined into the Safety Risk Index Ranking to help prioritize safety risks according to the table below.

The Chief Safety Officer documents recommendations regarding hazard rating and mitigation options and reports this information to the Accountable Executive.

Safety Risk Mitigation
The Chief Safety Officer, assisted by Key Staff subject matter experts, reviews current safety risk mitigations and establish procedures to 1) eliminate; 2) mitigate; 3) accept specific risks. Prioritization of safety remediation measures is based on risk analysis and a course of action acceptable to Manteca Transit management.

The safety risk must be mitigated if ranked as Unacceptable (High- Red). Those safety risks that have been mitigated, even those mitigated risks shown as Acceptable status (Low -Green) undergo regular and consistent monitoring to ensure the mitigation strategy is effective.

Key strategies to minimize the types of risks that potentially exist include:

Critical 2
Could result in one or more of the following: permanent partial disability, injuries or occupational illness that may result in hospitalization of at least three personnel, reversible significant environmental impact, or monetary loss equal to or exceeding $1M but less than $10M
Marginal 3
Could result in one or more of the following: injuries or occupational illness resulting in one or more lost work day(s), reversible moderate environmental impact, or monetary loss equal to or exceeding $100k but less than $1M
Negligible 4 Could result in one or more of the following: injuries or occupational illness not resulting in lost work day, minimum environmental impact. Or monetary loss less than $100k.

Safety Risk Assessment Matrix
Severity →
Probability ↓
Catastrophic
1 Critical
2 Marginal
3 Negligible
4 A-Frequent 1A 2A 3A 4A
B- Probable 1B 2B 3B 4B
C-Occasional 1C 2C 3C 4C
D- Remote 1D 2D 3D 4D
E- Improbable 1E 2E 3E 4E
F- Eliminated
Safety Risk Index Ranking
1A, 1B, 1C, 2A, 2B High Unacceptable
1D, 2C, 3A, 3B Serious Undesirable - With management decision required 1E, 2D, 2E, 3C, 3D, 3E, 4A, 4B, Medium Acceptable - with review by management 4C, 4D, 4E Low Acceptable - without review
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• Development and deployment of policies and procedures that address known hazards and risks, • Discussion of other actions, strategies and procedures that might help safeguard against unknown/unforeseen risks,
• Training of drivers and other agency staff on all safety policies and procedures, • Training of drivers and other agency staff on methodologies for handling emergencies, and • Training of drivers and staff on proper and effective use of emergency equipment and communication technologies and protocol.

Safety risk mitigations are tracked and updated in the Hazard Log by the Chief Safety Officer.

The City of Manteca identifies mitigations & strategies to minimize exposure to infectious diseases, consistent with Centers for Disease Control and Prevention or State health authority guidelines to exposure of infectious diseases through the Safety Risk Management process (Section 7 of this document). These mitigations & strategies include:
• Clear driver protection barriers on all buses and at the lobby counter to separate staff and customers; • Sanitation stations (e.g. hand sanitizer dispensers) at the following entrances: (1) Driver Breakroom, (2) All Lobby entrances at the Transit Center.
• Mask recommendation for all passengers and staff;
• Available personal protection equipment (PPE) for all staff; • Enhanced bus cleaning protocols;
• Implementation of any other emerging best-practice, as recommended by health authorities.” Safety Performance Monitoring and Measurement
Periodic review of safety processes, policies and systems are conducted as an ongoing activity. As accident and injury investigations, facility inspections or risk assessments identify new risks, the safety management system will be amended and incorporated into the overarching Agency Safety Plan.

Training will be provided to all transit employees to be aligned with the changes. Formal reviews will be completed by the operations management team to ensure that updates are accurate and accounted for, and that standards are in alignment with agency policy.

Continual monitoring of safety performance metrics and analysis of safety performance data by Agency staff will ensure that any trends or lack of progress for change are identified and addressed and do not go uncovered. Senior Management needs safety performance data to evaluate whether implemented safety VI. SAFETY ASSURANCE
ATTACHMENT 2
risk mitigations are appropriate and effective. In addition, to evaluate how well the agency’s safety performance matches established safety objectives and safety performance targets.

The following is Manteca Transit’s methods and processes to identify hazards. The Agency considers, as a source for hazard identification, data and information provided by an oversight authority and FTA.

Hazards are identified through a variety of sources, including:
• Employee safety reporting,
• Safety audits
• Daily review of DriveCam incidents to monitor and coach driver behaviors, • Daily review of DOMO dashboard to monitor Safety Key Performance Indicators; including speeding events, pre-trip/ post trip inspections, and driver safety scorecard, • Monthly Facility Safety inspections,
• Monthly ride checks to evaluate driver performance - MTM Driving Evaluation Form, • Monthly Secret Rider program to evaluate driver performance and vehicle conditions, • Regular review of onboard IDrive for specific incidents • Safety review prior to implementing any service change or any known detour, • Annual vehicle inspections and preventative maintenance inspections as per manufacturer recommendation.
• Observations from supervisors,
• Comments from customers, passengers, and third parties, • Maintenance reports
• Review of monthly performance data and safety performance targets, • Safety committee, driver and all-staff meetings
In the event of a fatality, Manteca Transit complies with all FTA drug and alcohol requirements.

In California, every driver involved in an accident that results in death, injury, or property damage over $1000, effective January 1, 2017, must report the accident on a Report of Traffic Accident Occurring in California (SR 1) form to DMV. The report forms are available at www.dmv.ca.gov, by calling 1-800- 777-0133, and at CHP and DMV offices. Also, under California Vehicle Code §16002(b) the driver of a vehicle that is owned or operated by a publicly owned or operated transit system, or that is operated under contract with a publicly owned or operated transit system, and that is used to provide regularly scheduled transportation to the general public or for other official business of the system shall, within 10 days of the occurrence of the accident, report to the transit system any accident of a type otherwise required to be reported pursuant to subdivision (a) of Section 16000 . MTM Transit requires driver notification to the City of Manteca immediately and maintains records of any report filed pursuant to this paragraph.

Safety Communication
City of Manteca and MTM Transit communicates safety and safety performance information throughout the organization that, at a minimum, conveys information on hazards and safety risks relevant VII. DEFINITIONS AND ACRONYMS
ATTACHMENT 2
to employees’ roles and responsibilities and informs employees of safety actions taken in response to reports submitted through an employee safety reporting program.

Ongoing safety communication is critical and MTM Transit ensures communication occurs up, down, and across all levels of the organization. Any lessons learned are communicated to all concerned.

Management commitment to address safety concerns and hazards is communicated on a regular basis.

Management encourages and motivates employees to communicate openly, authentically, and without concern for reprisal; ensures employees are aware of SMS principles and understand their safety-related roles and responsibilities; conveys safety critical information such as accident data, injuries, and reported safety concerns and hazards and their resolutions to employees. MTM Transit's tools to support safety communication include:
• Safety bulletins
• Safety notices
• Posters
• Newsletters
• Seminars and workshops
• New employee training and refresher training through TAPTCO • Intranet or social media
• Monthly Safety Training Meetings
• Safety Committee Meetings (quarterly, or as needed)
• Direct contact, verbally and in meetings
Competencies and Training
Agency employees and contractors directly responsible for safety achieve their competencies and training through any one or all of the following methodologies:
• New Hire Orientation as required through TAPTCO
• Monthly Safety Meetings with all employees to discuss Safety Key Performance indicators and safety related topics; including speeding, distractions, driving techniques and others. • Formal classroom training
• Target Solution Trainings
Manteca Transit is committed to developing, implementing, and consistently improving strategies and processes to ensure that transit achieves the highest practicable level of safety. Manteca Transit has adopted the principles and methods of SMS as the basis for enhancing the safety of public transportation. Manteca Transit will follow the principles and methods of SMS in development of future versions of its Public Transit Agency Safety Plan. More detailed information and examples of current practices are included in the attachments in the last section of this document.

Accident: An Event that involves any of the following: a loss of life; a report of a serious injury to a person; a collision of public transportation vehicles; an evacuation for life safety reasons.

VIII. DEFINITIONS AND ACRONYMS
ATTACHMENT 2
Accountable Executive: A single, identifiable person who has ultimate responsibility for carrying out Manteca Transit’s Safety Plan; responsibility for carrying out the agency’s Transit Asset Management Plan; and control or direction over the human and capital resources needed to develop and maintain both the agency’s Safety Plan, in accordance with 49 U.S.C. §5329 (d), and the agency’s Transit Asset Manage Plan in accordance with 49 U.S.C. § 5326.

Agency or Transit Agency: City of Manteca - Manteca Transit Caltrans: The California Department of Transportation
Chief Safety Officer: An individual who has responsibility for carrying out Manteca Transit Safety Plan and reports directly to the Transit Agency’s Accountable Executive.

CRF: Code of Federal Regulations.

Event: Any Accident, Incident, or Occurrence.

FTA: The Federal Transit Administration, an operating administration within the United States Department of Transportation.

Hazard: Any real or potential condition that can cause injury, illness, or death, damage to or loss of the facilities, equipment, rolling stock, or infrastructure of the system, or damage to the environment.

Incident: An event that involves any of the following: A personal injury that is not a serious injury; one or more injuries requiring medical transport; a damage to facilities, equipment, rolling stock, or infrastructure that disrupts the operations of the transit agency.

Investigation: The process of determining the causal and contributing factors of an accident, incident, or hazard, for the purpose of preventing recurrence and mitigating risk.

National Public Transportation Safety Plan: The plan to improve the safety of all public transportation systems that receive federal financial assistance under 49 U.S.C. Chapter 53.

Occurrence: An Event without any personal injury in which any damage to facilities, equipment, rolling stock, or infrastructure does not disrupt the operations of the Transit Agency.

Part 673: 49 CFR (Code of Federal Regulations) Part 673.

Performance Measure: An expression based on a quantifiable indicator of performance or condition that is used to establish targets and to assess progress toward meeting the established targets.

Performance target: A quantifiable level of performance or condition, expressed as a value for the measure, to be achieved within a time period required by the Federal Transit Administration (FTA).

Risk: The composite of predicted severity and likelihood of the potential effect of a hazard.

Risk mitigation: A method or methods to eliminate or reduce the effects of hazards.

Safety Assurance: Processes within the Transit Agency’s Safety Management Systems that function to ensure the implementation and effectiveness of safety risk mitigation, and to ensure that the Transit Agency meets or exceeds its safety objectives through the collection, analysis, and assessment of information.

Safety Management Policy: The Transit Agency’s documented commitment to safety, which defines the Transit Agency’s safety objectives and the accountabilities and responsibilities of its employees in regard to safety.

ATTACHMENT 2
Safety Management Systems (SMS): The formal, top-down, organization-wide approach to managing safety risk and assuring the effectiveness of a Transit Agency’s safety risk mitigation. SMS includes systematic procedures, practices, and policies for managing risks and hazards.

Safety Performance Target (SPT): A Performance Target related to safety management activities.

Safety Promotion: A combination of training and communication of safety information to support SMS as applied to the Transit Agency’s public transportation system.

Safety Risk Assessment (SRA): The formal activity whereby the Transit Agency determines Safety Risk Management priorities by establishing the significance or value of its safety risks.

Safety Risk Management (SRM): A process within the Transit Agency’s Public Transportation Agency Safety Plan for identifying hazards and analyzing, assessing, and mitigating safety risk.

Serious injury: Any injury which: (1) requires hospitalization for more than 48 hours, commencing within seven days from the date the injury was received, (2) results in a fracture of any bone (except simple fractures of fingers, toes, or noses), (3) causes severe hemorrhages, nerve, muscle, or tendon damage; (4) involves any internal organ, or (5) involves second or third-degree burns, or any burns affecting more than five percent of the body surface.

State of Good Repair (SGR): The condition in which a capital asset is able to operate at a full level of performance.

Transit Asset Management Plan: The strategic and systematic practice of procuring, operating, inspecting, maintaining, rehabilitating, and replacing transit capital assets to manage their performance, risks, and costs over their life cycles, for the purpose of providing safe, cost-effective, and reliable public transportation, as required by 49 U.S.C. 5326 and 49 CFR part 625.

U.S.C.: United States Code.

XI. ATTACHMENTS
a. MTM Organizational Chart
i. MTM Transit Safety Management System and Agency
Safety Plan
ii. MTM Transit System Safety Program Plan
iii. MTM Drug and Alcohol Policy
iv. MTM Emergency Action Plan
v. Heat Illness and Stress Prevention Plan
vi. MTM Information Security Program Handbook
vii. MTM Injury and Illness Prevention Program
b. City of Manteca, Injury and Illness Prevention Program c. City of Manteca, Incident Reporting and Investigation d. City of Manteca, Vehicle Use Policy
e. City of Manteca, Hazard Communication Program
f. Automobile Accident / Property Damage Investigation Report ATTACHMENT 2
Operations Hierarchy for the Manteca Transit, MTM Transit (Contractor) General Manager
Operations/Safety Manager
Manager
Dispatchers (3) Bus Operators (15) Utility/Vehicle Cleaner Maintenance Manager
Road Supervisor
ATTACHMENT 2

Safety Management System (SMS)
and Agency Safety Plan (ASP)
As Required Per 49 CFR 673
2023
ATTACHMENT 2

Endorsements
Chief Executive Officer Date

Chief Operations Officer Date

Director of Risk Management Date

Regional Director of Maintenance Date

Director of Safety Administration Date

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Table of Contents
Safety Policy ......................................................................................................................... 1 Message from Alaina .............................................................................................................. 1 Safety Administrative Control Requirements ........................................................................ 3 Purpose .................................................................................................................................. 3 Scope...................................................................................................................................... 4 Goals ...................................................................................................................................... 5 Safety Performance Targets and Indicators ........................................................................... 6 Departments and Departmental Safety Goals ........................................................................ 7 Elements of the Public Transportation Agency Safety Plan (PTASP) .....................................20 Introduction and Elements of the Program .......................................................................... 20 Safety Risk Management .....................................................................................................23 Overview .............................................................................................................................. 23 Hazard Management Process – Activities & Methodologies .................................................. 23 Safety Assurance .................................................................................................................34 Safety Performance Monitoring ........................................................................................... 34 Accident/Incident Notification, Reporting, & Investigation ................................................. 39 Safety Validation of Change ................................................................................................. 42 Maintenance and Inspection Programs for Vehicles, Systems, and Infrastructure .............. 48 Emergency Planning and Response ...................................................................................... 50 Environmental Management Program ................................................................................. 53 Safety Promotion ................................................................................................................54 SMS/ASP Training and Implementation Tasks and Activities ............................................... 54 Employee Safety Training ..................................................................................................... 58 Drug and Alcohol Program ................................................................................................... 60 Hazardous Materials and Communication Program ............................................................. 60 Infectious Disease Exposure ................................................................................................. 61 SMS/ASP Review and Modification ...................................................................................... 62 Safety Committees Used to Update Plans ............................................................................ 62 SMS/ASP Dissemination ....................................................................................................... 63 Glossary...............................................................................................................................64 Revision Record ...................................................................................................................67 Appendix A: State/Local Specific Addendums, Attachments, and/or Plans ..........................68 ATTACHMENT 2
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Safety Policy
Message from Alaina
MTM Transit, LLC has an internal Safety Culture
Development program, which is designed to educate and
instill a safety-first culture at all levels of MTM Transit using Federal Transit Administration (FTA) suggested elements of safety. Employee compensation is aligned with safety
performance. To embrace and support our commitment to
safety, we put safety first for our customers, clients, and employees.

Safety takes a preeminent role in decision making before all other considerations. This document serves collectively as MTM Transit’s Safety Management System (SMS) and Agency Safety Plan (ASP). MTM Transit is committed to the requirements of this SMS/ASP as outlined in 49 CFR Part 673. Additionally, this SMS/ASP meets the FTA’s Public Transportation Agency Safety Plan (PTASP) guidelines and integrates PTASP safety elements into all MTM Transit locations and operations. Using the procedures and processes detailed in this SMS/ASP, we will achieve a superior level of safety in our operations.

This SMS/ASP establishes hazard resolution mechanisms to guide our managers in our safety processes and training initiatives, as well as helps them identify and address hazards associated with our transportation services. It also ensures we evaluate the effect these proposed changes will have on safety, so we train employees properly on safety and create a culture of safety awareness.

MTM Transit adheres to safety requirements during implementations, and our management teams provide the ongoing support to achieve our SMS/ASP objectives. The success of this SMS/ASP depends on our employees understanding their responsibilities to meet the safety requirements of their positions and support the overall safety culture. Our success also depends on employees prioritizing safety above all else and identifying potential hazards.

The Chief Operating Officer, Regional Vice Presidents, Director of Safety Administration, Regional Directors of Maintenance, General Managers, Maintenance Managers, and Safety Managers will implement and administer a comprehensive hazard identification and mitigation plan tailored after the established Military Standard 882- E, as outlined in this SMS/ASP. This SMS/ASP will prevent, control, and resolve unsafe conditions and hazards which may occur ATTACHMENT 2
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while providing service to our clients. The Executive Safety Committee developed this SMS/ASP, which applies to all MTM Transit locations and employees.

By using this SMS/ASP, MTM Transit will achieve optimal safety and develop an effective safety culture to reduce at-risk behaviors. This proactive approach dictates the organization, at all levels, remain actively engaged in the safety program.

As required by this SMS/ASP, each MTM Transit location will implement safety, health, and environmental controls and operating systems, procedures, and practices to maximize employee safety. All personnel will fulfill the safety requirements of their positions, and all supervisors and managers will enforce the safety requirements. Further, all personnel must support the implementation of this SMS/ASP and provide support to achieve program goals.

We must appreciate the fact our decisions and actions affect the safety of those in other areas of our operations. By following the processes described in this SMS/ASP, we will improve our operational performance and safety.

MTM Transit is an industry leader in safety and customer service and places the safety and security of our customers and employees above all else.

Best regards,
Alaina Maciá
President and Chief Executive Officer

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Safety Administrative Control Requirements
This Safety Management System (SMS) and Agency Safety Plan (ASP) communicates system safety goals and documents/defines the safety responsibilities, activities, and capabilities established to promote and improve system safety throughout all operations and services MTM Transit operates. It is designed to meet the Federal Transit Administration (FTA) “Moving Ahead for Progress in the 21st Century” (MAP-21) Public Transportation Agency Safety Plan (PTASP) standards. This SMS/ASP includes responsibility for monitoring compliance of our transportation operations and support activities, and for reinforcing safe work practices to identify risks as well as reduce accidents and incidents.

This SMS/ASP describes how accountability for system safety is integrated and shared throughout the organization. It establishes mechanisms to address the safety implications of system modifications prior to making changes. It also provides a systematic method to identify and resolve hazards in an expedient and cost-effective manner, while maintaining the safest possible operating environment. Further, this SMS/ASP provides the background, organizational structure, management processes, and descriptions of the operational facilities, systems, and personnel responsible to provide safe and reliable operations and maintenance. Finally, this SMS/ASP identifies the relationship and responsibilities between MTM Transit and State, Federal, and local agencies/organizations which impact our system safety. This SMS/ASP is the primary mechanism to achieve internal and external safety and regulatory requirements.

This SMS/ASP requires all transit-related activities include hazard and risk identification and control throughout the planning, development, modification, operation, maintenance, and disposition of all systems, equipment, facilities, and other properties throughout their life cycle.

The policy, goals, and objectives of this SMS/ASP apply to all MTM Transit personnel, including all subcontractors. All employees and subcontractors must adhere to safe work practices when in contact with passengers, other employees, private property, and the public.

Purpose
The purpose of this SMS/ASP is to institute formal mechanisms to:

X Establish system-wide processes to identify and analyze hazards/risks associated with MTM Transit’s operations and to implement preventative actions to eliminate, control, and/or minimize their impacts by applying the FTA’s PTASP elements ATTACHMENT 2
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X Establish responsibilities, which are primarily hazard identification/analysis, and ensure tasks are assigned, understood, documented, and tracked in an organized and useful manner
X Implement system safety policies and procedures which can be measured, audited, and evaluated to determine the effectiveness of our Safety Management System (SMS) – these include hazard and risk management activities and processes X Satisfy Federal, State, and local requirements
This SMS/ASP is used to prevent injuries, accidents, incidents, environmental damage, and other losses. It focuses on identifying hazards, assessing the levels of risk, and developing resolutions prior to the occurrence of an accident, incident, injury, illness, environmental damage, or other loss. As this hazard and risk identification/resolution process makes up the core of our SMS, MTM Transit will implement this process for every phase of our Safety Program, from conception through operation, and finally through disposition. The result of this process includes procedures and policies related to other subordinate and supportive aspects of our SMS, such as safety certification of newly acquired facilities, rolling stock, and operations.

The effectiveness of our SMS, as well as the hazard/risk identification and elimination processes described herein, are evaluated through internal reviews of day-to-day operations and activities. The internal reviews are used as a tool to modify safety-critical elements and system safety processes on a continuing basis, in turn optimizing operational safety and performance.

The reviews are conducted according to industry standard practices and applicable regulations and requirements.

Scope
The FTA’s PTASP and this SMS/ASP apply to MTM Transit’s Safety Program in its entirety, including all employees affecting, or affected by, its operations and services throughout all design, construction, testing, operations, maintenance, and disposition phases. It is not possible to address all the specific safety-related responsibilities of personnel and departments in an SMS/ASP of this type. Relevant documents such as rulebooks, standard operating procedures, plans, and other procedures are referenced and should be reviewed to achieve a complete understanding of our SMS.

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Goals
MTM Transit is committed to ensuring our operations and equipment are safe, and our employees and subcontractors always engage in safe work practices. MTM Transit has established a zero-tolerance policy for non-compliance with this SMS/ASP and considers public, employee, and passenger safety to be a paramount consideration in all decisions.

The goal of this SMS/ASP is to achieve the highest level of safety for all our clients, customers, employees, subcontractors, and the public. This SMS/ASP provides direction to all employees and subcontractors who are involved in activities providing or supporting MTM Transit’s operations and services, ensuring a constant review of our records and practices through quality assurance activities, internal safety reviews, investigations, and daily oversight.

The goals of this SMS/ASP are to:

X Enable employees and subcontractors to identify, eliminate, minimize, and/or control hazards and their associated risks
X Promote and apply the FTA’s PTASP safety process elements to all MTM Transit’s safety processes
X Promote a high level of safety awareness among employees, managers, and subcontractor personnel
X Operate a fiscally responsible program, using good business principles to make safety a management and work performance indicator which is just as important as productivity and work quality
X Provide safe, secure, and reliable service which protects employees and passengers, as well as minimizes property damage to vehicles, facilities, and the environment X Create a level of safety throughout MTM Transit’s operations which exceeds other transit companies
X Comply with all applicable requirements of regulatory agencies, as well as all Federal, State, and local requirements
X Work with State, County, City, Metropolitan Planning Organizations, and other parties to examine transportation corridors, as well as consider land use, economic activity, population patterns, and connections among these elements and transportation X Maximize the safety of future operations through the design and procurement process X Foster the development of a system-wide safety program and safety culture ATTACHMENT 2
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The MTM Transit Regional Vice Presidents, Director of Safety Administration, and Regional Directors of Maintenance have primary responsibility for monitoring the goals established by this SMS/ASP. Progress toward meeting stated goals is continually evaluated through an internal safety review process.

Safety Performance Targets and Indicators
MTM Transit has established the following performance indicators to monitor the ongoing success of our SMS:

X Zero preventable accidents
X Zero employee injuries (non-lost time or lost time)
X 95% or greater on-time performance
X Zero missed trips
X 100% on-time preventative maintenance services
In partnering with our clients, and in accordance with FTA 49 CFR 673, MTM Transit collectively sets the following Safety Performance Targets:

X Total number of fatalities reported, excluding suicides X Fatality rate per vehicle revenue miles
X Total number of injuries reported to the National Transit Database (NTD), excluding assaults and other crimes
X Injury rate per total vehicle revenue miles
X Total number of safety events meeting the major reporting threshold reported to the NTD X Safety events rate per vehicle revenue miles
X Average distance between major mechanical failures
An example of how MTM Transit tracks these safety performance targets is illustrated below.

Safety Performance Targets
(Specify performance targets based on the safety performance measures established under the National Public Transportation Safety Plan)
Mode of
Service Fatalities
Fatalities
(per 100k
VRM) Incidents
Incidents
(per 100k
VRM)
Safety
Events
Safety
Events (per
100k VRM)
System
Reliability
(VRM/failures)
Service
Type 0 0 X X X X X
Service
Type 0 0 X X X X X
Please Note: VRM stands for vehicle revenue miles.

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Departments and Departmental Safety Goals
\Contact Centers
Our contact centers’ main functions are to manage
trip intake entry for customers in MTM Transit
contracts that require we take reservations. Many
Customer Care Representatives (CCRs) and Support
Representatives (SRs) work in contact centers across
the country and use phones, chat, and methods of
self-service actions. Our CCRs and SRs enter
information on the customers’ trips into various
online routing, scheduling, and dispatching (RSD)
systems such as Reveal, as well as other applicable forms.

Safety issues in the contact centers range from physically walking into buildings, obstructions in hallways, and areas with water which could make floors slippery. Tripping, slipping, and falling are the biggest concerns. There are smaller concerns, including not closing file cabinets and tripping or running into open drawers.

Safety Goals for Contact Centers
X Zero preventable accidents
X Zero employee injuries (non-lost time and lost time)
SMS/ASP for Contact Centers
X Working with facilities to ensure parking lots are safe (salted, paved with no holes, clearly lighted, etc.)
X Walking through contact centers daily to ensure all obstructions, including wires, boxes, and papers, are cleared off the floor and pathways
X Ensuring all employees are trained on best safety practices to use office furniture and equipment
\Finance and Accounting
MTM Transit’s Finance and Accounting team establishes and executes financial and tax strategy and enforces policies for all financial activities. This team includes accounts payable and receivable, payroll, treasury, general accounting, financial reporting and analysis, budgeting and forecasting, pricing, data analytics, and financial audit. Our Finance and Accounting Department ATTACHMENT 2
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is accountable for accurately reporting all monthly statistics related to accidents and incidents Visibility into past performance creates a culture of accountability and motivates employees to improve. Furthermore, this department will support an effective Transit Asset Management (TAM) Plan, which keeps the fleet in a State of Good Repair (SGR).

Safety Goals for Finance and Accounting
X Zero preventable accidents
X Zero employee injuries (non-lost time and lost time)
SMS/ASP for Finance and Accounting
X Working with facilities to ensure parking lots are safe (salted, paved with no holes, clearly lighted, etc.)
X Walking through office area daily to ensure all obstructions, including wires, boxes, and papers, are cleared off the floor and pathways
X Ensuring all employees are trained on best safety practices to use office furniture and equipment
\Information Technology
Information Technology (IT) manages the technology used throughout MTM Transit, as well as monitors and implements abatement strategies for cyber security threats. This includes the individual devices (e.g., laptops, tablets, monitors, etc.) and the applications on those devices, as well as the servers, networks, and software in MTM Transit data centers and partner data centers. The IT team acquires, installs, and maintains equipment and designs, develops, and maintains many of the applications used throughout MTM Transit. Most IT staff are in MTM Transit’s locations in Lake Saint Louis and Maryville, Missouri, and Overland Park, Kansas, but there are also IT employees in other MTM Transit offices across the country. The main MTM Transit data center is in St. Louis, Missouri, with a back-up facility in Houston, Texas.

Safety issues in IT include movements at the office, lifting/carrying equipment, and repetitive stress issues. Injuries resulting from falling, straining, and repetitive work at computers are most concerning.

Safety Goals for Information Technology
X Zero preventable accidents
X Zero employee injuries (non-lost time and lost time)
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SMS/ASP for Information Technology
X Working with facilities to ensure parking lots are safe (salted, paved with no holes, clearly lighted, etc.)
X Walking through office areas daily to ensure all obstructions, including wires, boxes, and papers, are cleared off the floor and pathways
X Ensuring all employees are trained on best safety practices to use office furniture and equipment
\Logistics Operations
Our Logistics Operations Department oversees all applicable non-emergency medical transportation (NEMT) recruitment and performance in MTM Transit contracts that require this service. Logistics Operations manages the availability of NEMT transportation and successful completion of trips for these contracts. MTM Transit’s subcontracted NEMT transportation providers report all accidents and incidents through MTM Transit’s Quality phone line and email address. The Logistics Operations Department then follows up as needed on any issues.

Safety Goals for Logistics Operations
X Zero preventable accidents
X Zero employee injuries (non-lost time and lost time)
X 95% or greater on-time performance
X Zero missed trips
SMS/ASP for Logistics Operations
X Working with facilities to ensure parking lots are safe (salted, paved with no holes, clearly lighted, etc.)
X Walking through office areas daily to ensure all obstructions, including wires, boxes, and papers, are cleared off the floor and pathways
X Ensuring all employees are trained on best safety practices to use office furniture and equipment
\Legal and Risk Management
The Legal and Risk Management Department oversees all legal and external matters, including accidents, incidents, litigation, investigations, compliance, mergers and acquisitions, personnel matters, and contract matters. The basic mission of this department is to build a strategic system to manage staff, technology, subcontractors, and internal resources; to manage claims ATTACHMENT 2
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and company-wide risk issues; and to track performance data and measure efficiency. The mission of Legal and Risk Management includes:

X Financial Management
X Subcontractor Management
X Cross-Functional Alignment
X Technology and Process Support
X Service Delivery and Alternative Support Models
X Organizational Design, Support, and Management
X Communications
X Data Analytics
X Regulatory Compliance
X Information Governance and Records Management
X Strategic Planning
Safety Goals for Legal and Risk Management
X Zero preventable accidents
X Zero employee injuries (non-lost time and lost time)
X Zero workers’ compensation injuries
X Zero wheelchair passenger injuries resulting from improper securement of the wheelchair in a vehicle
X Zero wheelchair passenger injuries resulting from improper securement of the passenger in the wheelchair with seatbelt or other fastening device SMS/ASP for Legal and Risk Management
X Working with facilities to ensure parking lots are safe (salted, paved with no holes, clearly lighted, etc.)
X Walking through office area daily to ensure all obstructions, including wires, boxes, and papers, are cleared off the floor and pathways
X Ensuring all employees are trained on best safety practices to use office furniture and equipment
X For Subcontractor Management, developing strong safety metrics for credentialing and approval of subcontracted transportation providers, operators, and vehicles X Establishing stringent criteria for criminal background checks and motor vehicle operator records and approving or disapproving operators on these criteria metrics

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\Maintenance
Our Maintenance Department maintains MTM Transit’s rolling stock, maintenance shops, and grounds at MTM Transit facilities, as well as provides maintenance for the vehicles we operate in contracts that require this service. This department maintains and tracks maintenance schedules for all vehicles MTM Transit operates, as well as manages repairs and part replacements. Some facilities operate 24 hours a day and perform most of their maintenance activities at night when more of the fleet is off the road.

Each maintenance employee completes training courses at the time of hire, including:

X Operator training, which covers defensive driving and safe vehicle operation X Occupational Safety and Health Administration (OSHA) required topics and trainings X Maintenance software training
X Applicable, local original equipment manufacturer (OEM) and vendor trainings for specific site-based equipment
Monthly safety meetings are conducted to refresh and retrain the maintenance employees on topics such as safe vehicle operation, OSHA, local safety items and initiatives, etc. Additionally, each MTM Transit location that has a maintenance facility has a specific maintenance plan outlining service requirements compliant with local, State, Federal, and contractual requirements.

Safety Goals for Maintenance
X Zero preventable accidents
X Zero employee injuries (non-lost time and lost time)
X Clean shops to reduce hazards and injuries such as slips and falls X OSHA compliance training for all shop employees
X 100% on-time preventative maintenance service
X Well-maintained vehicles that reduce safety issues
SMS/ASP for Maintenance
X Working with facilities to ensure parking lots are safe (salted, paved with no holes, clearly lighted, etc.)
X Walking through shop daily to ensure all obstructions, including wires, boxes, and papers, are cleared off the floor and pathways
X Ensuring all employees are trained on best safety practices to use shop equipment X Providing hazard awareness training for 100% of maintenance employees ATTACHMENT 2
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X Emphasizing shop cleanliness during training and employee performance reviews X Fixing items which could cause potential injury to operators or passengers X Following proper preventative maintenance program
X Ensuring vehicles are in safe working order prior to them going out on route \Marketing
Marketing works to identify and source potentially successful products and services for the marketplace we operate in and then promote these products. We promote our services through social media, online venues, search optimization, drip campaigns, tradeshows, trade group participation, public relations, and events. Marketing also supports business acquisition through the Request for Proposal (RFP) process. The RFP team scans the marketplace for RFPs fitting MTM Transit’s guardrails, and then works with subject matter experts (SMEs) to prepare detailed and compliant responses, highlighting our company’s competitive advantaged.

Marketing supports internal communication efforts through Core, the company’s intranet, as well as through quarterly Vision presentations for employees and other communications. This function is important as it ensures all employees understand safety is core to our mission, vision, and values. Marketing plays a key role in creating safety-based digital and hard copy material necessary for safety programs and campaigns.

Safety Goals for Marketing
X Zero preventable accidents
X Zero employee injuries (non-lost time and lost time)
X One or more safety posts on Core each month
X One or more safety recognitions each month
X One or more safety presentations at industry events each year X One more publication of safety article in trade publication each year SMS/ASP for Marketing
X Working with facilities to ensure parking lots are safe (salted, paved with no holes, clearly lighted, etc.)
X Walking through office area daily to ensure all obstructions, including wires, boxes, and papers, are cleared off the floor and pathways
X Ensuring all employees are trained on best safety practices to use office furniture and equipment
X Using internal and external communication to emphasize our focus on safety ATTACHMENT 2
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X Recognizing and highlighting employees who embody the safety culture we are building X Becoming a thought leader for safety by presenting on safety at tradeshows, posting safety blogs on our website, and publishing safety articles in trade publications – this reinforces our safety message and attracts like-minded individuals who want to work for a company with a strong safety culture
\Operations
Our Operations Department runs the day-to-day operations in the company and oversees MTM Transit sites where we conduct business for our clients. MTM Transit provides transit operations, as well as some NEMT services, for FTA recipients that provide public transportation services for paratransit and/or fixed route operations. MTM Transit conducts business operations in for clients across the country.

