Public Transportation
Agency Safety Plan
Adopted October 13, 2020
City of Santa Monica’s
Big Blue Bus
1660 7th Street
Santa Monica, CA 90401
1 Transit Agency Information
Transit Agency Name City of Santa Monica’s Big Blue Bus Transit Agency Address 1660 7th Street
Santa Monica, CA 90401
(310) 458-1975
Account Executive Anuj K. Gupta, Director of Department of Transportation Chief Safety Officer Liseth Guizar, Transit Safety and Training Manager Modes of Service Covered by
This Plan
Fixed Route Bus Service
Contracted Paratransit Services
Modes of Service Provided by
Agency
Fixed Route Bus Service
Contracted Paratransit Service (MODE)
FTA Funding Types 5307 (direct recipient), 5310 (sub-recipient) Does the agency provide
transit services on behalf of
another transit agency or
entity? If so, describe
No
Name of Entity That Drafted
This Plan
Liseth Guizar; Big Blue Bus
Signature by the Accountable
Executive
Signature of Accountable Executive Date of Signature
Approval by City Council Name of Approving Entity Date of Approval City of Santa Monica’s City Council 10/13/2020
Relevant Documentation (title and location)
Staff Report No. 4220
Certification of Compliance
(Self-Certification through
TRAMS)
Name of Individual that Certified Plan Date of Certification Relevant Documentation (title and location)
2 Safety Performance Targets
FTA Safety Performance Targets
Specify performance targets based on the safety performance measures established under the National Public Transportation Safety Plan. The rates are calculated per 100,000 Vehicle Revenue Miles (VRM) Mode of Transit
Service
Fatalities
(Total)
Fatalities
(Rate per
100,000
VRM)
Injuries
(Total)
Injuries
(Rate per
100,000
VRM)
Safety
Events
(Total)
Safety
Events
(Rate per
100,000
VRM)
System
Reliability
Fixed Route 0 0 25 .7 650 13.0 14,000
MODE 0 0 3 .00002 15 .00008 12,511
BBB Performance Targets
Specify performance targets based on the safety performance measures established under the National Public Transportation Safety Plan.
OPERATIONS
Preventable
Accidents
(Rate per
100,000 Total
Miles)
Preventable
Injuries
(Rate per
100,000
Total Miles)
MAINTENANCE
Maintenance
Injury
Reports
Preventable
Maintenance
Collisions
(Total Number
of Collisions)
Target 2.5 .5 18 3
Safety Performance Target Coordination
Describe the coordination with the State and Metropolitan Planning Organization(s) (MPO) in the selection of State and MPO safety performance targets.
BBB will coordinate with the Southern California Association of Governments (SCAG) to select safety performance targets. SCAG has designated the Senior Regional Planner for Transit and Rail as the safety performance target coordinator. BBB officially transmits its targets in writing to SCAG by April 1st of each year.
Targets
Transmitted to
the
Metropolitan
Planning
Organization
Metropolitan Planning Organization
Name Date Targets Transmitted
Southern California Association of
Governments 7/8/2020
SCAG
Coordinator
Contact
Information
Coordinator / Title Contact Information
Priscilla Freduah-Agyemang [email protected]
Senior Regional Planner, Mobility Planning
and Management (213) 236-1973
3 Version and Updates
Version
Number
Sections/Pages
Affected
Reason for Change Date Issued
1 N/A Original- Adopted by Council 10/13/20
2 All Updated department name to
Department of Transportation and
updated leadership team titles
2 2 Updated MODE performance targets
2 21 Edited Safety Committee information
2 22 Updated evaluators of SafetyPro
2 29-30 Added mitigation measures for
reducing assaults on transit workers
2 48 Added training programs
2 52 List of Referenced Documents
4 Table of Contents
Transit Agency Information.................................................................................1
1. Executive Summary....................................................................................7
2. Background................................................................................................8
2.1. Authority ................................................................................................8
2.2. Public Transportation Agency Safety Plan (PTASP)..................................8
2.3. Safety Management System (SMS) .........................................................9
2.4. Big Blue Bus’ Agency Safety Plan Management.....................................10
2.5. Applicability..........................................................................................10
2.6. Annual ASP Review and Update............................................................11
2.7. Certification of Compliance...................................................................11
2.8 Safety Plan Documentation...................................................................12
3. Safety Management Policy.......................................................................12
3.1. Safety Management Policy Statement ..................................................13
3.2. Management of Safety..........................................................................14
3.3. Employee Safety Reporting Program.....................................................17
3.4. Safety Management Policy Communication..........................................17
4. Safety Risk Management .........................................................................19
4.1. Safety Hazard Identification..................................................................19
4.1.1. Safety Hazards and Analysis Reporting Program (SHARP)...................20
4.1.2. SafetyShare Committees....................................................................20
4.1.3. SafetyPro Onboard Observation Program ..........................................21
4.1.4. Employee Injury Review Team ...........................................................21
4.1.5. Occurrence Review Team...................................................................21
4.2. Safety Risk Assessment.........................................................................22
4.2.1. Hazard Analysis Team ........................................................................22 5 4.2.2. Risk Assessment Methodology...........................................................23
4.2.3. Hazard Risk Severity...........................................................................23
4.2.4. Hazard Risk Probability ......................................................................24
4.2.5. Hazard Risk Assessment.....................................................................25
4.3. Safety Risk Mitigation ...........................................................................27
4.3.1. Hazard Resolution..............................................................................29
4.3.2. Hazard Risk Control............................................................................29
4.3.3. Hazard Risk Conditions Reporting ......................................................30
4.3.4. Hazard Risk Conditions Investigation .................................................30
5. Safety Assurance......................................................................................31
5.1. Safety Performance Monitoring and Measurement ..............................32
5.1.1. FTA’s Safety Performance Targets......................................................32
5.1.2. Internal Safety Reviews......................................................................35
5.1.3. Investigation of Safety Events............................................................36
5.1.4. Corrective Action Plans......................................................................38
5.1.5. Safety Data Collection & Analysis.......................................................38
5.1.6. Drug & Alcohol Program ....................................................................38
5.1.7. Inspections.........................................................................................39
5.1.8. Hazardous Materials & Local State and Federal Regulations ..............40
5.1.9. Compliance ........................................................................................41
5.1.10.Procurement......................................................................................41
5.2. Management of Change........................................................................41
5.3. Continuous Improvement .....................................................................43 Agency Safety Plan Annual Review Process...................................................44
6. Safety Promotion.....................................................................................45
6.1. Safety Competencies.............................................................................45 6 6.2. Comprehensive Safety Training.............................................................46
6.3. Public Transportation Safety Certification Training Program.................48
6.4. Safety Communication..........................................................................48 7 1. Executive Summary
The purpose of this document is to establish the Public Transportation Agency Safety Plan (PTASP) for the City of Santa Monica’s Department of Transportation, operating as Big Blue Bus (BBB). The creation and implementation of BBB’s Agency Safety Plan is in response to the United States Department of Transportation (USDOT) Federal Transit Administration (FTA) Title 49 Code of Federal Regulations (CFR) Part 673. The regulation focuses on establishing a Safety Management System (SMS) framework approach to administering safety throughout the organization, and strategies for minimizing the exposure of the public, personnel, and property to unsafe conditions. The FTA defines SMS as:
“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.” This Agency Safety Plan describes that a SMS framework is comprised of four foundational components:
Safety Management Policy -- agency’s documented commitment to safety; defines the agency’s safety objectives and leadership accountabilities and responsibilities Safety Risk Management -- process for identifying hazards, assessing the hazards, and mitigating safety risk
Safety Assurance -- ensures the implementation and effectiveness of safety risk mitigation; ensures agency meets or exceeds its safety objectives through the collection, analysis, and assessment of information
Safety Promotion -- combination of training and communication of safety information to support SMS
The Agency Safety Plan (ASP) demonstrates the agency’s commitment to safety and will be used to identify programs and processes to minimize injuries and accidents. Management’s compliance with identified responsibilities in the Agency Safety Plan ensures that goals and objectives are achieved.
BBB’s Director of Department of Transportation is designated as the Accountable Executive defined by 49 CFR 625.5 responsible for ensuring that Safety Management System is effectively implemented throughout the agency.
8 2. Background
2.1. Authority
Big Blue Bus is a division of the Department of Transportation of the City of Santa Monica, and as such, is governed by the City’s seven-member City Council. The City of Santa Monica has historically taken an aggressive approach to providing Santa Monica area residents with public transit services. In 1928, the Santa Monica City Council initiated the bus line under powers granted by Article 11, Section 9 of the Constitution of the State of California, which states:
"A municipal corporation may establish, purchase and operate public works to furnish its inhabitants with light, water, power, heat, transportation, or means of communication. It may furnish these services outside its boundaries except within another municipal corporation which furnishes the same service and does not consent." Serving Santa Monica and the Los Angeles area since 1928, BBB is an industry leader in sustainable transit operations. Its fleet is comprised of 189 vehicles powered by alternative fuels include LNG, CNG and battery-electric vehicles. BBB facilities and staff employ eco-friendly materials and practices. Currently, BBB consists of approximately 450 employees. More than 44,400 riders daily use BBB via its 20 routes to traverse a service area spanning more than 58 square miles of the greater Los Angeles area.. Additionally, BBB operates a local demand response service, Mobility On-Demand Every Day (MODE), for seniors and people with disabilities. Service is funded via fare box revenues and a variety of county, State and Federal subsidies.
2.2. Public Transportation Agency Safety Plan (PTASP)
Under FTA’s Public Transportation Agency Safety Plan rule, each operator of public transportation that receives Federal financial assistance under 49 U.S.C. Chapter 53 is required to develop and implement a Public Transportation Agency Safety Plan based on the principles of Safety Management Systems. Transit operators must certify they have a PTASP in place meeting the requirements of the rule by December 31, 2020. Additionally, the PTASP must be updated and certified by the transit agency annually.
At a minimum, each Public Transportation Agency Safety Plan must consist of the following elements:
9 (1) The Public Transportation Agency Safety Plan, and subsequent updates, must be signed by the Accountable Executive and approved by the Santa Monica City Council. (2) The Public Transportation Agency Safety Plan must document the processes and activities related to Safety Management System (SMS) implementation. (3) The Public Transportation Agency Safety Plan must include performance targets based on the safety performance measures established under the National Public Transportation Safety Plan.
(4) The Public Transportation Agency Safety Plan must address all applicable requirements and standards as set forth in FTA’s Public Transportation Safety Program and the National Public Transportation Safety Plan. (5) Each transit agency must establish a process and timeline for conducting an annual review and update of the Public Transportation Agency Safety Plan.
2.3. Safety Management System (SMS)
BBB has adopted a Safety Management System (SMS) framework approach to administering safety throughout the organization and for its Agency Safety Plan.
SMS is a formal, top-down, data-driven, organization-wide approach to managing safety risks and assuring the effectiveness of safety risk mitigations. A SMS defines the safety culture (framework) of the organization and includes senior leadership commitment, front-line engagement, management accountability and continual safety process improvements derived from data-driven safety risk assessment.
SMS is flexible and adaptable to the mode, size, and complexity of any transit agency in any environment: urban, suburban, or rural. The foundation of SMS framework is comprised of four components (Table 1). SMS components interact with each other to provide an effective system of feedback.
SMS Component Description
I. Safety Management Policy Definition of safety policies, procedures, and organizational structure
II. Safety Risk Management Formal process for management of hazards to an acceptable level of risk
III. Safety Assurance Establishment of process measures, assessments and controls to assess the effectiveness of risk control
strategies
IV. Safety Promotion Safety training and risk communication practices to promote a culture of safety
10 2.4. Big Blue Bus’ Agency Safety Plan Management
BBB’s Agency Safety Plan (ASP) was developed in accordance with Federal and State rules and regulations. The Agency Safety Plan is the system-wide governing safety document for all transit modes operated by BBB. The Agency Safety Plan introduces Safety Management Systems to BBB through requirements outlined in the four key components of SMS:
1. Safety Management Policy
2. Safety Risk Management
3. Safety Assurance
4. Safety Promotion
The Agency Safety Plan consists of a series of policies and procedures, which must be undertaken to ensure the safety of its customers, employees, and the general public. The Agency Safety Plan identifies safety policies adopted by BBB, and the authorities and responsibilities associated with system safety for all levels of BBB management and employees.
The Chief Safety Officer is authorized by BBB’s Director of Department of Transportation to prepare, update and implement the Agency Safety Plan, and to coordinate efforts with other involved departments to document and implement SMS processes and activities.
The Agency Safety Plan emphasizes that accountability for safety lies with the Accountable Executive but safety rests with each BBB employee. All employees are required to strictly comply with the safety rules, procedures, and responsibilities established for their work duties.
BBB’s Agency Safety Plan responds to both 49 Code of Federal Regulations Part 673 and 49 U.S.C § 5329(d). The ASP is reviewed through Federal Transit Administration Triennial Audits and BBB’s Internal Safety Reviews. BBB supports the development and maturation of its SMS implementation through internal processes, SMS gap analysis and internal assessments, safety committees, and the information management of data.
This plan was adopted by the Santa Monica City Council on October 13, 2020,and supersedes all other system-wide agency safety plans.
2.5. Applicability
Transit operators that receive Federal financial assistance under 49 U.S.C. Chapter 53 are required to develop and implement an ASP based on the principles of SMS for all modes of transit they operate; the rule applies to recipients and sub-recipients of the federal financial assistance.
11 BBB’s ASP is applicable to its employees, facilities, service areas, and modes of transit (bus and paratransit) the agency directly operates. BBB utilizes external service providers (i.e., contractors) to provide transit service for the paratransit mode. Each external service provider shall develop and implement an agency safety plan applicable for the mode of transit it services on behalf of BBB. BBB is responsible for ensuring Part 673 requirements are satisfied for the external service provider’s PTASP.
For Public Transportation Agency Safety Plan details regarding MODE, BBB’s complementary paratransit service, see MV Transportation’s Agency Safety Plan.
2.6. Annual ASP Review and Update
BBB will conduct the annual review of the ASP at the beginning of each new calendar year, commencing January 1st through February 28th, to ensure it is current and in compliance with federal rules and standards. The responsibility to update and review the Agency Safety Plan, assess its effectiveness, develop and propose changes, solicit internal and external reviews, implement and control the revisions and distribute the changes rests with the Chief Safety Officer. In March, the revised ASP shall be presented to the Executive Leadership Team and Safety Committees for review and comments. Any proposed changes will be submitted to the Southern California Association of Governments for review and comments by April 1st. The ASP will be revised, responding to comments in April, with a final draft submitted to the Accountable Executive for final review by May 1st. The final ASP will be submitted to the Accountable Executive and City Council for signature to be executed no later than end of July.
Along with the ASP submission, BBB shall submit all other BBB documents/procedures referenced in the updated ASP.
2.7. Certification of Compliance
49 CFR 673.13 Certification of Compliance
BBB will self-certify the Agency Safety Plan via the FTA’s Certifications and Assurances process.
The FTA requires each transit agency, direct recipient, or state to annually self-certify that they have PTASPs that meet the requirements of this rule. FTA will use its existing Certifications and Assurances process for this effort.
12 2.8 Safety Plan Documentation
BBB stores and maintains the documents that set forth the agency’s ASP, including documents related to SMS, and results from SMS processes and activities that describe the programs, policies, and procedures that are used to carry out the plan. As required, these documents are made available to FTA, or other entitled entities. BBB maintains and stores in the agency’s libraries (servers and cloud-based) all new, revised, and archived documents for a minimum of three years.
3. Safety Management Policy
This chapter describes how BBB will implement SMS under the Safety Management Policy (SMP) requirements defined in the federal rulemakings. The SMP is the written foundation of BBB’s safety management system. It formally and explicitly commits BBB to the development and implementation of the organizational structures and resources necessary to sustain the safety management processes and activities of SMS. The Safety Management Policy establishes senior leadership and employee accountabilities and responsibilities for safety management throughout the agency.
This Safety Management Policy chapter consists of:
• Safety Management Policy Statement: A transit agency must establish its organizational accountabilities and responsibilities and have a written statement of safety management policy that includes the agency’s safety objectives. • Management of Safety: The transit agency must establish the necessary authorities, accountabilities, and responsibilities for the management of safety amongst the following individuals within its organization, as they relate to the development and management of the transit agency’s Safety Management System. • Employee Safety Reporting Program: A transit agency must establish and implement a process that allows employees to report safety conditions to senior management, protections for employees who report safety conditions to senior management, and a description of employee behaviors that may result in disciplinary action. • Safety Management Policy Communication: The safety management policy must be communicated throughout the agency’s organization.
13 3.1. Safety Management Policy Statement
Safety is BBB’s number one priority. We educate, encourage, and endorse a strong culture of safety at all levels of the organization, valuing the responsibility entrusted in us by the community that we serve. Big Blue Bus is committed to developing, implementing, maintaining, and constantly improving processes to ensure that all of 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 and exceeding established standards.
All levels of management and all employees are accountable for the delivery of this highest level of safety performance, starting with the Director of Department of Transportation.
Big Blue Bus is committed to:
• Supporting 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;
• Integrating the management of safety among the primary responsibilities of all managers and employees;
• Clearly defining for all staff, contractors, and managers alike, their accountabilities and responsibilities for the delivery of the organization’s safety performance and the performance of our safety management system;
• Establishing and operating 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; • Ensuring 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;
• Complying with, and wherever possible exceeding, legislative and regulatory requirements and standards;
• Ensuring that sufficient skilled and trained human resources are available to implement safety management processes;
• Ensuring 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;
• Establishing and measuring safety performance against realistic and data-driven safety performance indicators and safety performance targets; and • Continually improving safety performance through management processes that ensure that appropriate and safety management action is taken and is effective. 14 Objectives
Big Blue Bus has established the following objectives for the Agency:
• Perform annual audits to ensure compliance with SMS.
• Identify and resolve hazards through an established employee safety reporting system. • Conduct emergency drills.
• Manage preventable accident/incident key performance indicators. • Establish and monitor passenger injury benchmarks.
• Meet and exceed safety requirements in design specifications, engineering, facility construction, equipment and systems installation and testing, and in operations and maintenance.
• Evaluate safety implications of all proposed system modifications prior to implementation.
3.2. Management of Safety
BBB has established the necessary authorities, accountabilities, and responsibilities for the development and management of the agency SMS. To meet this, BBB has defined the roles of the Accountable Executive, Chief Safety Officer, and SMS Key Staff for the management of safety.
Safety Authorities, Accountabilities and Responsibilities Accountable Executive
Big Blue Bus has designated the Director of Department of Transportation as the Accountable Executive who is responsible for ensuring SMS is effectively implemented throughout the agency. The Accountable Executive is responsible for ensuring actions are taken as necessary to address substandard performance in BBB’s SMS. The Accountable Executive may delegate specific responsibilities, but the ultimate accountability for the transit agency’s performance cannot be delegated and always rests with the Accountable Executive. The Accountable Executive will also ensure the Executive Leadership Team is responsible for the following safety objectives:
• Carrying out the ASP and the TAM plan.
• Controlling or directing the human and capital resources needed to develop and maintain the ASP and TAM plan.
• Upholding and promoting safety policies, ensuring safety risk management and safety assurance.
15 • Supporting agency-wide safety performance measures and targets. • Holding managers accountable for the safety performance within their respective divisions.
• Fostering a strong safety culture.
• Allocating the appropriate staffing resources necessary to assure compliance with SMS requirements.
• Identifying the necessary funds to meet the safety performance requirements and incorporate them into budgeting plans, prioritizing and allocating expenditures according to safety risk.
Chief Safety Officer
BBB’s Accountable Executive has designated the Transit Safety and Training Manager as the Chief Safety Officer, who has the authority and responsibility for the day-to-day implementation and operation of BBB’s SMS. This position does not serve in any operational or maintenance capacities at BBB. The Chief Safety Officer’s responsibilities include:
• Facilitating full implementation of SMS across BBB.
• Developing and maintaining SMS documentation.
• Briefing the Accountable Executive on SMS implementation progress. • Advocating for a comprehensive safety culture.
• Planning safety management training.
• Monitoring the safety performance of BBB operations and activities through formal data collection and analysis.
• Tracking safety-critical issues and approving mitigation resources. • Monitoring corrective actions to conclusion.
Agency Leadership and Executive Management
The following are members of the Executive Leadership Team, other than the Accountable Executive and the Chief Safety Officer, who have authorities or responsibilities for day-to-day implementation and operation of BBB’s SMS:
• Chief Operations Officer -Oversight of Operations Divisions. • Assistant Director of Department of Transportation- Oversight of Maintenance, Finance and Administration.
• Transit Planning and Performance Manager- Oversight of all proposed system modifications prior to implementation, including but not limited to implementing new routes, modifying current routes and implementation of bus stops. 16 • Community Engagement and Customer Experience Manager- Oversight of internal and external communications, government relations, and customer service. • Maintenance Management- Oversight of fleet and facilities maintenance. • Transit Finance and Grants Manager- Oversight of budget and safety allocations Key Staff
BBB designates key staff members, teams, and committees to support the Accountable Executive and the Chief Safety Officer in developing and implementing the agency’s SMS.