Operations personnel are located at the MTM Transit headquarters at Lake St. Louis, Missouri site and in assigned areas of the country. Local Operations leadership is also on-site at the locations where we provide transportation services for hands-on control of the services MTM Transit provides.

Safety Goals for Operations
X Zero preventable accidents
X Zero employee injuries (non-lost time and lost time)
X 95% or greater on-time performance
X Zero missed trips
X 100% on-time preventative maintenance service
X Superior customer service and safe handling of all passengers SMS/ASP for Operations
X Working with facilities to ensure parking lots are safe (salted, paved with no holes, clearly lighted, etc.)
X Walking through office areas daily to ensure all obstructions, including wires, boxes, and papers, are cleared off the floor and pathways
X Ensuring all employees are trained on best safety practices to use office furniture and equipment
X Ensuring all operations employees follow safety policies and procedures ATTACHMENT 2
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\People and Culture
As teams under the People and Culture Department, both Human Resources (HR) and Training support MTM Transit’s safety goals. Our People and Culture Department strives to create a safe work environment for employees by raising awareness and acting on safety opportunities.

We believe in consistent communication, education, and training to raise awareness and impact our safety performance. Throughout various HR and Training initiatives, our teams integrate safety into our practices for all employees. We have developed and conducted Leadership Education and Development (LEAD) Training to educate leaders on the use of emergency preparedness, and we support the delivery of Transit and Paratransit Company (TAPTCO) training. Further, safety and emergency preparedness are topics included in all employee onboarding agendas.

Safety Goals for People and Culture
X Zero preventable accidents
X Zero employee injuries (non-lost time and lost time)
X Annual compliance training received by 100% of new and existing employees, including general safety best practices, active shooter training, and identifying workplace safety hazards
X Using the #SafetyFirst email burst to track and correct all reported workplace hazards in partnership with the Facilities Department, such as worn rugs, wire hangings, burned out lights, slippery floor conditions, spills, and other unsafe workplace condition X Educating the organization on safe workplace practices and policies which address both physical and emotional safety, through LEAD training, regular educational communications, annual compliance trainings, and general safety best practices SMS/ASP for People and Culture
X Working with facilities to ensure parking lots are safe (salted, paved with no holes, clearly lighted, etc.)
X Walking through office area daily to ensure all obstructions, including wires, boxes, and papers, are cleared off the floor and pathways
X Ensuring all employees are trained on best safety practices to use office furniture and equipment
X Partnering with the Facilities Department to address safety hazards at our various facilities
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X Educating employees on safe workplace practices and policies, both physical and emotional safety
X Tracking of all OSHA reportable accidents and days lost due to accidents \Procurement and Facilities
MTM Transit’s Procurement and Facilities Department negotiates costs with our vendors; works with the Legal Department to prepare contracts for facilities and supplies; issues applicable purchase orders for supplies; manages the company’s procurement and supplier relations processes; and ensures the functionality, comfort, safety, sustainability, and efficiency of the facilities and surrounding infrastructure we own and lease across the country. This department also helps to ensure and maintain the financial health of MTM Transit.

Safety Goals for Procurement and Facilities
X Zero preventable accidents
X Zero employee injuries (non-lost time and lost time)
SMS/ASP for Procurement and Facilities
X Working with facilities to ensure parking lots are safe (salted, paved with no holes, clearly lighted, etc.)
X Walking through office area daily to ensure all obstructions, including wires, boxes, and papers, are cleared off the floor and pathways
X Ensuring all employees are trained on best safety practices to use office furniture and equipment
X Partnering with the People and Culture Department to address safety hazards at our various facilities
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\Program Governance Oversight
MTM Transit’s Program Governance oversight functions consist of:

X Project Management Office (PMO), which includes Business Implementation and Business Process Management
X Quality Operations, which includes Quality Evaluations through Automated Voice Analytics, Complaint and Incident/Accident Management, and Credentialing X Compliance, which includes Internal Audit and Review, Compliance, and Investigation The PMO team is the primary point of contact in managing projects and the processes for evaluating, prioritizing, and monitoring projects, initiatives, and opportunities across all areas of MTM Transit. This team manages all implementation activities surrounding new products, new clients, existing client expansions, and contract terminations. The PMO supports internal business initiatives, such as the Reveal software rollout, Salesforce development, protocol management, annual Operations Manual updates, and other process changes that impact multiple departments. Their goal is to ensure accountability and clear direction on the execution of project rollouts.

MTM Transit’s Quality Operations and Compliance Departments oversee and monitor operations to ensure clients, subcontractors, and customers receive the highest quality services achievable. They track and trend complaints and satisfaction; monitor calls and report on quality outcomes; facilitate client audits and corrective action plans; perform internal audits of processes and procedures; maintain and review policies and procedures; and conduct investigations. Investigations may include examining suspected fraud and abuse. They also review liquidated damages and ensure contract compliance and manage MTM Transit’s Compliance Program, which monitors performance metrics and program improvements.

Program Governance oversight also includes the
implementation of client programs and monitors
compliance with contractual requirements. They
monitor any subcontracted transportation providers
and operators to ensure they meet both client and
MTM Transit credentialing standards; these standards
include clean background checks, clean driving records, adequate insurance, up-to date licenses, and quality
training to provide applicable NEMT for those contracts that require this service. For these subcontracted transportation providers, all vehicles must be titled, and safety inspected. Additionally, Program Governance investigates and reports on ATTACHMENT 2
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complaints, incidents, and accidents, as well as monitors on-time performance, no-shows, and turn-backs for any subcontracted transportation providers. These teams also work with its partners in the field to address issues and identify root cause.

Safety Goals for Program Governance
X Zero preventable accidents
X Zero employee injuries (non-lost time and lost time)
X Analyzing and trending 100% of complaints compared to the prior year X Validating and monitoring any subcontracted transportation providers, operators, and vehicle credentialing (checked daily)
X Monitoring any subcontracted transportation provider performance to ensure compliance with contract requirements, as well as Federal, State, and local laws and regulations (completed monthly)
X Conducting internal audit activities to ensure accountability to procedures, processes, and metrics (conducted quarterly)
SMS/ASP for Program Governance
X Working with facilities to ensure parking lots are safe (salted, paved with no holes, clearly lighted, etc.)
X Walking through office area daily to ensure all obstructions, including wires, boxes, and papers, are cleared off the floor and pathways
X Ensuring all employees are trained on best safety practices to use office furniture and equipment
X Working with the People and Culture Department to manage the Compliance Hotline X Immediately addressing reports of safety concerns
\Reveal
Reveal is an MTM Transit software program that provides a scheduling and tracking solution for several of MTM Transit’s operations. This software program allows MTM Transit to provide some of our transit clients with a software solution for paratransit and fixed route services that competes favorably with other companies’ software.

Safety Goals for Reveal
X Zero preventable incidents
X Zero employee injuries (non-lost time and lost time)
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SMS/ASP for Reveal
X Working with facilities to ensure parking lots are safe (salted, paved with no holes, clearly lighted, etc.)
X Walking through office area daily to ensure all obstructions, including wires, boxes, and papers, are cleared off the floor and pathways
X Ensuring all employees are trained on best safety practices to use office furniture and equipment
X Using the Reveal technology in as many MTM Transit locations as possible to increase on-time performance and prevent missed trips
\Safety
MTM Transit’s Safety Department is responsible for communicating system safety goals to all MTM Transit. This department designs policies defining safety responsibilities, activities, and capabilities established to improve our system safety throughout all operations and services that MTM Transit operates. In addition, the Safety Department is responsible for meeting the FTA MAP-21 PTASP standards. They monitor compliance of transportation operations and support activities and reinforce safe work practices aimed at identifying risks and reducing accidents and incidents.

The Safety Department, in cooperation with other MTM Transit departments, confirms accountability for system safety is shared throughout the organization and establishes mechanisms for ensuring the safety implications of system modifications are adequately addressed. In conjunction with Legal and Risk Management, they are responsible for identifying and helping other departments resolve hazards in an expedient and cost-effective manner, while helping MTM Transit maintain the safest possible operating environment for MTM Transit’s contracted services.

The Safety Department manages MTM Transit’s safety functions such as compliance with federal, state, and local regulations, and oversees safety requirements for our contracts and clients we serve. Responsibilities include hazard management, accident investigation, safety certifications, and safety training. The Safety Department’s Director of Safety Administration is the company’s SMS/ASP subject matter representative. The Safety Department is responsible for developing our SMS/ASP implementation processes for MTM Transit; coordinating with key staff to support SMS/ASP implementation; facilitating the development of SMS/ASP processes and activities; procuring technical resources for SMS/ASP implementation; communicating SMS/ASP implementation progress and challenges; and socializing SMS/ASP activities with other executives and staff.

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The Safety Department’s SMS/ASP goals include:

X Identifying SMS/ASP implementation roles and responsibilities for the appropriate staff in conjunction with the MTM Transit Executive Safety Committee X Helping senior management designate key staff who will support SMS/ASP implementation
X Ensuring key staff receive SMS/ASP training
X Developing an SMS/ASP implementation plan with the MTM Transit Executive Safety Committee, and communicating it throughout MTM Transit
X Briefing the stakeholders, Executive Safety Committee, and planning partners on the FTA PTASP and this SMS/ASP
X Helping the Executive Safety Committee develop and implement the SMS/ASP implementation plan
Safety Goals for Safety Department
X Zero preventable accidents
X Zero employee injuries (non-lost time or lost time)
X 95% or greater on-time performance
X Zero missed trips
X 100% on-time preventative maintenance service
SMS/ASP for Safety Department
X Working with facilities to ensure parking lots are safe (salted, paved with no holes, clearly lighted, etc.)
X Walking through office area daily to ensure all obstructions, including wires, boxes, and papers, are cleared off the floor and pathways
X Ensuring all employees are trained on best safety practices to use office furniture and equipment
X Providing guidance and oversight to other departments in the event of an accident or injury
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Elements of the Public Transportation Agency
Safety Plan (PTASP)
Introduction and Elements of the Program
The Federal Transit Administration’s (FTA’s) mandate “Moving Ahead for Progress in the 21st Century” (MAP-21) recommendations require all transit agencies to develop an Agency Safety Plan (ASP), which complies with the FTA statute element guidelines under the FTA’s Bus Safety Management Program, which is also supported and outlined by the American Public Transportation Association (APTA). MAP-21’s Public Transportation Agency Safety Plan (PTASP) outlines requirements which must be met by all FTA-funded transit systems operating in the United States. Since MTM Transit provides public transportation for transit agencies in the United States, we created this SMS/ASP for our company safety guidelines to meet or exceed the FTA’s PTASP requirements. Our SMS/ASP has four primary elements, which are described below.
\Element #1: Safety Policy
Establishes senior management's commitment to continually improve safety; defines the methods, processes, and organizational structure needed to meet safety goals X Establishes management commitment to safety performance X Establishes clear safety objectives and commitment to manage those objectives X Defines methods, processes, and organizational structure needed to meet safety goals X Establishes transparency in safety management
X Provides fully documented policies and processes
X Maintains employee reporting and resolution systems
X Provides accountability of management and employees
X Builds upon the existing processes and procedures
X Facilitates cross-organizational communication and cooperation

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\Element #2: Safety Risk Management
Determines the need for, and adequacy of, new or revised risk controls based on the assessment of acceptable risk
X A formal process within the SMS/ASP composed of:
o Describing the system
o Identifying the hazards
o Assessing the risks
o Analyzing the risks
o Controlling the risks
X The SMS/ASP process may be embedded in the processes used to provide the product/service
\Element #3: Safety Assurance
Evaluates the continued effectiveness of implemented risk control strategies; supports the identification of new hazards
X Includes process management functions which systematically provide confidence to ensure organizational outputs meet or exceed safety requirements X SMS/ASP has a dual safety assurance focus:
o Product/service providers
X Ensures compliance with FTA PTASP requirements and FTA orders, standards, policies, and directives
o Information acquisition
ƒ Audits and evaluations
ƒ Employee reporting
o Data analysis
o System assessment
X Will investigate safety events and reports, as well as develop corrective actions to address these events and prevent reoccurrence
X Provides insight and analysis regarding methods and opportunities for improving safety and minimizing risk
X Existing assurance functions continue to evaluate and improve service

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\Element #4: Safety Promotion
Includes training, communication, and other actions to create a positive safety culture within all levels of the workforce
X Safety promotion activities within the FTA PTASP framework include:
o Providing SMS/ASP training
o Advocating and strengthening a positive safety culture o System and safety communication and awareness
o Matching competency requirements to system requirements o Disseminating safety lessons learned
X Everyone has a role in promoting safety
These four supporting elements are comprised in different areas of this SMS/ASP in the order they are listed above. As an example, Safety Risk Management is covered in the next section of this SMS/ASP, followed by Safety Assurance and Safety Promotion. Our Safety Policy section is immediately following the Table of Contents.

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Safety Risk Management
Safety Risk Management uses hazard identification and hazard resolution to assess the needs of the organization and mitigate risk. Hazard identification, analysis, and resolution (i.e., Hazard Management) is the process used to identify, analyze, and mitigate hazards associated with the design, construction, testing, start-up, and operation of MTM Transit’s locations and services to ensure the safety of customers, employees, and the public. All hazards are categorized by severity and probability of occurrence, analyzed for potential impact, and resolved by design, procedures, warning devices, and/or other methods so they fall within the prescribed level of risk acceptable to MTM Transit.

Overview
The hazard management process is designed to proactively identify, eliminate, and control hazards before losses occur. It serves as the cornerstone of the SMS/ASP and is based on a methodology which involves:

X MTM Transit employees’ understanding of its systems/functions and how these systems/functions relate to and interface with client operations and services X Identifying the critical elements and steps (i.e., inspections, modifications, reviews, analyses, tests, etc.) necessary to achieve the desired level of safety X Establishing processes and management controls to ensure identified critical elements and steps are consistently carried out
X Monitoring compliance with the processes established through safety data analysis, management reports, observations, internal audits, inspections, reviews of documentation, and other means
X Improving the processes by reviewing effectiveness of management controls in achieving the desired level of safety (i.e., through internal safety audits) and then modifying safety critical elements and processes on a continuing basis Hazard Management Process – Activities & Methodologies
A hazard is any condition or set of conditions, internal or external to the system or system operation which, when activated, can cause injury, illness, death, or damage, including loss of equipment, property, or severe environmental damage. MTM Transit ensures all our personnel and subcontractors use acceptable hazard identification, analysis, and resolution methods as they pertain to the delivery of our clients’ operations and services.

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\Hazard Reporting
MTM Transit’s hazard reporting process is depicted in the diagram below.

All employees are instructed to report any hazards encountered in the workplace. To report hazards, MTM Transit has made the following means available to all employees:

X Workday App. Each employee can log into the Workday app and report any hazards identified by selecting “Report Safety Incident” and then selecting “HazardObservation.” The hazard report is then sent to the local management team for assessment and follow-up.

X Local Safety Committees. During monthly safety committee meetings, reported hazards may be brought to the committee’s attention to address, create mitigation plans, and then close out if practical.

X Reporting Directly to Local Management Team. Any hazard may be reported directly to a member of the local management team at any time.

Follow-up
Monitor corrective actions for effectiveness and provide feedback to the reporting party.

Resolve Hazard
Assume risk or implement corrective actions to eliminate or control the hazard; document actions taken.

Hazard Assessment is Made
Determine hazard causes, evaluate severity and probability factors, determine corrective actions, and notify management as necessary.

Hazard or Safety Concern Reported
Hazard or safety concerns are reported according to the appropriate chain of command and are documented.

Hazard or Safety Concern Identifed
Hazard and safety concerns can be identified by all personnel, including subcontractors, passengers, and the public.

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MTM Transit does not discipline or retaliate against an employee who reports a safety hazard to the company. However, MTM Transit reserves the right to discipline – in accordance with company policy or collective bargaining agreements – any employee who intentionally or deliberately violates a company safety policy.
\Hazard Identification and Analysis
The objective of the hazard identification and resolution process is to identify and define as many credible hazardous conditions as possible and to eliminate or control these conditions or associated activities prior to their causing or contributing to an accident, incident, injury, death, or other major loss or undesired event. This proactive approach stresses the thorough evaluation of systems and proposed modifications from a safety perspective before losses occur. The hazard identification/resolution process applies to all MTM Transit’s operations and services, with special emphasis placed on the initial stages of the design process for new equipment and new start-up projects, including applying the hazard identification and resolution process prior to implementing modifications of existing facilities, systems, or rolling stock. This is due to the large impact these activities often have on the system. Emphasis is also placed on the processes used for employee screening, hiring, and training, as these are key to preventing accidents.

Elimination and control of hazards requires evaluating the cause and consequence of a hazard; eliminating or controlling the hazard; and implementing and monitoring hazard mitigations. All employees are responsible for identifying, reporting, and, when possible, eliminating or controlling hazards they encounter. MTM Transit identifies and reports hazards to our clients, including passenger complaints.

The hazard analysis process attempts to determine the factors that led to the hazard, likely or potential outcomes, and the impacts these outcomes will have on the system. This includes evaluation of the risks and priority associated with the hazard. Once these are evaluated, we take action to mitigate, control, or eliminate the hazard and its associated risks. Hazard management attempts to reduce the severity of accidents and incidents by introducing protective devices and equipment, procedures, and/or system modifications to reduce the amount of human and property damage in the event of an accident or incident.

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\Methods of Hazard Identification
Methods to identify hazards include conducting system inspections, audits, and regulatory inspections; evaluating reported hazards and complaints received from employees, customers, and subcontractors; reviewing accidents, incidents, and system failure reports and conducting in-depth investigations to identify causes; and conducting inductive and deductive hazard identification and analysis. While identifying every hazard within a system is impossible, the implementation of one or all these methods can greatly increase an agency’s ability to identify and eliminate or control hazards.

Through the implementation of this SMS/ASP, MTM Transit has established a formal process for hazard identification and analysis through self-identification. This is done either through employees, management techniques such as inspections and audits, or reviews of daily operating reports to identify trends. Conducting inspections and audits includes leading site surveys and personnel interviews to evaluate employee work practices and work environments.

The inspection portion of this method is used daily by all personnel during the performance of their job duties and requires an attentive eye or the use of safety checklists. Evaluating employee, customer, and location reports of hazards requires more in-depth activities, including conducting site surveys or performing interviews.

MTM Transit personnel are instructed to identify and report hazards or potential hazards, as well as to secure the hazard area until it can be properly controlled or eliminated. Identified hazards are to be reported immediately, according to the proper chain of command and either verbally or by using the Hazard Identification Program Reporting Form, to the employee’s direct supervisor, department manager, and/or the Safety Manager or General Manager. Hazards can also be reported to our Safety Committee. An employee reporting a hazard, along with their direct supervisor, are required to formally document the hazard or safety concern. All reports are investigated, and hazards and deficiencies are corrected or resolved.

This SMS/ASP encourages all employees to become safety officers and does not allow for discipline to any employees for reporting hazards, unsafe acts, or unsafe conditions. All reporting of unsafe acts and conditions is recognized as a proactive safety measure by MTM Transit.

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If a hazard or safety concern is so severe it cannot be addressed by reporting to an employee’s immediate supervisor, our General Manager is notified. While MTM Transit’s staff and Safety Committee may continue to develop acceptable corrective actions, the General Manager, Safety Manager, Director of Safety Administration, and Regional Vice President are responsible for the safety of each MTM Transit location. The Regional Vice President and Director of Safety Administration have final authority and approval of the corrective actions to be taken and whether the risk presented by the hazard is acceptable. The Regional Vice President and Director of Safety Administration’s decision is formally documented, and the results of employee reports are communicated back to the employee.

It is the responsibility of all employees to identify and report hazards and unsafe conditions.

However, while Safety Managers and Safety Supervisors work in or travel through various facilities and properties, they may identify hazards or unsafe conditions. As this occurs, if the hazard or unsafe condition cannot be immediately eliminated or controlled, the Safety Supervisor reports the hazard to the General Manager for resolution.

MTM Transit also identifies hazards through reviewing accidents, incidents, and system failure reports, as well as by conducting in-depth investigations to identify causes. Although MTM Transit strives to prevent these problems, they can be used to improve the work environment and eliminate hazards. MTM Transit conducts comprehensive investigations of these types of events, which determine their underlying causes and identify hazards not readily identifiable during daily operations or through inspections, audits, or employee, customer, or subcontractor reports. Once identified, the hazards are eliminated or controlled and tracked through a hazard identification log.
\Hazard Categorization and Risk Management
Once hazards have been identified, MTM Transit evaluates them to determine the level of risk or impact they may have on the system. Generally, the greater the probability of a hazard to cause injury or loss, the greater the risk is, and the greater the need to resolve the hazard. The severity of the consequences the hazard may present are taken into consideration when evaluating the level of risk associated with the hazard.

For each location, MTM Transit assesses levels of risk, determines what actions need to be taken to correct identified hazards, and documents all hazards and their associated risks. This assessment system is based on the United States Military’s MIL-STD-882E and is a qualitative calculation based on largely subjective judgments used to determine the risk associated with each hazard and the urgency for implementing corrective measures to eliminate or reduce risk.

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This risk assessment system has been incorporated into formal system safety analysis and enables decision makers to understand the risk involved in accepting a hazard in relation to the cost (schedule, dollars, operations, etc.) to reduce the hazard to an acceptable level.

Risk assessment includes evaluating hazard severity (categorizing the hazard) and evaluating hazard probability. Factors considered in this analysis include impact to project schedule and impact on the public's perception of safety on the system in the community.

Hazard Severity
Hazard severity is a subjective determination of the worst case which could result from human error, design inadequacies, component failure, or malfunction. Each level of severity is attributed both physical description (i.e., fatality, injury, property damage, etc.) and monetary value. The levels of severity are as follows:

X Category 1, Catastrophic. Hazard could result in death, permanent total disability, loss exceeding $1 million, or irreversible severe environmental damage which violates law or regulation.

X Category 2, Critical. Hazard could result in permanent total disability, injuries or occupational illnesses which may result in hospitalization of two or more persons, loss exceeding $200,000, but less than $1 million, or reversible environmental damage that violates law or regulation.

X Category 3, Marginal. Hazard could result in injury or occupational illness resulting in one or more lost workdays, loss exceeding $10,000, but less than $200,000, or mitigatable environmental damage without violation of law or regulation where restoration activities can be accomplished.

X Category 4, Negligible. Hazard could result in injury or illness not resulting in a lost workday, loss exceeding $2,000, but less than $10,000, or minimal environmental damage not violating law or regulation.

Hazard Probability
Hazard probability is described quantitatively in potential occurrences per units of time, miles, trips/runs, or passengers carried. A hazard probability may be derived from the analysis of transit system operating experience, evaluation of each location safety data, or from historical safety data from other transit contracts MTM Transit operates. The probability levels are defined as follows (probability level definitions were derived from United States Military Standard 882E):

X A – Frequent. Likely to occur frequently to an individual item; continuously experience in the system; Mean Time Between Events (MTBE) less than 1,000 operating hours.

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X B – Probable. Will occur several times in the life of an item; will occur frequently in the system; MTBE equal to or greater than 1,000 operating hours and less than 100,000 operating hours.

X C – Occasional. Likely to occur sometime in the life of an item; will occur several times in the system; MTBE equal to or greater than 100,000 operating hours and less than 1,000,000 operating hours.

X D – Remote. Unlikely, but possible to occur in the lifetime of an item; unlikely but can be expected to occur at some time in the system; MTBE greater than 1,000,000 operating hours and less than 100,000,000 operating hours.

X E – Unlikely. So unlikely to occur, it can be assumed occurrence may not be experience; unlikely, but possible to occur in system; MTBE greater than 100,000,000 hours.

Hazard risk classification combines the hazard severity and probability into a single risk index.

The hazard risk index values are used by grouping hazards into categories, which can be used to generate specific actions such as mandatory reporting of the most severe hazards to management for action. The table below provides the hazard risk matrix used by MTM Transit to determine the actions taken in response to reported hazards.

Hazard Risk Matrix
Probability of
Occurrence
Severity of Occurrence
Category 1
Catastrophic
Category 2
Critical
Category 3
Marginal
Category 4
Negligible
A – Frequent 1A 2A 3A 4A
B – Probable 1B 2B 3B 4B
C – Occasional 1C 2C 3C 4C
D – Remote 1D 2D 3D 4D
E – Unlikely 1E 2E 3E 4E
Hazard Risk Index Criteria by Index
1A, 1B, 1C, 2A, 2B, 3A Unacceptable
1D, 2C, 2D, 3B, 3C Undesirable – Management Decision Required 1E, 2E, 3D, 3E, 4A, 4B Acceptable With Management Review 4C, 4D, 4E Acceptable Without Review
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Hazard and Risk Resolution
Hazard and risk resolution is the corrective action taken in response to the hazard identification and risk assessment process. Both time and resource restrictions determine the level of resolution that can be accomplished. When possible, the MTM Transit department in which the hazard exists works with the local Safety Manager to develop and implement the approved corrective action plans. Both the Safety Manager and the applicable department track the corrective actions until the hazard is eliminated or controlled.

The goal is to first eliminate the hazard (if possible) and then reduce its risks if it cannot be eliminated. If the risk cannot be eliminated or reduced, or if it is impossible or impractical to eliminate the hazard, the General Manager may choose to accept the risk for all hazards related to MTM Transit’s operations. In these cases, we ensure compliance with all applicable rules, procedures, policies, and regulatory requirements. If the General Manager accepts the risk, it must be approved by the Chief Operating Officer, the Director of Safety Administration, and applicable Regional Vice President.

MTM Transit resolves hazards by either engineering or management controls. Engineering controls are changes made to the system to eliminate hazards or mitigate their risks. An example may be building a separate storage facility for hazardous chemicals or installing a protective barrier around rotating machinery. Management controls are changes made to the organization itself; an example may be posting signs or changing procedures to limit employee exposure to the hazard.

MTM Transit uses the following order of precedence to eliminate or control hazards and their associated risks. A combination of several or all the following may be used, depending on the nature and extent of the hazard:

X Design for Minimum Risk. Design will attempt to eliminate hazards. If an identified hazard cannot be eliminated, its associated risk is reduced to an acceptable level through design selection. This may be constrained by time, money, manpower, or other limitations.

X Incorporate Safety Devices. If the hazard cannot be eliminated or its risk controlled to an acceptable level, safety design features or devices are used to reduce risk to an acceptable level.

X Provide Warning Devices. If neither design nor safety features/devices can reduce the risk to an acceptable level, warning devices are used to detect the condition and produce an adequate warning signal to alert individuals to the hazard. Warning signals and their operation are designed to minimize the probability of individuals reacting incorrectly to the signals and are standardized and similar.

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X Develop Special Procedures and Training. If the hazard cannot be eliminated through design or its associated risk adequately controlled through design selection, safety features/devices such as personal protective equipment (PPE) or warning devices are used, followed by approved procedures and training. This is the least effective method of hazard resolution.

MTM Transit reevaluates the control method after its implementation to determine and verify its effectiveness. If the hazard has been eliminated or controlled, or if level of risk presented by the hazard is deemed to be acceptable, the Safety Manager documents this decision and notify all affected parties.

Minimum Requirements for Notification of Unacceptable Hazardous Conditions and Corrective Action Plans
Each MTM Transit location must notify the Director of Safety Administration of all unacceptable hazardous conditions. At a minimum, the Director of Safety Administration must be notified of:

X Malfunctions of safety critical systems that could result in a catastrophic or single-point failure
X Broken or missing safety-critical equipment, infrastructure, or systems that could result, or have resulted in, employee or passenger injury/damage to client or MTM Transit property
X All complaints and safety-related comments that cannot be resolved locally and require support from the MTM Transit support team
The local Safety Manager investigates all reported hazards to identify root causes. The Director of Safety Administration works with the local Safety Manager and all necessary departments and personnel to develop and implement corrective action plans to eliminate or control the hazardous condition. Corrective actions developed by each MTM Transit location are submitted to the Director of Safety Administration and their Regional Vice President for review and approval prior to their implementation.

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\Safety Data Acquisition and Analysis
MTM Transit gathers and analyzes safety program data through our fleet maintenance software database and other company databases. We use this software to monitor and evaluate the effectiveness of each location’s maintenance safety program and identify areas requiring additional attention; to measure MTM Transit’s progress in meeting safety-related performance targets; and to meet reporting requirements. Data that MTM Transit analyzes includes employee injury and illness data, vehicle accident data, and operator and supervisor reports. MTM Transit is required to notify our corporate team and insurance reporting hotline of all accidents and incidents which have occurred, including the type and severity of each accident/incident.

Our General Managers and Safety Managers track reported hazards through the Hazard Identification Log, which is used for trend analysis, enabling the identification and resolution of potential system-wide hazards or deficiencies. The Hazard Identification Program Log stores, maintains, and tracks the corrective actions and the status of identified and reported hazards, and internal and external safety review findings. The Hazard Identification Program Log also serves as a management tool and repository for past and future safety hazards identified by MTM Transit, passengers, and outside agencies such as the Federal Transit Administration (FTA). MTM Transit uses the data included in the Hazard Identification Program Log to generate reports which enable management to monitor safety performance over time.

MTM Transit provides the data necessary for our clients to make its monthly reports to the National Transit Database (NTD) in accordance with NTD reporting criteria. These reports provide information pertaining to the different types of accidents and incidents, the total number of accidents and incidents, and the frequency rates of accidents and incidents. MTM Transit also tracks employee accident and incident trends through the Occupational Safety and Health Administration (OSHA) 300 injury and illness log to determine high-hazard work areas or job classifications, employee training and re-training needs, or to determine the levels of disciplinary action required following an accident or incident. Data is also gathered regarding workers' compensation claims and costs and is used for insurance purposes.

Vehicle maintenance and equipment failure data is gathered by MTM Transit to ensure preventative maintenance is being conducted on time and to evaluate equipment quality and warranty period performance. Equipment that fails within the time frame of the warranty period can be replaced at limited or no cost under the provisions of the warranty. Information pertaining to equipment that repeatedly fails or that requires high maintenance costs provides management with reasoning necessary for discontinuing its use and selecting different equipment or a different equipment manufacturer.

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Once gathered, identified hazards are linked to the Hazard Management Process and used to correct, track, and report identified hazardous work areas and job classifications. Areas and job classifications with high accident, incident, injury, and/or illness rates will typically contain hazardous conditions which cause or contribute to accidents, incidents, injuries, and illnesses.

These identified hazards are investigated to find the root cause and causal factors.

Recommendations are provided to eliminate, mitigate, and/or control the hazards.

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Safety Assurance
MTM Transit monitors safety through data analysis and our Internal Safety Auditing (ISA) Program, which has many components including performance targets and indicators, a hazard management program, and an emergency management plan.

To ensure safety across our organization, MTM Transit identifies and determines the causes and implications of substandard performance and eliminates or mitigates these causes. Safety Assurance activities include:

X Investigating accidents and incidents to identify root causes X Developing and maintaining formal activities to assess and control safety risks X Monitoring and auditing operational and maintenance processes, including those of subcontracted service providers
X Monitoring the effectiveness of corrective action plans X Managing processes which enable employees to report hazards X Maintaining formal activities to identify service changes X Implementing processes to maintain safety performance X Eliminating or modifying safety risk controls which are no longer needed Safety Performance Monitoring
MTM Transit’s process for monitoring the performance of our SMS/ASP for each of our locations begins with regularly monitoring progress toward achieving performance targets and indicators. MTM Transit collects and analyzes program data monthly to determine if performance targets are being met. Summary statistics are presented to MTM Transit’s corporate management team that highlight areas where targets are being missed and surpassed. All instances in which targets are not being met are discussed to determine the reasons and implement corrective actions.

Safety performance is also monitored through an Internal Safety Auditing (ISA) Program designed to measure the ongoing effectiveness of our SMS/ASP and determine the extent to which departments, personnel, and subcontractors are fulfilling their responsibilities under the SMS/ASP. It is the objective of the ISA Program to verify on an ongoing basis which safety processes have been developed and implemented in accordance with our SMS/ASP and the Federal Transit Administration’s (FTA’s) Public Transportation Agency Safety Plan (PTASP) ATTACHMENT 2
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throughout MTM Transit’s operations. It is also the objective of the ISA Program to assess the effectiveness of the safety processes; to identify process deficiencies, potential hazards, and system risks; to verify prior corrective actions are being tracked for closure and to evaluate their effectiveness; and to recommend system safety improvements. Any subcontractorprovided services may be added and included in the program. The ISA Program encompasses the review and evaluation of the following:

X Policy Statement. An annual review of the Policy Statement is completed to ensure consistency with the most current practices and management objectives for each of our location contract programs. The policy statement describes the authority which establishes the SMS/ASP and is signed by the Chief Executive Officer or Chief Operating Officer.

X Purpose, Scope, Goals, and Objectives. An annual review of our SMS/ASP is completed to ensure the purpose of the Plan is defined and consistent with the most current management goals. Goals are identified to ensure the SMS/ASP fulfills its purpose.

Objectives are identified to monitor and assess the achievement of goals.