Primary duties include:
• Implementing safety risk management, safety assurance, and safety training and communication protocols of their department.
• Conducting baseline risk assessments in their divisions. • Overseeing the safety performance of all personnel and equipment under their supervision.
• Implementing and maintaining safety-related control measures/mitigations. • Familiarizing employees with the safety requirements and hazards associated with the work to be performed.
• Responding to identified hazards that may impact safety performance. • Supporting and requiring employees within their department to participate in safety training activities.
• Reporting all safety hazards and near misses through the Safety Hazard and Analysis Reporting Program (SHARP).
• Implementing and adhering to SMS procedures and processes within their span of control.
• Maintaining employee department safety training databases.
Transit Safety Officer: Coordinates SMS activities with executive leadership, division managers, and frontline employees. Facilitates the coordination of Safety Risk Management, evaluations and investigations, and controls with special attention to cross-organizational impacts.
Conducts safety promotion efforts. Develops and coordinates the provision of the data and dashboards for tracking and monitoring of safety performance.
Transit Maintenance Safety Training Coordinator: Leads maintenance safety audits with support from appropriate divisions. Develops, coordinates, and maintains safety training requirements for Maintenance personnel. Conducts safety promotion efforts for Maintenance.
Develops and coordinates the provision of the data and dashboards for tracking and monitoring of safety performance.
17 Transit Maintenance Superintendent: Plans and manages the operations of the Maintenance Division by setting goals and objectives, establishing performance and safety standards.
Organizes and supervises staff and contractors in the maintenance of buildings, grounds, bus stops and terminals; ensures that utility systems are operational; and actively participates in SafetyShare Safety Committees.
SafetyShare Committees: A comprehensive, collaborative forum that brings a cross-functional team representing all Big Blue Bus Divisions together for the discussion, evaluation and resolution of safety concerns in order to better control risk, detect and correct safety problems earlier, and share and analyze safety data more effectively.
3.3. Employee Safety Reporting Program
BBB has established an Employee Safety Reporting Program known as the Safety Hazard and Analysis Reporting Program (SHARP), a non-punitive reporting system that allows all employees to report any workplace safety concerns and unsafe employee behaviors. The SHARP is a fundamental source for reporting safety concerns and for hazard identification. SHARP is a key part of eliminating and mitigating safety risks of the consequences of hazards resulting from BBB operations or activities to a point which is consistent with an acceptable level of safety performance.
Employees who participate in the SHARP are ensured that no action will be taken against any employee who discloses a safety concern, unless disclosure indicates, beyond any reasonable doubt, an illegal act, gross negligence, or a deliberate or willful disregard of regulations or procedures. (Appendix A- 1: DI IV-1-8 Employee Safety Hazard and Analysis Reporting Program (SHARP)
3.4. Safety Management Policy Communication
As the Safety Management Policy Statement serves as the transit agency’s documented commitment to safety and defines the agency’s objectives and the accountabilities and responsibilities of its employees regarding safety, communication of the SMP throughout the agency is paramount to the success of SMS implementation. The BBB SMP is communicated to all employees and contractors in hard-copy and electronic formats through:
• Trainings
• Email
• SharePoint
18 • My Info Blue portal for Motor Coach Operators
• Employee mailboxes
• Bulletin boards
• New employee orientation
• Onboarding of contractors
All revisions, if applicable, will be signed by the Accountable Executive and an agency wide notification will be acted upon immediately.
19 4. Safety Risk Management
This chapter describes how BBB will implement SMS under the Safety Risk Management (SRM) requirements defined in the federal rulemakings. SRM is the formalized, proactive approach to ensure safety risk analyses and assessments are met. Safety Risk Management is a system of hazard identification and evaluation, management to control hazards to an acceptable level of risk, evaluation of the results, then mitigating safety risk. BBB’s Safety Risk Management Process develops a comprehensive and systematic hazard management process for all elements of our public transportation system, which can identify, evaluate, track and then eliminate or minimize safety hazards associated with the system operations.
Safety Risk Management Processes are comprised of the following activities:
• Safety Hazard Identification: A transit agency must establish methods or processes to identify hazards and consequences of the hazards.
• Safety Risk Assessment: A transit agency must establish methods or processes to assess the safety risks associated with identified safety hazards. • Safety Risk Mitigation: A transit agency must establish methods or processes to identify mitigations or strategies necessary as a result of the agency’s safety risk assessment to reduce the likelihood and severity of the consequences.
The Safety Risk Management Process applies to all BBB employees and obligates everyone to constantly observe hazards in their work areas and report them to the safety officer, their safety committee, or to their supervisor or manager. The continuous identification, monitoring, and elimination of hazards is key to an effective safety risk management process for all modes of BBB transportation.
4.1. Safety Hazard Identification
One goal of Safety Risk Management is to develop and refine an agency wide comprehensive and systematic program which can identify and then eliminate or minimize all safety hazards. A hazard is defined as 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 a public transportation system; or damage to the environment. Hazard identification is the process in which the hazards to passengers, employees, general public, equipment and assets of the transit system are identified. Once the hazards are identified then proper measures can be taken to mitigate. Hazard identification sources throughout the agency may include, but are not limited to:
1. BBB’s employee safety reporting program (SHARP)
2. Inspections
3. Internal safety investigations
4. Accident/employee injury/ security reports
20 5. SafetyShare committee reviews
6. Industry data
7. Customer/public feedback
8. Governmental sources (FTA, NTSB, TSA)
BBB also relies heavily upon the skills, experience and training of its personnel to ensure that appropriate and proven methods are employed to identify hazards or unsafe conditions.
A hazard is defined as 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 a public transportation system; or damage to the environment (49 C.F.R. §673.5).
BBB has established the following programs as sources for identifying hazards.
4.1.1. Safety Hazards and Analysis Reporting Program (SHARP) All employees are trained and encouraged to report hazards, risks, incidents and close calls, using BBB’s SHARP. Employees can submit SHARP reports in several ways: hard copies which are located throughout the campus, online through MyInfoBlue or SharePoint, by email, or in person. Safety reporting can also be done anonymously through hard copy as the employee’s name is not a required field. (Appendix A-1: DI IV-1-8 Employee Safety Hazard and Analysis Reporting Program (SHARP))
4.1.2. SafetyShare Committees
BBB established two SafetyShare Committees; a DOT Safety Committee and Operations Safety Committee, as a tool for developing and promoting a safe, healthy and secure environment for all employees and customers. The committees provide a comprehensive, collaborative forum that brings a cross-functional team representing all Big Blue Bus Divisions together for the discussion, evaluation and resolution of safety concerns in order to better control risk, detect and correct safety problems earlier, and share and analyze safety data more effectively.
Safety committee membership shall include staff members from each respective division. It shall consist of an equal number of frontline employee representatives and management representatives. Employees are welcome to participate on the safety committees regardless of education or background. Members shall be selected and shall hold a one-year term, with any vacancies filled prior to the next scheduled meeting.
The committees identify and analyze hazards by:
• Providing a forum for employee concerns and suggestions about safety and health, including the review of written reports to assist in the improvement and correction of identified, unsafe conditions or practices;
21 • Reviewing investigations of occupational accidents and causes of incidents resulting in an occupational injury, illness, or exposure to hazardous substances in order to determine corrective actions or identify actions that will help prevent future events, and to identify trends; and
• Reviewing results of periodic scheduled worksite inspections. (Appendix A-2: DI IV-1-2 Safety Committees)
4.1.3. SafetyPro Onboard Observation Program
The goal of the SafetyPro Onboard Observation Program is to ensure that the BBB training team understands the challenges and changes in operating environments in the service area, that our Motor Coach Operators (MCO) are operating vehicles safely, and to ensure that the customer experience is meeting or exceeding BBB standards.
The Training Coordinators and Motor Coach Operator Supervisors, who serve as Evaluators of the program, observe the MCO’s driving skills and provide an evaluation. Based on their observations, Evaluators make recommendations to the Operations division to either commend, coach and counsel, or refer the MCO to the Training Division for retraining. (Appendix A-3: DI IV-1-7 SafetyPro Onboard Observation Program)
4.1.4. Employee Injury Review Team
The Employee Injury Review Team consists of personnel from the Safety and Training, Maintenance and Operations Divisions. Workers compensation injury reports are reviewed and analyzed for trends. The team reviews the accident details, the activities the employee was performing when the event occurred, key causal factors, and the recommendations to prevent the injury in the future. If the injury is found to be preventable, recommendations are made to meet with the injured employee and provide guidance on the required safe work practices.
4.1.5. Occurrence Review Team
The Occurrence Review Team consists of personnel from the Safety and Training, Operations, and Maintenance Divisions (if pertinent). The team reviews accident data provided by the Transit Safety Officer. The data is analyzed for trends, recurring locations, and based on the findings, the team discusses mitigation measures. The data, findings, and mitigation measures are shared with the SafetyShare Committees and are discussed at the Quarterly Safety Meetings.
22 4.2. Safety Risk Assessment
Safety Risk Assessment is the formal activity whereby BBB determines SRM priorities by establishing the significance or value of its safety risk. It is used to describe the overall process or method where the agency:
• Identifies hazards and risk factors that have the potential to cause harm (hazard identification).
• Analyzes and evaluates the risk associated with that hazard (risk analysis, and risk evaluation).
• Determines appropriate ways to eliminate the hazard or control the risk when the hazard cannot be eliminated (risk control).
The aim of the risk assessment process is to evaluate hazards, then remove that hazard or minimize the level of its risk by adding control measures, as necessary. Risk assessments are very important as they form an integral part of the Safety Risk Management Process. They help to:
• Create awareness of hazards and risk.
• Identify who may be at risk (e.g., employees, visitors, contractors, the public, etc.). • Determine whether a control program is required for a particular hazard. • Determine if existing control measures are adequate or if more should be done. • Prevent injuries or illnesses, especially when done at the design or planning stage. • Prioritize hazards and control measures.
• Meet legal requirements where applicable.
BBB established the Hazard Analysis Team to assess the safety risk of the consequences of identified safety hazards and to prioritize the hazards based on this safety risk. The team identifies policies/procedures that are already in place and provides mitigation recommendations to Management based on the level of safety risk.
4.2.1. Hazard Analysis Team
The Hazard Analysis Team consists of personnel from the Safety and Training, Planning and Operations Divisions. The team analyzes hazards reported via the various hazard identification methods and prioritizes them based on this safety risk. Once a hazard has been identified and analyzed, the team evaluates:
• The consequences of the hazard in terms of the probability of the consequences; 23 • The consequences of the hazard in terms of their severity of impact of the consequences if they occur; and
• The current risk mitigations in place.
4.2.2. Risk Assessment Methodology
Risk Assessment is a quantitative calculation based largely on subjective judgments used to determine how much risk is associated with each hazard, and thus the urgency for implementing corrective measures to eliminate or reduce the hazard to a level of acceptability.
Risk Assessment has two steps: evaluating hazard severity (categorizing the hazard) and evaluating hazard probability. The factors considered in this analysis include system safety, schedule, potential loss of property and the impact on the public perception of safety in the community where the system operates.
4.2.3. Hazard Risk Severity
Hazard Risk Severity is a subjective measure of the worst credible mishap resulting from personnel error, environmental conditions, design inadequacies, and/or procedural efficiencies for system, subsystem, or component failure or malfunction.
The categorization of hazards is consistent with risk-based criteria for severity: it reflects the principle that not all hazards pose an equal amount of risk to personnel safety. BBB follows these criteria, as do most transportation organizations, including the National Transportation Safety Board (NTSB).
24 Risk Severity Levels
Severity Level Injury or
Occupational
Illness
Property
Damage
System Disruption
(Injury related
excluded)
Evacuation
1 Catastrophic Death > $250k > 24 hrs. Fire/Life
safety
evacuation
2 Critical Serious injury $250k – 100k 12 – 24 hrs.
3 Marginal Non-serious
injury
(Ambulance
transport)
$100K – 25K 4 – 12 hrs.
4 Negligible Non-serious
injury
(No ambulance
transport)
< $25K < 4 hrs.
Table 1: Hazard Risk Severity Levels
4.2.4. Hazard Risk Probability
The probability of a particular event or a specific hazard occurring may be defined in quantitative or qualitative terms, such as a ratio of the number of times that a specific event occurs to the total number of trials in which this event will occur during the planned life expectancy of a system. Generally, hazard risk probability is described qualitatively in potential occurrences per units of time, miles, passengers carried or trips/runs. A hazard risk probability may be derived from the analysis of transit system operating experience, evaluation of BBB safety data or from historical safety data from similar systems. 25 Risk Probability Levels
Description Level Likelihood of event
in life of a specific
item
Occurrence within
Fleet or Inventory
MTBE* in
Operating
Hours (oh)
MBTE in
days
Frequent A Will occur often Continuously
experienced
< 1,000 oh 1 per
month
Probable B Will occur several
times
Will occur
frequently
1,000 -
100,000 oh
1 per
year
Occasional C Likely to occur
sometime
Will occur several
times
100,000 -
1,000,000 oh
1 per 2
years
Remote D Unlikely, but
possible to occur
Unlikely, but can
reasonably be
expected to occur
1,000,000 -
1000,000,00
0 oh
1 per 5
years
Improbable E So unlikely, it can be
assumed occurrence
may not be
experienced
Unlikely to occur,
but possible
>
100,000,000
oh
1 per 10
years
Eliminated F Incapable of occurrence. This level is used when potential hazards are identified and later eliminated
Table 2: Hazard Risk Probability Levels
4.2.5. Hazard Risk Assessment
When the Hazard Risk Severity Index is combined with the Hazard Risk Probability Index, the result is the Risk Assessment Matrix (Table 3). The Risk Assessment Matrix identifies the risk assessment index based upon hazard category and probability and the criteria for defining further actions based upon that index.
Substantial property damage, death, serious injuries and evacuation for life safety reasons are considered to be major or severe consequences based on mandatory reporting and would require a Hazard Category rating of either 1 (Catastrophic) or 2 (Critical).
More severe incidents that result in Catastrophic and Critical consequences require a comprehensive investigation in which one or more safety analyses are performed to enable 26 management to understand the level of risk involved and the consequences of accepting the risk relative to the cost of reducing or eliminating the risk.
Risk Assessment Matrix SEVERITY
1. Catastrophic 2. Critical 3. Marginal 4. Negligible
PROBABILITY
A. Frequent High High Serious Medium
B. Probable High High Serious Medium
C. Occasional High Serious Medium Low
D. Remote Serious Medium Medium Low
E. Improbable Medium Medium Medium Low
F. Eliminated Eliminated
Resolution Requirements
High * Unacceptable correction required
Serious Undesirable correction may be required, decision by management Medium Acceptable w/ with review and documentation by management Low Acceptable without review
Eliminated Acceptable no action needed
Table 3: Risk Assessment Matrix
Hazard Risk ratings will be labeled as HIGH, SERIOUS, MEDIUM, LOW, and ELIMINATED.
HIGH risk hazards (1A, 1B, 1C, 2A, 2B) that receive an unacceptable initial hazard analysis made by management, hazard analysis team, or safety committees receive immediate attention/control. A high hazard rating requires corrective action. Hazards that receive a high hazard rating will be elevated from the hazard/near miss log.
SERIOUS hazards (1D, 2C, 3A, 3B) that are undesirable may require corrective action and decisions by management. Hazards that receive a serious hazard rating will remain on the hazard/near miss logs until resolved.
MEDIUM (1E, 2D, 2E, 3C, 3D, 3E, 4A, 4B) hazards may be acceptable with review by management. Events from a medium hazard are less likely to occur and are less severe in nature.
LOW (4C, 4D, 4E) hazards do not require review and are acceptable.
ELIMINATED hazard is no longer present.
27 4.3. Safety Risk Mitigation
BBB’s Safety Risk Mitigation process is the analysis and subsequent action taken to reduce the risk associated with an identified hazard to the lowest practical level. The elimination and/or mitigation of the perceived risk to a level which is calculated to be as low as reasonably practical must take place. This process is known as safety risk mitigation. Therefore, mitigation may be considered the activities or measures which we take to address the hazard and bring under control, the safety risk probability and severity of the consequences.
The most effective safety risk control/mitigation strategies are typically based on the implementation of additional safety controls or the reinforcement of existing ones. Safety controls can be grouped under the 3 E’s of Safety:
• Engineering
• Education
• Enforcement
The order of precedence for satisfying system safety requirements and resolving identified hazards should be as follows:
1. Design for minimum risk: Design new facilities and equipment to eliminate hazards. If an identified hazard cannot be eliminated, its associated risks shall be reduced to an acceptable level (see Risk Assessment Methodology) through the design selection.
2. Utilization of safety devices: In the event that an identified hazard cannot be eliminated, or its associated risk cannot be reduced through design selection, that risk shall be reduced to an acceptable level through the use of protective safety features or devices. A provision shall be made, and procedure shall be issued for periodic inspection and functional checks of safety devices.
3. Warning devices: When neither design nor safety devices can effectively eliminate identified hazards, or reduce risk to an acceptable level, warning devices shall be used to detect the condition and produce an adequate warning signal to alert individuals to the hazard. Warning devices should be standardized to minimize the probability of incorrect reaction of personnel to these warning signals.
4. Develop special procedures and training: When it is impossible or impractical to eliminate hazards through design selection or adequately reduce its associated risks through safety or warning devices, then approved procedures and special training programs shall be used. 28 Procedures may include the use of personal protective equipment. Precautionary notations and warning signs shall be standardized.
An example of this process is BBB’s strategy for reducing assaults on transit workers.
1. Design for minimum risk: All new bus procurements include safety protective measures in its design, such as protective safety barriers, onboard surveillance cameras, and warning systems.
2. Utilization of safety devices: In order to mitigate assaults on transit workers, buses were retrofitted to include protective safety barriers designed with transit operator safety in mind. The barriers allow for operators to connect and interact with passengers through the clear protective shield, while also providing a physical barrier to protect the drivers should the need arise.
3. Warning devices: All buses are equipped with silent alarms which may be activated by transit workers if they fear for their safety or the safety of BBB passengers. The silent alarm will notify BBB Dispatch, activate the microphones on the buses, and disable the ability for communications to call the bus. Upon receipt of this alarm, BBB dispatch will contact law enforcement and provide the location of the bus.
4. Develop special procedures and training: All MCOs, mechanics, and customer service personnel are trained in de-escalation techniques. The training is provided by the Santa Monica Police Department and is available in person and online. In addition, procedures are in place to report security incidents onboard buses and at DOT facilities. BBB dispatchers are trained on how to respond to the incidents, while staff are trained on how engage with customers, deescalate, and call for assistance when necessary.
Additional mitigations include DOT’s Transit Safety Officer (TSO) Program. TSOs are contracted security guards who ride onboard buses and patrol facilities and bus stops. TSOs will assist MCOs in responding to disruptive activities onboard buses and serve as a deterrent to crime, unsafe behaviors, and transit worker assaults. 29 4.3.1. Hazard Resolution
Hazard Risks identified are evaluated, eliminated or controlled in accordance with a resolution schedule. The schedule listed below is utilized to ensure an optimum level of safety and to expedite the resolution of identified hazards.
CRITERIA RESOLUTION
Unacceptable – correction required
The hazard must be eliminated or mitigated in the
most expedient manner possible before normal
service may resume. Interim corrective action may
be required to mitigate the hazard to an acceptable
level while the permanent resolution is in
development.
Undesirable – correction may be
required, decision by management
A hazard at this level of risk must be eliminated or
mitigated unless a documented decision to manage
the hazard until resources are available for full
mitigation is issued and approved by the Director of
Department of Transportation.
Acceptable with review and
documentation by management
Management must determine if the hazard is
adequately controlled or mitigated as is.
Acceptable without review No action required.
4.3.2. Hazard Risk Control
Most hazards identified in the system by personnel in the field are reported to Dispatch or are forwarded to the Safety and Training Division via the SHARP.
When hazards are identified during the review of the plans and specifications for equipment or facility modifications, the hazards and options for resolving them are discussed with Management.
30 Hazards identified after accidents/incidents, data analysis or via inspection reports and the safety reporting system are submitted to the Safety and Training Division and tracked via the Hazard Log.
Each employee is encouraged to report any unsafe condition to his or her immediate Supervisor or to the safety reporting system. If a resolution is not achieved at the Division level, the issue is brought to the Chief Safety Officer.
4.3.3. Hazard Risk Conditions Reporting
Once a hazard risk is identified on BBB’s system, a determination will be made to its potential severity and probability of occurrence by Safety personnel. The hazard will then be entered onto the Hazard Log and monitored until closed.
4.3.4. Hazard Risk Conditions Investigation
Formal investigation shall be conducted in accordance with the BBB Accident/Incident Investigation Procedures. BBB will furnish personnel, information, and aid in the completion of an investigation as needed to support the above task.