X Performance Targets and Indicators. Performance Targets and Indicators are reviewed annually to determine performance; they are revised as necessary to strive towards continual performance improvements. Stated management responsibilities are also identified. As mentioned previously, if partnering with a transit agency client, the following safety Performance Targets are implemented:

Safety Performance Targets
(Specify performance targets based on the safety performance measures established under the National Public Transportation Safety Plan)
Mode of
Service Fatalities
Fatalities
(per 100k
VRM) Incidents
Incidents
(per 100k
VRM)
Safety
Events
Safety
Events (per
100k VRM)
System
Reliability
(VRM/failures)
Service
Type 0 0 X X X X X
Service
Type 0 0 X X X X X
Service
Type 0 0 X X X X X
Service
Type 0 0 X X X X X
Please Note: VRM stands for vehicle revenue miles.

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X Management Structure. Every two years, a review of the SMS/ASP is completed to ensure it presents the most current management and organizational structure, including organizational charts, scope of services, physical characteristics, and operations/maintenance aspects. This review includes:
o Verification the Chief Operating Officer and Director of Safety Administration retain full authority for implementing an SMS/ASP for all locations, ensuring sufficient resources are being allocated to implement the Plan o Verification each location General Manager has authority to support the implementation of the SMS/ASP equivalent to that of other Managers and Senior Leaders
o Verification the SMS/ASP has been approved and adopted by each of our clients o Review of stated safety functions and how they are integrated throughout each location’s operations and services
X SMS/ASP Review and Modification. An annual review of the SMS/ASP is completed to ensure it meets applicable regulatory requirements and remains consistent with the PTASP as issued by the FTA. This review also includes verifying MTM Transit has processes in place to ensure this SMS/ASP remains a controlled document but is also easily accessible to all personnel and subcontractors working for MTM Transit. This annual review includes verification only the most recent controlled copies of the SMS/ASP have been issued and are being used.

X Plan Implementation. Entails a review of the activities conducted by the MTM Transit location to implement and administer the SMS/ASP for the respective locations, including the activities, tasks, and responsibilities of each MTM Transit location under the Safety Management System (SMS) Program. This includes a review of all tasks performed by position and management accountability to implement and administer the SMS/ASP, as well as all supporting procedures, policies, and documents.

X Hazard Management Program. Entails a thorough review of the process for identifying, evaluating, controlling, and tracking hazards and risks, including the development and management of corrective action plans and their status. This includes the evaluation of processes used to implement the hazard management program throughout MTM Transit’s operations and services.

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X Management of Change. Includes reviewing MTM Transit configuration management processes, including those of each client contract, as they pertain to each location to verify their effectiveness. This includes reviewing processes for:
o Making changes to location operating and maintenance rules and procedures affecting safety to ensure they remain applicable and correct, without introducing new hazards
o Safety and Security Certification of new start-up projects, as well as major projects to extend, rehabilitate, or modify existing systems, or to procure or replace vehicles and equipment
o Maintaining safety during System Modifications which do not require formal safety and security certification, but which have safety impacts o Procurement management to ensure safety principles are included to prevent the introduction of unsafe equipment and materials into MTM Transit’s operations and services
X Safety Data Acquisition and Analysis. Includes evaluation of the processes used to collect and analyze safety-related data and the processes used to determine trends as they relate to system safety.

X Accident and Incident Reporting and Investigation. Includes evaluation of the processes used to notify outside agencies of accidents involving each location, including the National Transportation Safety Board (NTSB), the FTA, and the Occupational Safety and Health Administration (OSHA). Each MTM Transit location holds primary responsibility for making these notifications with support by the Director of Safety Administration. We also evaluate the processes used to investigate and identify accident and incident causes; develop and implement corrective actions; and corrective actions with other outside entities as necessary.

X Emergency Management. Includes reviewing emergency plans and procedures to ensure applicability with MTM Transit’s operations and services, social behavior, and technologies, as well as emergency response agency implications and the effectiveness of processes for interdepartmental coordination.

X Facility and Equipment Maintenance Audits and Inspections. Includes identifying facilities, equipment, and systems subject to regular safety-related inspections and testing, as well as processes for reporting, documenting, and tracking deficiencies, hazards, and corrective actions. This also includes identifying and verifying established ATTACHMENT 2
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maintenance cycles and required documentation of maintenance performed on these systems and facilities, as well as inspections and audits of procedures and work practices to identify deficiencies, trends, and signs of sabotage, and the methods used to document and track deficiencies, hazards, and corrective actions.

X Training and Certification Review and Audits. Includes review of MTM Transit’s training certification and re-certification programs, policies, procedures, and processes to ensure a comprehensive staff training program exists for operations personnel and personnel directly responsible for safety, ensuring these programs are effective. It also includes verifying an adequately trained Safety Supervisor conducts safety training.

X Hazardous Materials Program. Includes the review of hazard communication programs and processes for chemical storage, procurement, Safety Data Sheet (SDS) reviews, environmental management programs, and container labeling.

X Drug and Alcohol Program. Includes the review of drug and alcohol policies to ensure consistency with State, Federal and local regulations, as well as management policies and compliance with stated drug and alcohol policies.
\Internal Safety Audit Program
MTM Transit, while fully involved in the operations and services of each contract, is responsible for overseeing the ISA Program to ensure the SMS/ASP is being implemented and continuously measured for effectiveness.

The results of each internal review and audit are provided in an Audit Report listing a summary of the findings, detailed recommendations to correct open items, and an initial hazard analysis.

Open findings are documented in the audit’s Action Plan Log, where all findings, recommendations, corrective actions, responsible departments/personnel, estimated closure dates, and status information are maintained. For each hazard and deficiency identified, a hazard risk assessment value is determined so the hazards and deficiencies can be prioritized for closure.

The MTM Transit Regional Vice Presidents and Director of Safety Administration plan a safety audit schedule for those locations scheduled for a review. At least seven days of notice is given to each location detailing the specific dates and times of the internal safety review along with a request for specific documentation to be evaluated during the review.

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Accident/Incident Notification, Reporting, & Investigation MTM Transit’s SMS/ASP is a proactive method of improving safety designed to identify and eliminate hazards before they can cause or contribute to accidents/incidents, rather than the traditional approach of reacting after accidents/incidents occur. Under this framework, the occurrence of an accident or incident can be viewed as a failure of the System. When implemented fully, the SMS/ASP acts as an accident prevention program. While it is the goal to provide accident-free service, this goal is not easily achievable in the public transit environment where the delivery of service is affected by numerous outside and uncontrollable factors. When accidents/incidents occur, MTM Transit investigates to identify root causes and contributing factors so future events can be prevented. Effective accident/incident reporting and investigation is a key component of the Safety Assurance process.

MTM Transit conducts a formal, objective investigation of all accidents and incidents involving people or property, regardless of origin, the operators involved, or the responsible party. As part of our accident/incident investigation procedures, MTM Transit maintains accurate accident and incident data, including:

Accident/Incident Type
Backing Left Turns Right Turns
Merging Intersections Fixed Objects
Sideswipes Hit in Rear Passenger Falls
Rear-ends Passenger Behavior Wheelchair Securements
Pedestrian Incidents Bicycle Incidents Thermal Events
National Transit Database (NTD) Reportable Accidents include events that are related to or affect revenue service, affect persons engaged with the transit system, and meet one or more of the following reporting thresholds:

X Fatality, including suicides
o Deaths resulting from illness or other natural causes are not reportable.

X Immediate transport away from the scene for medical attention (one or more persons) o Each person is reported as an injury if they are immediately transported away from the scene for medical attention.
o Illnesses requiring transport for medical attention are not reportable. o Transport can be by any means (i.e., Emergency Medical Services (EMS), Road Supervisor, etc.).

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X Estimated property damage equal to or exceeding $25,000, including all property involved, including damage to private vehicles, if applicable X An evacuation for life safety reasons
o A life safety event is one that presents an imminent danger to all people in or on transit property.

NTD Reportable Incidents include:

X Collisions. Must meet a reporting threshold as described above.

X Fires. Must meet a reporting threshold as described above.

X Hazardous Material Spills. Must meet a reporting threshold as described above and require specialized clean-up.

X Acts of God. Must meet a reporting threshold as described above.

X System Security Events. Must meet a reporting threshold as described above, including the following and other miscellaneous security incidents:
o Suspicious Packages
o Bomb Threat or Bombing
o Chemical, Biological, Radiological, or Nuclear Release o Burglary
o Vandalism
o Hijacking
o Arson
o Sabotage
o Cyber Security Events
X Personal Security Events. Must meet a reporting threshold as described above, including the following and other safety occurrences:
o Homicide
o Assault
o Rape
o Suicide or Attempted Suicide
o Robbery
o Larceny or Theft
MTM Transit also maintains accurate accident/incident data, including:

X Whether an accident was preventable or non-preventable X Number, type, and severity of injuries
X Who was injured (i.e., passengers, employees, public, etc.) X Damage estimates and final repair costs
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\Notification Responsibilities
Once notified of an accident or incident, the MTM Transit local Dispatcher (or other applicable team member as designated by the contract) gathers as much information as possible regarding the event and immediately notifies applicable emergency response units such as Emergency Medical Services (EMS), State and/or local Police, Fire Department, and/or other emergency response agencies as necessary. The Dispatcher (or other applicable team member) also notifies the General Manager, Operations Manager, Safety Manager, Road Supervisor(s), and any other individuals as directed by the Operations Manager or General Manager. All local team members follow MTM Transit’s Standard Operating Procedures (SOPs) for accident/incident reporting.
\Accident/Incident Investigation
MTM Transit thoroughly investigates all accidents, incidents, and near misses. We also maintain applicable records, including corrective action plans developed because of investigation findings. This may include working with local and/or State Police during an investigation. The degree of an investigation and the parties involved depend on the type and extent of the accident/incident.

MTM Transit encourages all employees to report near misses. The reporting of near misses by employees is non-punitive and is seen as a proactive way to prevent future accidents. In fact, we verbally recognize our employees for reporting near misses. MTM Transit is authorized to conduct the investigation of an accident or incident in the most expedient manner possible.

This includes impounding, receiving, and examining evidence related to the accident/incident.

MTM Transit also maintains the integrity of evidence and chain of custody. In fulfilling this responsibility, we may use secure facilities and assistance from the local and/or State Police forces. At no time does an investigation interfere with rescue operations.

MTM Transit strives to identify the causes and contributing factors to each accident/incident and takes immediate corrective actions to ensure the same or similar type of accident/incident does not occur. It is critical the accident/incident investigation process maintains a strong link to the hazard and risk identification and resolution process.

Hazards identified because of an investigation are evaluated according to the hazard identification and resolution process previously detailed in this SMS/ASP. Hazard resolutions are incorporated into procedures, designs, construction, modifications, and procurements to prevent further accidents/incidents of a similar nature.

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\Accident/Incident Investigation Report
MTM Transit prepares and submits an Accident/Incident Report and, if required, a detailed Comprehensive Report of the accident/incident investigation. \Post-Accident/Incident Investigation Activities
Because the primary reason for conducting an accident/incident investigation is to determine accident/incident causes and to prevent reoccurrences, it is critical to ensure approved corrective actions are not only implemented, but also monitored to confirm and measure their effectiveness. All accident/incident information, including investigation reports, witness statements, photographs, corrective action plans, and disciplinary action taken against an operator or employee because of the accident/incident, are documented and maintained by MTM Transit. All accident/incident investigation findings including root causes and hazards identified during the investigation are linked, fully evaluated, and managed through our accident/incident reporting and investigation process.

Safety Validation of Change
Effectively evaluating and managing the impacts of changes on the transit system is essential to ensuring ongoing safety performance. MTM Transit has developed formal processes to identify and evaluate changes in the organization before they occur to ensure system safety is maintained. This includes ensuring all changes and modifications made to MTM Transit’s client systems, operations, services, facilities, equipment, vehicles, and other properties, as well as changes made to polices, plans, rules, procedures, and other documentation that may impact or be affected by the SMS/ASP, are systematically planned for, evaluated, approved by appropriate parties, and documented.

This safety validation of change process, which is also referred to as our configuration management process, is designed to ensure operational compliance with approved technical criteria and requirements, as well as to evaluate and control safety risks. Configuration management of documents involves controlling changes and modifications made to documents including, but not limited to policies, procedures, guidelines, rulebooks, training materials, drawings, schematics, manuals, catalogues, bulletins, notices, general orders, pamphlets, information related to replacement parts and components, and/or other technical data.

Configuration management of facilities, systems, vehicles, and equipment begins during development of the final design and extends through construction, start-up, and operations, concluding with deactivation of the facility, system, vehicle, and/or equipment.

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This configuration management process establishes a method for formally reviewing and approving proposed modifications to ensure the modification:

X Will be compliant with applicable State, Federal, and local regulations X Will be compatible with and consistent throughout all existing policies, procedures, and rules
X Will not reduce the safety and hazard controls already in place X Will not introduce new hazards to the system
MTM Transit administers this process for all client operations and services. This includes creating and maintaining operating, maintenance, and training materials to support the operations and maintenance of our clients’ operations, unless our client specifies different procedures. \Configuration Management of Documents
It is the responsibility of all personnel whose duties entail the authoring and/or revising of documents affecting or affected by the Safety Program to thoroughly evaluate proposed changes to these documents, ensuring changes meet the requirements of the review process. If proposed changes do not meet one or more of the four requirements, they cannot be made.

Once a safety change has been thoroughly evaluated and made to a document, it is the responsibility of that document's authoring or controlling party to disseminate the revised document to all applicable personnel. It is also the responsibility of the authoring or controlling party to notify the applicable personnel at MTM Transit of what other documents have been changed or must now be revised because of the change or modification.

Configuration management activities as they pertain to the Safety Program have not been assigned to a specific department within MTM Transit but are instead carried out by each of the individual departments within MTM Transit and by the applicable management individuals responsible for and involved in the Safety Program. It the responsibility of all personnel involved with a location’s operations and services to not only implement the configuration management practices detailed by this SMS/ASP, but to maintain up-to-date files or document libraries of all the documents pertaining to the operation and services provided by MTM Transit pertaining to their location.

All personnel must remain cognizant and up to date regarding the rules, regulations, procedures, and/or policies related to their job responsibilities. MTM Transit maintains a central electronic and hard copy library of documentation for the company and at each corresponding location.

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\Rules and Procedures Reviews
To provide safe and reliable service to its customers, MTM Transit annually reviews and revises our operating and maintenance rules and procedures. We also review rules and procedures when accident/incident investigations determine the need for a change; in response to system modifications or changes including new system and/or equipment procurements; in response to changing Federal, State and/or local regulations and requirements; and/or because of findings generated through the ISA Program or audits performed by external agencies. We perform these reviews to ensure existing safety requirements are met; to verify proposed changes do not create new hazards or present additional risks to the system; to ensure the effectiveness of existing safety controls will not be reduced; and to ensure risks to personnel, passengers, subcontractors, equipment, facilities, and/or other properties or the environment will not be increased.

Rules and procedures subject to the review process include location operator training documents and SOPs; vehicle, system, and facility maintenance manuals and procedures; training materials and programs; People and Culture policies and procedures; and safety programs, plans, and procedures. As a national contract service provider based in St. Louis, Missouri, MTM Transit has established national procedures and adapted them to local conditions and requirements. MTM Transit’s Chief Operating Officer, Regional Vice Presidents, Director of Safety Administration, and Regional Directors of Maintenance oversee this process, including how it is implemented for all locations. Disciplinary action is taken to ensure compliance with safety rules and procedures through our safety points policy detailed in our employee handbook.
\Safety Certification
The FTA requires a formal Safety Certification Program be implemented for projects that receive funding from the FTA, which is applicable for many of our transit clients. Safety certification is a multi-phase process designed to verify all planned safety activities are completed and properly documented prior to beginning revenue operations or the start of services related to a contract acquisition, new service contract, or system modification; safety requirements included in contract specifications are properly interpreted, designed, and incorporated into the project; safety related plans, procedures, and training materials related to the project are reviewed for consistency and compatibility with upgrades, changes, or modifications made throughout the project; and new documentation is developed and approved prior to the start of revenue service.

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The Safety Certification Process includes hazard identification, analysis, and mitigation across the functions of our operations, safety, and maintenance areas. This process ensures safety concerns and hazards are adequately addressed prior to the initiation of passenger operations for new projects and major projects to extend, rehabilitate, or modify the existing system; taking over a new service contract; and replacing vehicles and equipment. This process also applies to all other projects determined by MTM Transit to be of sufficient significance requiring formal safety certification. MTM Transit has not needed to use this process up to the time of writing of this document.

The Safety Certification Process begins with the identification of system safety requirements, including those detailed in technical specifications and design criteria applicable to the project.

Hazard analyses, fault tree analyses, failure modes and effects analyses, and other safety and security assessment documents developed by MTM Transit and/or our subcontractors as part of the project are the primary means for determining implementation of safety design criteria.

These analyses also verify safety requirements have been implemented; identified hazards, threats and vulnerabilities have been mitigated; and verification methods (i.e., inspections, analyses, tests, etc.) have been used to demonstrate compliance.

Certifiable elements are next identified and include all project elements which can affect the system safety of passengers, employees, clients, subcontractors, emergency responders, or the public. They can be broadly classified as:

X Facilities and Equipment
X Systems
X Integrated Test Requirements
X Operational Requirements
Completion of activities in these areas provides assurance through documented evidence the project conforms to all specified safety requirements. The certifiable elements for a project are defined by reviewing the project design criteria manual, project management Plan (PMP), and technical specifications, as well as past and similar projects.

The Safety Certification Process also includes the review of audits, inspections, and tests where the safety and security of customers and/or employees, equipment, or facilities could be affected by the improper or incorrect construction or manufacture of system elements. These audits, inspections, and tests cover facilities and system elements and may include inspections, qualification tests, performance tests, and acceptance tests. MTM Transit developed the tests to verify the integration and compatibility of equipment, facilities, and operation/maintenance procedures to function together under normal, abnormal, and emergency situations. This includes verifying the environmental constraints and capabilities of the system and facilities we will be providing to our clients.

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Certifiable elements in each construction package are certified independently once all subelement and sub-item submittals are received, reviewed, approved by the construction staff, and verified. Any open items which remain in effect with operational restrictions are documented and attached to the certificate. These restrictions must be resolved and approved by the Director of Safety Administration or the Chief Operating Officer and our respective client. \Managing Safety in System Modifications
MTM Transit’s processes for reviewing system changes and modifications as they pertain to each location have been developed to ensure proposed modifications and changes are compliant with all applicable State, Federal, and local regulations; are compatible with existing systems; will not reduce the safety and hazard controls already in place on the system; and will not introduce new hazards to the system. The review and approval process applies to:

X Changes in safety-critical processes or functions
X New construction projects or modifications to existing facilities, which are limited in scope and do not require formal safety and security certification X Equipment acquisitions or modifications/overhauls of existing equipment X Proposed system expansions including new routes or operating territories The MTM Transit Director of Safety Administration approves the System Modification Review and Process, and it is carried out during each phase of the project, beginning with the preliminary review process. The Director of Safety Administration also ensures the proposed change or modification is evaluated by qualified personnel to determine its effect on MTM Transit’s systems and the pertaining client operations. This requires reviewing applicable regulations, conducting site visits, reviewing specifications, and performing analyses, including preliminary hazard analyses and/or fault tree analyses. These types of analyses may require the efforts of multiple departments and personnel, or the outside support and expertise of subcontracted personnel. Once changes are complete, personnel in the area in which the change occurred are responsible for monitoring and evaluating the effects the modification has had on the system or operation. All system changes must be thoroughly documented. \Managing Safety in Procurement
The procurement and implementation of new services, equipment, and other materials directly impacts the safety of our operations and services. It is necessary to ensure the procurement process considers and evaluates safety risks prior to a new procurement being made. The procurement process attempts to ensure services, equipment, and other procured materials will not degrade the safety of any MTM Transit operations or services, ensuring commitment in ATTACHMENT 2
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keeping all equipment in a state of good repair. These requirements are met by including safety requirements in technical specifications and contracts; evaluating impacts on our operations and services in accordance with the hazard identification and resolution process; requesting SDSs for new chemicals in accordance with the hazardous materials program; requesting and analyzing insurance requirements; requiring the submittal of certificates of compliance stating all work has been performed in compliance with the technical specifications; evaluating replacement parts and sub-components; and monitoring performance.

When procuring services, equipment, and other materials, MTM Transit’s goal is to meet or exceed all Federal, State, and local requirements and keep our clients apprised of the process.

Where required, MTM Transit also coordinates with the transit agency on adhering to the FTA Transit Asset Management (TAM) plan on managing capital assets.

For most MTM Transit locations, the client procures the vehicles and some of the durable maintenance equipment. MTM Transit is typically responsible for procuring road supervisor vehicles, uniforms, parts, fluids, and other materials to support operations and maintenance, as well as renting the maintenance facility and procuring the utilities for the facility. MTM Transit meets or exceeds client requirements related to the parts and fluids used on the vehicles to ensure equipment longevity. MTM Transit also typically procures the maintenance and scheduling software used in many of the transit systems we operate.

During emergencies, the procurement of services, equipment, and/or materials may be necessary to maintain safety, as well as MTM Transit’s client operations and services. These situations are considered emergency conditions and as such special procedures are enacted to respond to and control the event. Examples of emergency conditions or events, which may require the emergency procurement of services, equipment, and/or materials, include severe weather conditions; emergency response and recovery activities related to accidents or incidents; equipment failures and malfunctions; employee strikes or work stoppages; or any other reason which may create an immediate threat to public health, welfare, or safety.

In all cases, the procurement process is conducted according to company policies and procedures and the Hazard Management Program as described in this document. All decisions regarding the procurement process are made with regards to safety and the effects and impacts the procurement will have on the safety of MTM Transit’s operations and services.

Every effort is made to ensure the procurement of new services and equipment will not diminish the effectiveness of current safety processes or hazard controls, nor create new or additional hazards within the system. All parties involved with or affected by the procurement are notified and continually informed regarding the procurement.

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Maintenance and Inspection Programs for Vehicles,
Systems, and Infrastructure
Maintenance and inspection programs are necessary to maintain MTM Transit’s vehicles, equipment, systems, and infrastructure in a state of good repair. Failure to administer such programs could result not only in a degradation of service, but a degradation of safety. MTM Transit monitors and audits maintenance and inspection programs to measure safety program performance and ensure system safety is maintained. MTM Transit has a robust maintenance program and adheres to all scheduled maintenance timelines.

MTM Transit is usually responsible for maintaining vehicles, maintenance equipment, and the maintenance facilities of our contracted services. Our maintenance program is based on preventative maintenance, non-scheduled maintenance, and campaigns to improve fleet safety and reliability. This includes client operations, rolling stock, communications systems, equipment, and facilities. All maintenance work is performed according to MTM Transit’s applicable preventative maintenance schedules, procedures, and/or manufacturer recommendations.

Maintenance and inspections are also conducted
because of accidents/incidents; employee or
passenger complaints or notifications; warranty
work; and/or safety analyses and hazard reports.

Maintenance procedures are maintained in our
maintenance facilities. The following summarizes key
standards and procedures related to MTM Transit’s
maintenance safety compliance assessment and
inspection processes:
f Pre-trip Inspections. All vehicle operators perform pre-trip inspections of their vehicles prior to entering revenue service. All vehicle defects identified by the operator are noted on the applicable pre-trip inspection form and reported to maintenance personnel. If a vehicle has a defect or is damaged to the extent the operator feels it is unsafe for service, they notify the Dispatch and maintenance teams so the vehicle can be repaired or replaced. If vehicles are safe for service, they are operated, and all nonsafety or security related defects are corrected as soon as possible. Maintenance personnel maintain a record of all operator defect reports using the Driver Vehicle Inspection Report (DVIR) books, which are maintained for each vehicle.

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f Vehicle Accident/Incident Repairs. All accidents and incidents involving vehicles are reported to the Dispatch team immediately. Vehicles damaged because of an accident/incident are removed from revenue service, evaluated by maintenance personnel, and repaired as soon as possible, depending upon the degree of damage. f Preventative Maintenance. Scheduled maintenance activities include, but may not be limited to, preventative maintenance programs tied to vehicle mileage, manufacturer recommendations, or industry standards. MTM Transit has established preventative maintenance programs for all vehicles, as well as programs to identify and eliminate potential problems prior to the need for performing corrective maintenance, which can often be much more costly.

Maintenance Supervisors monitor maintenance activities and ensure required inspections and repairs are conducted according to schedules and procedures. Maintenance Supervisors also ensure all repairs are made and documented according to local, State, and Federal regulations.

In addition, MTM Transit’s operations, maintenance, and safety staff perform daily facility and equipment inspections as part of their normal duties to ensure the system remains safe and reliable. The General Manager also conducts monthly inspections of the maintenance facility.

Stations and stops owned and operated by outside parties are maintained by their respective owners.

The General Manager and applicable members
of each local management team perform
detailed facility and equipment inspections of
our property, as well as review inspection
procedures, checklists, findings, and corrective
actions developed and implemented. MTM
Transit inspects preventative maintenance
records to identify hazards and verify the
accuracy of inspections, testing data, and
methods. Audits and inspections may include
interviews with MTM Transit employees, reviews of procedures and records, first-hand observations of operating and maintenance activities, and visual examinations and measurements of vehicles, systems, and equipment.

General Managers and Supervisors immediately notify their location’s employees of any hazard identified in the workplace and of action to take to eliminate and/or control the hazard. It is the responsibility of the MTM Transit department in which the hazard was identified to notify all ATTACHMENT 2
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other MTM Transit departments and personnel who may be affected by or exposed to the hazard. It is also the responsibility of the MTM Transit department in which the inspection took place to implement and monitor the success of proposed recommendations and corrective actions, as well as to follow the Hazard Management Program as required by this SMS/ASP.

Inspection results, reports, recommendations, corrective actions, and follow-up activities taken because of the inspection are documented and maintained in the Hazard Identification Program Log. Work orders are generated to resolve identified issues, and the responsible maintenance divisions or subcontractors are notified.

The maintenance and inspection program functions as a component of the ISA Program and is directly linked to the Hazard Management Program. All findings are documented, evaluated, and prioritized for closure in accordance with the Hazard Management Program. Written checklists may be used to support the inspection process. Written reports are prepared detailing inspection findings, corrective actions, responsible parties for implementing the corrective actions, and estimated closure dates. Follow-up inspections are conducted to ensure action was taken.

Emergency Planning and Response
Effective emergency preparedness, response, coordination, and training are essential elements to minimizing losses during accidents/incidents or the occurrence of an emergency or disastrous event. The objective of emergency preparedness and planning is to ensure fast and efficient response to emergencies to minimize risk to the safety and health of passengers, employees, and emergency response personnel, and to avoid unnecessary property loss. To meet this objective, MTM Transit has a written comprehensive Emergency Response Plan (ERP), which establishes the roles and responsibilities to be carried out by our locations and by various emergency response agencies during emergencies. The ERP is supplemented by emergency operating rules. These documents can be referenced to gain a complete understanding of the responsibilities and policies regarding emergency preparedness, response, coordination, and training. During emergencies, it is MTM Transit’s policy to:

X Provide the most effective and timely response to any emergency or disaster, ensuring the safety of the public, passengers, and employees
X Provide for the immediate needs of individuals involved in the emergency, ensuring all passengers, bystanders, and employees receive care and treatment X Ensure the highest practical level of service for all passengers is maintained by providing alternate or temporary service while striving to restore normal service and equipment in line with Emergency Support Function 1 – Transportation ATTACHMENT 2
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X Coordinate with Federal, State, and local authorities to make available additional or alternative transit service as deemed necessary to support response efforts of these authorities
o This response is consistent with the federally initiated National Incident Management System (NIMS) and Incident Command System (ICS) adopted by Federal, State, and local agencies.

X Ensure customers, the public, and the media are presented with timely, accurate, and easily understandable information regarding service changes, disruptions, and/or re-routing X Ensure protection and preservation of MTM Transit and client assets X Coordinate debris removal and clean-up activities with local, State, and Federal agencies o The Environmental Protection Agency (EPA) is contacted for accidents/incidents resulting in environmental impacts.

X Conduct accident/incident damage assessments to determine the resources necessary for recovery and the services which can be restored
X Assist in any subsequent accident/incident investigation process conducted by Federal, State, or local authorities or agencies with regulatory authority including the NTSB, FTA, Transportation Security Administration (TSA), Federal Bureau of Investigation (FBI), and/or other agencies
X Document and maintain records of all disasters and emergencies Through our clients, administrative authority is given for the provision of transit and commuter transportation services, for the implementation of safety, security, and emergency preparedness requirements. This includes internal mobilization of personnel, resources, and additional services as deemed necessary by our clients or as directed by emergency responders and law enforcement agencies.

During an emergency or disaster involving personnel and/or passengers, all personnel located at the scene of the emergency are under the authority of the Incident Commander (Fire, Police, etc.) and then under the authority of the MTM Transit Operations Manager or Road Supervisor.

These authorities will manage the incident consistent with NIMS and ICS. \Preparedness
MTM Transit prepares for emergencies and disasters by training personnel and conducting tabletop and functional exercises, emergency drills, and individual unit drills, depending on each client’s requirements. Emergency drills demonstrate personnel understand and can carry out their individual roles and responsibilities during an emergency and are familiar with the requirements, equipment, and layout.

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Discussion-based exercises such as tabletop drills are conducted to prepare MTM Transit and client personnel and participating agencies for emergencies. The purpose of these drills is to ensure everyone understands their roles and responsibilities during an emergency and to check which procedures are up to date with accurate information.

Functional exercises, such as full-scale exercises and emergency drills, are conducted to ensure individuals clearly understand the steps they must perform during an emergency. Typical drills include operators assisting passengers in deboarding; crowd control during an emergency; and Dispatcher personnel responding to operator-initiated emergency call-ins. These drills may also include personnel from external law enforcement agencies. \Response
The response phase of emergency management puts the planned emergency activities, responsibilities, and agreements into effect. The emergency preparedness planning (EPP), Emergency Operations Plans (EOPs), SOPs, and interagency agreements in place have been written to ensure when an emergency or disaster occurs, MTM Transit management personnel and first response agencies and organizations can break down their areas of responsibility into manageable units, assess what has happened, what can be done, and what is needed. Response efforts focus on the preservation of lives concurrent with incident stabilization activities. These activities are conducted consistent with NIMS and ICS. and often require teamwork with other State and local emergency response agencies.
\Recovery
The recovery phase of emergency management includes the restoration of normal services/conditions and the assessment and documentation of emergency response operations.

Depending on the nature and severity of the event and its aftermath, restoration of normal services and conditions depends upon other recovery activities. \Notification
It is the responsibility of MTM Transit personnel and our clients to understand the requirements for proper notification when an emergency or disaster occurs involving the service we provide. To minimize and control the threat to health, life, and property, all appropriate parties are notified as quickly as possible to ensure a timely response to the disaster or emergency.

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\Interagency Agreement
Interagency or inter-department agreements may be necessary to ensure all parts of our organization understand their roles and responsibilities during disasters and emergencies.

These agreements identify the roles and responsibilities of each organization, the chain of authority, and necessary contact information.
\Training of Personnel
Emergency Management Training is conducted through training drills and tabletop exercises.

Emergency response procedures are distributed to MTM Transit location personnel and other stakeholders as part of the training program and by MTM Transit departmental supervision based on the employee’s scope of responsibility.

Environmental Management Program
Improper labeling, storage, and handling of hazardous materials can result in consequences which endanger the lives of employees, subcontractors, passengers, and the public, but also endanger our facilities, properties, equipment, systems, operations, surrounding public properties, and the environment. An effective environmental management program addressing the procurement, use, and disposal of hazardous materials is essential to eliminating or reducing these consequences. All activities involving hazardous materials comply with applicable Federal, State, and local environmental protection laws and regulations, including those of the Clean Water Act, Clean Air Act, Resource Conservation and Recovery Act, and Comprehensive Environmental Response and Compensation and Liability Act.

MTM Transit has established procedures pertaining to the disposal of hazardous materials and wastes related to hazardous material spills and/or releases. These procedures define personnel and department responsibilities when responding to emergency events involving hazardous materials and wastes, as well as responsibilities for the accumulation, recycling, and disposal of these materials. Appropriate procedures are followed when handling contaminated liquid waste; spent engine fluids such as engine oil, transmission fluid, hydraulic fluid, and antifreeze; caustic waste; non-hazardous liquid waste; spent oil filters; fluorescent light tubes and batteries; and scrap tires.

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Safety Promotion
To promote safety, MTM Transit provides employees with formal safety training, a formal means of communicating safety information, and a means for employees to report safety concerns.

MTM Transit communicates safety information to employees through our MTM Transit Employee Handbook; Injury and Illness Prevention Plan (IIPP); and in this SMS/ASP. The purpose of these documents is to confirm employees are aware of SMS/ASP requirements, to ensure appropriate personnel in the organization convey safety critical information to all employees, and to explain why safety actions are taken and procedures are introduced or changed. Under our Safety Program, communication with employees is made through daily safety messages posted on employee bulletin boards and radio announcements, as well as monthly safety meetings, trainings, and day-to-day operations.

SMS/ASP Training and Implementation Tasks and
Activities
All MTM Transit employees have roles and responsibilities under the Safety Management System (SMS). As required by the Safety Policy established by this SMS/ASP, which has been approved and adopted by our CEO, all employees are responsible and accountable for fulfilling and complying with the safety requirements of their positions, for supporting the implementation of the SMS/ASP, for receiving supplemental training, and for providing support necessary to achieve program goals.

The lines of authority for implementing the SMS/ASP begin with each location’s management staff, who are supported by executive management, and empowered and authorized to design, implement, train, and administer a comprehensive, integrated SMS/ASP to support our transit operations and services.

The General Manager at each location identifies and addresses safety concerns; tracks and verifies implementation of recommendations and corrective actions; and reports the status of our SMS/ASP to the MTM Transit Executive Safety Committee and the Director of Safety Administration. Each General Manager, serving as the SMS/ASP Manager for their location, is authorized to lead the development, implementation, training, and maintenance of any other plans, policies, procedures, and processes to support and implement the SMS/ASP.

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The matrix below depicts the roles and responsibilities of MTM Transit personnel and other stakeholders as they pertain to our Safety Program. As used in the matrix, the following notations are defined as:

X P – Primary Task Responsibility. The identified participant is responsible for the preparation of the specified documentation.

X S – Secondary or Support Responsibility. The identified participant is to provide the necessary support to accomplish and document the task or requirement.

X R – Review/Comment Responsibility. The identified participant may review and provide comment on the task or requirement.

X A – Approval Responsibility. The identified participant is to review, comment, and subsequently approve the task or requirement.

Safety Tasks/Responsibilities Matrix
Task/Activity
Executive Team Dir. of Safety Admin. General Manager Safety Manager Maintenance Mgr. Safety Committee Operations Maintenance Management Commitment/Policy A P S S S P S S
Summary Section A S P S S R S S
Authority A P P P P R S S
Purpose A S P S S R S S
Goals and Objectives A P P P P S S S
Scope A P P P P S S S
SMS/ASP Control and Revisions A S P S S R R R
Operations and Maintenance Safety A S P S S P P P
Maintenance of Equipment A S P S S P P P
Facilities and Systems Description A R P R R R R R
Organizational Structure A P S S S R R R
Inter-Company Coordination A P P P P R R R
Safety Committee A S P S S P P P
Hazard Management (ID, Analysis, and Resolution) A S P S S P P P Equipment and System Design A S P S S R R R
Safety Certification Program A S P S S S S S
Configuration Management A P P P P P P P
Accident/Incident Investigation A S P S S P P P
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Safety Tasks/Responsibilities Matrix
Task/Activity
Executive Team Dir. of Safety Admin. General Manager Safety Manager Maintenance Mgr. Safety Committee Operations Maintenance Safety Inspections A S P S S P P P
Facilities Inspections A S P S S P P P
Equipment Inspections A S P S S P P P
Operations Safety A S P S S P P P
Emergency Operations Response Procedures A P S S S P P P Emergency Exercises and Drills A S P S S P P P
Operational Documents A S S S S P P P
Rules and Procedures Review A S S S S P P P
Occupational Safety and Health Program A S S S S P S S
Industrial Hygiene Program (if applicable) A P S S S P S S Hazardous Materials Program A S S S S P S S
Personal Protective Equipment Program A S S S S P S S
Subcontractor Safety Program (if applicable) A P P S S P S S Safety Data Acquisition, Analysis, and Reporting A P P S S P P P Reports A P P S S S S S
Training A P P S S P P P
Environmental Protection Program A P S S S P P P
Internal Safety Review Program A P P S S P S S
Drug and Alcohol Abuse Program/Policy A P S S S P P P
Internal Audits A P S S S S S S
\Index of Supporting Documents
The following documents support the implementation of the SMS/ASP for MTM Transit:

X MTM Transit Hazard Identification Reporting Form
X MTM Transit Hazard Identification Log
X MTM Transit Injury and Illness Prevention Plan (IIPP) X MTM Transit Employee Handbook
X MTM Transit Employee Safety Manual

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\Safety Communication and Outreach
MTM Transit’s primary means of communicating safety information to employees, passengers, and the public is through Safety Messages and Safety Alerts sent via email and correspondence through Workday, our internal employee People and Culture system, as well as through location messages. MTM Transit communicates safety information to our employees by posting safety notices and bulletins to employee bulletin boards, through regular radio announcements, monthly Safety Committee Meetings, day-to-day management oversight, and through MTM Transit’s employee training program. MTM Transit has established a comprehensive Injury and Illness Prevention Program (IIPP) and this SMS/ASP detailing the company’s processes and requirements for maintaining workplace safety and security, including Occupational Safety and Health Administration (OSHA) program requirements. This is also covered in our MTM Transit Employee Safety Manual. \Workplace Safety Program
To meet contractual and State requirements where we operate, MTM Transit has implemented a thorough pre-hire employee screening program to ensure only qualified applicants are hired.

In addition, MTM Transit has established training programs providing in-class activities, curriculums, manuals, lesson plans, field exercises, drills, computer-based training, written and video communications, and testing for vehicle operators, maintenance personnel, and frontline employees. We developed our training programs to address safety topics and concerns, which employees may face during their daily duties.

Categories of safety-related work which require training and certification include:

X New Employee Orientation and Training Programs, emphasizing:
o Hazard Communications Training
o Personal Protective Equipment (PPE) Training
o Bloodborne Pathogens
o Drug and Alcohol Abuse Policy
o Hazard Identification and Resolution Training
o SMS/ASP Training
o State or Federally Mandated Training
o Injury and Illness Prevention Training
o First Aid and CPR Training
o ADA Laws and Regulations Compliance
o Ergonomics Training
o Accident/Incident/Near Miss Reporting
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X Operator Training and Certification
o Transit and Paratransit Company (TAPTCO) Operator Training Program, which includes contract specific Operator Rules and Procedures and Supervisor Training X Maintenance Training, including Vehicle Maintenance
X Facility, Systems, and Equipment Maintenance
X Safety Rules and Compliance Program
X Security and Emergency Preparedness, which includes contract specific Emergency Operating Procedure Training and Emergency Response Training, as well as National Incident Management System (NIMS) and Incident Command System (ICS) training The training programs received by an employee depend on their job classification and responsibilities. The training programs include on-the-job training monitored by a Supervisor or mentor. Training efforts begin at the initial stages of employment and are continued periodically throughout an employee's career to maintain certifications and ensure the employee can perform their duties in a safe and efficient manner.

Employee Safety Training
A comprehensive employee/operator training program is essential to the successful operation of our clients’ services. Training programs developed by MTM Transit and associated subcontractors are used as the core training materials for our staff. Safety policies are covered in the TAPTCO operator training materials and our employee handbook, which are issued to all perspective operators as part of the training process. Documentation verifying each operator has received the training outlined in our program is retained and verified. All employees working in safety sensitive positions receive, at a minimum, instruction in the following areas:

X Requirements of MTM Transit’s SMS/ASP and the four Federal Transit Administration (FTA) “Moving Ahead for Progress in the 21st Century” (MAP-21) Public Transportation Agency Safety Plan (PTASP) elements as it relates to transit employees X Requirements of all Federal, State, and local law, codes, ordinances, and regulations as it relates to their positions
X Safe operation of in-service vehicles and associated equipment, including our Defensive Driving Course and On-Road Training and Wheelchair Lift Operation Training (to include operation of the lift if applicable)
o MTM Transit’s New Operator Training Program from TAPTCO includes 96 hours of minimum instruction with a minimum of 56 hours of training instruction in vehicles. This minimum hour threshold for instruction can be increased upon client request.

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o MTM Transit teaches defensive driving using the Look ahead, Look around, Leave room, and Communicate (LLLC) method.

X How to identify potential vehicle hazards through pre-operational and post-operational Daily Vehicle Inspections
X Procedures for handling and reporting in-service vehicle accidents and incidents involving clients and the public
X Procedures for handling and reporting roadside emergencies including Emergency Evacuation Training
X Proper documentation of activity within the system
X Passenger Assistance, Safety, and Sensitivity (PASS) Training concepts X Bloodborne Pathogen Training
X Lockout Tagout Training
X Hazard Communications Training
X Ergonomics Training
X Emergency Response and Emergency Preparedness Training X Emergency Response drills and simulations in conjunction with our clients and local emergency responders, as applicable
X Security Awareness Training from the National Transit Institute (NTI) Management team members are trained on managing the MTM Transit SMS and implementing locally to their facility. This training is conducted and documented annually and retained locally in the location’s training files.

Training is conducted through a combination of classroom and practical testing by a qualified instructor who evaluates students’ competencies. Upon completion of all training requirements, each prospective employee’s qualifications are evaluated and certified by the local Safety Manager or Safety Supervisor, prior to their first assignment operating in the system. A current copy of all certifications for instructors and operators is maintained by MTM Transit, as well as each individual service provider, and available for audit upon request.

MTM Transit conducts scheduled refresher training to review all subjects covered in the initial training, as well as how to continually avoid unsafe situations or practices. A Training Attendance Report on all refresher or remedial training provided to safety sensitive employees is documented.

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Drug and Alcohol Program
MTM Transit has a zero-tolerance policy for drugs and alcohol. The company’s program has been reviewed and approved by the FTA and is administered by a third party, Foley. As required by federal guidelines, MTM Transit’s drug and alcohol testing policy is compliant with 49 CFR Part 40 and 655 as amended, and the Federal Drug Free Workplace Act. It also:

X Defines the responsibilities of personnel
X Identifies the circumstances under which an employee may be tested for alcohol and/or drugs
X Includes the dangerous effects of controlled substances and the consequences of violating the policy
X Informs employees of the education and treatment program (rehabilitation program), which is available to employees requiring treatment or those who seek treatment voluntarily
X Requires all safety sensitive employees submit to random drug and alcohol testing X Requires all safety sensitive employees who have been absent from work for more than 90 calendar days submit to a drug and alcohol test and have a verified negative drug test result before returning to safety sensitive functions
X Requires all safety sensitive employees submit to drug and alcohol testing after being involved in an accident or incident which meets the FTA threshold for post-accident testing o Supervisors trained in post-accident procedures determine if an employee must submit to a post-accident drug and alcohol test.

MTM Transit’s zero-tolerance Drug and Alcohol Policy is available to all employees via the company intranet site or by contacting any Supervisor, Manager, or the People and Culture Department.

Hazardous Materials and Communication Program
Proper labeling, storage, and handling of hazardous materials is critical to maintaining safety throughout MTM Transit’s operations and services. Materials not labeled properly have the potential of being used and stored in combination with other incompatible materials, the results of which can be catastrophic. MTM Transit administers a hazardous materials program which applies to all employees and departments that buy, store, handle, and/or use hazardous materials.

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MTM Transit is responsible under the hazardous materials program to remain cognizant of the hazards and precautions associated with the hazardous materials bought, stored, handled, and/or used in the operation and maintenance of our services. Fulfillment of this responsibility is accomplished through:

X Training programs
X Review and distribution of Safety Data Sheets (SDSs)
X Review of container labeling
X Development of specification and procurement requirements X Development of hazardous substance lists
MTM Transit is also required to have and properly administer a procedure for reporting hazardous material accidents and incidents. MTM Transit ensures all personnel are informed regarding the hazards they may encounter in their work areas prior to the start of their initial assignments. These hazards include those presented by hazardous materials and substances.

MTM Transit’s department Managers and Supervisors determine the training requirements necessary to ensure employees can perform their duties in a safe and efficient manner. This training includes a discussion of the hazards presented by hazardous materials and substances, as well as the precautions and controls which must be taken or implemented to ensure safety when buying, storing, handling, and/or using the materials. Training is also provided to personnel who perform work on pipes and vessels, as well as to employees who perform hazardous or non-routine tasks, such as performing confined space entries. To facilitate the identification of training needs, site-specific hazardous substance lists are developed and maintained to track the quantities and locations of hazardous substances within the department.

MTM Transit maintains a formal process for reviewing and approving all chemicals and hazardous materials maintained by a department in which the material is stored, handled, or used, prior to their purchase. SDSs for all chemicals and hazardous materials are easily accessible to all employees and work areas.

Infectious Disease Exposure
MTM Transit continuously monitors and adopts guidelines and control measures recommended by the Center for Disease Control and Prevention, as well as local or State Departments of Health to minimize exposure to infectious diseases.

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SMS/ASP Review and Modification
As MTM Transit’s operations and services expand and change, so do the safety requirements associated with these operations and services. This SMS/ASP is considered a living document that is reviewed and updated annually to ensure it remains up-to-date and consistent with our operating, maintenance, management, and administrative rules, procedures, policies, and documents. This SMS/ASP is also reviewed to evaluate all tasks and identify new tasks that may be required as MTM Transit operations and services improve and expand; to refine and improve tasks, descriptions, and activities as necessary; and to identify those responsible for accomplishing newly added safety-related tasks and responsibilities.

This SMS/ASP is influenced through input received from employees, subcontractors, passengers, the public, emergency response agencies, and other State, Federal, and local regulatory agencies. Feedback is both welcomed and encouraged.

The Executive Safety Committee is ultimately responsible for initiating, developing, issuing changes, and gaining all approvals for this SMS/ASP. However, other stakeholders such as the MTM Transit Executive Team may recommend changes at any time. Personnel, including MTM Transit employees, may submit proposed changes to their respective Managers and Supervisors or directly to the Director of Safety Administration. If the Executive Safety Committee agrees the change is warranted, the change is incorporated into the annual review and revision cycle.

Safety Committees Used to Update Plans
For Small Urbanized Areas (population with fewer than 200,000 people), a transit agency must develop and update its SMS/ASP in partnership with front-line employee representatives. For Large Urbanized Areas (population with greater than 200,000 people), a transit agency in receipt of 5307 funding and serving a large, urbanized area must have a safety committee that is compliant with 49 U.S.C § 5329(d)(5). Any updates to the plan require partnership with the established Safety Committee. MTM Transit meets these safety committee requirements for each transit agency we operate; safety committees are used to update plans as necessary and/or when required.

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SMS/ASP Dissemination
Controlled copies of this SMS/ASP are disseminated to each MTM Transit location. The locations are responsible for reviewing and ensuring they possess the most current SMS/ASP and are also responsible for disseminating the SMS/ASP to their employees.

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Glossary
Accountability What an individual is required to achieve, directly or through those to whom the individual has delegated responsibility, regarding the operation of the Safety Management System (SMS)
Accountable
Executive
An individual identified within the organization with ultimate responsibility and accountability for the implementation and maintenance of the organization’s Safety Management System (SMS) Corrective Action
Plan
A plan developed to describe the actions to minimize control, correct, or eliminate hazards, which identifies the schedule and responsible parties for implementing these actions
Hazard Any condition or set of conditions, internal or external to the system or system operation which, when activated, can cause injury, illness, death, or damage, including loss of equipment or property, or severe environmental damage
Hazard Analysis Formal activities performed to analyze potential consequences of hazards during operations related to provision of services.

Hazard
Identification
Formal activities performed to identify hazards during operations related to provision of services
ISA Internal Safety Audit or Safety Audit
Location Each MTM Transit site or division providing service operations (We use this term and the term “division” to describe each of our MTM Transit locations.)
Management
System
An organizational structure and resources supporting data-based, strategic decision making by an organization’s senior management Passenger A person who is on board, boarding, or alighting from a transit vehicle for the purpose of travel
Public
Transportation
Agency Safety Plan
(PTASP)
Rule that requires certain operators of public transportation systems that receive federal funds under the FTA Urbanized Area Formula Grants to develop an Agency Safety Plan (ASP) that includes the processes and procedures to implement a Safety Management System (SMS), a comprehensive, collaborative approach to managing safety.

Responsibility Functions and duties describing the purpose of what an individual is required to do, regarding the operation of the Safety Management System (SMS)
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Risk Control Activities and resources to reduce or eliminate the effects of hazards Safety The state in which the potential of harm to persons or property damage during operations related to provision of services is reduced to and maintained at an acceptable level through a continuing process of hazard identification and safety risk management (also referred to as meaning “freedom from risk”)
Safety Assurance Processes within the SMS/ASP which function systematically to ensure the performance and effectiveness of safety risk controls and that the organization meets or exceeds its safety objectives through the collection, analysis, and assessment of information
Safety Culture
Process
A company safety program and safety process consisting of four key SMS/ASP elements from the Federal Transit Administration (FTA) helping ensure the company maintains a safe organization, protecting its employees and customers who use our services
Safety Deficiency A condition that is a source of hazards and/or allows the perpetuation of hazards in time
Safety Management
System (SMS)
The formal, top-down, organization-wide approach to managing safety risk and ensuring the effectiveness of safety risk controls; includes systematic procedures, practices, and policies for the management of safety risk
Safety Objective A high-level, global, generic, and non-quantifiable statement regarding conceptual safety achievements sought to be accomplished by an organization regarding its safety performance
Safety Performance An organization’s safety effectiveness and efficiency, as defined by safety performance indicators and safety performance targets, measured against the organization's safety objectives
Safety Performance
Indicator
A data-based, quantifiable parameter used for monitoring and assessing safety performance
Safety Performance
Monitoring
Activities aimed at the quantification of an organization’s safety effectiveness and efficiency during service delivery operations, through a combination of safety performance indicators and safety performance targets
Safety Performance
Target
A planned or intended, quantifiable improvement for safety performance indicator over a given period
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Safety Policy The public transportation system’s documented commitment to safety, which defines its safety objectives and the accountabilities and responsibilities of its employees regarding safety
Safety Promotion A combination of training and communication of safety information to support the implementation and operation of the SMS/ASP in the organization
Safety Risk The assessment, expressed in terms of predicted probability and severity, of the consequences of a hazard taking as reference the worst foreseeable, but credible, situation
Safety Risk
Evaluation
Refers to formal activities performed to determine safety risk probability and severity characteristics, such as the probability and severity of potential consequences of hazards, and to assess the tolerability of such consequences
Safety Risk
Management
A process within the SMS/ASP composed of describing the system, identifying the hazards, and analyzing, assessing, and controlling risk Safety Risk
Mitigation
Formal activities to control the probability and/or severity of the potential consequences of hazards during operations related to provision of services
Safety Risk
Probability
The likelihood a consequence might occur, taking as reference the worst foreseeable, but credible, condition
Safety Risk Severity The anticipated effects of a consequence, should it materialize, taking as reference the worst foreseeable, but credible, condition System Safety The application of operating technical and management techniques and principles to the safety aspects of a system throughout its life to reduce hazards to the lowest practical level through the most effective use of available resources
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Revision Record
Rev. # Date Page Section Notes

0.0 4/10/2019 Plan completed

1.0 5/12/2021 Plan updated per FTA guidelines

2.0 1/1/2023 Plan revisions per FTA guidelines

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Appendix A: State/Local Specific Addendums,
Attachments, and/or Plans
This area is reserved for State or local specific addendums, attachments, plans, etc. For example, MTM Transit’s SMS/ASP for Florida clients will include the State of Florida Minimum Safety, Operational, and Maintenance Requirements as required by the FL FAC 14.90 Rule. In this example, this Appendix will include a copy of MTM Transit’s compliant Florida System Safety Program Plan (SSPP), broken down by category requirement. As a further example, if MTM Transit has a contract in Florida for 5310 only, in this Appendix we will include what is required from the State Management Plan (SMP), such as a Transportation Operational Procedure (TOP).

Please note that State requirements do not conflict with parts of MTM Transit’s PTASP for each State. As needed, as will include any State requirements in the applicable PTASP sections as applicable.

ATTACHMENT 2

System Safety Program Plan (SSPP)
Prepared for
City of Manteca, California
2023
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Table of Contents
Section 1 – Introduction ..................................................................................................... 1 Executive Policy Statement......................................................................................................1 Authority .................................................................................................................................. 1 Scope........................................................................................................................................ 1 Goals and Policies .................................................................................................................... 1 Coordination ............................................................................................................................ 2 Section 2 – System Description ........................................................................................... 3 History and Background........................................................................................................... 3 Scope of Operation .................................................................................................................. 4 Organization and Structure......................................................................................................5 Equipment and Facilities.......................................................................................................... 8 System Modifications............................................................................................................... 8 Accident Investigation Training ............................................................................................... 9 Section 3 – System Safety Program ....................................................................................10 System Safety Organization ................................................................................................... 10 Personnel ............................................................................................................................... 11 Participation in Safety Teams and Boards ............................................................................. 11 SSPP Maintenance ................................................................................................................. 12 Employee Hiring Practices ..................................................................................................... 13 Notification of Vehicle Accidents........................................................................................... 16 Hazard Identification.............................................................................................................. 16 Security and Emergency Awareness...................................................................................... 20 Accident and Incident Investigations..................................................................................... 20 Safety Training ....................................................................................................................... 24 Safety-Related Operations Activities ..................................................................................... 26 Safety-Related Maintenance Activities.................................................................................. 29 Section 4 – Program Implementation and Maintenance .....................................................32 Internal Reviews..................................................................................................................... 32 External Reviews.................................................................................................................... 32 Collect and Maintain Data ..................................................................................................... 33 Professional Development..................................................................................................... 34 SSPP Implementation and Maintenance ............................................................................... 34 Section 5 – Certification.....................................................................................................36 System Safety Program Plan Certification Statement ........................................................... 36 Attachments ............................................................................ Error! Bookmark not defined.

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Section 1 – Introduction
Executive Policy Statement
MTM Transit is committed to providing safe, efficient, and courteous service to our customers.

To achieve the safest operating environment, MTM Transit establishes and maintains a safety policy stressing the importance of safety awareness throughout the organization. Our safety policy is presented in this System Safety Program Plan (SSPP).

Authority
I, Alaina Maciá, President and CEO, certify that this SSPP for MTM Transit will always be followed and fully enforced. I certify that all MTM Transit staff are fully aware of their responsibilities and their importance.

July 1, 2023
Alaina Maciá, President and CEO Date
Scope
MTM Transit's SSPP emphasizes that every employee is responsible for ensuring the safety of customers, employees, the public, contractors, and MTM Transit's property and fleet. The MTM Transit safety policy presented in this SSPP applies to all employees and to all MTM Transit vehicle activities, including but not limited to all operations; maintenance and support activities; and the design, construction, procurement, installation, and testing of equipment and facilities. MTM Transit's SSPP includes, but is not limited to, missions, responsibilities, rules, and procedures for a coordinated and comprehensive variety of safety programs developed to secure a systematic approach to transportation safety. Our SSPP also ensures all MTM Transit's safety responsibilities and tasks are documented in a logical and organized manner, and that programs are consistent with safety programs of transportation operators throughout the State of California.

Goals and Policies
MTM Transit's management is fully committed to developing, implementing, and updating clearly defined SSPP safety goals. SSPP safety goals provide direction to improve public safety by attaining a safe operating environment and reducing the number, rate, and severity of ATTACHMENT 2
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potential vehicle accidents. Our SSPP also provides procedures to measure the success of meeting established goals.

Safety goals are updated annually or as required based on system changes. All employees are actively encouraged to participate in developing and updating goals by presenting suggestions to the President/CEO and/or her designated representatives. The President/CEO has final approval of SSPP safety goals.

MTM Transit’s safety goals include, but are not limited to, the following:

X Reducing the number, rate, and severity of potential vehicle accidents X Attaining the safest possible operating environment
X Providing effective maintenance and preventative maintenance for all MTM Transit property in a timely manner
X Assigning each employee with responsibility for performing job functions in the safest possible manner
X Clearly defining employee safety roles and responsibilities X Continuously improving the skills and knowledge of all employees involved with the safety of the system through training and other means
X Continuously evaluating operations and procedures affecting system safety X Providing a system-wide safety policy that coordinates safety activities throughout the organization and ensures a systematic approach to managing safety hazards X Communicating appropriate safety policies and procedures to all employees and the public
X Interfacing effectively with appropriate government agencies, professional organizations, and citizen's groups regarding safety
Coordination
Our SSPP coordinates the safety activities of every department in the organization. Department responsibilities include, but are not limited to the following:

X The Operations department has a key responsibility in developing operating procedures for incidents and emergency situations.

X Administration has a key responsibility in coordinating SSPP activities and communicating and overseeing policies.

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Section 2 – System Description
History and Background
MTM Transit is a limited liability company (LLC) and certified woman-owned business enterprise (WBE) established in 2009 in the State of Missouri by the leadership of Medical Transportation Management, Inc. (MTM), a national leader in non-emergency medical transportation management. MTM Transit’s principal line of business is providing Americans with Disabilities Act (ADA) paratransit, fixed route, and microtransit service operations, as well as additional transit services such as mobility management, ADA paratransit eligibility assessments, travel training, transit call center operation, and transit quality assurance operations and support.

Access to local resources and amenities are important components of a healthy, productive life, and MTM Transit provides that access with the utmost dignity for every passenger. We are dedicated to offering a balance of innovation and best practices during this new era in transportation, deploying executive attention, technological advances, and responsiveness to maximize program success.

MTM Transit delivers cost savings, increased efficiencies, and customer satisfaction to clients and passengers across the United States in 16 states and the District of Columbia. We administer annual budgets of more than $27 million and serve a ridership of approximately 3,000 passengers per day by providing over 1.7 million trips per year. Having the support of our affiliate MTM, as well as a respected and practiced leadership team, makes MTM Transit well qualified to meet the paratransit transportation needs of Manteca residents.

To serve the City, MTM Transit employs the following positions:

X 3 managers, including a Safety and Training Manager
X 13 FTE operators (both full- and part-time)
X 1 road supervisor
X 3 dispatchers (1 lead, 1 full-time, and 1 part-time)
X 1 utility worker
The business address and telephone number for the local MTM Transit office is:

MTM Transit (at the Manteca Transit Center)
220 Moffat Boulevard
Manteca, CA 95336
(209)0456-8888
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Scope of Operation
This section covers the type of service provided by MTM Transit, as well as our operating routes, schedules, and safety-related maintenance requirements. \Scope of Transportation
MTM Transit operates the Manteca Transit system for the City, providing public fixed route bus services, as well as the Dial-A-Ride (DAR) and ADA paratransit vehicle service. Our service also includes in-house vehicle cleaning of the City vehicles used for Manteca Transit, while most of the vehicle maintenance is outsourced to Sunshine Auto Care, Inc., which is fully staffed with ASE-certified technicians and equipped with the tools and equipment needed to maintain and repair the City’s transit vehicles. Their facility is less than one mile from the Transit Center making it a cost-effective and efficient option for the program.

Vehicles used in the program include:

X 9 cutaway vehicles
X 1 35-foot fixed route bus
These vehicles include both ADA accessible and ambulatory vehicles, as outlined by the City. All vehicles are equipped with a two-way radio system connecting them with the dispatchers.

Maintenance Rules and Procedures
MTM Transit is committed to providing and following operating and maintenance procedures that promote system safety. We comply with all Federal, State, and local requirements regarding vehicle and property maintenance; we also ensure our maintenance subcontractors comply with these same requirements.

MTM Transit follows service standards prescribed by the vehicle manufacturer. The City vehicle maintenance guidelines are followed for inspection of all vehicles. Preventative Maintenance (PM) inspections are conducted at least every 45 days or 3,000 miles, or the manufacturer’s suggested mileage (whichever is less). As required, the service schedule is changed to fit those vehicles involved in extra heavy or extra light usages.

Maintenance replacement standards comply with those prescribed by Federal Department of Transportation (DOT) guidelines, which are checked annually by California DOT inspectors. All ATTACHMENT 2
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work is done by qualified maintenance technicians at off-site locations by private maintenance service facilities; most vehicle maintenance is outsourced to Sunshine Auto Care, Inc.

Daily pre- and post-trip inspections are performed by the operators in accordance with MTM Transit policy, as well as the City and California guidelines. Procedures include, but are not limited to, the following:

X An inside check of all exits, safety equipment, seats, and gauges X An operational check of all switch-operated items
X An outside check of the vehicle exterior, including all lights, tires, and mirrors The operator’s daily pre- and post-trip inspection report is completed and kept on file for one year.

Vehicle Operator Training Requirements
MTM Transit recognizes the importance of vehicle operator training for system safety. We follow all Federal, State, and local training requirements.

Additionally, all operators are licensed in accordance with the State regulations of the vehicle type they operate.

Forms used to assess required operator qualifications and skills include, but are not limited to, the following:

X Application
X Annual Physical Authorization Form
X Annual Operator Evaluation (including applicable road tests) Organization and Structure
Every employee and department of MTM Transit is expected to contribute to the safety of passengers, employees, and the public, as well as the prevention of property damage. All MTM Transit employees and departments are responsible and accountable for preventing accidents and conducting job functions safely. All employees and departments must comply with all applicable occupational safety operations standards, rules, and instructions pertaining to their job functions.

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\Structure of Organization
MTM Transit is comprised of management, supervisors, safety personnel, dispatchers, maintenance personnel, and operators. Our organizational chart structure is as follows:
\Function Safety Responsibilities
Management
The President/CEO has overall responsibility for establishing a company-wide commitment to safety and for operating and maintaining a safe transportation system. Local management works with the President/CEO to develop, communicate, implement, and update system safety goals. Local management is also responsible for:

X Incorporating safety awareness into all management decision-making activities X Ensuring that all MTM Transit policies are in accordance with safe operating procedures X Establishing, enforcing, assessing, and improving the overall safety program, safety program procedures, and processes for communicating safety policies and procedures X Investigating unsafe practices
X Ensuring that sufficient resources are available to implement safety-related activities (e.g., training, hazard resolution, and monitoring results) Supervisors, Safety Personnel, and Dispatchers
The safety responsibilities for supervisors, safety personnel, and dispatchers include, but are not limited to, the following:

X Ensuring operators are informed about all relevant information (e.g., road closings, vehicle changes, and schedule changes)
X Reporting accidents and incidents to management and the corporate safety function X Informing management of any system interruption that requires vehicles to be rerouted Management
Supervisors,
Safety,
Dispatchers
Maintenance Operators
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X Distributing safety correspondence, as required
X Investigating customer complaints
X Assisting in completing accident reports, as required X Implementing disciplinary actions when operating procedures or safety regulations are not followed
X Assuming emergency response responsibilities when management is not available Maintenance
Staff responsibilities for those involved in maintenance and facility safety include:

X Developing, following, assessing, and improving maintenance safety procedures X Ensuring MTM Transit has the number of vehicles required to provide daily service and that vehicles are in good repair
X Conducting scheduled operations (e.g., Preventative Maintenance) X Checking parts and components that may experience abnormal usage X Investigating and correcting maintenance problems identified by other functions of the organization
X Maintaining safe work area conditions
X Wearing all necessary protective equipment
X Ensuring that tools and equipment are properly maintained and in a state of good repair Operators
Operator safety responsibilities include:

X Adhering to all operating rules and regulations, including safety procedures X Conducting an appropriate pre-trip inspection to ensure the vehicle assigned is in proper operating condition, and that all mechanical defects are identified and reported before the vehicle is placed in service
X Conducting a post-trip inspection upon return to the location and reporting relevant information as appropriate
X Maintaining control of the vehicle and conduct on the vehicle X Reporting relevant information to the supervisors and dispatchers, including:
o Accidents and incidents
o Vehicle defects that may cause a service interruption o Customer disturbances or illnesses
o Route interruptions (e.g., detours)
X Complying with all MTM Transit and client accident reporting procedures following an accident
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X Complying with all MTM Transit and client fitness-for-duty drug and/or alcohol testing procedures
\Safety Change Recommendations
Every department within MTM Transit is encouraged to request changes which may improve safety conditions. Every employee is encouraged to bring recommendations regarding safety changes to the attention of their supervisor or a member of the local management team at their earliest convenience.

Employees who observe a potentially unsafe operation or condition are expected to bring the situation to the attention of their supervisor or a member of the local management team at their earliest convenience. Any employee involved in an accident is required to comply with MTM Transit’s reporting requirements. The safety personnel and management analyze accident reports to determine safety changes that may be required.

Equipment and Facilities
Equipment and facilities contribute to the safety of passengers, employees, and the public.

MTM Transit puts safety first when choosing vehicle stop locations and routes. Routes avoid dangerous locations and other safety hazards, such as backing up, to every degree practical.

Dispatchers are assigned to an office within the main building. Dispatchers are in contact with all operators through a two-way radio communication system.

All appropriate emergency numbers and copies of emergency procedures are provided to the dispatcher. A multi-line phone system is located next to the two-way radio.

All vehicles in the fleet meet or exceed State and Federal DOT standards. Two-way radio communications systems are installed in all vehicles. Safety equipment on each vehicle includes, but is not limited to, one five-pound BC fire extinguisher, one First Aid Kit, and one set of triangle reflectors.

System Modifications
Ongoing or planned activities to modify the system must consider safety. When modifying or improving existing facilities, management ensures that all applicable safety requirements are addressed and included in drawings, specifications, or plans for modification.

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When reviewing engineering changes, MTM Transit:

X Follows rules and procedures on incorporating changes and modifications into the system
X Follows procedures to evaluate the effect of the changes on safety X Reviews and upgrades safety analyses as required in evaluating system modifications Preventative Maintenance (PM) inspections are conducted at least every 45 days or 4,000 miles, or the manufacturer’s suggested mileage (whichever is less). In the event increments need to be adjusted, we will notify the City with written notice and discuss in further detail.

Accident Investigation Training
Each MTM Transit General Manager attends a Bait Fish Training Program to ensure one staff person at each location is certified in a comprehensive accident investigation.

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Section 3 – System Safety Program
System Safety Organization
MTM Transit has appointed a Safety and Training Manager who reports directly to the General Manager and has ultimate responsibility for safety. Their responsibilities include ensuring operators stay current with their safety training.

In addition to overseeing safety for the City, the Safety and Training Manager's responsibilities include assisting the General Manager with the following tasks:

X Investigating all accidents that are required by regulation to be reported to the City and the California DOT, including, but not limited to:
o All fatal accidents
o Accidents that result in five or more injuries
o A fire onboard a revenue vehicle to which emergency services respond o All accidents caused by mechanical failure
X Ensuring hazard assessments and appropriate resolution processes are initiated once an unsafe activity or situation is identified that presents a potential or actual hazard X Investigating all work-related employee injuries, especially those that may require immediate hospitalization, or result in disability or death X Evaluating health and safety issues on an ongoing basis to identify unfavorable practices and conditions that may require correction
X Incorporating safety constraints and preventative procedures into daily operations X Promoting system safety coordination to ensure that relevant safety information is communicated to all departments and personnel
X Assisting management and employees in the development and implementation of safety rules and procedures and emergency preparedness plans X Assisting in conducting safety inspections and performing system safety audits to monitor system-wide compliance with the SSPP
X Supporting management to ensure the SSPP is updated on an annual basis X Providing SSPP information to newly hired employees
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Personnel
The local management team includes the following individuals:

Name Title/Position
Mark Frailey General Manager
Francis Kemp Safety and Training Manager
Adam Perriera Maintenance Manager
Our local management team is supported by the following corporate support individuals:

Name Title/Position
Alaina Maciá President and CEO
Kerri Mileski Chief People Officer
Brian Balogh Chief Operating Officer
Scott Transue Regional Vice President
Monique Avalos Director of Safety Administration
Joe Sullivan Regional Director of Maintenance
Pat Lopez Director of Transit Technology
Ben Schandle Regional Director of Sales
Participation in Safety Teams and Boards
The commitment of MTM Transit's President/CEO and General Manager ensures that safety remains a vital concern at all MTM Transit meetings. The General Manager personally represents MTM Transit in local, State, and national safety organizations and committees, ensuring commitment to state-of-the-art safety ideas.