31 5. Safety Assurance
This chapter describes how BBB will implement SMS under the Safety Assurance (SA) requirements defined in the federal rulemakings. SA describes how the agency will measure and review our processes to remain in compliance. It ensures the ongoing, integrated assessment of the agency’s safety performance across departments and functions. BBB meets its safety objectives and safety performance targets through active system monitoring, safety reporting, routine workplace observations, inspections, audits, and other activities designed to support safety oversight and performance monitoring, measurements, and coordination.
Safety Assurance is comprised of:
• Safety Performance Monitoring and Measurement: A transit agency must establish activities to: monitor its system for compliance with, and sufficiency of, the agency’s procedures for operations and maintenance; monitor its operations to identify any safety risk mitigations that may be ineffective, inappropriate, or were not implemented as intended; and monitor information reported through any internal safety reporting programs.
• Management of Change: A transit agency must establish a process for identifying and assessing changes that may introduce new hazards or impact the agency’s safety performance, then evaluate the proposed change through its Safety Risk Management Process.
• Continuous Improvements: A transit agency must establish a process to assess its safety performance, then develop and carry out, under the direction of the Accountable Executive, a plan to address the identified safety deficiencies. 32 5.1. Safety Performance Monitoring and Measurement
This section addresses the monitoring and measurement process used to collect safety data within the Agency. SMS generates data and information that senior management needs in order to evaluate whether implemented safety risk mitigations are appropriate and effective and how well an agency’s safety performance is in line with established safety objectives and safety performance targets. Safety performance monitoring does not focus on monitoring individuals, but rather monitoring the safety performance of BBB through routine monitoring of operations and maintenance activities.
Examples of BBB’s safety performance monitoring activities include the following:
• Monitor SHARP hazard logs
• Monitor service delivery activities, including field observations • Monitor operational and maintenance data
• Conduct safety audits, studies, reviews and inspections • Conduct safety investigations
In addition to the data submitted to the National Transit Database (NTD), BBB utilizes detailed metrics to develop more refined safety performance measures and targets. As part of our performance management program, BBB has set targets for the reduction of NTD reportable injuries, fatalities, safety events and system reliability. In addition, BBB measures preventable accidents and all passenger injuries.
5.1.1. FTA’s Safety Performance Targets
In order to capture the broad and varied nature of public transportation FTA is relying on measures that can be applied to all modes of public transportation and are based on data that is generally currently collected in the National Transit Database. FTA’s safety performance measures focus on improving transit safety performance through the reduction of safety events, fatalities and injuries. The safety performance measures selected by FTA are intended to provide “state of the industry” high-level measures and help focus individual agencies on the development of specific performance indicators and measurable targets relevant to their operations.
BBB’s Agency Safety Plan must establish by mode seven safety performance targets in four categories:
1. Fatalities: Total number of reportable fatalities and rate per total vehicle revenue miles (VRM);
2. Injuries: Total number of reportable injuries to NTD and rate per total VRM;
3. Safety Events: Total number of reportable events and rate per total VRM; and
4. System Reliability: Mean distance between mechanical failures by mode. 33 BBB’s Safety Performance Targets (based on the safety performance measures established under the National Public Transportation Safety Plan) The rates are calculated per 100,000 Vehicle Revenue Miles (VRM)
Mode of
Service
Fatalities
(total)
Fatalities
(Rate per
100,000
VRM)
Injuries
(total)
Injuries
(Rate per
100,000
VRM)
Safety
Events
(total)
Safety
Events
(Rate per
100,000
VRM)
System
Reliability
(failures/VRM)
Fixed
Route
0 0 25 .7 650 13.0 14,000
MODE 0 0 3 3 15 12 N/A
Fatalities
Fatality is defined as a death or suicide confirmed within 30 days of a reported event. It does not include deaths in or on transit property that are result of illness or other natural causes.
Injuries
Injuries are defined as any damage or harm to persons as a result of an event that requires immediate medical attention away from the scene. In addition, FTA has established the term “Serious Injury”. A Serious Injury is defined as any injury that:
1. Requires hospitalization for more than 48 hours, commencing within 7 days from the date of the injury was received;
2. Results in a fracture of any bone (except simple fractures of fingers, toes, or nose);
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 5 percent of the body surface.
Safety Events
The safety events measure captures all reported safety events that occurred during transit operations and the performance of regular supervisory or maintenance activities. 49 CFR 673.5 defines an Event as any Accident, Incident, or Occurrence. 49 CFR 673.5 also defines an Accident as an Event that involves any of the following:
• A loss of life;
• A report of a serious injury to a person;
34 • A collision of public transportation vehicles;
• A runaway train;
• An evacuation for life safety reasons; or
• Any derailment of a rail transit vehicle, at any location, at any time, whatever the cause. 49 CFR 673.5 defines an Incident as an Event that involves any of the following:
• A personal injury that is not a serious injury;
• One or more injuries requiring medical transport; or
• Damage to facilities, equipment, rolling stock, or infrastructure that disrupts the operations of a transit agency.
49 CFR 673.5 defines an Occurrence as an Event without any personal injury in which any damage to facilities, equipment, rolling stock, or infrastructure disrupts in any way the operations of a transit agency.
System Reliability
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 measures how well a fleet of transit vehicles is maintained and operated.
Performance measurement is a key aspect of a safety risk management process and provides the basis for continuous safety improvement. As part of the annual review of the ASP, BBB will reevaluate its safety performance measures and determine how the measures should be refined, sub-measures developed, and performance targets selected. And, while the Safety and Training Division will be responsible for tracking this information, all BBB divisions will be responsible for providing the information to the Safety and Training Division.
Additional to FTA performance target requirements, the Safety and Training Division reports internal Key Performance Indicators (KPI) to the BBB Executive Team on a monthly basis. These KPI’s are focused on Service and Reliability, Accidents, Security Incidents. The KPI’s ensure the highest level of leaderships awareness of safety events and help to measure both leading and lagging indicators and assure continual improvements agency wide. 35 Relationship between Safety Performance and Transit Asset Management The safety and performance of a public transportation system depend, in part, on the condition of its assets. When transit assets are not in a state of good repair, the consequences include increased safety risks, decreased system reliability, higher maintenance costs, and lower system performance.
Transit asset management is a strategic approach to improving and maintaining the condition of transit capital assets. MAP-21 required the FTA to define the term “state of good repair,” develop objective standards for measuring the condition of capital assets and establish performance measures based on the state of good repair.
BBB’s Maintenance Division utilizes FTA’s Useful Life Benchmark to conduct condition assessments and develop performance targets. For details regarding BBB’s State of Good Repair, refer to BBB’s Transit Asset Management Plan. (Appendix A-4: BBB TAM Final Plan)
5.1.2. Internal Safety Reviews
BBB has developed and implemented a process for the performance of on-going Internal Safety Reviews (ISRs). The purpose of conducting internal system reviews is to evaluate the effectiveness of the implementation of the ASP. This process ensures the implementation of the ASP and evaluates the plan effectiveness on a continuous basis. An ISR of the ASP must be conducted annually, and all components of the ASP must be reviewed within a three -year period.
Internal safety reviews include the review of SMS components, safety procedures and practices, training, and all related documentation storage and records retention. Organizational functions subject to the ISR process include:
• Facility inspections
• Maintenance audits/inspections
• Review of rules, standard operating procedures, bulletins • Review of training/re-certification programs
• Emergency response planning, coordination, training
• Systems modifications (review and approval)
• Safety data analysis
• Employee safety programs
• Hazardous materials program
• Interdepartmental safety goals and objectives
• Occupational safety and health programs
36 • Contractor safety
• Procurement and specification engineering
• Drug and Alcohol Testing Program
• Any aspect or responsibility as outlined in this document
5.1.3. Investigation of Safety Events
The purpose of providing in-house management and investigations of work-related accidents, injuries and incidents is to limit injury and damage, identify facts, establish root causes, suggest methods for preventing recurrence, and eliminate or reduce health and safety risks for BBB’s staff and customers. Investigation results can be used to learn more about mechanical and other failures and human factors and to correct unsafe conditions.
Any incident resulting in a fatality, serious injury, or damage to property, equipment or environment is thoroughly investigated.
Investigation Process
Investigations are performed using National Safety Council/TSI guidelines, and BBB standards.
The investigation process begins after arranging for first aid or medical treatment for the injured person(s). The involved staff member’s immediate supervisor typically conducts the initial investigation in conjunction with the Safety and Training Division. • Maintenance-related injuries or collisions are investigated by the on-duty Maintenance Supervisor.
• Bus collisions/incidents are investigated by the on-duty Road Supervisor. • Administrative staff injury investigations are initiated by the staff member’s immediate supervisor and forwarded to the Safety and Training Division for follow-up. • Fatalities will be investigated by the appropriate City authority along with the Safety and Training Manager, the City’s Safety Officer, and with involvement from the Executive Leadership Team and City Attorney’s Office.
Steps of the investigation process include:
1. Call or gather the necessary person(s) to conduct the investigation.
2. Secure the area where the incident occurred and preserve the work area as it is.
3. Identify and gather witnesses to the event.
4. Interview the involved staff member(s).
37 5. Interview all witnesses.
6. Document the scene of the incident through photos or videos.
7. Complete the investigation report, including determination of what caused the incident and what corrective actions will prevent recurrences.
8. Use results to better identify and control hazards before they result in incidents.
9. Ensure follow-up on completion of corrective actions.
Identifying Causal Factors
The purpose of fact-finding is to determine all the contributing factors to why the incident occurred. Contributing factors may involve equipment, environment, people, and management.
Questions that help reveal these factors may include:
• Was a hazardous condition a contributing factor? (defects in equipment/tools/materials, condition recognized, equipment inspections, correct equipment used or available, substitute equipment used, design or quality of equipment) • Was the location a contributing factor? (route, sufficient workspace, environmental conditions)
• Was the job procedure a contributing factor? (written or known procedures, ability to perform the job, difficult tasks within the job, anything encouraging deviation from job procedures such as incentives, on-time performance or speed of completion) • Was lack of personal protective equipment or emergency equipment a contributing factor? (PPE specified for job/task, adequacy of PPE, whether PPE used at all or correctly, emergency equipment specified, available, properly used, function as intended)
• Was a management system defect a contributing factor? (failure of supervisor to detect or report hazardous condition or deviation from job procedure, supervisor accountability understood, supervisor or worker adequately trained, failure to initiate corrective action)
Documentation and Mitigations
Once the investigation report is completed, the report is submitted to the Safety and Training Division for review and inclusion into the Safety Risk Management Process (see Section 4 of this document). As stated in Section 4, the reports are reviewed by the appropriate teams for safety hazard identification, risk assessment and mitigation. Corrective actions are communicated to the appropriate division managers, committees, and involved staff. Investigation reports are stored by the Safety and Training Division. Workplace injury reports resulting in Workers Compensation claims are stored by BBB’s workers compensation third party administrator. 38 5.1.4. Corrective Action Plans
A Corrective Action Plan (CAP) is a set of actions to correct an issue, problem, non-compliance or underperformance. It is essentially a plan to improve performance and/or reduce risk.