Safety team responsibilities, including overseeing the identification, assessment, and resolution of actual or potential hazardous occurrences, are assigned to the General Manager and the Safety and Training Manager. These responsibilities include, but are not limited to, the following:

X Performing ongoing reviews of safety rules and procedures X Modifying current procedures, developing new procedures, and/or establishing new procedures, as required
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X Reviewing and approving safety ideas submitted from employees, contractors, vendors, and other sources
X Monitoring compliance with the SSPP and other safety requirements X Overseeing the publication and distribution of new or modified safety rules, policies, and procedures
X Analyzing accident trends, if any, pertaining to workplace injuries or on-road vehicle operator accidents
X Performing safety observations, whether announced or unannounced, including but not limited to:
o Actions of employees, contractors, and vendors
o Personal protective equipment (PPE)
o Tools and equipment
o Procedures
X Distributing safety bulletins
X Overseeing safety training
X Reviewing SSPP requirements for contract service providers, as required X Monitoring the condition of the building, facilities, and equipment X Coordinating recommendations resulting from investigations to prevent recurrences of hazardous conditions
Additionally, MTM Transit safety committees receive assistance as required from other sources.

For example, insurance company safety engineers assist in safety training and programs for all employees.

SSPP Maintenance
MTM Transit recognizes the importance of systematically reviewing, updating, and refining the SSPP. Unless otherwise required, this plan will be revised biennially. This plan may also be revised to respond to priority needs or critical events, as determined by the President/CEO.

Approved revision submissions are certified by top management. The refined plan is submitted for recertification and the number of accidents reported to the City for National Transit Database (NTD) reporting.

The internal review of the SSPP includes, but is not limited to, the following:

X Number of passenger fare vehicles
X Vehicle replacement information
X Corporate structure
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X Number of personnel
X Changes in policies, procedures, and practices
X Changes in facilities
X Reportable accidents
X Number of accident occurrences reported to the City for NTD reporting Management is responsible for distributing and communicating changes in the SSPP to all MTM Transit departments in a timely manner. Procedures to update the SSPP as required for priority/critical items and events, to control revisions, to coordinate revisions to the SSPP within the MTM Transit property, and to distribute changes to the SSPP are provided in this program.

Employee Hiring Practices
MTM Transit selects employees with the best job-related qualifications. Employees are selected without regard to race, color, religion, sex, national origin, age, marital status, handicap, disabled veteran status, Vietnam veteran status, or sexual preference, where prohibited by applicable State or local law. All employment-related policies, procedures, and actions are designed to comply with applicable laws.
\Procedures
MTM Transit has developed clear hiring policies. Safety qualifications are incorporated into job requirements for all positions. The safety history of applicants is reviewed prior to hiring.

Employment is contingent upon receipt by MTM Transit of satisfactory references, which may include proof of licenses, degrees, satisfactory driving records, and other documentation. Each current hire has a two-year minimum employment record. All current employees of MTM Transit have been hired from related companies.

MTM Transit’s hiring procedures also include, but are not limited to, the following:

X Compliance with all Federal, State, and local guidelines regarding approval for positions such as vehicle operators (e.g., infractions on operator records that may be sufficient cause to decline approval for such operators may include no more than four points on a driving record and no drug or alcohol conviction within the past five years) X Checking references from the applicant's three most recent employers within the last ten years
X Storing replies from references in the new employee's personnel file ATTACHMENT 2
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Minimum Qualifications for Operators and Other Employees To protect the interests of MTM Transit and the privacy of employees, background investigations of individuals applying for safety sensitive and other positions follow all applicable laws.

All MTM Transit employees are important to ensuring safety within our organization. It is especially important that operators and safety sensitive employees meet or exceed all requirements set by Federal, State, and local authorities prior to being hired.

All operators must meet all qualifications stated above, as well as the following requirements:

X A valid California Class “B” driver’s license and medical card X Verification of Transit Training Certificate issued by the DMV, pursuant to Section 12804.6
X A California General Public Paratransit Vehicle (GPPV) certificate issued by the DMV X Pre-employment DMV checks and a DMV re-check at least every six months to determine and ensure a satisfactory driving record
X Complete MTM Transit’s extensive training program
Newly transferred employees and new hires receive safety training and safety policy briefing during the orientation process. Operators are required to attend a pre-service classroom program to review driving safety, passenger safety, and MTM Transit policies. New hires sign a receipt acknowledging they have received and read all appropriate MTM Transit policies and rules.

ADA training takes place with all employees and includes, but is not limited to, the following:

X Titles of the ADA
X Person with a disability ADA definition
X Basic purpose
X What the ADA addresses
X Access to communication and information
X Employee training
X Boarding/alighting time
X Lift and securement use, including the use of securements per company policy on all wheelchairs
X Maintenance of lifts, including that all those who request the lift may use it X Mobility aids and life support systems
X Additional charges
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X Refusing service to customers with disabilities
X Providing priority seating
X Permitting riders to disembark
X Announcement of stops
X Identifying vehicles and/or customers
Ongoing Requirements
Employee performance is continuously reviewed for compliance with job requirements.

Operators are required to maintain a current driver’s license and to show it upon request, as required.

Physical, mental, and skill exams are administered, in accordance with Federal and State regulations. Drug and alcohol testing are performed in accordance with State and Federal laws.

MTM Transit complies with the FTA requirement to randomly drug test 50% of the safety sensitive workforce annually and to conduct annual random alcohol tests of 10% of the total workforce.

Employee records of preventable accidents and/or incidents on the job are reviewed.

Additional training is initiated as required. All employees are expected to ensure that the property conforms to the local and State requirements.

Substance Abuse Programs
MTM Transit does not tolerate employee drug or alcohol abuse. We monitor drug and alcohol abuse in accordance with Federal DOT guidelines. MTM Transit requires pre-employment drug and alcohol tests. Employees are also required to take an annual drug and alcohol test.

Monitoring is also done for reasons including, but not limited to, the following:

X Random testing
X Reasonable suspicion
X Post-accident
MTM Transit does not allow a "second chance" regarding substance abuse that can affect safety. USDOT/FTA regulations regarding a four-hour minimum time between alcohol use and driving time are strictly adhered to. Employees suspected of abusing drugs or alcohol are interviewed, tested, and if circumstances warrant, given a reasonable suspicion test, which could result in termination if positive for prohibited substances or alcohol.

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Notification of Vehicle Accidents
MTM Transit gives the City immediate notice and written notice, as further detailed in this policy, of the following accidents:

X All fatal accidents
X Any accident which results in five or more injuries to persons involved in the accident X All accidents caused by mechanical failure, including, but not limited to, all fires that occur in revenue service that require passenger evacuation and response by a fire department regardless of whether injuries were incurred Immediate notice of the above occurrences is also reported by telephone to MTM Transit claims reporting at 563-585-8856 or Weekends/Afterhours 877-241-6121. Immediate notice of all said accidents is required, and such notice is not delayed for more than 90 minutes. These notices, at a minimum, include the date, time, and location of the occurrence and the approximate number of persons killed or injured. The person making the notification provides their name and title, the public transportation system or service involved, and states where they can be reached for further details. In addition, the person making the notification also supplies any additional information requested. MTM Transit ensures all physical evidence of the accident scene is properly documented prior to the scene being cleared.

Hazard Identification
MTM Transit performs hazard analysis to identify hazardous conditions that may be eliminated or controlled. Potential hazards are systematically identified and assessed to determine their impact on the total system. Determinations are made regarding the extent of corrective measures to eliminate the hazard or reduce its severity. \Safety Problem Identification
The identification of hazards that may potentially result in accidents is the first step in a proactive safety program. MTM Transit's hazard resolution process provides plans and procedures to identify and manage hazards. The process identifies and analyzes safety issues for the purpose of determining hazard severity and probability, recommending corrective actions, and documenting results.

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The hazard identification process is initiated through any of the following ways:

X Customer Concerns. Customer safety concerns regarding operator performance, service, or equipment are recorded. Concerns are reviewed and reported to the General Manager. Resolutions are explored.

X Employee Observations. Any employee who observes any current unsafe condition is responsible for notifying their supervisor or a member of the local management team regarding concerns at their earliest convenience.

X Internal/External Audits. Findings of audits conducted by and for MTM Transit are monitored and communicated to the responsible department.

X Unusual Events. Management is responsible for initiating responses to unusual events that occur within the facilities or vehicle system.

X Legislative Requirements. The General Manager monitors legislation pertaining to safety and informs appropriate departments as required.

X Industry Trends. Each department is responsible for analyzing industry trends that may be related to internal hazards.

X Safety Team. Team members are responsible for conducting safety observations and monitoring corrective action regarding observed hazards or safety compliance.

In addition to the hazard resolution process, ongoing operations are monitored and reviewed, equipment is inspected and analyzed, and operating procedures are analyzed to identify potential safety problems. Hazards that are identified are described on the Hazard Assessment Form. \Hazard Assessment
Hazard probability ratings on the Hazard Assessment Form are defined based on the following chart:

Description Level Specific Individual Item Fleet or Inventory Frequent A Likely to occur frequently Continuously experienced Probable B Will occur several times in the life of
an item Will occur frequently
Occasional C Likely to occur sometime in the life of
an item Will occur several times
Remote D Unlikely but possible to occur in the
life of an item
Unlikely but can reasonably
be expected to occur
Improbable E So unlikely that it can be assumed
occurrence may not be experienced Unlikely to occur, but possible ATTACHMENT 2
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Hazard severity ratings on the Hazard Assessment Form are defined based on the following chart:

Hazard Risk Matrix
Probability of
Occurrence
Severity of Occurrence
Category 1
Catastrophic
Category 2
Critical
Category 3
Marginal
Category 4
Negligible
A – Frequent 1A 2A 3A 4A
B – Probable 1B 2B 3B 4B
C – Occasional 1C 2C 3C 4C
D – Remote 1D 2D 3D 4D
E – Unlikely 1E 2E 3E 4E
Hazard Risk Index Criteria by Index
1A, 1B, 1C, 2A, 2B, 3A Unacceptable
1D, 2C, 2D, 3B, 3C Undesirable – Management Decision Required 1E, 2E, 3D, 3E, 4A, 4B Acceptable With Management Review 4C, 4D, 4E Acceptable Without Review
\Hazard Analysis And Resolution
MTM Transit has established methods to develop and implement resolution alternatives.

Decisions regarding how to resolve hazards are made once the Hazard Assessment Form has been used to establish frequency and severity of the problem, all aspects of the problem are reviewed, key individuals are consulted, and an assessment is made of the involved risk. The Hazard Assessment Form is used to establish priorities of corrective action and problem resolution.

Methods to develop and implement resolution alternatives include, but are not limited to, the following:

X As soon as a potential or actual hazardous condition is reported by an employee, customer, or other source, the department head responsible for the equipment, facility, or environment subject to investigation is immediately notified.

X If, in the best judgment of the responsible party, a hazard exists that requires urgent attention, immediate action is taken to dispose of the hazard.

X A hazard assessment is forwarded to the General Manager or their designated representative to justify decisions or actions taken or suggested to be taken regarding any hazards or reports of hazards.

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X In most situations, resolutions to problems are developed with the cooperation of the department manager or supervisor presenting the problem, a member of the local management team, and other individuals as required. Examples of recommendations include, but are not limited to, the following:
o Repair or replacement of vehicles
o Route changes
o Retraining
o Corrective action for an employee
X Hazard assessment reports and resolution priorities are evaluated by the General Manager or their designated representatives. Recommendations may range from "Immediate Resolution Required," to "Resolution Required Within 24 Hours," to "Resolution Required Within One Week of Notification,” to "Conditionally Acceptable." If at any time the General Manager does not concur with the hazard assessment or action taken, they make the final determination regarding the disposition of the hazard.

X When evaluating assessment reports, the impact on safety resulting from implementation resolution alternatives are assessed. The effects of the implemented resolutions are assessed also for further action.

X The safety team is responsible for coordinating all corrective action implementation.

X Follow-up is conducted to ensure that work is completed on all implemented resolutions. The safety team is responsible for overseeing the follow-up process.

X Hazard assessment reporting information is reviewed monthly. Trend analyses of all reported potential hazards, incidents, or accidents are also performed monthly.

Additional Hazard Assessment and Resolution Procedures
In addition to the methodology described above, other procedures for hazard assessment and resolution have also been established. These procedures include, but are not limited to, conducting:

X Daily inspections of work areas
X Weekly inspections of fire panels, sprinkler control valves, and standpipes X Monthly inspections of lifts, jack stands, electrical disconnects, service panels, safety interlocks, first aid stations, and general housekeeping ATTACHMENT 2
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Security and Emergency Awareness
While many of the emergency preparedness plans include information of a confidential and security sensitive nature, some of the elements are as follows:

X Vulnerability self-assessment is completed on the FTA website questionnaire.

X Employee awareness training is provided by our staff. Training includes all the elements of System Security and incorporates the National Transit Institute (NTI) videos “Warning Signs” and “The Mark” as training tools.

X Documents that are of a security sensitive nature are marked as such to limit access.

X The corporate and local staff receives FTA and Department of Homeland Security (DHS) alerts from the automated system on a regular basis as they are issued.

X The local staff are active members and available to participate in local emergency preparedness plans, drills, and activities with all local emergency agencies.

Accident and Incident Investigations
In the event of any accident, post-accident, or incident, investigations are initiated by management as part of the hazard resolution process. The accident investigation plan is tied into the accident prevention program. The General Manager is ultimately responsible for both programs. Equipment used for accident/incident investigations includes cameras, recorders, witness forms, and checklists. Results and recommendations of accident/incident investigations are distributed to all relevant personnel for review and comments. \Company Accident Record
MTM Transit's goal is to remain accident free. The number of accidents has been in the single digits to date and remains so currently. Below is an example of accidents reported for a typical year:

X Accidents = 0
o Reportable to NTD = 0
o Reportable to DMV (more than $1,000) = 0
o Reportable to Insurance Company (less than $1,000) = 1 ATTACHMENT 2
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\When to Complete Reports
An accident report must be completed when:

X A vehicle is involved in a collision with another vehicle, a stationary object, or a pedestrian
X A customer falls while boarding, alighting, or outside the vehicle X A pedestrian collides with a vehicle
X A customer is injured because of vandalism to the vehicle X An operator is hurt while operating the vehicle or while in the vehicle An incident report must be completed for:

X Miscellaneous incidents such as fires
X Police assistance required on or near the vehicle
X Vandalism on the vehicle that does not cause injury
X A customer becomes ill on the vehicle and requires assistance \How to Inform the DOT About Accidents
The operator retains an Accident Register, including any accident information required, as per DOT regulations 390.15.
\Reporting Work Related Accidents
An employee who sustains an injury because of their employment is responsible for:

X Reporting the accident or injury immediately to their supervisor o If the nature of the injury requires immediate emergency medical treatment, the employee's supervisor calls for immediate assistance.
o Based on the seriousness of the accident, the dispatcher notifies emergency personnel of the situation.

X Reporting for first aid treatment, if required
X Completing an MTM Transit Worker's Compensation Report of Injury Form within 24 hours of the accident or injury, as appropriate
o If the employee is unable to complete the form, their supervisor is responsible for its completion.

X Cooperating in all aspects of their medical treatment to ensure the employee can return to work as soon as it is medically feasible
Once the form is complete, the employee's supervisor is contacted to investigate the circumstances that caused the accident or incident. Depending on findings, recommendations ATTACHMENT 2
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from management may include that the employee receive safety counseling and/or that they contributed to the cause of the accident.
\Operational Accident/Incident Investigations
In the event an employee is involved in an accident while operating a revenue or non-revenue vehicle, the employee is responsible for the following:

X Reporting the accident or incident immediately to the dispatcher and advising the dispatcher if medical assistance is required at the scene o If the radio is not working, the employee uses a public telephone to call the dispatcher.

X Ensuring that any vehicle involved in an accident (other than a negligible incident) is not moved until police or an MTM Transit representative arrives to give authorization to move the vehicle
X Ensuring that no statements are made except to police or vehicle representatives X Securing reports from witnesses to the accident
X Remaining on the scene until the vehicle is released by the police or MTM Transit management
X Complying with FTA/USDOT drug and alcohol testing
X Making a full report of the accident after returning to the office o The report must be signed and dated, with facts plainly indicated. o If circumstances (e.g., injury) prevent an employee from personally reporting an accident, the employee's supervisor ensures that a report is completed.

The employee's supervisor is responsible for:

X Reviewing the accident report for all relevant documentation and determining if the accident was preventable or non-preventable
X Forwarding the accident report and all relevant documentation to the General Manager to independently determine if the accident was preventable or non-preventable, and actions that should be taken
\Performing Scene Investigations
Scene investigations are required for all accidents except those with negligible results. Scene investigations include, but are not limited to, gathering reports, taking pictures, developing scene layouts, and cooperating with government agencies as required. Operators assist with passenger stabilization, develop scene layouts, identify witnesses, and assist policy officers, as required.

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Hazard Assessment Forms are completed. Accidents are reviewed by MTM Transit officials and safety representatives from appropriate insurance companies. Accidents are assessed and analyzed, and resolutions are generated and prioritized. Drafts of suggested resolutions are distributed to appropriate departments. Final resolutions are made.

Depending on the findings of post-accident reviews, operators are provided with additional training in operator safety and education, and/or other appropriate actions are taken in all relevant departments. Follow-up checks are performed to determine the effectiveness of the recommendations, and provisions are made to amend or revise recommendations and the accident/incident investigation plan. The investigation is tied into the accident prevention program and the report becomes part of the safety data file. \Analysis of Accident Reports
Data analysis of accidents and property loss are performed by management and reported on a regular basis; these reports include cost, injury, and lost workdays. These metrics are reported on a quarterly basis, at a minimum. Management reviews of accident and incident recommendations take place in a timely manner.

If an accident, incident, workplace injury, or potential hazard occurs, a hazard assessment report is completed, and resolution priorities are evaluated. Recommendations may range from "Immediate Resolution Required," to "Resolution Required Within 24 Hours," to "Resolution Required Within one week of Notification," to "Conditionally Acceptable." The General Manager circulates the report to any other departments that are affected for comments. The affected departments either indicate agreement with the recommendations that are proposed or provide comments to facilitate corrective action. The General Manager has final approval of the corrective action plan.

All investigations and reports are completed within seven days of any accident, incident, or workplace injury that may result in death or disability, require hospitalization, or, in the judgment of the General Manager, require an investigation. All other investigations and reports are completed within two weeks. Required corrective actions are implemented.

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\Safety Data File
Accident and incident investigation reports and/or recommendations are part of the safety data file. Records are maintained in accordance with Federal and State laws. Reports are retained for periods in conformance with local, County, State, and Federal regulations. Records are readily accessible to those who are required to have access to them. \Previous Investigation Records
Previous investigation records meet the following requirements:

X Previous investigations are fully documented and include recommendations to management. The cost of the accident is analyzed and categorized. Accident recommendations are prioritized. In the case of an accident, the operator's record is reviewed, causes are determined, and the operator is debriefed.

X Recommendations are implemented or a rationale is provided as to why not.

X Follow-up checks are made to determine the effectiveness of the recommendations.

X Provisions are made to amend or revise the accident/incident investigation, as required.

Safety Training
The local management team is responsible for establishing guidelines and developing and conducting training to all employees, as appropriate. The safety team evaluates the development of training activities that impact safety and provides the final approval to conduct training.

All training is done in conformance with State regulations and laws. Training is provided individually and/or in group sessions. Required and needed training in the classroom and/or on a vehicle is provided by certified instructors. Training is provided in the timeframes required by law and when deemed appropriate by management. The training program plan is reviewed biennially, or as required by property condition. Required introductory and refresher classroom sessions are given by certified instructors.
\Documentation
As part of the training program, students are provided manuals, safety rules, and a rule book, as appropriate. To satisfactorily complete the training, students must demonstrate familiarity with safety rules and demonstrate familiarity with procedures to identify, assess, and report hazards.

Following training, feedback is elicited from students regarding the effectiveness of instruction.

MTM Transit records the number of students who complete and do not complete training, and ATTACHMENT 2
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the reasons why students do not finish. The General Manager conducts periodic audits to establish the quality and effectiveness in meeting safety-related goals and objectives. \Training Requirements for Operators
Training requirements define the scope of the program, both for in the classroom and on the road. Training orientation requirements for operators include a general orientation program with the property. Familiarity with the properties, facilities, and local area is also required.

Training includes roads and route training, applicable map reading, and the location of local medical, police, and fire facilities. Trainees are required to undergo route training to destinations and points of common interest. Route training includes first driving the route without passengers, and then driving the route with passengers. An operator trainer is in attendance during route training activities.

Safety is a part of the overall training program. With responsibility for both training and safety, the local management team ensures that safety training is initiated into the overall training program.

Instructors meet selection standards, including safety training. Standardized lesson plans include training requirements. The role of safety in the overall organization and management's attitude and policy toward safety are made clear.

Operator training encompasses all applicable Federal, State, and local safety rules and regulations. Instruction on the operation of safety-related equipment includes, but is not limited to, the following topics:

X The safe operation of:
o Doors, door interlocks, and other safety features
o Wheelchair lift and its safety features, as applicable o Brakes and safe acceleration and deceleration rates
o Mirrors, sun visors, and wipers
o Vehicle communication system (e.g., radio)
X Passenger safety, which includes knowledge of onboard causes of accidents and injuries, safe acceleration and deceleration rates, and sensitivity to the physical limitations of disabled persons and the elderly
X Emergency standard operating procedures, which includes, but is not limited to, training for:
o Traffic accidents
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o Collisions with fixed objects
o Onboard fire or smoke
o Passenger injury or illness
o Onboard theft, fight, or improper conduct
o Snow, flooding of route, and severe weather
o Odor of raw fuel fumes
o Use of appropriate safety equipment (e.g., accident kits) X Formal defensive driving techniques
MTM Transit also posts safety bulletins and has frequent safety discussions. Newly assigned vehicle operators and new hires receive safety training prior to performing the job. Retraining procedures are in place for operators.

Additionally, the local staff participates in maintenance training when new equipment is brought onboard, whenever possible.
\Evacuation Training
All operators are trained in the evacuation of a vehicle in an emergency. Qualified instructors teach operators how to properly evacuate passengers from a vehicle in a safe and orderly fashion.

Training includes safety video and safety meetings with group discussions. To ensure that operators are prepared for vehicle evacuation, prior to each vehicle going into service a pre-trip vehicle inspection is completed by each operator to be certain that all emergency equipment is in safe operating condition.

Safety-Related Operations Activities
MTM Transit recognizes that the environment in which the vehicle operates plays a significant role in the number and types of accidents. Heavy traffic conditions, poor roads, cold and icy winters, and narrow thoroughfares are all situations which the operator must deal with. A poor environment can create conditions which lead to a high frequency of non-severe accidents and mechanical failures, which can prove costly to the system in the long run.

Passenger acceptance of the system can degenerate. The public's opinion of the transit system can also be harmed because of accidents relating to a poor environment. All facets of the ATTACHMENT 2
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operating environment are explored thoroughly and a means to deal with them are identified in the SSPP.
\Operator Safety Responsibilities
MTM Transit has a policy regarding safety responsibilities of the operations/transportation department. As described previously, this policy includes the responsibilities for the supervisors, safety personnel, dispatchers, and operators. Operator safety responsibilities include:

X Adhering to all operating rules and regulations, including safety procedures X Conducting an appropriate pre-trip inspection to ensure the vehicle assigned is in proper operating condition, and that all mechanical defects are identified and reported before the vehicle is placed in service
X Conducting a post-trip inspection upon return to the location and reporting relevant information as appropriate
X Maintaining control of the vehicle and conduct on the vehicle X Reporting relevant information to the supervisors and dispatchers, including:
o Accidents and incidents
o Vehicle defects that may cause a service interruption o Customer disturbances or illness
o Route interruptions (e.g., detours)
X Complying with all MTM Transit and client accident reporting procedures following an accident
X Complying with all MTM Transit and client fitness-for-duty drug and/or alcohol testing procedures
\Emergency Response Procedures
MTM Transit has emergency response procedures in place and trains operators to respond to a variety of emergencies. Procedures in place include, but not limited to, emergency operating procedures for:

X Fire or smoke on the vehicle
X Evacuating passengers from the vehicle
X Collision with another vehicle or fixed object
X Striking a pedestrian
X Disruption incident on the vehicle
X Severe or inclement weather
X Route detours
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\Pre- and Post-Trip Inspections
As discussed previously, operators conduct pre- and post-trip inspections of vehicle equipment including, but not limited to, the following:

X Brakes and door systems
X Onboard communication systems, exterior and interior lights, and reflectors X Tires, lug nuts, and studs
X Steering assembly and suspension system
X Kneeling system, wheelchair lift (as required), and tie down systems X Windshield wipers, mirrors, horn, and seat belts
X Vehicle exterior, vehicle interior, and steps
X Onboard fire extinguisher, first aid kit, fuses, and triangle reflectors \Hours of Service
This MTM Transit operation for the City follows the short-haul hours of service provision which states:

X The operator operates within a 150 air-mile radius (172.6 statute miles) of the normal work reporting location
X The operator, except an operator-salesperson, returns to the work reporting location and is released from work within 14 consecutive hours
X A passenger-carrying commercial motor vehicle operator has at least eight consecutive hours off-duty separating each 14 hours on-duty
X The motor carrier that employs the operator maintains and retains for a period of six months accurate and true time records showing:
o The time the operator reports for duty each day
o The total number of hours the operator is on-duty each day o The time the operator is released from duty each day
o The total time for the preceding seven days for operators used for the first time or intermittently
\Revenue Service Checks
Revenue service checks are conducted at various times and places, especially within school zones and areas with a high citation rate. Revenue service checks include, but are not limited to, the following:

X Determining the operator's general performance and conformance to the standard operating procedures
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X Determining the operator's handling of elderly and disabled passengers and sensitivity to their situation
X Schedule adherence
Additional Operator Safety-Related Activities
Operations works with the local management team to establish safety training requirements.

Operations helps resolve unsafe practices and investigates accidents and incidents, as outlined in this SSPP. Safety performance is part of employee evaluation.

Safety-Related Maintenance Activities
MTM Transit recognizes that well-maintained equipment and facilities result in a reduction in potential hazards. Our service also includes in-house vehicle cleaning of the City vehicles used for Manteca Transit, while most of the vehicle maintenance is outsourced to Sunshine Auto Care, Inc., which is fully staffed with ASE-certified technicians and equipped with the tools and equipment needed to maintain and repair the City’s transit vehicles. Their facility is less than one mile from the Transit Center making it a cost-effective and efficient option for the program.

All maintenance work adheres to applicable Federal, State, and local requirements, including the City’s requirements. All maintenance technicians are certified. Maintenance technicians complete a Preventative Maintenance Inspection and Service Checklist per the City requirements. Inspections are carried out twice a year to ensure compliance with maintenance regulations.

This section refers to maintenance rules and procedures that apply to safety, including flow of information, working schedules and responsibilities of maintenance personnel, equipment and locations which require maintenance, and frequency in which activities are carried out. Routine procedures including pre-trip inspections carried out by operators prior to taking a vehicle into service and procedures regarding defects that are discovered while in service are also provided in this SSPP.
\Vehicle Maintenance Policies and Programs
Vehicle maintenance policies and procedures presented in this SSPP include, but are not limited to, the following:

X Employees receive orientation to vehicle maintenance policies and programs.

X Scheduled service is appropriately provided for equipment, based on mileage and time.

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X Preventative Maintenance (PM) inspections are conducted at least every 45 days or 3,000 miles, or the manufacturer’s suggested mileage (whichever is less).

X Outside contracted maintenance technicians providing repairs for MTM Transit are expected to adhere to maintenance policies that promote safety.

X MTM Transit adheres to rigorous policies regarding the purchase and maintenance of used vehicles.

X Supervisors ensure that emergency request for safety-related requirements are processed in an expeditious manner.

X Prior to the award of a contract, bid, or proposal, the maintenance department ensures that MTM Transit has complied the most appropriate specifications, including all safety requirements.

X Supervisors ensure that all warranty provisions contained in vehicle, product, or service agreements are complied with by vendors as required.

X Supervisors ensure that tests of vehicles or products are performed with the proper tools and equipment and that employees performing tests have received appropriate training in test procedures.

X Supervisors monitor vehicle and safety information issued by manufacturers and vendors to ensure that such information is disseminated to all affected departments and employees.
\Preventative Maintenance Procedures and Schedules
Preventative maintenance procedures and schedules include, but are not limited to, ordering materials and components to keep MTM Transit’s fleet in a state of good repair, ensuring that the preparation of specifications and selection of materials and components address all applicable safety requirement and established performance limits, test requirements, and allowable wear limits for vehicles and components. Preventative maintenance tests and inspections include, but are not limited to, the following:

X Brake and air systems
X Onboard communication systems, interior and exterior lights, and reflectors X Tires, lug nuts, and studs
X Steering assemblies
X Wheelchair lift/kneeling systems (as applicable) and tie down systems X Windshield wipers, mirrors, and horns
X Body exterior, interior, and steps
X Suspension systems
X Fire extinguishers, first aid kits, fuses, and triangle reflectors X Seat belts
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\Corrective Maintenance Procedures
Corrective maintenance procedures for equipment and systems in place include, but are not limited to, the following:

X Maintenance procedures are current, and the revisions are controlled.

X Maintenance personnel are provided current corrective maintenance procedures, which supervisors ensure are followed.

X Corrective maintenance actions are recorded and filed.

X Defect reports provided by operators are used for corrective maintenance planning.

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Section 4 – Program Implementation and
Maintenance
Internal Reviews
MTM Transit performs internal audits to help ensure that all elements within the property follow the SSPP. As appropriate, the plan includes a schedule of audits, objectives of the audits, and how identified discrepancies are resolved.

Periodic reviews are performed to ensure that operators and all other employees are following procedures. Maintenance work recall records are reviewed to check the proficiency of the maintenance personnel. The Motor Vehicle Department's instant notification system for traffic violation conditions is applied for all employees. All operators are periodically checked as appropriate per specific State guidelines. Periodic road checks are performed by safety personnel.

Management conducts periodic revues to ensure that the quality of training for operators and all personnel is appropriate. Results of the reviews are distributed to appropriate personnel, with actions assigned. Management follows up on the effectiveness of actions taken because of the internal reviews.

External Reviews
MTM Transit is also subject to external reviews, audits, and/or investigations with outside agencies including, but not limited to, the following:

X Federal
o Federal Transit Administration
o Environmental Protection Agency
o Occupational Safety and Health Administration
o Bureau of Alcohol, Tobacco, and Firearms
o American Public Transit Association.
o National Transportation Safety Board
o National Institute for Occupational Safety and Health (for workplace safety) X State of California
o California Department of Transportation
o California Department of Environmental Conservation
o California Department of Labor
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o California Office of the Physically Challenged
o Controller
X Local
o Mass Transit Operating Assistance Program (e.g., records management) o UMTA (e.g., records management)
o Health Department
o Fire Marshall
o Planning Commission
o Department of Public Works (Hazardous Materials Section) o Police Departments
o Emergency Planning Commissions
o Fire Departments
o Audit Department
X Other
o Insurance Company audits include reviewing operator abstracts, accident files, and workplace safety. MTM Transit participates in emergency preparedness meetings under the direction of the Local Emergency Planning Commission. o Recommendations made by external auditing agencies are reviewed by management and appropriate departments. Recommendations are filed with a rational for action. Actions are made as required.

Collect and Maintain Data
MTM Transit recognizes the importance of identifying the types of information collected at the location, how it is used to verify the level of safety, where the information is filed, and how it is retrieved. The safety team plays a key role in analyzing and utilizing data.

Each department gathers and files relevant internal safety data. Data includes, but is not limited to, all relevant information required by organizations providing external reviews, as well as information required for internal reviews. Data is provided to MTM Transit management.

Accident, incident, and/or defect reports are collected and maintained as discussed in this SSPP.

Data collected is indexed, filed, and readily available. Collection and maintenance of all reports meets Federal, State, and local requirements.

Maintenance records and reports are maintained as per the City and/or State requirements.

Commented [JT1]: Are these applicable for Manteca?
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Operator reports are maintained in personnel files.

Inspection reports are collected and maintained in various areas including, but not limited to the following:

X Scheduled maintenance reports
X Collective maintenance reports
X Vehicle pre- and post-trip inspection reports or shift inspection reports X Vehicle safety inspection reports
X Route inspection reports
Professional Development
MTM Transit encourages all employees, particularly those responsible for safety, to enhance their professional skills through training, development planning, professional affiliations, and other programs. Training is provided to all MTM Transit employees.

Mandatory and voluntary programs provided by manufacturers, educational institutions, and other sources are scheduled for employees as appropriate. Records regarding training are kept for each employee. A training and development plan is in place for individuals responsible for safety.

Safety team personnel are informed of new codes and regulations that affect MTM Transit.

Members of the safety team are encouraged to attend professionally accepted safety courses, such as at USDOT Transportation Safety Institute and universities for professional development.

Safety team members are encouraged to participate in industry-wide organizations.

SSPP Implementation and Maintenance
Management is responsible for distributing and communicating changes in the plan to all MTM Transit departments in a timely manner. Procedures to update the SSPP as required for priority/critical items and events, to control revisions, to coordinate revisions to the SSPP within the MTM Transit location, and to distribute changes to SSPP include the following:

X The SSPP is distributed by the President/CEO and/or the General Manager to all supervisors and managers. All recipients are required to sign a System Plan Signature Statement, indicating that they received the plan and are responsible for having the plan available to all employees in their department.

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X The safety team ensures that the SSPP is revised on a biennial schedule and includes as a minimum, fleet information, an organizational chart, and any updated polices or procedures.

X The SSPP is reviewed annually by all departments to ensure changes that affect vehicle operations or impact the SSPP are incorporated, as necessary.

X Plan revisions or updates are distributed as addendum pages to all plan holders and other affected personnel.

X When there are significant revisions of the SSPP, the plan is rewritten and distributed to replace the old plan.

X In the event significant changes are made regarding operating procedures and policies, training is provided to employees as appropriate.

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Section 5 – Certification
System Safety Program Plan Certification Statement
I, Alaina Maciá, President and CEO, certify that this SSPP for MTM Transit has been properly distributed, is currently in effect, functioning as stated, and will be fully enforced by company management.

July 1, 2023
Alaina Maciá, President and CEO Date
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ATTACHMENT 2
Transit Employee
Safety and Training Manual
2022
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TABLE OF CONTENTS
TABLE OF CONTENTS ................................................................................................................................ 1 YOUR TRANSIT EMPLOYEE SAFETY AND TRAINING MANUAL ............................................................................... 2

1. GENERAL ............................................................................................................................................. 2 EMPLOYEE SAFETY EXPECTATIONS ......................................................................................................................... 2 DEFINING AND MEASURING MTMTRANSIT’S SAFETY CULTURE ............................................................................................ 3 TRAINING REQUIREMENTS ................................................................................................................................... 5 TRAINING DOCUMENTATION ................................................................................................................................ 8

2. CUSTOMER SERVICE ............................................................................................................................. 8 CUSTOMER RELATIONS ........................................................................................................................................ 8 CUSTOMER EXPECTATIONS ................................................................................................................................... 9 BENEFITS OF GOOD CUSTOMER SERVICE ............................................................................................................... 10 PREVENTING PROBLEMS BEFORE THEY BEGIN ........................................................................................................ 10 LATE/MISSED TRIP POLICIES .............................................................................................................................. 11 COMMUNICATING WITH PASSENGERS .................................................................................................................. 12 CUSTOMER INTERACTION POLICY ........................................................................................................................ 14

3.SAFETY – EMPLOYEES AND PASSENGERS ............................................................................................. 15 FUNDAMENTAL SAFETY PRACTICES FOR SAFE DRIVING ............................................................................................ 15 DEFENSIVE DRIVING ......................................................................................................................................... 16 ACCIDENTS ..................................................................................................................................................... 18 MAJOR SAFETY INCIDENTS ................................................................................................................................. 19 MINOR SAFETY INCIDENTS ................................................................................................................................. 20 SAFETY VIOLATION POINT ASSESSMENTS .............................................................................................................. 20 GENERAL GUIDELINES FOR VEHICLE OPERATORS .................................................................................................... 25 SAFETY AND EMERGENCY PROCEDURES IN A COLLISION ........................................................................................... 27 TRANSPORTING PASSENGERS WITH DISABILITIES ..................................................................................................... 30 BLOODBORNE PATHOGENS PROTECTION .............................................................................................................. 31

4. AMERICANS WITH DISABILITIES ACT (ADA) ......................................................................................... 32 PERSON WITH A DISABILITY ................................................................................................................................ 32

5. CUSTOMER SERVICE, WHEELCHAIR/MOBILITY ASSISTANCE, SECUREMENT, AND SENSITIVITY ............. 35 SAFETY RESPONSIBILITY ..................................................................................................................................... 35 PERSONAL SPACE ISSUES/COMMUNICATION ......................................................................................................... 35 MOBILITY DEVICES ........................................................................................................................................... 37 WHEELCHAIR LOADING PROCEDURES AND LIFT OPERATION ..................................................................................... 39 WHEELCHAIR LIFT OPERATION ............................................................................................................................ 40 MANUAL LIFT OPERATION ................................................................................................................................. 41 APPENDICES .......................................................................................................................................... 46 APPENDIX A – SAMPLE OPERATOR JOB DESCRIPTION .............................................................................................. 47 APPENDIX B - FUNDAMENTAL SAFETY PRACTICES QUIZ ........................................................................................... 48 APPENDIX C – TRAINING ACKNOWLEDGEMENT ...................................................................................................... 53 ATTACHMENT 2
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YOUR TRANSIT EMPLOYEE SAFETY AND TRAINING MANUAL
This Transit Employee Safety and Training Manual has been designed in conjunction with the Employee Handbook to provide you with information and guidelines about the safety policies, practices, responsibilities, and benefits that are part of working for MTM Transit.

While it covers many of our policies and procedures, it is not intended to cover every question or situation that may arise. Further, it should not be deemed to constitute an employment contract. The manual includes some common operator job details such as defensive driving, ADA passenger sensitivity and mobility device securement.

1. GENERAL

EMPLOYEE SAFETY EXPECTATIONS
\SAFETY IS A CONDITION OF EMPLOYMENT
MTM Transit must exhaust every reasonable means to lead, motivate, train, and take provisions to ensure our employees work to and help maintain a safe workplace. We expect our employees to follow the rules and not take chances. The actions of all MTM Transit employees reflect on MTM, so employees are responsible for behaving in ways that are beneficial to the company and, at the very least, they should not take chances or do anything that can cause harm to them or others.

We all share the responsibility for encouraging a strong safety culture at MTM Transit by working constantly to improve behavior and performance in the workplace. We all share accountability to encourage our peers to value our MTM Transit safe work practices and safety processes in a positive, proactive way. If you think a job or a task is unsafe, stop the work. You are empowered to stop unsafe acts or unsafe conditions.

If you see something unsafe, report it. If you see an unsafe behavior, correct it, or report it. MTM Transit will not discipline reported/ reporting employees. We will retrain employees to avoid the risky behavior or unsafe act in the future.

Per the new Safety Management System (SMS) guidelines mandated by the Federal Transit Administration (FTA), all MTM Transit employees are expected to be safety officers and the eyes of safety for the company and their fellow workers.

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\SAFETY IS AN ETHICAL RESPONSIBILITY OF ALL EMPLOYEES
At its core, ethics holds up a positive vision of what is right and what is good. It defines what is "worth" pursuing as guidance for our decisions and actions. Workplace injuries and deaths are too often seen in the abstract as statistics. However, when it happens to someone we love, we suddenly see the reality of the horrible pain and suffering and its widespread effect. It is our ethical responsibility to do what is necessary to help protect our fellow employees from death, injury, and illness in the workplace. This is the only foundation upon which a true safety culture can be established in any workplace. All MTM Transit employees must act as safety officers and work as a team. \PERSONAL “OWNERSHIP” FOR SAFETY Many employees work individually as operators of motor vehicles. While on the road, the vehicle operator is the only person in control of his/her work environment. Control depends on the employees’ attitudes and commitment to safety. We must take the time to do each of our jobs correctly; “at-risk” behaviors cannot be taken. Each employee is expected to drive defensively and watch out for potential hazards.

DEFINING AND MEASURING MTMTRANSIT’S SAFETY CULTURE
Defining, measuring, and developing metrics is an important first step to take toward developing and implementing a sustainable transit safety culture.

As a company, we must focus on a model of building a strong safety culture by uniting all ranks of our employees to share a common vision of safe and efficient operations. Our goal of a sustainable transit safety culture is based on the premise that our safety culture should modify human behavior, values, and attitudes about safety. If there is a failure in a plan, policy, procedure, or communication, with our company having a strong safety culture, the safety behavior will align with integrity and engagement to yield a safe response by all. Safety metrics that show our employees how we are performing will help drive an improvement to our overall safety culture.

The safety culture of our organization reflects the perceptions and values that our employees share regarding safety in the workplace. This model has a direct, measurable relationship to organizational performance, efficiency, and outcome. While we have proclaimed a commendable record of safety for our employees and passengers, there is always room for improvement. Reducing the number of incidents through training and ATTACHMENT 2
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coaching our employees to avid risky behaviors will help us sustain a strong and vibrant transit safety culture. Ensuring our employees become actively engaged in safe behaviors and following the rules will help.
\UNDERSTANDING HOW OUR SAFETY CULTURE AFFECTS OUR ACCIDENT PERFORMANCE It has been suggested theoretically that every company has a safety culture, no matter how good, bad, or indifferent that culture might be. Part of our safety culture performance is measured by the frequency of vehicle accidents we incur. Our company prior vehicle accident history has included fixed object accidents, sideswipes, and overhead clearance accidents, which indicates our operators’ lack of space around their vehicle’s awareness and aggressive driving behaviors. To summarize, nearly all our preventable accidents had resulted from operator error.

Although most of our company accidents are minor in nature, we know from experience and the Heinrich Accident Model that we train our employees about, statistically speaking, we were increasing our exposure to incurring a major occurrence. The Heinrich 300-29-1 model tells us that for every 300 near misses there will be 29 minor injuries and one major injury. The pyramid representation of the model is as follows:

According to the model, to reduce accidents, we need to reduce the base of the pyramid, namely near misses. As stated previously, nearly all our preventable accidents in the past have been the result of operator error. How then, to reduce the base of near misses? ATTACHMENT 2
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Identify the near misses, analyze the data, and determine if we need to conduct training or some other solution to mitigate the near misses and to reduce our exposure.

We will continue to focus on the minor issues and near misses, so that we can help eliminate our exposure to major occurrences. This is an instrumental part of improving our overall safety culture as a company. If our employees understand Heinrich’s Pyramid and believe in avoiding risky behaviors, our safety performance will improve and with that improvement, help drive an improvement to our company’s overall safety culture.

TRAINING REQUIREMENTS
All vehicle operators must undergo required classroom and behind-the-wheel training before entering service. All new vehicle operators are extensively evaluated and must pass numerous testing criteria to ensure they are ready to drive in-service before driving with customers in revenue operations.
\OPERATOR TRAINING PROGRAM
Our new vehicle operator training program follows the Transit and Paratransit Transportation Company (TAPTCO) program, an industry leading Transit and Paratransit program that many transit agencies in North America are currently teaching. In addition, we include effective state-of-the-art training programs and procedures that are proven strategies specific to our internal safety processes and to our service. Following this formal training period, operators also participate in an exercise known as cadet route training with a behind-the-wheel instructor. Cadet route training allows our operators to develop their on-route/on-road skills to gain a first-hand perspective and understanding of the route or service to which they will be assigned. The classroom, behind-the-wheel, and route training portions of our training program are described in greater detail below.

Training Calendar
Operators will receive essential training that encompasses rules of the road, defensive driving, safety standards, vehicle features and use, pre-trip and post-trip vehicle inspections, Americans with Disabilities Act of 1990 (ADA) equipment usage, customer service, sensitivity and empathy training, accident and incident procedures, proper communication procedures, and extended time behind the wheel. The future success and retention of excellent vehicle operators starts with an effective and comprehensive training program.

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Our training program is a minimum of 96 dedicated training hours for paratransit operators and 120 dedicated hours for fixed route operators. A detailed breakdown of our paratransit operator program is outlined below.

Paratransit Training Overview and Key
Type Description Total Hours
CLS Classroom Instruction 40.0
BTW Behind-the-Wheel (with 14.5 hours of simulated service) 55.5 TST Classroom Testing 0.5
Grand Total 96.0
Paratransit Training Breakdown
Type Training Topic Hours
Day 1 CLS Welcome to MTM Transit and Paperwork 1.0
CLS Meet the General Manager and Local Staff 0.5
CLS Introduction to Professional Driving 0.5
CLS Federal Laws and Regulations 0.5
CLS Hazard Communication 0.5
CLS Creating a Drug and Alcohol-Free Workplace 1.0
CLS Preventing Harassment 0.5
CLS Bloodborne Pathogens 1.0
CLS Fatigue Management 0.5
CLS Wellness 0.5
CLS Whistleblower 0.5
CLS Safety Best Practices 1.0
Day 2 CLS Introduction to the Vehicle 3.0
CLS Pre-Trip Inspections 1.0
CLS Pre-Trip Inspections (Engine and Drivetrain) 0.5
CLS Post-Trip Inspections 0.5
BTW Pre-Trip Inspections/Post-Trip Inspections Practice 0.5 CLS Mirror Adjustments 0.5
BTW Mirrors and Reference Points (On Vehicle) 1.0
CLS LLLC Defensive Driving or Smith System Program 1.0
Day 3 CLS Pre-Trip and Post-Trip Inspection Introduction 0.5 CLS Pre-Trip and Post-Trip Inspections (Revisited) 1.0
BTW Closed Skills Course Introduction 0.5
BTW Closed Skills Course 3.0
BTW Closed Skills Course 3.0
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Type Training Topic Hours
Day 4 CLS Preventing Distractions (Video and PowerPoint) 1.0 CLS Following Distance 0.5
CLS Vehicle Emergencies 1 1.0
CLS Vehicle Emergencies 2 1.0
CLS Sexual Harassment - Respectful Workplace 0.5
CLS Accident Procedures (Book and PowerPoint) 1.0
BTW On the Road Safe Driving Skills 3.0
Day 5 CLS Intersections 0.5
CLS Railroad Crossings 0.5
CLS Local Service Requirements and Fares 1.5
CLS Empathy and Customer Service Video from Project Action 0.5 CLS Introduction to ADA and Sensitivity (Walking Blindfolded and Riding Bus While Strapped in a Wheelchair and Blindfolded) 0.5 BTW On the Road Safe Driving Skills 4.5
Day 6 CLS Pedestrian and Bicycle Awareness 1.0
CLS Preventing Backing Accidents 1.0
BTW On the Road Defensive Driving Instruction 4.0
BTW On the Road Safe Driving Skills 2.0
Day 7 CLS Merging, Lane Change, and Passing 0.5
CLS Special Driving Condition 0.5
CLS Introduction to Customer Service (START Program) 1.0 BTW On the Road Safe Driving with Defensive Driving Instruction 6.0 Day 8 CLS Introduction to ADA and Sensitivity (Using Paratransit Customer Service Applications) 1.0
CLS ADA, Lifts, Ramps, Securement, and Service Animals Classroom 1.0 CLS Lifts, Ramps, and Securement 3.0
BTW Lifts, Ramps, and Securement - Student Passengers 3.0 Day 9 CLS Map Reading 1.0
CLS Conflict/Aggression Management 1.0
CLS MTM Transit’s Accident and Emergency Procedures 1.0 CLS NTI's Warning Signs and NTI's The Mark (videos) 1.0 BTW On the Road Safe Driving Skills 4.0
Day 10 CLS Contract Specific Requirements 1.0
CLS Classroom Review 0.5
TST Classroom Final Written Exam Test 0.5
BTW Safe Driving Skills/Route Training 6.0
Day 11 BTW Safe Driving Skills/Simulated Service 8.0
Day 12 BTW Safe Driving Skills/Simulated Service 6.5
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Type Training Topic Hours
BTW On the Road - Final Graded Assessment 1.0
CLS Graduation from Training 0.5
Grand Total 96.0
*The above classroom training exceeds all state standards and contains all required courses.

Following this formal training period, operators also participate in an exercise known as cadet route training with a behind-the-wheel instructor for a minimum of two days. Cadet route training allows our operators to develop their on-route/on-road skills to gain a firsthand perspective and understanding of the route or service to which they will be assigned.

TRAINING DOCUMENTATION
\TRAINING REPORTS
Training evaluations or training reports must be completed whenever an operator trains another operator to include new hire, refresher, or remedial training. This will ensure that all training is documented, identified and any deficiencies or follow up training that is required is completed. All paperwork must be filled out accurately, with detailed information and explanation of training tasks, evaluation of the training and identify any remedial training needed.

2. CUSTOMER SERVICE

CUSTOMER RELATIONS
The importance of good service cannot be underestimated. A point to remember for all operators is that we provide customer service in the form of safe and reliable transportation from one point to another. When a service is provided rather than selling a product, the way our customers are treated determines whether they continue to be loyal customers. It is important to always remember that transportation is a service industry and that our employees are the principal customer service representatives.

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CUSTOMER EXPECTATIONS
Customers expect us to provide them with vehicles that are safe, clean, comfortable, and well-maintained. Customers expect our transportation service to be safe, reliable, convenient, and affordable, and our operators to be well informed.

Customers expect our operators to:
• Provide a safe ride
• Deliver and pick-up on time
• Know the best routes to their destination
• Act in a professional manner
• Be knowledgeable about their needs
• Be knowledgeable about different types of mobility aids • Be familiar with different types of lifts, ramps, and securement systems • Greet customers
• Always offer assistance for paratransit operations
MTM Transit operators work directly with the public in a professional manner and perform at the front line for the company. As a MTM Transit mobile ambassador, it is the operator’s professional customer service skills that will encourage customers to continue to use MTM Transit services.

Operators must always be courteous, reliable, and knowledgeable. \COURTEOUS OPERATORS
• Always give a cheerful “hello” or “good day” when meeting a customer • Treat the customer with respect, giving them the benefit of the doubt in the event of a disagreement
• Communicate in an appropriate and accurate manner
• Never embarrass a customer
• Always have patience
\RELIABLE OPERATORS
• Pick up customers on time
• Provide the appropriate assistance boarding and alighting the vehicle ATTACHMENT 2
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• Maintain their schedules
• Drive defensively
\KNOWLEDGEABLE OPERATORS
• Provide accurate and appropriate information
• Know the appropriate route to take
• Know the proper assistance techniques to use
• Anticipate, remember, and provide the needs of customers MTM Transit operators are our frontline customer service representatives: MTM Transit Ambassadors. It is up to our operators to fulfill our customers’ expectations about our service. MTM Transit expects its operators to meet and/or exceed these expectations.

BENEFITS OF GOOD CUSTOMER SERVICE
The MTM Transit customer is not the only one to benefit from good customer service.

Operators who use good customer service skills benefit from increased respect and support, and experience fewer daily frustrations. Good customer service will encourage customers to:
• Be pleasant while in the vehicle
• Be receptive to instructions
• Provide support when dealing with other difficult customers • Continue to use the service
Customers, operators, and MTM Transit all benefit from good customer service:
• Customers benefit from better service
• Operators benefit from increased customer respect and support • MTM Transit benefits from increased ridership and customer loyalty •

PREVENTING PROBLEMS BEFORE THEY BEGIN
Applying the following skills and techniques will make interacting with customers and anticipating their needs straight forward. One of the keys to great customer service is to prevent problems before they begin.
\PREPARE FOR THE WORKDAY
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• Dress in a professional manner
• Inspect vehicle for any situations that may cause customer complaints • Ensure that materials and information are available to customers \WELCOME CUSTOMERS
• Let the customer know they are welcome in the vehicle • Inform the customer of any service delays or problems that day \LISTEN TO CUSTOMER CONCERNS
• When service problems come up, listen to the customers, and understand their complaint
• Offer customer empathy, do not blame others, and offer a solution when possible \THANK CUSTOMERS
• Greet all customers when they get on and off your vehicle • Let customers know that their business is appreciated • Build a rapport with customers through courtesy
• Be sure to inform customers of any delays that will occur in coming days \GENERAL GUIDELINES TO REMEMBER
• Greet each customer with a friendly hello and a smile • Assist customers in a friendly, non-threatening way
• Request that each customer considers his or her own personal safety. Remind customers to “please wear your seat belt” and “watch your step” • Offer to assist all customers who have mobility impairments • Always avoid conflict with customers and the public
• If a customer’s concerns cannot be satisfied, refer the customer to management • Do not deviate from the scheduled stop; Dispatch must approve any changes • If the operator has any questions in route, they should always call Dispatch

LATE/MISSED TRIP POLICIES
Any late or missed trip must be reported to Dispatch immediately so that the required documentation can be supplied to the client and appropriate actions can be taken.

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Operators are required to notify Dispatch prior to experiencing a late trip so that they may try to arrange for another vehicle to make the pick-up on time.

COMMUNICATING WITH PASSENGERS
Be sure the public address system is working correctly prior to placing a bus into service.

While operating a bus in fixed route service, you must be sure to follow the Americans with Disabilities Act of 1990 (ADA) guidelines and announce stops at:
• Major transfer points with other routes
• Major intersections/destination points and points of interest (landmarks) • Sufficient intervals along the route to permit orientation • Any stop requested by the customer must also be announced Make sure to program and/or change destination sign information on the exterior and interior displays so that it reflects the current destination and direction for all passengers to see.
\SENSITIVITY AND ETIQUETTE FOR COMMUNICATING WITH PERSONS

WITH DISABILITIES
Remember that a person who has a disability is a person, just like anyone else.

Do not make assumptions; if a question arises about what to do, how to do it, what language or terminology to use, or what assistance to offer, ask the person with the disability. That person should be the first and best resource.

Assist customers quietly and tactfully. Respect the person's right to reject help or to indicate the kind of help needed. Always tell the person what you will do before you do it; for example, “I am providing my arm to assist you.” Never invade a person’s personal space without telling them what and why you are doing it. If they refuse, contact Dispatch.

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If assistance cannot be provided in the way that is asked, be open in discussing this with the person with the disability. Operators have a right to set limits on what can and cannot be done.

If the person talks about the disability, engage politely without prying. Be guided by the wishes of the person with the disability.

Appreciate what the person can do. Remember that difficulties the person may be facing may stem more from society's attitudes and barriers than from the disability itself.

Be considerate of the extra time it might take for a person with a disability to speak or perform any task. Let the person set the pace in walking or talking.

Speak directly to a person who has a disability. Do not consider a companion or interpreter to be a conversational go-between.

Do not move a wheelchair, crutches, or other mobility aids out of reach of a person who uses them.

Never start to push a wheelchair without first asking the occupant to do so.

Before deciding whether to push a wheelchair up or down a step, curb, or other obstruction, ask the person if and how he or she wants you to proceed, and be respectful of your own limitations.

Do not lean on a person's wheelchair when talking, it is an invasion of personal space. Do not pat a person in a wheelchair on the head, this can be considered patronizing.

Give full, unhurried attention to a person who has difficulty speaking. Do not speak for the person but give help when needed. Keep encouraging rather than correcting. When necessary, ask questions that require short answers or a nod or shake of the head.

Do not pretend to understand a person with a speech difference when you do not. Do not be afraid to let the person know that you do not understand. Be patient, not only with the person with the disability, but also with yourself.

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Speak calmly, slowly, and distinctly to a person who has a hearing problem or other difficulty understanding. Stand in front of the person, speak directly to the person, and use natural gestures to aid communication. When full understanding is doubtful, try writing notes.

Do not pet or otherwise distract dog guides; they are working and must not be distracted.

Be alert to possible existence of architectural barriers in places you may want to enter with a person who has a disability. Watch for inadequate lighting which inhibits communication by persons who have hearing problems.

CUSTOMER INTERACTION POLICY
MTM Transit is committed to treating our customers with respect, dignity, and courtesy.

This commitment and the nature of our business require that the relationship between MTM Transit employees and customers be strictly professional. To preserve the safety, security, and trust of our customers and to minimize claims of harassment or the appearance of impropriety, operator interactions with customers must be free from personal relationships, conversations, or contact/conduct that could be construed as harassment, abuse, or otherwise inappropriate.

Examples of prohibited conduct which will result in disciplinary action, up to and including immediate termination, include:
• Sexual advances, request for sexual favors, and other verbal or physical conduct of a sexual nature
• Threats, abuse, coercion, or intimidation of any nature • Use of profane abusive or insulting language
• Accepting or offering any gifts, invitations, or favors of any kind • Discussing personal life or the customer’s personal life • Dating or meeting a customer for personal reasons on or off duty The reasons listed for discipline and discharge above are examples only and are not meant to include, and do not include all reasons for which an employee may be disciplined, up to and including termination.

Questions concerning this policy should be addressed with immediate supervisors.

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3.SAFETY – EMPLOYEES AND PASSENGERS
The health and safety of our employees and passengers is MTM Transit’s foremost business consideration. In keeping with this principle, MTM Transit pledges to:
• Strive to achieve the goal of zero accidents and injuries • Provide mechanical and physical safeguards wherever they are necessary • Conduct routine safety and health inspections to find and eliminate unsafe working conditions, control health hazards, and comply with all applicable and Occupational Safety and Health Administration (OSHA) safety and health requirements
• Train all employees in safe work practices and procedures • Investigate accidents to determine the cause and prevent similar accidents • Enforce company safety and health rules and require employees to follow the rules as a condition of employment
All employees are responsible for their own safety, as well as protecting the safety of their fellow colleagues and passengers of MTM Transit. Employees are expected to participate in the safety and health program, which includes immediately reporting accidents, hazards, and unsafe work acts and conditions to their supervisor.

Failure to follow any safety procedure or guideline will result in a disciplinary action, up to and including termination of employment.

FUNDAMENTAL SAFETY PRACTICES FOR SAFE DRIVING
There are 18 fundamental safety practices that all operators must know and commit to memory before entering service. These 18 safety best practices are at the core of our safe driving principles. These fundamental safety practices make up the foundation of defensive driving and avoiding “at risk” behaviors and help our operators maintain a safe environment for our customers and the motoring public. These practices are:

1. Leave room / Always stay back four seconds

2. Look ahead

3. Look around

4. Communicate

5. Stay within the posted speed limits

6. Be in control, take your time. If late, stay late.

7. Do not back the bus – if you must back, follow G.O.A.L.

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8. Rock and roll for turns

9. Use your reference points

10. Adjust your mirrors

11. Do a thorough pre-trip and post-trip and only operate a safe vehicle

12. Smile and always be polite. Courtesy is contagious

13. Focus on the driving

14. Always stop at stop signs

15. Slow down and pull back for rain, snow, ice, or fog

16. Get enough sleep, always be alert and awake

17. Always keep your balance, no rushing and use three points of contact

18. Never be under the influence of drugs or alcohol

DEFENSIVE DRIVING
Defensive driving helps prevent and reduce damages during collisions with people, vehicles, and fixed objects. It helps us protect people from injury and equipment from damage. MTM Transit teaches the LLLC defensive driving program from TAPTCO.

Police decide who is “at fault” for an accident by determining who has the greatest responsibility for the cause of an accident. Someone “at fault” is responsible for 51% or more of the responsibility.
\LLLC PROGRAM
Using the TAPTCO Four Driving Principles of Safety, Look Ahead, Look Around, Leave Room, and Communicate, gives you the time and information you need to avoid an accident and be an all-around better operator. It also helps you avoid other vehicles.

Look Ahead
The first principle is Look Ahead. It is not enough to just know what is happening in your immediate environment. Defensive Driving is about knowing what will happen, and you can do so by keeping an eye-lead time of 15 seconds. Scan the road ahead to see any action or potential issues before you reach them to have as much time as possible to react.

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Look Around
The Look Around principle, like the Look Ahead principle, has to do with the environmental demands that you perceive. You need to Look Around your vehicle, not just in front. Everything around you is constantly changing: the roadway, the traffic, pedestrians. Change your point of focus every two seconds and check your mirrors every five to eight seconds to see around you and navigate your blind spots. This way, you avoid driving with a fixed stare and stay more alert.

Leave Room
In some ways, the third principle – Leave Room – is the most important to defensive driving. It is the most basic as far as preventing collisions; keep adequate space in between you and other vehicles or fixed objects. It is essential to Leave Room on all six sides of the vehicle: in front, behind, left, right, above, and below. The easiest space to control is the space in front of you. You need to maintain a three to five second following distance in clear conditions to account for other operators’ mistakes.

Communicate
While the first three LLLC Defensive Driving principles are about what information you perceive, - Communicate is about what information you give other operators. You must let other operators on the road know what you intend to do so they can act accordingly.

The most basic is your turn signal. Use your turn signal for three to five flashes before turning or changing lanes.

Application of these LLLC principles will greatly improve your driving. \PREVENTABLE VS. NON-PREVENTABLE ACCIDENTS/INCIDENTS
Preventable Accident/Incident
A Preventable Accident/Incident is one in which the operator failed to do everything reasonably possible to avoid or to mitigate damage and/or injuries. This definition is provided by the National Safety Council and is universally accepted in the public transportation industry.

Non-Preventable Accident/Incident
A Non-Preventable Accident/Incident is one in which the operator did everything reasonably possible to avoid, and to mitigate damage and injuries.

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\BEEP AND BACK MTM Transit requires all operators to beep their horn and put on their hazard lights/flashers prior to backing their vehicle every time they back up. \G.O.A.L. (GET OUT AND LOOK)
Operators must get out and walk around the vehicle to check for hazards before backing up.

Backing into a spot when arriving will greatly reduce the risk of needing to back up the vehicle when leaving. This can reduce the risk of an accident by as much as 25%.

MTM Transit policy is to have a four-second following distance (1001, 1002, 1003, 1004).

During inclement weather and night driving, add additional time. It is the operator’s responsibility to add enough time to follow safely in all conditions.

Do not forget that intersections are the most dangerous place to be. Scan every intersection before entering it, and while moving through it.

Cover the brake while going through an intersection.

Look left, right, and left, and forward before moving into an intersection. “Rock and Roll” in the seat to avoid blind spots in crosswalks and intersections, most pedestrian accidents happen when operators fail to see people in a blind spot.

Watch for signs of trouble and changing conditions while driving, parked cars, stale lights, crosswalk signs, and pedestrians crossing with, and against the traffic light.

ACCIDENTS
MTM Transit is committed to ensuring the safety of the public, our passengers, and our employees. To ensure we promote the “Safety First” culture within our organization, we have developed a Safety Point Program and Guidelines to ensure compliance and adherence to MTM Transit policies and procedures. All employees who fall within a safety sensitive position are required to abide by these guidelines and are subject to the Safety Points Program, accrual process, and disciplinary structure.

Any work-related accident or incident that involves a MTM Transit employee or equipment will be investigated by the local management. They will determine root cause and responsibility of the accident or incident. If the investigation determines that the accident or incident was “preventable” and is therefore the responsibility of the employee, the employee will be charged with the applicable safety points. Any damage to ATTACHMENT 2
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company equipment will be assessed to the most recent operator who used the vehicle/equipment, who failed to report the damage as required by company policy, and/or failed to annotate damages on the daily vehicle inspection report.

Any employee who is involved in a major incident (see guidelines below) will be placed on administrative leave, pending investigation.

Any employee who is involved in a preventable accident or incident will be subject to retraining and disciplinary actions, up to and including termination. Retraining must be performed before placing the employee back in service. This determination will be based on the safety point system and the severity of the accident or incident as defined below.

MAJOR SAFETY INCIDENTS
A major incident is one involving any vehicle which is owned or operated by MTM Transit or occurring on MTM Transit property. For disciplinary actions and reporting purposes, major safety incidents include but are not limited to the following:
• Fatality
• Passenger incident or injury involving improperly securing a passenger • Preventable roll-away incident
• Unsafe act resulting in a major injury or property damage • Preventable environmental spills
• Vehicle roll-over/lay-over
• Vehicle fire
• Incidents with employee or operator allegation of negligence of equipment or maintenance failure
• Incidents where employee or operator drug and/or alcohol use may be involved Major traffic violations include, but are not limited to, any citation that occurs in a company or personal vehicle involving:
• Driving under the influence of alcohol or drugs
• Hit and run accidents (including hit and run of unattended vehicles) • Open container; possession of a controlled substance
• Failure to stop for or immediately report an accident • Reckless and careless driving; excessive speeding
• Driving while impaired
• Filing a false accident report
• Homicide, manslaughter, or assault involving the usage of a vehicle • Driving with a revoked or suspended license
• Attempting to evade a police officer
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MINOR SAFETY INCIDENTS
Minor safety incidents are defined as other incidents that do not meet the definition or criteria of a “major” incident.

SAFETY VIOLATION POINT ASSESSMENTS
The table below details specific safety violations and the associated point values:

Safety Violation Points
Non preventable accident/incident 0
Unsafe maneuvers or acts 1
Traffic camera violations 1
Speeding 1
Failure to perform a complete and thorough vehicle inspection 1 Failure to perform door-to-door ADA service when required 2 Backing incident 2
Conviction of minor traffic violation 2
Preventable accident/incident without any damage 1
Preventable accident/incident with less than $500 damage to our vehicle 2 Preventable accident/incident with less than $2,000 damage to our vehicle 3 Preventable accident/incident with less than $10,000 damage to our vehicle 4 Preventable accident/incident with greater than $10,000 damage to our vehicle 6 Using a cell phone or non-approved electronic device while operating a company vehicle 6 Failure to stop at a railroad crossing 3
Failing to deliver/hand off customer to approved caretaker when required 6 Failure to immediately report a citation, accident/incident in company vehicle 6 Any preventable roll-away incident 6
Failure to secure/transport a wheelchair and/or mobility device 6 Tampering with, disabling, or otherwise interfering with onboard or other monitoring equipment
6 Receiving a speeding citation for 15mph or above the speed limit in a company vehicle 6 Major preventable accident/incident (examples above) 6
Conviction of a major traffic violation (list above) 6
Hitting a pedestrian with a vehicle 6
Most incidents that occur will be addressed by the Safety Points Program. If a situation falls outside the Safety Points Program, MTM Transit has the right to impose discipline, up ATTACHMENT 2
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to and including termination, in the event of an unsafe act, failure to follow company policies and guidelines involving safe work practice and/or procedures, or negligent operation of any company vehicle or equipment occurs. These guidelines would be imposed regardless of the point values assessed under the Safety Point System. Behaviors that are deemed as unsafe acts are also subject to disciplinary action regardless of whether injury to employee or passenger occurs. Discipline of this nature will be reviewed and approved by the VP of Operations, Regional VP, Director of Safety Administration, and People and Culture.
\MAXIMUM ALLOWABLE STANDARD
MTM Transit’s maximum allowable points are as follows:
f New Employees within Introductory Period: Receipt of four (4) or more points will result in termination. Any new employee who receives two (2) or more occurrences within the introductory period will result in termination regardless of total point accumulation.
f Employees beyond the Introductory Period: Receipt of six (6) or more points within an 18-month rolling calendar will result in termination. Any employee who receives three (3) or more occurrences within an 18-month rolling calendar will result in termination regardless of total point accumulation.