BBB shall develop and implement corrective action plans (CAPs) to address risk and hazards identified through investigations, the hazard management process, audit findings, internal safety review findings, or recommendations specified internally. The CAP shall describe the actions the Agency will take to minimize, control, correct, or eliminate identified risks and hazards, the schedule for taking those actions, and the individual(s) and or department(s) responsible for taking those actions.
All CAPs are managed and reviewed on a monthly basis by the Hazard Analysis team
5.1.5. Safety Data Collection & Analysis
Safety data is collected through a variety of sources including SHARP reports, occurrence reports, internal safety reviews, safety committee meetings, occupational injury reports, incident reports, reports from the CAD/AVL, asset management, planning or operations software systems, system monitoring including testing and inspection records, and the hazard management program. The information collected from these sources is analyzed for trends and potential safety impacts.
Identified areas of concern are reported to appropriate personnel and are presented at various committee and staff meetings (i.e. Safety Meetings, Safety Committees, Executive Leadership Team meetings).
The Safety and Training Division collects, classifies, and analyzes accident/incident, occupational injury and illness data to identify trends, hazards or unsafe conditions using the data sources referenced above. The finding are then routinely communicated to affected or interested BBB divisions.
5.1.6. Drug & Alcohol Program
The City of Santa Monica has implemented the Drug and Alcohol Policy/Procedures for Employees in Safety-Sensitive Job Functions for covered BBB employees to ensure compliance with federal regulations of the United States Department of Transportation (USDOT).
BBB is committed to maintaining a safe and productive work environment and providing safe, dependable and efficient transportation services to our customers. We recognize that our safety-sensitive employees’ potential use of illegal drugs and misuse of alcohol poses a significant risk to public safety, as well as the employee’s health and well-being, and can cause 39 loss of efficiency and productivity or a disruptive work environment. In view of this, BBB has adopted a Drug and Alcohol Program that is designed to:
1. Provide a drug and alcohol-free work environment;
2. Deter and detect employees’ use of illegal drugs and misuse of alcohol;
3. Prohibit the unlawful manufacture, distribution, dispensing, possession, or use of drugs; and
4. Encourage employees to seek professional assistance anytime personal problems, including drug or alcohol dependency, may adversely affect their ability to safely perform their assigned duties.
Participation in this program is a requirement of all safety-sensitive employees, and therefore, is a condition of employment. (Appendix A-5: Drug and Alcohol Policy/Procedures for Employees in Safety-Sensitive Job Functions)
5.1.7. Inspections
BBB conducts inspections to assure that all systems, facilities, and equipment operate as required, or in the event of failure or degradation of functionality, that operational safety is not compromised. Facilities and equipment are inspected on a routine basis according to company policies, SOPs, guidelines, and recommendations as required by federal, state, and local regulations. Through the BBB inspection processes, hazards are identified, corrected, and monitored. The following sections outline the inspection processes per mode.
Facilities Inspections
Inspection and maintenance of facilities and related equipment is performed in accordance with manufacturers’ manuals, codes, standards and established procedures. Visual inspections of facilities are performed by Facility Maintenance personnel for safety hazards and to assure the security of them. Noted defects are addressed appropriately and with the pertinent division.
Work requirements that are beyond the capability or capacity of in-house maintenance personnel are performed through service contracts. They include such areas as landscape maintenance; janitorial services; elevator maintenance; fire protection system inspection and services; LCNG maintenance and repair services, heating, ventilating, and air conditioning (HVAC) services; storm water drainage, plumbing, standby generator services; waste removal services.
40 BBB Bus System Inspections
Major elements in the bus system that directly affect safety are: vehicles, right of way, bus shelters, bus stop signs, layovers and shared transit centers. The goal is to maintain a level of readiness that ensures safe, efficient and reliable transit service. Preventive maintenance activities on equipment and other safety critical equipment are performed in accordance with manufacturers’ recommended practices and are documented. Checklists are used in conducting inspections of facilities and equipment.
Inspections and maintenance of all vehicles, equipment, and wayside systems are performed in accordance with the manufacturer’s manuals, codes, standards and established procedures using written checklists.
Inspections and maintenance of facilities and related equipment is performed in accordance with manufacturers’ manuals, codes, standards and established procedures. Visual inspection of bus shelters and stops are performed by Facility Maintenance personnel and/or its contractor for safety hazards and to assure the security of them. Noted defects that affect passengers are reported to the Operations Division.
Critical hazardous conditions that are noted during inspections are immediately reported to the Maintenance Manager for corrective action. The deficiency is recorded in the maintenance department’s Fleet Management system. Deficiencies that do not require immediate attention are logged in Maintenance Connect and scheduled for future repair or corrective action. The Safety and Training Division receives copies of all deficiency reports for tracking through the Hazard Management process. The adequacies of control measures for safety critical equipment and systems are evaluated to ensure the proper corrective actions are in place to control potentially hazardous conditions to passengers, employees, and the general public.
5.1.8. Hazardous Materials & Local State and Federal Regulations BBB ensures the health and well-being of all BBB employees through routine inspections that identify, control or eliminate health hazards that potentially exist in the workplace.
Comprehensive health programs and policies have been established to protect BBB workers and comply with Occupational Safety and Health Administration (OSHA) regulations.
The Safety and Training Division is responsible for the development and implementation of employee safety and health training programs. The programs and activities performed by BBB & the City of Santa Monica to fully comply with all local, state and federal requirements relating to hazardous materials are delineated in the City of Santa Monica’s Injury and Illness Prevention Program (Appendix A-6: Injury and Illness Prevention Written Program). 41 5.1.9. Compliance
Rules Compliance is the state of being in accordance with established standards, processes, procedures, methods, and regulations. BBB has developed Departmental Instructions, Bulletins, SOPS, Motor Coach Operator’s Handbook, Training Manuals, and individual department procedures that govern the adherence for safety and operations.
5.1.10. Procurement
The Maintenance Division works in conjunction with the Safety and Training Division when purchasing personal protective equipment for employees, controlling chemicals and other hazards in the workplace, mandating safety requirements in specific contracts and requiring compliance from specific vendors with BBB’s safety requirements. The purchasing process begins with the preparation of a request that is submitted to the City’s Procurement Division.
Procurement planning includes considering safety, technical, business, management, and other issues in controlling acquisition from inception to completion.
In defining vehicle design requirements, operational and passenger safety are the highest priorities. Design criteria are established to ensure all equipment meets or exceeds all state and federal standards and regulations in effect at the time governing the specific equipment.
Conditions covered in the contract specifications include verification of compliance, commencing with the design phase and periodic inspections and testing during the construction phase performed by qualified consultants. A thorough inspection and system testing is performed before the equipment is conditionally accepted.
5.2. Management of Change
Change Management is a critical part to having an effective Safety Assurance program. Any change may introduce new hazards and safety risk into transit operations. BBB has established criteria that define when a change must be evaluated through the SRM process. When a proposed or identified change meets or triggers BBB established criteria, BBB uses the SRM process to review existing mitigations to determine if they are sufficient or if new mitigations are necessary. BBB’s change management process assures that changes to existing operations and extension projects are reviewed for conformance with existing federal, state, and local standards and to identify and assess potential hazards before making changes. The following sections explain BBB’s Change Management processes:
• Modification and Expansions
42 • Configuration Management
• Safety and Security Review
Modifications and Expansions
The Maintenance Division is responsible for the rehabilitation, renewal, and modernization of BBB facilities and BBB vehicles. The Maintenance Manager is responsible for ensuring that hazards associated with the system designs, expansions, or modifications are included in the hazard resolution process.
Decisions about the design, acquisition, or modification of system assets and services are based on operational needs and on safety and security implications. BBB actively solicits input from a variety of sources including its own stakeholders, other agencies with expertise, governmental entities, published research, and independent contractors.
Configuration Management
BBB’s Configuration Management process ensures that the physical configuration and functional accuracy of all BBB facilities, vehicles and equipment are properly documented.
Changes to the system and/or subsystem(s) will not be made without first having a determination, by the affected department and the Safety and Training Division on how the changes might affect the safety of the system. These changes may involve existing system or proposed design and construction.
Safety and Security Review
As new facilities, equipment and systems are incorporated into general use, they are evaluated for continued safety and security and any lessons learned are applied to future procurements.
Using principles outlined in Crime Prevention through Environmental Design (CPTED), CalOSHA standards, and general industry practices, BBB employs safety assessments throughout the life of any project, acquisition or procurement of vehicles, equipment or systems.
BBB conducts a Safety and Security Review (SSR) that verifies that the system, as designed and installed, meets or exceeds statutory requirements for safety, secure operations, and maintenance. The SSR process addresses conditions that could result in harm, whether unintentional (safety) or intentional (security). Application of the SSR promotes an informed management decision-making process in project design, construction, testing, and initiation into revenue service.
43 Another key component of safety and security review is a quality control and assurance program to assure that the system is constructed and installed in accordance with design criteria and design specifications. Ongoing inspections and audits are conducted, and adjustments made to facilities and systems as required. As BBB systems continue to expand, all safety certification requirements are met.
Checklists of safety requirements are developed and the Safety and Training Division systematically assures compliance to these requirements.
5.3. Continuous Improvement
Continuous Improvement is defined by the FTA as a process by which a transit agency examines safety performance to identify safety deficiencies and carry out a plan to address the identified safety deficiencies. It is the ongoing effort BBB makes to improve safety, while at the same time improving our services and operations.
Continuous Improvement is measured by monitoring BBB’s safety performance indicators.
Progress is related to the maturity and effectiveness of an SMS. Safety assurance processes support improvements to the SMS through efforts of continual verifications and follow-up actions. It uses information gained from employees and safety assurance activities (including investigations, reviews, and audits) to identify areas that could be improved.
As BBB builds on its SMS, considerations will be made to the following industry best practices:
• There is evidence of lessons learned being incorporated into the policy and procedures; • The organization benchmarks its SMS against other organizations and is an active promoter of SMS within the transit industry;
• Best practice is sought and embraced;
• Surveys and assessments of organizational culture;
• The organization requires contracted organizations not required by regulations to have an SMS; and
• Contractors can participate and share information in the SMS.
Other sources of data for continuous improvement include comments from USDOT, FTA and any other regulatory compliance agency.