The Safety Points listed above are subject to change based on contracts and/or CBA within each location.

Accident/Injury
All employees are responsible for their own safety, as well as protecting the safety of their fellow colleagues and passengers of MTM Transit. Employees are expected to participate in the safety and health program, which includes immediately reporting accidents, hazards, and unsafe work acts and conditions to local management.

If you are injured or experience an at-risk occurrence on the job, the incident must be reported immediately to local management. An Accident/Injury Form must be fully completed, signed by you and local management, and submitted to the Director of Safety Administration, People and Culture, and Risk Management within 12 hours of the incident. Failure to report an accident will result in assigned safety points, as defined above.

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If required, an appointment will be scheduled for you with a physician at MTM Transit’s workers’ compensation facility. You may obtain a second opinion at your expense.

Circumstances surrounding an injury will be fully and fairly investigated to determine the root cause(s) of the injury. Due to reasonable timeframe issues, if you do not seek medical attention within three business days of incident, MTM Transit may refuse your request to seek medical attention.

All employees must have a signed Wellness Waiver on file prior to using any on-site MTM/MTM Transit fitness equipment.
\ON THE JOB INJURIES
Employee Injury or Employee Exposure
The term “injury” is used to identify both employee injury and employee exposure.

Employee injuries need to be investigated and treated like a collision investigation.

OSHA Injury Reporting Rule Change
The Occupational Safety and Health Administration’s (OSHA) Final Rule on Recording and Reporting Occupational Injuries and Illnesses, effective as of December 1, 2016 says that “no employee will be retaliated against or suffer any adverse action for reporting a work related injury or illness”, which implies that no employee can be drug or alcohol tested for reporting an employee injury unless they meet the testing threshold because of their involvement in an accident with passengers or other vehicles or because they meet the drug and alcohol testing guidelines under reasonable suspicion.

All employee injuries are established as being Preventable or Non-Preventable in nature.

When establishing whether the injury is Preventable or Non-Preventable, the following will be taken into consideration:
• The type of injury
• Degree of injury; how it occurred
• Pre-injury action of the employee involved
Circumstances surrounding the injury will be fully and fairly investigated to determine the root cause(s) of the injury.

Non-Preventable Injury
Any injury that warrants reporting, yet there were no employee actions that contributed to the injury.

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Preventable Injury
Any employee injury in which the employee failed to do everything possible to prevent the injury from occurring.

Note: An employee involved in a preventable injury will be placed on administrative leave pending completion of an investigation and completion of the required retraining. Safety points may be assessed as appropriate.

When the investigation is completed, an appropriate action will be taken. Appropriate action may include written warnings, suspension, termination, and/or retraining. When an investigation of a collision reveals that suspension or termination is the correct action, or events are so severe that termination based on the event is appropriate, then prior to acting, operators of company vehicles will be suspended pending a decision regarding termination. All suspensions are served with no pay and there is no PTO time allowed for suspension due to a preventable injury. Any mandated retraining time is payable at the employee’s normal pay rate.

Injury Retraining
If an injury is deemed preventable, a certified trainer will perform retraining. The trainer will thoroughly review the injury and its root cause(s) with the employee. The trainer will provide retraining appropriate for the injury type. Employee must be retrained before returning to his/her assigned job. Recommended retraining must be determined and documented. A minimum of one (1) hour of retraining encompassing the root cause of the injury must be reviewed with the injured employee. A return to the scene of the injury and discussion with the employee to discuss employee behavior(s) that contributed to the injury and how to prevent future injuries may be held.

General Guidelines
Any employee convicted with a felony or misdemeanor, or any sexually related offense either on-duty or off duty, is required to inform local management immediately, if possible, but no later than prior to the next scheduled work shift.

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Note: This does not apply where it conflicts with state laws. Operators and safety sensitive employees are required to report all DUI or DWI related charges, vehicular collisions, and any traffic citations and convictions (except parking violations) received in any vehicle immediately, if possible, but no later than prior to their next scheduled work shift. Citations received while driving a MTM Transit vehicle must be reported immediately. Failure to report known citations could lead to disciplinary actions.

Weapons Free Workplace
MTM Transit strives to provide a safe work environment for all employees. It is a violation of policy for any employee to possess and/or use a firearm or other weapon while on MTM Transit premises and/or on duty. Employees who violate this policy will be subject to disciplinary action, up to and including termination of employment. \SECURITY AND SAFETY
Security
Only authorized employees of MTM Transit are permitted to access MTM Transit buildings and work areas. This is to ensure employee safety, protect MTM Transit equipment and property, and to comply with HIPAA privacy and security standards.

All visitors to MTM Transit facilities must sign in and out using the visitor log and complete a HIPAA Confidentiality Agreement at the reception or sign in desk. Where appropriate, all visitors should be issued a visitor badge that must be returned at the end of the visit. Visitors are strictly prohibited from being unsupervised while visiting MTM Transit buildings and work areas.

Safety at the Facility
Employees are asked to observe the following regulations:
• Employees using a vehicle owned or operated by MTM Transit are not permitted to transport family or friends at any time
• Park your vehicle only in the employee designated building parking lot(s) • Do not park in designated visitor spaces
• Do not park in designated handicap spaces unless vehicle is identified as such • Do not exceed driving at 5 mph either in the in the parking lot entrances or any part of the lot
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• Do not have weapons, liquor, or other contraband in your vehicle at work • MTM Transit cannot be responsible for any damage to vehicle caused by an accident on company property, including parking lots
• MTM Transit will not release copies of videos unless court ordered

GENERAL GUIDELINES FOR VEHICLE OPERATORS
The following guidelines have been established for employees who operate company vehicles:

1. Employees who have a condition which could affect the safe operation of a motor vehicle are prohibited from operating MTM Transit vehicles.

2. All employees operating a MTM Transit vehicle must display a picture ID and must be a minimum age of 21 years.

3. No employee shall operate a MTM Transit vehicle unless in possession of a valid driver’s license and certificate of the appropriate class endorsed for passenger transportation required by federal, state, or local government entities, or by the client.

4. All operators must possess a CDL if required for the vehicle and/or client.

5. It is the employee’s responsibility to keep such licenses and permits current and valid. An employee who does not have a current and valid license will be suspended without pay to renew such license. Employees will be given no longer than three (3) business days to renew the license. If the appropriate documentation is not submitted within five (5) business days, employment will be terminated.

6. Failure at any time for any reason to maintain a valid driver’s license and any certificates required by federal, state, or local laws to operate company vehicles will be just cause for immediate discharge. Similarly, employees who operate MTM Transit vehicles without a valid driver’s license or certificate will result in the immediate termination of their employment.

7. As a condition for continuing employment, employees must meet the minimum background check standards listed below. Disqualifiers include:
• Driving while intoxicated (DWI), or driving under influence (DUI) within ten (10) years of start date
• Manslaughter
• Leaving the scene of a collision
• Driving with a suspended or revoked license
• Felonies
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• Possession of a controlled substance
• Failure to report a collision
• Reckless driving/speed contests or making a false accident report • Negligent homicide or assault arising out of the use of a motor vehicle • Careless driving or attempting to elude an officer of the law

8. Any employee arrested, indicted, incarcerated, convicted, or otherwise charged with a felony or misdemeanor, or any sexually related offense either on-duty or off duty, is required to inform his/her supervisor immediately, if possible, but no later than prior to the next scheduled work shift.

NOTE: This does not apply where it conflicts with state laws. Operators and safety sensitive employees are required to report all DUI or DWI related charges, vehicular collisions, and any traffic citations and convictions (except parking violations) received in any vehicle immediately, if possible, but no later than prior to their next scheduled work shift. Citations received while driving a company vehicle must be reported immediately.

9. Employees must abide by all federal and state requirements relating to the position they hold at MTM Transit.

10. Employees are required to complete a pre-trip inspection and fill out a DVI Report prior to departing on scheduled runs. Employees are also responsible for ensuring that the full emergency kit and biohazard or spill kit (where appropriate) and all wheelchair securement straps assigned to each vehicle are checked daily, according to the DVI pre-trip procedure.

11. Unless directed by Dispatch, it is a violation of policy for employees to use routes other than the prescribed routes established by the applicable manifests.

12. Employees must be familiar and proficient with all mobility device handling and securement procedures. Failure to properly secure any mobility assistance device or wheelchair, or failure to properly secure any passenger or to properly load, transport, or unload mobility impaired passengers in a company vehicle will result in disciplinary action, up to and including termination of employment.

13. As a condition of employment, all vehicle operators will be required to successfully complete a ride-along evaluation on a yearly basis with a qualified trainer.

14. Moving violations and accidents that appear on an operator’s MVR are on a 36-month rolling calendar due to insurance guidelines. (Note that the date used is the “conviction date” NOT the violations date.
**Risk Management and MTM Transit’s guidelines for Driver’s Motor Vehicle Records are subject to change and will always supersede Safety Guidelines.

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SAFETY AND EMERGENCY PROCEDURES IN A COLLISION
It is especially important to know what to do during an emergency, to know the procedures to follow, and how to contact someone for help. \MTM TRANSIT’S DEFINITION OF COLLISION AND/OR INCIDENT
A collision is contact with any object, vehicle, or person in which any damage has been incurred by either party involved.

An Incident is any collision in which no damage is incurred by either party involved, or any other miscellaneous damage incurred while not operating the vehicle. Incidents also include slips, trips, and falls by customers on the vehicle and during boarding and alighting.
\DOT / FTA DEFINITIONS FOR A COLLISION
Collision with vehicles is an incident in which a vehicle strikes or is struck by another vehicle. Collision with people is an incident in which a vehicle strikes a person (suicides not included). Reports to FTA /DOT are made if the collision results in a death, an injury with immediate treatment at a medical facility, or property damage over $25,000.00. All FTA reportable incidents are referred to as National Transit Database (NTD) reportable incidents and must be reported to the FTA’s NTD database by each of our clients or by MTM Transit if the client designates us to report them.

The primary responsibilities of a MTM Transit operator during an emergency procedure is to protect oneself and the customers on the vehicle and then to protect the vehicle and company property.
\COMPANY PROCEDURES TO FOLLOW AFTER A COLLISION / INCIDENT

1. An incident or collision happens.

2. Vehicle Operator pulls the vehicle over and asks any onboard passengers if they are okay.

3. Incident is called in to Dispatch.

4. Dispatch notifies Police or 911 as needed and depending on severity.

5. Supervisor or Manager investigates if possible after they are contacted by Dispatch.

6. Supervisor contacts the GM or Project Manager.

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7. Vehicle Operator puts out warning triangles and takes cell phone pictures of damages and the surrounding area of the incident occurrence.

8. Operator must return to base and complete paperwork with a supervisor or management before leaving work.

9. If a claimant is transported from the scene to a medical facility due to injuries a safety supervisor follows up later at the medical facility to check on their condition.

10. Supervisor or manager contacts Director of Safety Administration

11. Investigation is completed at the scene. The Vehicle Operator will be drug and alcohol tested (if required per FTA testing guidelines).

12. Vehicle Operator completes his/her incident paperwork with Supervisor before leaving work if they have not already been relieved to do so.

13. For all new incidents and collisions, fill out the CBCS loss reporting form and email it to [email protected] within 12 hours. The subject line of your email should indicate if the report is a record only. Urgent claims with significant injury or major damage during CBCS business hours (8:00 AM – 5:00 PM Central Time) should be called in to Drew Inmon at 563-585-8856. Urgent claims with significant injury or major damage that occur after CBCS business hours should be called into the CBCS afterhours line at 877-241-6121. The afterhours line should only be used to report urgent claims that require immediate assistance. The follow-up accident reporting paperwork needs to be emailed to Risk Management, Senior Manager of Risk Management, and the Director of Safety Administration.

14. All workers compensation claims need to be email reported to [email protected] within 12 hours and the paperwork emailed to Risk Management, Senior Manager of Risk Management, Legal and the Director of Safety Administration.

15. All accident and injury paperwork is processed and prepared by safety manager or GM and sent to Risk Management and corporate safety.

16. GM submits paperwork to client.
\EMERGENCY MANAGEMENT
If an emergency occurs, operators, as leaders, must take actions necessary to protect customers, themselves, and their vehicle. Fortunately, we are not confronted with handling fires, robberies, and other emergencies every day. No two emergencies are the same. Experience is the only way to gain knowledge of how to behave in an unfolding emergency. In an emergency, immediate action must be taken.

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Four types of emergencies that can be encountered are:
• Fires
• Medical emergencies
• Threats of violence and robbery
• Collisions
Manage emergencies by practicing the Seven Basic Emergency Management Steps:

1. Remain Calm

2. Assess the Situation

3. Protect the People, then Property

4. Obtain Help – Call Dispatch

5. Reassure and Assist Customers

6. Secure the Scene

7. Gather Information
Emergency First Aid
If involved in a personal injury collision and no emergency medical personnel is on the scene, try to help the victims. If emergency medical assistance is already on the scene, follow their instructions and pay close attention to the road and traffic control officers.

Basic first aid should be used if emergency help is not immediately available. Remember to call 911 only when needed. If basic first aid is required:
• Administer basic first aid
• Try not to move injured persons
• Perform CPR, if necessary, if trained
• Apply pressure to wounds to stop bleeding
• Cover the victim with a blanket or a coat to maintain body temperature and help prevent shock
Emergency Evacuation
The first and most important responsibility is to protect customers and yourself. In case of fire or collision, a speedy evacuation could be critical. If evacuation is required, follow these steps:
• Get everyone’s attention and tell them that there is a chance of fire or there is a fire; tell them that they will have to leave the vehicle • Give clear directions and point where to go
• Verify the direction given is safe
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• Direct the evacuation; use hand signals if needed
• Be calm and give instructions to assist customers off the vehicle; do not to pull them
• Account for all customers
• Ask a customer or passerby to lead the group to the designated place; if possible, move customers at least 100 feet from the vehicle
• Keep customers in a group and as far away from the vehicle and traffic as possible • Do not allow smoking near the vehicle
• If the vehicle has a lift, remember the lift will not work with the power off • It may be necessary to cut or remove all customer restraints and leave mobility devices behind
• It may be necessary to carry or drag a customer with a disability from the vehicle • Direct other customers to assist if necessary and possible • If someone refuses to leave the vehicle, be prepared to drag them off • To eliminate confusion and misunderstanding during radio communications, the use of 10 codes will be minimal; the preferred method for communication is through common spoken word
Any employee who is involved in a major incident will be placed on administrative leave pending investigation.

The operator’s contribution to the cause of the injury or collision will be considered when assessing safety points. The Safety Points Policy and/or discipline will apply.

TRANSPORTING PASSENGERS WITH DISABILITIES
The Americans with Disabilities Act of 1990 (ADA) prohibits discrimination and ensures equality of opportunity and access for people with disabilities. It provides the general framework and approach for ending discrimination to people with disabilities.

It is MTM Transit’s policy to ensure a non-discriminatory, accessible, and safe transportation service to our passengers with disabilities. Employees are always required to treat all passengers, including those with disabilities, with courtesy and dignity.

Violation of this policy is subject to disciplinary action, up to and including termination of employment.

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Operators who transport passengers with disabilities should have basic knowledge about the disability of the passenger(s), to ensure that they are transported safely and appropriately.

BLOODBORNE PATHOGENS PROTECTION
The Federal OSHA Bloodborne Pathogen Standard was designed to reduce and minimize the potential for occupational exposure to the Human Immunodeficiency Virus (HIV), the Hepatitis B Virus (HBV), and other human bloodborne pathogens (BBP).

BBP are micro-organisms that live in blood and certain body fluids and have the potential to cause serious diseases. BBP can live and breed in:
• Blood
• Semen and vaginal secretions
• Amniotic fluid in pregnant women
• Any other fluid or body part that is visibly contaminated with blood or body fluids Some of the BBP that our operators could potentially be exposed to at work include:
• HIV/AIDS – Acquired Immune Deficiency Syndrome. No vaccine or cure is currently available
• Hepatitis B – Also called HBV, most common strain of hepatitis. Vaccine and treatment are available.

To avoid exposure and possible infection, all employees are trained in universal precautions, and are required to attend the bloodborne pathogen training program. The course will inform employees about precautions to be taken to eliminate the risk of infectious diseases that can be contracted through exposure, and the proper methods of handling potential contaminants.

In the event of a BBP situation due to a vehicle accident, onboard injury, or a passenger in need, the following steps should be followed:
• Notify Dispatch that a situation has occurred
• Obtain first aid and assistance by contacting 911 if needed • Use clean-up kit equipment (latex gloves) around the injured passenger • Follow the clean-up procedures in the BBP Kit
• When clean-up is completed, wash hands thoroughly with soap, disinfectant, and hot water ASAP
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4. AMERICANS WITH DISABILITIES ACT (ADA)
The ADA law is a civil rights law which prohibits discrimination against people with disabilities. By enacting the Americans with Disabilities Act of 1990 (ADA) (Revised 2009, 2011), Congress intended the act to “provide a clear and comprehensive national mandate for the elimination of discrimination against individuals with disabilities.”

PERSON WITH A DISABILITY
ADA Definition
• Person with a physical or mental impairment that substantially limits one or more major life activities
• Person perceived or regarded as having a mental or physical impairment that substantially limits one or more major life activities
• Person having a record of a mental or physical impairment that substantially limits one or more major life activities
Basic Purpose
• Assures equality of opportunity, full participation, independent living, and economic self-sufficiency for individuals with disabilities Employee Training
• Personnel must be trained on ADA guidelines and requirements • Vehicles and equipment must be operated safely
• Level of service must be provided as required by ADA guidelines and requirements • All individuals with disabilities must be treated in a respectful and courteous way Boarding/Alighting Time
• Adequate time must be allowed for boarding/alighting of customers with disabilities
• Adequate time shall include time for customers to get to a seat • All passengers shall board in no specific order

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Lift and Securement Use
• All wheelchairs must be transported if the wheelchair fits in the vehicle • Securement system is permitted to secure wheelchair
o Service shall not be denied based on difficulty in securing the wheelchair, or because the securement is not effective or satisfactory according to company policy
• Anyone requesting to use a vehicle lift must be permitted to use the lift to enter the vehicle
• Each securement location must have a 4-point customer restraint system • If customers are required to use a seat belt restraint, only a customer lap/shoulder restraint (seat belt) can be required
• Individuals may be transferred from wheelchair to vehicle seat • If necessary or requested, operators must assist with use of:
o Securement system
o Ramp
o Lift
• Assistance must be provided even if the operator must leave his/her seat to help Maintenance of Lifts
• MTM Transit follows a regular and frequent lift maintenance program • Operators must report non-operating lifts as soon as possible • Every effort must be made to repair lifts before the next day of service • Inoperable lifts must work before vehicle is returned to provide service UNLESS no spare lift is available
• Maintenance must be performed no more than three (3) days in urban areas (>50,000)
• Maintenance must be performed no more than five (5) days in rural areas (<50,000)
• If headways exceed 30 minutes on routes with an inoperable lift, alternative transportation must be provided, which includes but not limited to:
o Accessible supervisor vehicle
o Paratransit vehicle
o Another bus
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Mobility Aids and Life Support Systems
• Service animals must be allowed to accompany customers • Customers must be permitted to travel with life support equipment, including but not limited to respirators and portable oxygen
Refusing Service to Customers with Disabilities
• Service can only be refused, conditioned, or suspended if an individual engages in violent, seriously disruptive, or illegal conduct; behavior that offends, annoys, or inconveniences other customers is not deemed “seriously disruptive” Fixed Route
• Priority seating must be provided to those with disabilities • Other customers maybe be asked to vacate their seat for an ADA customer, but they cannot be forced to do so
Permitting Riders to Disembark
• Individuals who use wheelchairs must be permitted to disembark at any stop unless:
o The lift cannot be deployed
o The lift would be damaged if deployed
o Temporary conditions prevent the safe use of the stop by all customers Announcement of Stops
• Operators must announce stops at:
o Major transfer points with other routes
o Major intersections/destination points and points of interest (landmarks) o Sufficient intervals along the route to permit orientation of customers o Any stop requested by the customer
Identifying Vehicles and/or Customers
• At stops that service more than one route, verbal or other communication is required to identify vehicle and identify customers seeking to ride on their vehicle • Always facilitate the communication process
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5. CUSTOMER SERVICE, WHEELCHAIR/MOBILITY

ASSISTANCE, SECUREMENT, AND SENSITIVITY
The objective of this training is to provide instructions on how to maneuver customers using mobility devices, operate the wheelchair lift, board ambulatory customers using the lift, transport customers using mobility devices, and use sensitivity in interactions with customers.

SAFETY RESPONSIBILITY
As providers of transportation services to individuals utilizing mobility devices, it is our responsibility to ensure that all necessary steps are taken to ensure customer safety. This means following all the rules and procedures pertaining to mobility device securement.

There is no room for exceptions when it comes to maneuvering, securing, and transporting mobility devices. You must follow the MTM Transit policy.

PERSONAL SPACE ISSUES/COMMUNICATION
When providing service to customers in mobility devices, communication is a key to our success. Communication enables us to do two things:

1. Obtain information that allows us to safely assist the customer without violating independence

2. Helps us develop a trust factor between the vehicle operator and the customer When assisting customers in mobility devices, it is important to remember to speak directly to the customer. Be sure to address the customer directly – not the caregiver.

Making direct eye contact with the customer goes a long way toward establishing trust. In addition, if the customer is non-verbal, it is essential to observe their response (facial expressions, hand gestures, etc.) to gauge their overall comfort level.

Communicate every action beforehand; sudden movements can be disconcerting for any customer, particularly those in mobility devices. If every action is communicated and approved by the customer, the possibility of misinterpretation will be limited. Develop the habit of asking permission before touching the mobility device. This shows respect for the customer’s right to choose. It should never be forgotten that the mobility device is an extension of the customer. Touching the mobility device without permission is no different than touching the customer without permission.

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When aiding the customer to or from the vehicle, it is a good idea to engage the customer in conversation. This technique gives you the opportunity to gather important information, such as is it the customer’s first time using the service. This information greatly enhances the operator’s ability to provide safe, efficient service. Be sure to keep conversation professional in nature. Avoid discussing personal details such as marital status. Do not develop personal relationships with customers.

When assisting customers onto the lift, it is important to communicate every step in the process. A customer in a mobility device has the right not to be controlled by another person. This is true even for the simple act of reaching around to lock the mobility device brakes. This act has the potential to cause discomfort if the customer is not prepared for the action. Remember, if communication is used prior to action, there will be less potential for misinterpretations.

Securing mobility device customers into securement positions is where the greatest number of personal space issues comes into play. Once again, communication is the key to success. The most sensitive aspect of this procedure is the securement of the lap restraint. It is important to inquire as to whether the customer can secure their lap restraint on their own before making any attempt to do this for them. If you are aware that the customer is not able to secure the lap restraint, it is critical that you bring the belt to its fully extended position as you place it around them to avoid contact with sensitive areas. Along with communication, this technique will help ensure that the operator’s intentions are clear.

Safety Note: No matter if the customer or the operator secures the lap restraint, it is the responsibility of the operator to ensure the restraint is secured properly.

These communication techniques should be used no matter what the perceived level of disability the customer may be. Simply because a customer may be severely disabled does not necessarily mean they are not aware of their surroundings. Communication is the key to any successful trip. If dialogue is continuous, the operator will leave little room for the customer to misunderstand the intent to respectfully perform his/her job duties.

ATTACHMENT 2
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MOBILITY DEVICES
\COMPONENTS OF A WHEELCHAIR
\MANEUVERING CUSTOMERS IN MOBILITY DEVICES
Body Mechanics
Vehicle operators can safely maneuver mobility devices without injury by using proper body mechanics. The following steps apply:

1. Be sure to be directly behind the wheelchair before attempting to move it

2. Position feet shoulder distance apart, with one foot slightly forward

3. Always push instead of pulling

4. Use leg muscle instead of back muscle
Choice of Path
It is important to choose a good path when maneuvering wheelchairs and other mobility devices. Choose the best path for maneuvering. Smooth, firm, dry, and clean paths make maneuvering a wheelchair or mobility device easier. When possible, avoid surfaces that are rough, soft, wet, slippery, or dirty.

Curbs
Maneuvering wheelchairs and other mobility devices up and down curbs is dangerous if the proper procedures are not used. If the service requires that customers be transported up and down steps, be sure you use the actions necessary to accomplish this task safely.

ATTACHMENT 2
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Maneuvering Up a Curb

1. Position the wheelchair facing the curb

2. Slowly push foot down on the tipping lever while pulling down and back on the push handles

3. Pull back far enough until the wheelchair is balanced on its rear wheels and the caster wheels are higher than the curb

4. Roll the wheelchair forward until both rear wheels are in contact with the curb

5. Lower the wheelchair until the casters touch and they are straight

6. Lift up on the push handles and push the wheelchair forward using the strength of legs, not back
Maneuvering Down a Curb

1. Position the wheelchair facing away from the curb (back to the street); lean into the wheelchair

2. With hands gripping the push handles, carefully place one foot onto the lower surface
ATTACHMENT 2
PAGE 39

3. Pull the wheelchair towards your body, slowly backing the rear wheel down the curb using leg muscles; do not use the strength of arms or back, hips may be used to help balance the wheelchair

4. Once the rear wheels are on the lower surface, pull the wheelchair into a neutral balance position; continue to guide the wheelchair backwards until the casters are clear of the curb

5. Place the casters onto the ground straight and continue maneuvering the wheelchair
Safety Note: Always look for alternatives to maneuvering over curbs and steps, even if it means walking a bit further.

Ramps
When maneuvering chairs and other mobility devices up and down ramps, operators should always be positioned on the downside at the customers back. This will allow the chair to be pushed forward up the ramp and back the chair down the ramp.

Multiple Steps
We are to do everything possible to avoid maneuvering customers in mobility devices up and down multiple steps. If a situation is encountered that calls for maneuvering a customer in a mobility device up or down more than one step, contact Dispatch for assistance. Under no circumstances is the vehicle operator to attempt to maneuver up or down multiple steps without assistance.

WHEELCHAIR LOADING PROCEDURES AND LIFT OPERATION
\LOADING CUSTOMERS ONTO THE WHEELCHAIR LIFT
MTM Transit strongly recommends that customers using mobility devices should face away from the vehicle when using the customer lift. The customer can elect to ride the lift in any position they choose. Loading facing away from the vehicle provides the following advantages:

1. Most of the weight is concentrated toward the supported end of the platform; therefore, there is less sway

2. There is less chance that the feet of the customer will get caught in the gap plate as the lift rises to floor level
ATTACHMENT 2
PAGE 40

3. The vehicle operator can maintain better control by having access to the hand grips of the wheelchair

4. The wheelchair is in proper position to be rolled straight backing into the securement position in the vehicle

WHEELCHAIR LIFT OPERATION
These are the steps that should be followed when using the customer lift:

1. Position the vehicle on a level surface where the lift rests on the sidewalk whenever possible

2. Shift vehicle into park

3. Set the emergency brake

4. Turn on the emergency flashers

5. Turn control switch for the customer lift to the lift position (varies depending on model)

6. Ensure the customer is clear of the lift and that their wheelchair brakes are set

7. Open the lift doors, unfold the lift, and lower the lift to the ground

8. Standing in front of the wheelchair, push the wheelchair onto the lift and set the brakes; make sure the chair restraint is in the up position on the lift platform

9. Secure the restraining belt on the lift (if equipped with one)

10. Raise the lift a couple of inches off the ground and check end safety flap to ensure it is locked

11. Raise the lift to the floor level with one smooth operation

12. Release the brakes and push the wheelchair over the threshold partially into the vehicle and reset the brakes.

13. Re-enter the vehicle

14. Unlock the brakes on the wheelchair, keeping a hand on the wheelchair

15. Pull the wheelchair back into the vehicle, off the lift

16. Once inside, move to the front of the wheelchair and guide it into position for securing

17. Lock the brakes when position properly and proceed to secure the chair with the securement system. Four belts must be used to tie down the mobility device and the seat belt and shoulder harness must be used to secure the passenger

18. Before returning to the operator seat, check all belts and securement points for tightness and proper alignment
ATTACHMENT 2
PAGE 41

MANUAL LIFT OPERATION
If the power to the lift malfunctions, it is important that vehicle operators know and understand how to manually operate the lift. This procedure for manual operation varies depending upon the manufacturer and model of the lift in use. Please refer to your trainer and vehicle for instructions.
\SECURING CUSTOMERS IN MOBILITY DEVICES
Four Point Securement Process
All mobility devices must be secured using a four-point securement system. Two of the securement straps must be ratchet types. Straps must be fastened to the frame of the chair; never fasten straps to the wheels.

1. Attach one end of the securement strap to the rear floor and secure the other end to a solid part of the wheelchair frame as high as practical (the goal should be to form a 45-degree angle between the straps, the floor, and the chair).

2. Tighten the straps while pulling the chair toward you. Move to the other side and secure the straps in the same manner.

3. Pull the wheelchair in the direction of the securement tightening the strap until all the slack is removed.

4. Test for tightness by trying to move the wheelchair back and forth. The back-andforth method allows for a backward and downward pull on the mobility device.

5. After the rear belts are secure, attach a strap to the front track on each side of the wheelchair. Attach these straps to a solid part of the frame in front of each side and pull them equally tight.

6. Check for any loose fittings, slack, or connections that may not hold. Remove the slack, and if necessary, repeat the process to ensure the securement straps are properly placed.

7. Ask to have the customer use the lap/shoulder restraint.

Powered Wheelchairs
The same principals apply for powered wheelchairs. Please ask the customer to disengage all switches and belts before loading the wheelchair onto the lift. To disengage a powered chair, move the belt release handle on each side forward or backward (depending on model). The belts should release from the pulleys and the wheelchair will be inoperable.

Ask to have the customer use the lap shoulder restraint.

ATTACHMENT 2
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Some powered wheelchairs cannot be disengaged. When this situation occurs, extra caution must be taken to turn off the power and set the brakes firmly once the power wheelchair is on the lift.

Three Wheel Mobility Devices
While attempting to secure a three-wheel mobility device, disengaging the power on most models causes the brakes to automatically come on and it will not move. When attempting to load the customer and the mobility device onto the lift, ask the customer to back the mobility devices onto the lift.

1. Place a lap restraint belt, if equipped, around the customer and the seat before loading onto the lift. Follow the lift securement procedures and lift in one smooth motion.

2. Once the lift has been raised, maneuver the mobility device firmly against the wall or folded seat area on the vehicle.

3. Lock the swivel seat of the mobility device in the forward-facing position.

4. Attach two securement straps to the floor at the rear of the mobility device at a sufficient distance from each side to provide equal pull to the left, right, and rear.

5. Loop these straps through the securement points provided on the mobility device or the seat post near the base.

6. Pull the straps tight.

7. Move to the front of the mobility device and attach the front securement straps to the floor a sufficient distance from the mobility device providing equal pulling from each side.

8. Loop the straps through the securement space provided, or if necessary, place around the steering post. Do not place the straps above any flexible joints which may be part of the steering post.

9. Pull the front straps tight to ensure equal pressure in all four directions.

10. Ask to have the customer use the lap/shoulder restraint.

Other Powered Mobility Devices
If encountering mobility devices that have more than four wheels, or less than three wheels, the same rules apply and are required as with other devices – use a four-point securement to a fixed location on the device and ask to have the customer use the lap/shoulder restraint. For any questions when encountering a new device call Dispatch for additional assistance.

ATTACHMENT 2
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\SAFETY NOTES
Straps are not to be fastened to removable parts of the mobility device, nor are they to be fastened through the spokes of the wheels. Straps should never be crossed from the floor to the mobility device.

Body Mechanics: When tightening straps, kneel, keep back straight, and pull upon the straps to tighten.

Never attempt to lift a mobility device; they are designed to roll.

Shoulder Harness: If the vehicle is equipped with a shoulder harness, it should be secured on all customers using mobility devices.

Transferring Customers from Mobility Devices into Seats Some customers may be capable of transferring from their mobility device to a seat in the vehicle. Customers who choose to transfer may do so, provided they can do it without assistance from the vehicle operator.

The mobility device must be stored and secured in a safe location by the vehicle operator.

This can be accomplished by securing the empty device as if it were occupied.

When transporting customers in mobility devices, vehicle operators need to remember the following facts:

1. Centrifugal force (outwards) is exerted on wheelchairs when the vehicle goes around a corner. The occupant of the chair may feel he or she is being pulled forward out of the chair, or that the chair may tip backward, depending upon the direction of the turn.

2. Slow, steady turns must be made; 5 MPH is maximum speed on a turn. Do not brake in the turn process. Brake before the turn then lightly accelerate during the turn.

3. Wheelchairs pick up road shock each time the vehicle hits a bump. Care and judgment are needed to avoid unnecessary bumps or potholes. If a road is unavoidably bumpy, slow down and ease the vehicle through.

4. Stopping and starting the vehicle exerts pressure on the sides of the wheelchair and its occupant.

5. Fast movement in either direction may bruise or injure a customer if they are thrown sideways against the armrest of the wheelchair.

ATTACHMENT 2
PAGE 44

6. Vehicle starts should be steady and even. Stops should begin back far enough to prevent the customer from feeling a hard backward movement.

The bottom line for driving a vehicle carrying mobility devices is to strive for smoothness and safety. Smoothness is a product of proper speed for all conditions. Vehicle operators should place safety first and schedule second to avoid driving too fast for safe transportation of customers in mobility devices.

Ambulatory Customer Boarding Using the Lift
Any person requesting the use of the lift must be allowed to use it. When ambulatory customers request boarding, the following steps are to be followed:

1. The vehicle should be positioned so the lift will rest on level ground

2. Instruct the customer to stand on the lift; we recommend that customers stand and hold onto the grab rails, facing the vehicle

3. Be sure to notify the customer before raising the platform

4. Notify the customer that your hand will be placed just behind their back as a safety precaution while operating the lift, to prevent a fall Bus Kneeling Procedure
All vehicles equipped with a kneeling feature should be used in the following manner:
• Place the vehicle in park and set the parking brake
• The vehicle should be positioned so it will be above level ground • Notify the customer prior to lowering the height of the coach • Be sure to lower the vehicle completely before allowing customers to board • Raise the bus back to normal height prior to moving bus and resuming travel Wheelchair/Mobility Device Securement Policy
The objective of this policy is to have “zero” injuries and incidents to our customers from unsecured or improperly secured mobility devices.
\RESPONSIBILITY
The procedures discussed in this policy are to be considered as the minimum acceptable standard to be followed. It is the responsibility of all vehicle operators to ensure that all mobility devices are secured from uncontrolled movement prior to placing the vehicle in motion.

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It is also the responsibility of local management team to advise, instruct, and enforce the policy as well as provide the necessary materials and training to enable employees to adhere to this policy.
\POLICY
The customers who ride in our vehicles depend on us for safe, caring, reliable transportation. Therefore, vehicle operators are to ensure that all mobility devices (wheelchairs, 3-wheel devices, etc.) are secured from uncontrolled movement prior to placing their vehicle in motion. All mobility impaired customers using such devices are to be loaded, secured, and transported and unloaded according to company policy and training.
\DISCIPLINARY ACTIONS
Any vehicle operator who fails to perform to this policy in securing, loading, transporting, or unloading any customer using a mobility device will be subject to discharge regardless of injury or non-injury to any customer. All incidents of this type will be investigated and reviewed prior to any action taking place. See more about this in the safety points section.

ATTACHMENT 2
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APPENDICES
Appendix A Sample Operator Job Description
Appendix B Fundamental Safety Practices Quiz
Appendix C Training Acknowledgement
ATTACHMENT 2
JOB TITLE: Driver ;KƉĞƌĂƚŽƌͿ
CLASSIFICATION: Non-Exempt (hourly)
ORGANIZATION: MTM Transit
LAST UPDATED: 03/26/2020
Position Summary
The Driver ;KƉĞƌĂƚŽƌͿ is responsible for providing Paratransit and/or Non-Emergency Transportation services in a safe and reliable manner. The Driver will ensure the customer and client receive the highest degree of courtesy and professionalism. This work is done in compliance with the procedures defined by the client and in conformance with company procedures.

Essential Functions
x Provide safe and reliable transportation
x Demonstrate excellent defensive driving skills
x Provide excellent customer service to both internal and external stakeholders x Must assist with passenger loading and unloading from vehicle x Must assist with any mobility device and securement as required for safety protocols x Ensure the on-time pick-up and drop off of the customer x Demonstrates understanding and sensitivity to the needs of older adults and individuals with disabilities x Complete thorough vehicle pre-trip, post-trip, and DVI inspections as required x Complete paperwork as required
x Utilize tablets or electronic devices as required
Knowledge, Skills, and Competencies
x Ability to use a tablet, GPS, two way radio, or other electronic device x Ability to maintain high level of confidentiality
x Ability to communicate with others and comprehend instructions x Ability to understand highway traffic signs, signals, maps, manifests, and schedules x Ability to obtain knowledge of FTA, ADA, and DOT regulations x Familiarity with the main roadways and major highways in the service area Required Education and Experience
x High school diploma or G.E.D. equivalent
x Must meet the minimum age requirements as specified by the contract x Possess a continuously valid US driver’s license for the length of time required by the contract x Possess valid authorization to work in the United States x Must possess the required type of driver’s license per the client contract x No suspensions, DUI, or citations in length of time specified by the contract x Must be able to pass DOT physical and pre-employment drug/alcohol screening x DƵƐƚƉĂƐƐĐƌŝŵŝŶĂůďĂĐŬŐƌŽƵŶĚĐŚĞĐŬŝŶǀĞƐƚŝŐĂƚŝŽŶ
APPENDIX A – SAMPLE OPERATOR JOB DESCRIPTION
ATTACHMENT 2
Working Conditions
x This job operates in a professional work environment
x This role requires driving a variety of vehicles including but not limited to vans and cutaway buses x Normal setting for this position is outdoors and/or driving a video/GPS monitored vehicle x May be subject to adverse weather conditions during times of travel, transfer of clients, and vehicle inspections
x Exposure to a physical environment, which involves dirt, odors, noise, weather extremes or other elements x Driving during all hours of the day including at night and low levels of visibility Physical Requirements
x Requires sitting in and operating a vehicle for prolonged periods of time x Requires close visual acuity when operating a computer and motor vehicle x Requires pushing, pulling, bending, twisting and lifting a minimum of 50 pounds x Must be able to move within and around a vehicle, including kneeling, stooping, bending, and squatting x Must be able to push, pull, and secure a wheel chair or other mobility device with or without individuals of various statures and sizes
Supervision
x This position does not involve supervision of direct reports ATTACHMENT 2
Acknowledgement
I have read and understand my position description and certify that I understand the requirements of the essential functions and duties of the position and will fulfill the stated expectations:
____without accommodations
____with the following accommodation(s): ____________________________________________________________ Equal Opportunity Employer: MTM is an equal opportunity employer.

If you are in need of accommodations, please contact People & Culture at (636) 561-5686.

Employee Name (print):

Employee Signature: Date:

Supervisor Name (print):

Supervisor Signature:

Title: Date:

This job description in no way states or implies that these are the only duties to be performed by the employee occupying this job. Employees may be required to follow other job-related instructions and to perform other jobrelated duties as requested, subject to all applicable state and federal laws. Certain job functions described herein may be subject to possible modification in accordance with applicable state and federal laws.

Original: Human Resources
Cc: Employee’s Supervisor
Employee
ATTACHMENT 2
PAGE 48

APPENDIX B - FUNDAMENTAL SAFETY PRACTICES QUIZ
Fundamental Safety Practices Quiz
Name: __________________________________

1. What does an operator use to keep a vehicle centered in the roadway or to position a vehicle 6 to 12 inches from the curb, to avoid an accident when making a turn, and to avoid striking objects when backing?
A. Reference Point
B. Lucky Charms
C. Hindsight
D. A Spotter

2. According to company policy, the maximum allowable vehicle speed when making a turn is:

A. 5 MPH
B. 35 MPH on right turns and 25 MPH on left turns
C. 55 MPH
D. No Specific Speed

3. “Rocking and rolling” in the operator’s seat prior to making a turn means to what? A. Turn the vehicle radio to 97.3
B. To move around in the operator’s seat to see around obstacles and eliminate blind spots
C. To imitate Elvis by swiveling one’s hips
D. It is a slang term for listening to CD’s while driving

4. (Heinrich Theory) 300:29:1 means what?
A. For every 300 unsafe acts or near misses, there are 29 minor accidents, and 1 catastrophic accident
B. Theory of light speed vs. sound speed
C. For every 300 hours, 29 babies are born
D. 330
ATTACHMENT 2
PAGE 49

5. In the spaces below, write out the four principles of Defensive Driving from TAPTCO’s LLLC program.
______________________________ ______________________________ ______________________________ ______________________________

6. The purpose of mirror adjustments is to enable the operator to:

A. See adults and other pedestrians around the vehicle
B. See vehicles and objects around the vehicle
C. Eliminate blind spots around the vehicle
D. All the above

7. According to MTM Transit policy, the minimum allowable following distance is:

A. 2 seconds
B. 2 seconds, except at high speeds where 6 seconds is allowed C. 4 seconds
D. 30 seconds

8. While driving, following distance can be measured by:

A. The number of tractor trailer lengths between cars
B. Counting the seconds for when the vehicle immediately in front of you passes a fixed object until you pass the same fixed object
C. Adjusting your speed so that each desired second of following distance is equal to 10 MPH (for 2 seconds, drive 20 MPH)
D. Counting to 10 and dividing by 2

9. Stopping distance is increased by:

A. Following distance
B. Adverse weather conditions
C. Line of sight
D. Traffic conditions

10. How often are pre-trip vehicle inspections performed? A. Daily
B. Prior to a vehicle going into service
C. Every 1500 miles
D. Monthly
ATTACHMENT 2
PAGE 50

11. What is the most dangerous location for a vehicle to be? A. Wal-Mart parking lot
B. Freeway on ramps
C. Intersections
D. Straight, dry highway

12. You should do what before entering an intersection? A. Let it clear
B. Proceed only after the light turns yellow
C. Stop, look, and listen
D. Look in the rear-view mirror

13. A Space cushion gives the operator time to:

A. Hide
B. Take defensive action
C. Take evasive action and back up
D. Call Dispatch and ask for directions

14. When approaching an intersection, always expect:

A. Trouble
B. The police
C. An ambulance
D. A bus stop

15. To cover your brake means to:

A. Make sure that the brake pedal is covered by a rubber pad B. Place your foot over the brake in anticipation of the need to brake C. Refers to a type of maintenance performed on your vehicle

16. To eliminate blind spots an operator should:

A. Rock and roll
B. Get out and walk around
C. Call Dispatch and get a spotter
D. Put sunglasses on
ATTACHMENT 2
PAGE 51

17. To be safe, an operator should always drive:

A. Offensively
B. Defensively
C. Slow
D. Fast

18. To drive defensively means that an operator:

A. Anticipates that other operators will do what is right or safe B. Anticipates that other operators will do what is wrong or unsafe C. Does not anticipate what other operators will do
D. Is only concerned with his or her own driving

19. List the Five Areas of a pre-trip inspection
______________________________ ______________________________ ______________________________ ______________________________ ______________________________

20. Safety means _______________ of _________________from unintentional harm.

ATTACHMENT 2
PAGE 52
Fundamental Safety Practices Questionnaire – Answers

1. A

2. A

3. B

4. A

5. Look Ahead
Look Around
Leave Room
Communicate

6. D

7. C

8. B

9. B

10. B

11. C

12. A

13. B

14. A

15. B

16. A

17. B

18. B

19. Operator (Driver) Compartment
Customer Compartment
Brake Check
Exterior
Tires / Wheels

20. Freedom/Risk

ATTACHMENT 2
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APPENDIX C – TRAINING ACKNOWLEDGEMENT
Employee Safety and Training Manual – Training Acknowledgement I certify that, as an employee of MTM Transit, I have read this manual and understand my responsibilities in the following areas:
• Safety related to MTM Transit employees
• MTM Transit’s Safety Culture
• Heinrich’s Pyramid – 300-29-1
• LLLC Defensive Driving
• 18 Safe Behaviors
• Customer Service
• Customer Interaction Policy
• Emergency Procedures/Communications
• Radio Communication Policy
• Fundamental Safety Practices
• Defensive Driving
• Americans with Disability Act (ADA)
• Customer Service/Wheelchair and Mobility Assistance/Securement/Sensitivity • Map Reading and Manifests
• Passenger Count
• Transfers
• Fare Handling
I further certify that I have read and that I understand the MTM Transit policies contained in both the Employee Handbook and the TAPTCO New Operators Manual.

I understand that revised information may supersede, modify, or eliminate existing policies, rules, and benefits at any time.

Signature: _______________________________________
Print Name: ______________________________________ Date: ______________ ATTACHMENT 2

Drug and Alcohol Policy
All Transit Locations
(with the exception of Hamilton County, OH)
Zero Tolerance
2023
ATTACHMENT 2
PAGE 1

TABLE OF CONTENTS
TABLE OF CONTENTS ...................................................................................................................................1

1. CHIEF EXECUTIVE OFFICER STATEMENT ...................................................................................................2 2 COVERED EMPLOYEES ..............................................................................................................................3

3. USDOT/FTA PROHIBITED DRUG CLASSES .................................................................................................3

4. PRE-EMPLOYMENT DRUG & ALCOHOL BACKGROUND CHECKS................................................................3

5. PRE-EMPLOYMENT TESTING....................................................................................................................4

6. RANDOM TESTING...................................................................................................................................4

7. REASONABLE SUSPICION TESTING...........................................................................................................5

8. POST-ACCIDENT TESTING.........................................................................................................................5 FATAL ACCIDENTS ..............................................................................................................................................5 NON-FATAL ACCIDENTS ......................................................................................................................................5

9. URINE SPECIMEN COLLECTIONS...............................................................................................................6

10. REFUSAL TO SUBMIT TO URINE DRUG TESTING .....................................................................................7

11. URINE SPECIMEN ANALYSIS...................................................................................................................8 NEGATIVE-DILUTE SPECIMENS..............................................................................................................................8

12. ROLE OF THE MEDICAL REVIEW OFFICER (MRO) ....................................................................................9

13. CONSEQUENCE FOR MRO VERIFIED POSITIVE DRUG TEST ...................................................................10

14. SPLIT SPECIMEN TESTING ....................................................................................................................10

15. ALCOHOL PROHIBITION .......................................................................................................................10

16. ALCOHOL TESTING ...............................................................................................................................11

17. CONSEQUENCE FOR A USDOT/FTA CONFIRMED ALCOHOL VIOLATION ...............................................11

18. REFUSAL TO SUBMIT TO ALCOHOL TESTING ........................................................................................12

19. MTM TRANSIT TESTING PROGRAM CONTACTS....................................................................................13 SUBSTANCE ABUSE POLICY.................................................................................................................................14 SUBSTANCE ABUSE POLICY (UPDATED 04/19/21) .................................................................................................15

20. REFERENCES ........................................................................................................................................16 ATTACHMENT 2
PAGE 2

1. CHIEF EXECUTIVE OFFICER STATEMENT
MTM Transit is dedicated to providing safe, dependable, and economical transportation services to our patrons. MTM Transit’s employees are a valuable resource, and we want to provide a safe, healthy, satisfying working environment. In meeting these goals, it is our policy to:
x Assure employees are not impaired in their ability to perform assigned duties in a safe, productive, healthy manner
x Create a workplace environment free from the adverse effects of drug and alcohol abuse or misuse
x Prohibit the unlawful manufacture, distribution, dispensing, possession, or use of controlled substances; it is the responsibility of the employee to inform MTM Transit of any Federal or State criminal drug statute convictions in writing, within five calendar days of conviction.
x Encourage employees to seek professional assistance when substance abuse adversely affects their ability to perform their assigned duties; employees may access such assistance by contacting our Employee Assistance Program (EAP) at (888) 311-4327.

We established this policy to comply with the Federal Transit Administration regulations codified as 49 CFR Part 655, as amended and USDOT regulations codified as 49 CFR Part 40, as amended. Additionally, the USDOT published 49 CFR Part 32, implementing the Drug-Free Workplace Act of 1988, which requires the establishment of drug-free workplace policies and the reporting of certain drug-related offenses to the Federal Transit Administration (FTA).

Policy provisions authorized by MTM Transit are identified by italicized and bolded (MTM Transit Policy) throughout this document. All other policy provisions are implemented under the authority of the United States Department of Transportation (USDOT) and the FTA.

Per MTM Transit’s authority, violation of this substance abuse policy will result in termination of employment and/or exclusion from hire.

This policy is effective on October 1, 2022.

Name: Alaina Maciá Title: President and CEO
Signature: Date: October 1, 2022
ATTACHMENT 2
PAGE 3

2. COVERED EMPLOYEES
x Operating a revenue service vehicle, whether in or out of revenue service x Control the movement/dispatch of a revenue service vehicle x Perform maintenance on a revenue service vehicle or equipment used in revenue service
x Carry a firearm for security purposes
x May perform any of the above safety sensitive functions in a supervisory or training role.

This policy is applicable to the following positions within MTM Transit:
f General Manager f Maintenance Manager
f Operations Manager/Safety Manager f Mechanics
f Road Supervisor f Utility Personnel
f Dispatch Manager/Supervisor f Drivers
f Dispatcher

3. USDOT/FTA PROHIBITED DRUG CLASSES
Consumption of these drugs is prohibited at all times.
f Amphetamines f Cocaine f Marijuana
f Opioids f Phencyclidine (PCP)

4. PRE-EMPLOYMENT DRUG & ALCOHOL BACKGROUND CHECKS
In accordance with 49 CFR Part 40.25, MTM Transit must make and document good faith efforts to perform drug and alcohol background checks for all applicants applying for a safety-sensitive position and all current employees applying for transfer into a safetysensitive position. Testing information will be requested from each of the applicant’s previous DOT covered employers during the two years prior to the date of application.

MTM Transit must obtain the applicant’s written consent for the release of their drug and alcohol testing information from their previous DOT covered employers to MTM Transit.

Applicants refusing to provide written consent are prohibited from performing safetysensitive functions for MTM Transit.

Safety-sensitive applicants who have previously violated the USDOT testing program must provide documentation that they have successfully completed the USDOT’s Return-toATTACHMENT 2 PAGE 4
Duty process with a DOT-qualified Substance Abuse Professional (SAP). Failure to provide satisfactory documentation will exclude the applicant from being hired or transferred into a safety-sensitive position with MTM Transit.

5. PRE-EMPLOYMENT TESTING
All applicants for safety-sensitive positions shall undergo a pre-employment urine drug test. MTM Transit must receive an MRO-verified negative drug test result prior to the applicant’s first performance of any safety sensitive function, including behind-the-wheel training.

If an applicant’s pre-employment urine drug test result is verified as positive, the applicant will be excluded from consideration for employment in a safety-sensitive position with MTM Transit.

The applicant will be provided a list of USDOT-qualified Substance Abuse Professionals.

An employee returning from an extended leave period of 90 consecutive days or more, and whose name was also removed from the random testing pool for 90 days or more, must submit to a pre-employment urine drug test. MTM Transit must be in receipt of a negative drug test result prior to the employee resuming any safety-sensitive function.

6. RANDOM TESTING
Safety-sensitive employees will be subject to random, unannounced testing. MTM Transit will perform random testing in a manner that meets or exceeds the FTA minimum annual testing requirements, as amended. The selection of employees for random testing will be made using a scientifically valid method. All safety-sensitive employees will have an equal chance of being selected each time a random draw is performed. Random alcohol tests will be conducted just before, during or just after the employee’s performance of a safety-sensitive function. Random drug tests may be conducted anytime an employee is on duty.

Once an employee is notified that they have been selected for a random test, they must proceed immediately to the testing location. Failure to proceed immediately may be deemed a refusal to test.

ATTACHMENT 2
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All random testing for drugs and alcohol conducted under this part are unannounced and unpredictable, and that the dates for administering random tests are reasonably spaced throughout the calendar year. Random testing must be conducted at all times of day when safety-sensitive functions are performed.

7. REASONABLE SUSPICION TESTING
All safety-sensitive employees must submit to reasonable suspicion drug and/or alcohol testing when a supervisor or company official trained in detecting signs and symptoms of drug use and alcohol misuse has made specific, contemporaneous, articulable observations concerning an employee’s appearance, speech, behavior and/or body odor.

Reasonable suspicion testing for alcohol misuse will occur when observations are made just before, during, or just after the employee’s performance of a safety-sensitive function. Reasonable suspicion testing for prohibited drugs may be conducted anytime an employee is on duty or on standby for duty and a trained supervisor has made the observations.

8. POST-ACCIDENT TESTING

FATAL ACCIDENTS
Safety-sensitive employees must submit to post-accident drug and alcohol testing following an accident involving a public transportation vehicle that results in the loss of human life. In addition to a surviving operator of the vehicle, any other surviving, safetysensitive employee whose performance could have contributed to the accident must also be tested.

Nothing in this section shall be construed to require the delay of necessary medical attention for the injured following an accident or to prohibit a covered employee from leaving the scene of an accident or to prohibit a covered employee from leaving the scene of an accident for the period necessary to obtain assistance in responding to the accident or to obtain necessary emergency medical care.

NON-FATAL ACCIDENTS
All safety-sensitive employees whose actions cannot be completely discounted as a contributing factor must submit to post-accident drug and alcohol testing when a nonATTACHMENT 2 PAGE 6
fatal accident involving a public transportation vehicle meets one or more of the following meets one or more of the following thresholds:

1. An individual suffers bodily injury and immediately receives medical treatment away from the scene.

2. One or more vehicles incurs disabling damage that requires the vehicle(s) to be towed away from the accident scene.

3. If the public transportation vehicle is a rail car, trolley car, trolley bus or vessel and has been removed from service.

MTM Transit officials will use the best information available at the scene, to determine if a safety-sensitive employee’s performance can be completely discounted as a contributing factor to the accident.

Post-accident drug and alcohol tests will be conducted as soon as practicable following the accident. Any safety-sensitive employee involved in an accident must refrain from alcohol use for eight (8) hours following the accident or until the employee undergoes a post-accident alcohol test. Any safety-sensitive employee who leaves the scene of the accident without a justifiable reason or explanation prior to submitting to drug and alcohol testing may be deemed to have refused the test. However, employees are not prohibited from leaving the scene of an accident to obtain assistance in responding to the accident or to obtain necessary emergency medical care.

Nothing in this section shall be construed to require the delay of necessary medical attention for the injured following an accident or to prohibit a covered employee from leaving the scene of an accident or to prohibit a covered employee from leaving the scene of an accident for the period necessary to obtain assistance in responding to the accident or to obtain necessary emergency medical care.

9. URINE SPECIMEN COLLECTIONS
Urine specimen collections will be conducted in accordance with USDOT rule, 49 CFR Part 40, as amended. Collectors will be appropriately trained and qualified to perform urine specimen collections for USDOT covered employers. Urine specimen collectors will use the split-specimen collection method and will afford the donor (employee) the greatest degree of privacy permitted per 49 CFR Part 40, as amended. When an observed collection is required, the observer will be of the same gender as the donor (employee).

ATTACHMENT 2
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10. REFUSAL TO SUBMIT TO URINE DRUG TESTING
The following actions constitute a “refusal to test” in accordance with 49 CFR Part 40, as amended:

1. Failure to appear for any test within a reasonable time, as determined by the employer, consistent with applicable DOT agency regulations, after being directed to do so by the employer (pre-employment testing not applicable).

2. Failure to remain at the testing site until the testing process is completed (after the process has been started).

3. Failure to provide a urine specimen for any drug test required by this part or DOT agency regulations.

4. In the case of a directly observed or monitored collection in a drug test, fail to permit the observation or monitoring of your provision of a specimen.

5. Failure to provide a sufficient amount of urine when directed, and it has been determined, through a required medical evaluation, that there was no adequate medical explanation for the failure.

6. Failure or decline to take an additional drug test the employer or collector has directed you to take.

7. Failure to undergo a medical examination or evaluation, as directed by the MRO as part of the verification process, or as directed by MTM Transit.

8. Failure to cooperate with any part of the testing process (e.g., refuse to empty pockets when directed by the collector, behave in a confrontational way that disrupts the collection process, fail to wash hands after being directed to do so by the collector).

9. For an observed collection, failure to follow the observer’s instructions to raise your clothing above the waist, lower clothing and underpants, and to turn around to permit the observer to determine if you have any type of prosthetic or other device that could be used to interfere with the collection process.

10. Possessing or wearing a prosthetic or other device that could be used to interfere with the collection process.

11. Admitting to the collector or MRO that you adulterated or substituted the specimen.

12. When the MRO verifies your drug test result as adulterated or substituted.

Refusing to submit to a USDOT/FTA required test is a violation of the USDOT/FTA testing program. Employees are required to be immediately removed from safety-sensitive duty and provided a list of USDOT-qualified Substance Abuse Professionals.

Per MTM Transit authority, violation of the USDOT/FTA testing program will result in termination of employment.

ATTACHMENT 2
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11. URINE SPECIMEN ANALYSIS
All specimens will be transported or shipped to a laboratory certified by the Department of Health and Human Services (DHHS). All specimens will be analyzed at the laboratory in accordance with 49 CFR Part 40, as amended. The procedures that will be used to test for the presence of prohibited drugs will protect the employee and the integrity of the drug testing process, safeguard the validity of the test results and ensure that the test results are attributed to the correct employee. Laboratory confirmed drug test results will be released only to a certified Medical Review Officer (MRO) for review and verification.

NEGATIVE-DILUTE SPECIMENS
Upon receipt of an MRO verified negative-dilute drug test result with creatinine levels greater than 5 mg/dL and less than 20 mg/dL, MTM will require applicants and employees to submit to a second urine collection per 49 CFR Part 40.197. The collection of the second specimen will not be conducted using direct observation procedures. The MRO verified result of the second urine drug test will be accepted by MTM as the final result and the test of record. MTM Transit will apply this policy provision uniformly for all pre-employment and random urine drug tests reported by the Medical Review Officer to have creatinine levels greater than 5mg/dL but less than 20mg/dL (negative-dilute results). Once notified that a second collection is required, employees must proceed immediately for testing. An employee’s failure to report immediately may be deemed as a refusal to submit to testing, which is a violation of the USDOT/FTA testing program.

Per MTM Transit authority, violation of the USDOT/FTA testing program will result in termination of employment.

ATTACHMENT 2
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12. ROLE OF THE MEDICAL REVIEW OFFICER (MRO)
The role of the Medical Review Officer is to review and verify laboratory confirmed test results obtained through a DOT-covered employer's testing program. When a nonnegative drug test result is received, the MRO will communicate with the donor (employee) to determine if a legitimate medical explanation exists. When a legally prescribed medication has produced a non-negative result, the MRO will verify the prescription and report the result as “negative” to MTM Transit. Medical conditions and other information obtained by the MRO during the interview with the donor will be maintained in a confidential manner. However, if the MRO believes that a medication prescribed to the donor may pose a significant safety risk, the MRO will require the donor to contact his/her prescribing physician and request that the physician contact the MRO within 5 business days.

The MRO and prescribing physician will consult to determine if the employee’s medication use presents a significant safety risk. MTM Transit will be notified by the MRO when the outcome of the consultation results in a determination that the donor’s medication use presents a significant safety risk. If the employee’s prescribing physician fails to respond, the safety concern will be reported to MTM Transit without consultation.

Based on the MRO recommendation, MTM Transit may deem the employee medically disqualified from performing safety-sensitive functions. The MRO assigned to review and verify laboratory drug test results for MTM Transit is:

Name of MRO: Fredrick Pope MD., MRO – Foley MRO Services Address: 140 Huyshope Ave.

Hartford, CT 06106
Phone Number: 860-815-0825
Fax Number: 860-815-0749
Name of Alternate MRO: Samar Choksi, MD
Address: 2221 SW 19 Av Rd. Suite 200
Ocala, FL 34471
Phone Number: 215-637-6800
Fax Number: 215-637-8246
ATTACHMENT 2
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13. CONSEQUENCE FOR MRO VERIFIED POSITIVE DRUG TEST
When MTM Transit is notified of an MRO verified positive drug test, or a test refusal due to adulteration or substitution; the violating employee will be immediately removed from safety-sensitive duty and provided a list of DOT-qualified Substance Abuse Professionals.

Applicants will be excluded from hire and provided a list of DOT-qualified Substance Abuse Professionals.

Per MTM Transit authority, violation of the USDOT/FTA testing program will result in termination of employment.

14. SPLIT SPECIMEN TESTING
As an important employee protection, split specimen collection procedures will be used for all USDOT/FTA urine collections. When an employee challenges an MRO verified result, he/she may request that the split specimen (bottle B) be tested at a different DHHS certified laboratory that conducted the test of the primary specimen (bottle A).

Instructions for requesting the split specimen test will be provided by the Medical Review Officer during his/her interview with the donor (employee). In accordance with USDOT rule, MTM Transit will ensure that the fee to process the split specimen test is covered, in order for a timely analysis of the split specimen. MTM Transit may seek reimbursement for the cost of the split specimen test.

15. ALCOHOL PROHIBITION
Safety-sensitive employees are prohibited from consuming alcohol while performing safety-sensitive functions, within (4) four hours prior to performing a safety sensitive function, or during the hours that they are on call or standby for duty. No safety-sensitive employee shall report for duty or remain on duty while having an alcohol concentration of 0.04 or greater. Safety-sensitive employees must not consume alcohol within eight (8) hours following an accident or until the employee submits to post-accident testing, whichever occurs first.

ATTACHMENT 2
PAGE 11

16. ALCOHOL TESTING
All alcohol screening tests and confirmation tests will be performed in accordance with USDOT rule, 49 CFR Part 40. The procedures that will be used to test for alcohol misuse will protect the employee and the integrity of the testing process, safeguard the validity of the test results, and ensure the test results are attributed to the correct employee.

When an alcohol-screening test indicates a blood alcohol concentration (BAC) of 0.02 or greater, a confirmation test will be performed using an evidential breath-testing device listed on the USDOT/ODAPC webpage as an “Approved Evidential Breath Measurement Device”. The confirmed blood alcohol concentration (BAC) result will be transmitted by the technician to MTM Transit in a confidential manner. A safety-sensitive employee who has a confirmed blood alcohol concentration (BAC) of 0.02 or greater but less than 0.04 will be removed from safety-sensitive duties for a period of at least (8) eight hours or until test results fall below 0.02.

17. CONSEQUENCE FOR A USDOT/FTA CONFIRMED

ALCOHOL VIOLATION
A safety-sensitive employee who has a confirmed blood alcohol concentration (BAC) of

0.04 or greater has violated the USDOT/FTA testing program and will be removed from safety-sensitive duty and provided a list of DOT-qualified Substance Abuse Professionals.

Per MTM Transit authority, violation of the USDOT/FTA testing program will result in termination of employment.

ATTACHMENT 2
PAGE 12

18. REFUSAL TO SUBMIT TO ALCOHOL TESTING
The following actions constitute a refusal to submit to an alcohol test:

1. Fail to appear for any test within a reasonable time, as determined by the employer, consistent with applicable DOT agency regulations, after being directed to do so by the employer.

2. Fail to remain at the testing site until the testing process is complete

3. Fail to provide an adequate amount of saliva or breath for any USDOT required alcohol test

4. Fail to provide a sufficient breath specimen, and the physician has determined, through a required medical evaluation, that there was no adequate medical explanation for the failure

5. Fail to undergo a medical examination or evaluation, as directed by the [Agency]

6. Fail to sign the certification at Step 2 of the ATF

7. Fail to cooperate with any part of the testing process.

Refusing to submit to a USDOT/FTA required test is a violation of USDOT/FTA testing program. Employees must be immediately removed from safety-sensitive duty and provided a list of USDOT-qualified Substance Abuse Professionals.

Per MTM Transit authority, violation of the USDOT/FTA testing program will result in termination of employment.

ATTACHMENT 2
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19. MTM TRANSIT TESTING PROGRAM CONTACTS
Drug and Alcohol Program Manager (DAPM)
Name: Denea Vander Wall
Address: 16 Hawk Ridge Drive, Lake St. Louis, MO 63367
Phone: 636 357-8243
Email: [email protected]
Alternate and Local DAPM
Name: Local General Manager Name
Address:

Phone:

Email:

Substance Abuse Professional
Name: American Substance Abuse Professionals
Phone: 1-888-792-2727 | Reference code: 121
Please sign the Acknowledgement of Receipt of this Policy (attached) and return to your supervisor or Designated Employer Representative.

ATTACHMENT 2
PAGE 14
Employee Acknowledgement of Receipt of
MTM Transit

SUBSTANCE ABUSE POLICY
For additional information or questions contact your local program administrator or DAPM:

Denea Vander Wall
MTM Transit, LLC
Sr. Manager, HR – MTM Transit
[email protected]
By signing this form I am acknowledging that I am not currently in violation of this policy and that I am not currently using any prohibited substances, and that if I violate any parts of 49 CFR part 40 and 655, or this policy I may be terminated. I have received a legible copy of the MTM Transit Substance Abuse Policy, and 60 minutes of training on prohibited drugs and alcohol. I understand that my employment with MTM Transit is conditioned upon full adherence to this policy.

Employee Name:

Employee Signature: Date:

Supervisor Name:

Supervisor Signature: Date:

Employee Copy
ATTACHMENT 2
PAGE 15
Employee Acknowledgement of Receipt of
MTM Transit
SUBSTANCE ABUSE POLICY (UPDATED 04/19/21)
For additional information or questions contact your local program administrator or DAPM:

Local General Manager
Or
Denea Vander Wall
MTM Transit, LLC
Sr. Manager, HR – MTM Transit
[email protected]
By signing this form I am acknowledging that I am not currently in violation of this policy and that I am not currently using any prohibited substances, and that if I violate any parts of 49 CFR part 40 and 655, or this policy I may be terminated. I have received a legible copy of the MTM Transit Substance Abuse Policy, and 60 minutes of training on prohibited drugs and alcohol. I understand that my employment with MTM Transit is conditioned upon full adherence to this policy.

Employee Name:

Employee Signature: Date:

Supervisor Name:

Supervisor Signature: Date:

Employee Copy
ATTACHMENT 2
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20. REFERENCES
The referenced USDOT and FTA regulations, as well informational material related to this testing program are available for review and/or download from the Florida Department of Transportation’s Substance Abuse Management Website: http://sam.cutr.usf.edu.

Further information may be obtained from the USDOT’s Office of Drug and Alcohol Policy and Compliance website: https://www.transportation.gov/odapc and the Federal Transit Administration’s (FTA) website: https://transit-safety.fta.dot.gov/DrugAndAlcohol/Default.aspx ATTACHMENT 2

EMERGENCY ACTION PLAN
AUGUST, 2023

MTM TRANSIT
220 Moffat Boulevard
Manteca, CA 95336
www.mtmtransit.com
ATTACHMENT 2
Emergency Action Plan