44 Agency Safety Plan Annual Review Process
BBB is the authority for the development, implementation, and management of the ASP. The Safety and Training Division has the primary responsibility of implementing the ASP. Annual review of the ASP is mandatory and specific responsibilities of the federal requirement standard within the ASP framework include, but are not limited to:
a. By the second week of March of each year notify the Southern California Association of Governments of any recommended changes to the ASP for review and approval. b. Revisiting the ASP annually to reflect changes in organizational structure and new systems that require significant changes in operation
c. Review progress on goals and objectives
d. Refine and improve on the current goals and objectives of the SMS program e. Identify new tasks or objectives to respond to system growth or any new regulations that effect system safety
f. Identify any additional safety-related tasks and responsibilities. 45 6. Safety Promotion
This chapter describes how BBB will implement SMS under the Safety Promotion requirements as defined in federal rulemakings. The Safety Promotion component of this plan will serve a dual role of outlining BBB’s Competencies & Training and the agency’s various Safety Communication processes. Under Safety Promotion, BBB is required to maintain routine and relevant safety communication throughout the agency. This information includes, but is not limited to, hazards and safety risks relevant to employees’ roles and responsibilities along with safety actions taken in response to reported safety concerns. BBB is also required to ensure staff at every level receives comprehensive safety training. More specifically, employees and contractors that are directly responsible for the safety of BBB’s system will receive both comprehensive and technical training to ensure competency. Select employees will fall under the Public Transportation Safety Certification Training Program Rule (49 CFR Part 672).
Safety Promotion is comprised of:
• Safety Competencies and Training: A transit agency must establish and implement a comprehensive safety training program for all agency employees and contractors directly responsible for safety in the agency’s public transportation system. The training must include refresher training, as necessary.
• Safety Communication: A transit agency must communicate safety and safety performance information throughout the agency’s organization that, at a minimum, conveys information on hazards and safety risks relevant to employee’s roles and responsibilities and informs employees of safety actions taken in response to reports submitted through an employee safety reporting program.
6.1. Safety Competencies
The role of each BBB employee varies in the level of safety criticality based on the employee's daily functions. While the applicability of some safety competencies is cross-departmental, there are functions that are more specialized and technical based on each employee's roles & responsibilities. For example, all BBB employees are trained and expected to report safety hazards for proper mitigation. However, the role of an Administrative employee will require a different set of competencies than a Maintenance employee. Job competencies are detailed on each employee's job specification sheet, which is retained in designated Human Resources 46 databases. Competencies are also identified in each department's respective training manuals and applicable guidelines.
6.2. Comprehensive Safety Training
The adoption of FTA’s Safety Management Systems (SMS) framework is an agency-wide effort.
BBB staff at every level of the organization will be required to complete training based on their designated SMS role. The assignment of SMS roles ensures each employee understands the importance of safety; the fundamentals of SMS; safety reporting; and knowledge of their individual role within BBB’s safety management structure. Training will range from a comprehensive safety training, hazard identification and reporting to full Public Transportation Safety Certification Training Program (PTSCTP) certification and biennial refresher training.
SMS training will be introduced to new BBB employees during the on-boarding process through New Employee Orientation training; and to current employees through online and in-class training. All courses required for PTSCTP certification are provided by Transportation Safety Institute (TSI) in the classroom or online. The full listing of courses and schedules can be found on TSI’s website. New users to the site may sign up for a free account to review the catalogue and register for classes.
Safety and Security Training activities are managed through the Safety and Training Division and are designed to prepare staff for the transit work environment. Job-specific training programs are designed to enhance safety and security skills necessary for safe, secure, reliable and high quality service. The Safety and Training Division will be responsible for tracking the completion of required training and maintaining appropriate training records. Divisions will still be required to maintain other safety critical trainings, based on job responsibilities.
General Safety Training
All employees are trained with respect to their roles and responsibilities as they relate to BBB’s safety performance. Training includes:
Motor Coach Operator Safety Training Programs
• Defensive Driving Program
• Accident Retraining
• Return-to-Work training
• Operator Refresher Training
• Customer Service Training
• Verification of Transit Training courses
o 8-hour classroom training each renewal year
47 o 8-hour in-service and behind-the-wheel training each non-renewal year • TSA Security Program Training
• De-Escalation
Maintenance/Facility Safety
• Mandatory OSHA/CalOSHA trainings
• Aerial Platform Certification
• Powered Industrial Truck (Forklift) Certification
• Noise Protection
• Lock Out Tag Out
• Personal Protection Equipment
• Respiratory Protection
• Welding, Cutting, and Brazing Safety
• Confined Spaces
• OSHA 10-HOUR and 30 HOUR
• TSA Security Program Training
General Safety Programs
• Blood Borne Pathogens
• Drug and Alcohol Awareness
• Ergonomics
• Back Safety
• Fall Protection
• Fire Safety
• Emergency evacuation plans
• Right-To-Know
• Workplace Violence
• Active shooter survival
• Terrorism awareness
• De-Escalation
• Cybersecurity
• Harassment Prevention
48 6.3. Public Transportation Safety Certification Training Program
The Federal Transit Administration (FTA) recommends that designated personnel and contractors who are directly responsible for the safety oversight bus and paratransit safety comply with 49 CFR Part 672: Public Transportation Safety Certification Training Program (PTSCTP), Final Rule.
For bus transit system operators, this rule is voluntary.
The following outlines the curricula for voluntary PTSCTPs.
PTSCTP Voluntary Curriculum Designated Personnel with Bus and Paratransit Safety Oversight • SMS Awareness – e-learning delivery
• Safety Assurance - e-learning delivery
• SMS Principles for Transit
• Transit Bus System Safety
• Effectively Managing Transit Emergencies
• Fundamentals of Bus Collision Investigation
Refresher Training Recommendation: One hour of safety oversight training is recommended every two years following completion of the initial certification.
6.4. Safety Communication
BBB is committed to ensuring employees throughout the agency are aware of any policies, activities and procedures that are related to their roles and responsibilities. The maintenance of multiple communication channels ensures employees are routinely briefed on safety critical information relevant to their respective roles. Management utilizes various channels of communications which may include, but are not limited to:
SafetyShare
In 2017, BBB established its safety program, SafetyShare, which promotes the following methods of communication.
• Quarterly Mandatory Safety Meetings for Service Delivery Staff which communicates:
o Safety topics
o Review of performance measures
o Review of SHARP reports and resolutions
• Biennial Campus Safety Meetings which communicates:
o Safety topics
49 o Review of performance measures
o Review of SHARP reports and resolutions
• SafetyShare Committees which communicates:
o Safety topics
o Review of performance measures
o Review of SHARP reports and resolutions
o Observations from safety inspections
o Review of employee injuries
• Maintenance tailgate meetings which communicates:
o Daily safety topics and recommendations
o Procedural updates
• MyInfoBlue portal- an online portal available to all staff which stores safety bulletins Tools to support safety communication include:
• Safety bulletins
• “Safety Corner” bulletin boards
• Electronic screens in Ready Room, Maintenance Shop and Fueling Island break room • Safety Posters
• Toolbox talks in tailgate meetings
• Refresher trainings
• MyInfoBlue
• SharePoint
• Trapeze-based texts and messages
• Emails
It is critical to the SMS process that a continuous loop of communication is maintained between frontline, managerial and executive staff to ensure safety concerns are communicated, evaluated and addressed in a timely and effective manner. Executive Management has established a safety reporting program, SHARP, for all BBB employees to voice safety concerns.
Employees are responsible for utilizing the reporting program under BBB’s SMS. Retaliation against any employee for communicating a safety concern is prohibited. Action will not be taken against an employee unless such disclosure indicates an illegal act, gross misconduct/negligence, or a deliberate or willful disregard of BBB rules, policies and procedures. (Appendix A: Doc. 1 -DI IV-1-8 Employee Safety Hazard and Analysis Reporting Program (SHARP))
50 Conclusion
Big Blue Bus staff is entitled to a safe and healthful place in which to work. As such, BBB is committed to developing, implementing, maintaining, and constantly improving processes to ensure that all of 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 and exceeding established standards.
51 Appendix A: List of Reference Documents
Referenced Document
1. DI-IV-1-8 Employee Safety Hazard and Analysis Reporting Program (SHARP)
2. DI IV-1-2 Safety Committees
3. DI IV-1-7 SafetyPro Onboard Observation Program
4. BBB TAM Final Plan
5. Drug and Alcohol Policy/Procedures for Employees in Safety-Sensitive Job Functions
6. Injury and Illness Prevention Written Program
7. City of Santa Monica’s COVID-19 Prevention Program
8. City of Santa Monica’s ATBP and Communicable Disease Exposure Control Plan
9. 49 CFR Part 673-Public Transportation Agency Safety Plans 52 Appendix B: Definitions
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 rail transit vehicles; a runaway train; an evacuation for life safety reasons; or any derailment of a rail transit vehicle, at any location, at any time, whatever the cause.
Accountable Executive
A single, identifiable person who has ultimate responsibility for carrying out the Safety Management System of a public transportation agency, and control or direction over the human and capital resources needed to develop and maintain both the agency’s Public Transportation Agency Safety Plan.
Chief Safety Officer
An adequately trained individual who has responsibility for safety and reports directly to the Accountable Executive. A chief safety officer may not serve in any other operational or maintenance capacity.
Corrective Action Plan
A plan developed by the transit agency that describes the action the agency will take to minimize, control, correct, or eliminate hazards, and the schedule for implementing those actions.
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 a public transportation 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; or damage to facilities, equipment, rolling stock, or infrastructure that disrupts the operations of a transit agency.
Investigation
The process of determining the casual and contributing factors of an accident, incident, or hazard, for the purpose of preventing recurrence and mitigating risk.
Safety Assurance
The process within a transit agency’s Safety Management System that functions to ensure the implementation and effectiveness of safety risk mitigation, and to ensure that the transit 53 agency meets or exceeds its safety objectives through the collection, analysis, and assessment of information.
Safety Management Policy
A transit agency’s documented commitment to safety, which defines the transit agency’s safety objectives and the accountabilities and responsibilities of its employees regarding safety.
Safety Management System (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
A quantifiable level of performance or condition, expressed as a value for a given performance measure, achieved over a specified timeframe 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 Management
A process within a Transit Agency’s Safety Plan for identifying hazards, assessing the hazards, and mitigating safety risk.
Safety Risk Mitigation
The activities whereby a public transportation agency controls the probability or severity of the potential consequences of hazards.
Safety Risk Probability
The likelihood that 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
54 Appendix C: Acronym List
Abbreviation Definition
APTA American Public Transportation Association
ASP Agency Safety Plan
BBB Big Blue Bus
CAP (S) Corrective Action Plan
CFR Code of Federal Regulations
USDOT United States Department of Transportation
FTA Federal Transportation Administration
ISR Internal Safety Review
KPI Key Performance Indicator
MAP-21 Moving Ahead for Progress in the 21st Century Act MTBE Mean Time Between Events
NTSB National Transportation Safety Board
PTASP Public Transportation Agency Safety Plan
PTSCTP Public Transportation Safety Certification Training Program SCAG Southern California Association of Governments
SHARP Employee Safety Hazard and Analysis Reporting Program SMP Safety Management Policy
SMS Safety Management System
SOP Standard Operating Procedure
SRM Safety Risk Management
SSCP Safety and Security Certification Plan
TSI Transportation Safety Institute
VRM Vehicle Revenue Miles
ATTACHMENT 1
DI-IV-1-8 Employee Safety Hazard and
Analysis Reporting Program (SHARP)
ATTACHMENT 2
DI-IV-1-2 SAFETY COMMITTEES
Revised Date: 7/27/2022 Safety Committees Page 1 of 5
I. PURPOSE
To establish a comprehensive, collaborative forum that brings a cross-functional team representing all Santa Monica Department of Transportation (DOT) Divisions together for the discussion, evaluation and resolution of safety concerns in order to better control risk, detect and correct safety problems earlier, and share and analyze safety data more effectively.
II. SCOPE
This policy and plan applies to all employees of the City of Santa Monica’s Department of Transportation.
III. POLICY
The DOT shall establish two Safety Committees; a Campus Safety Committee and an Operations Safety Committee, as a tool for developing and promoting a safe, healthy and secure environment for all employees and customers.
IV. ELIGIBILITY
Safety Committee Member applicants must meet the following qualifications:
• A minimum of two (2) years employed by DOT
• No significant disciplinary action in the past 12 months V. MEMBERSHIP
The safety committees shall include staff members from each respective division. It shall consist of an equal number of frontline employee representatives and management representatives. Employees are welcome to participate on the safety committees regardless of education or background. Members shall be selected and shall hold a one-year term, with any vacancies filled prior to the next scheduled meeting.
DEPARTMENTAL INSTRUCTION
Subject: Safety Committees Document #: IV-1-2
Issued By: Transit Safety and Training Division
Approved By: Total Pages: 5
Issue Date: 6/15/2017 Revision Date: 7/28/2022
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Candidates for membership shall complete the “Safety Committee Membership Application” and submit it to the Transit Safety and Training Manager. Operations Safety Committee members shall be selected by representatives from the Sheet Metal Air Rail and Transportation Union (SMART) while the Campus Safety Committee members shall be selected by representatives from the International Brotherhood of Teamsters. The selection shall be made based on the candidate’s qualifications which are listed on the application.
The safety committees shall be comprised of members from the following divisions.
ALL employees are encouraged to apply.
A. Campus Safety Committee
Employee Membership:
• Two (2) Transit Mechanics
• One (1) Motor Coach Cleaner or Transit Maintenance Worker • One (1) Transit Maintenance Supervisor
• One (1) Member from any of the following Transit divisions:
o Transit Planning and Performance Division
o Transit Finance and Administrative Services
o Transit Community and Government Relations Division
o Transit Operations (Administration)
• One (1) Member from the Mobility Division
• One (1) Member from the Parking Division
• One (1) Transit Safety and Training Manager or Designee • One (1) Transit Maintenance Superintendent or Designee B. Operations Safety Committee
Employee Membership:
• Two (2) Motor Coach Operators
• One (1) SMART Representative
• One (1) Motor Coach Operator Supervisor
• One (1) Transit Safety and Training Manager or Designee • One (1) Transit Operations Superintendent or Designee • One (1) Transit Maintenance Superintendent
VI. PROGRAM ELEMENTS
Safety committees will meet on a quarterly basis, uniformly scheduled in advance as to time, date, and place, unless otherwise determined by the Committee.
Committee meetings shall generally be one hour in length.
At a minimum, the safety committees shall address the following:
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(1) Provide a forum for employee concerns and suggestions about safety and health, including review of written reports to assist in the improvement and correction of identified, unsafe conditions or practices; (2) Review investigations of occupational accidents and causes of incidents resulting in an occupational injury, illness or exposure to hazardous substances in order to determine corrective actions or identify actions that will help prevent future events;
(3) Review results of periodic scheduled worksite inspections; (4) Review results of investigations of alleged hazardous conditions brought to the attention of any committee member;
(5) Identify and recommend risk-based mitigations or strategies necessary to reduce the likelihood and severity of the consequences identified through safety risk assessments;
(6) Identify mitigations or strategies that may be ineffective, inappropriate, or were not implemented as intended;
(7) Identify safety deficiencies for purposes of continuous improvement; (8) Review and approve the DOT’s Public Transportation Agency Safety Plan; and
(9) Keep records of attendance and subjects discussed.
VII. RESPONSIBILITIES
Each safety committee shall elect a Chairperson. During the first year following the establishment of the safety committees, the Transit Safety and Training Manager shall serve as chair. In subsequent years, the Chairperson shall be elected by the membership.
Safety Committee Chairperson
(1) Facilitate the committee activities and meetings. Ensure the effectiveness of the meeting by directing discussions to meet goals and objectives.
(2) Schedule and develop an agenda for meetings based on member input in conjunction with the Transit Safety and Training Division. (3) Coordinate the assignment of activities of committee members. (4) Establish necessary deadlines based on member input. (5) Follow-up on assigned responsibilities.
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(6) Recommend the removal of a Safety Committee Member if the member is not performing his/her responsibilities.
(7) Introduce new members.
Safety Committee Secretary (Designated Safety & Training Staff Assistant) (1) Document attendance.
(2) Keep a written record of topics discussed, issues raised, and suggested resolutions.
(3) Record action items, assigned activities, and estimated dates of completion.
All Safety Committee Members
(1) Attend and participate in safety committee meetings. (2) Support and participate in safety committee activities. (3) Actively promote safety, health and security.
Management/Supervisors
(1) Actively promote safety, health and security. Lead by example. (2) Follow and enforce all safety and health rules and procedures. (3) Support employee elections as needed.
(4) Facilitate and ensure employee participation. Allow the time for committee representative participation in meetings and assigned responsibilities which may include training.
(5) Address safety concerns and suggestions. Participate in the committee process.
(6) Allocate the funds/resources necessary to implement safety and health committee activities.
(7) Provide timely feedback to the committee.
(8) Perform the initial investigation of all injuries, incidents, and near-misses.
Transit Safety and Training Division
(1) Actively promote safety, health and security.
(2) Support and participate in safety committee meetings and activities. (3) Provide information and technical expertise.
(4) Investigation of accidents, injuries, incidents and near-misses. (5) Effectively communicate changes in applicable regulations to management and staff.
All Employees
(1) Actively promote safety, health and security.
(2) Learn and follow all safety rules and procedures.
(3) Bring safety concerns and suggestions to supervisor and/or safety committee representative immediately.
(4) Attend all safety and security trainings.
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VIII. RECORDKEEPING
The Secretary shall keep minutes, including discussion of topics, and shall document attendance. Unresolved items shall be retained on the committee minutes and the items may be moved to old business.
Minutes from the safety committees and documentation of attendance shall be retained by the Safety and Training Division for a minimum of one year. Minutes shall be accessible to all employees via SharePoint
Attachments:
• Safety Committee Membership Application
DocuSign Envelope ID: 2AD04EA6-F0B2-4763-ABCD-134995556755 ATTACHMENT 3
DI-IV-1-7 SAFETYPRO ONBOARD
OBSERVATION PROGRAM
DEPARTMENTAL
INSTRUCTION
SafetyPro Onboard Evaluation Program IV-1-7
Employee Engagement Committees Page 1 of 3
1. PURPOSE
City of Santa Monica’s Big Blue Bus (BBB) is committed to reducing preventable accidents by providing Motor Coach Operators (MCO) with guidance and training through the observation of driving skills.
2. GOAL
The Goal of the SafetyPro Onboard Observation Program is to ensure that the BBB training team understands the challenges and changes in operating environment in the service area, that our MCOs are operating vehicles safely, and to ensure that the customer experience is meeting or exceeding BBB standards.
3. POLICY
Big Blue Bus shall establish procedures for the evaluation of MCO driving skills and subsequent recommendations made based on onboard and visual observations.
4. SCOPE
This policy applies to all BBB Motor Coach Operators.
Subject: SafetyPro Onboard Observation Program Document #: IV-1-7 Division: Transit Safety and Training Division Total Pages: 2 Issued By: Liseth Guizar, Safety and Training Manager Issue Date: 1/10/2019 Approved By: Ed King, Director of Transit Services Approver Initials: Note:
Revision Information
Rev. No. Date Activity
1 7/2/2024 Removed number of observations/changed Coach and Counseling to Operations Review / changed numbering format.
DEPARTMENTAL
INSTRUCTION
SafetyPro Onboard Evaluation Program IV-1-7
Employee Engagement Committees Page 2 of 3
5. PROCEDURES
a. Evaluators will consist of either Training Coordinators and/or Supervisors trained in the observation and evaluation of safe driving skills.
b. MCOs will be selected for observation based on a randomized list. A list will be generated for each pull period. Once the selected MCO is evaluated, the name will be removed from the list. Copies of the pull lists will be saved for a period of one year.
c. Evaluators will board a bus and observe the MCO’s driving skills for a brief period. d. Evaluators will make notes of their observations on the SafetyPro Evaluation Form. e. Based on their observations, Evaluators will make recommendations to the Operations Division (OPS) for specific MCO retraining needs, , operations review, or commendation (see Section 6. Evaluation Recommendations). f. The evaluation report and recommendations will be forwarded to Operations for review and consultation on the appropriate level of follow up by both divisions.
DEPARTMENTAL
INSTRUCTION
SafetyPro Onboard Evaluation Program IV-1-7
Employee Engagement Committees Page 3 of 3
6. EVALUATION RECOMMENDATION PROCESS
a. Evaluators will complete a report of their observations and make recommendations to commend, coach and counsel, or refer MCO to the training division for retraining.
I. Commend: MCO drove safely, defensively, displayed excellent customer service
II. Operations Review: Safety violations (seatbelt, one-handed driving, etc) III. Retrain: Driving-specific issues (insufficient right-side clearance/turns/lane changes, etc)
b. Recommendations for Operations Review and Retraining shall be submitted to OPS, for their concurrence based upon the evaluation.
I. Operations Review to be completed by an MCO Supervisor.
II. Retraining to be completed by a Training Coordinator. c. Commendations: Safety and Training will send a letter congratulating the MCO for safe driving practices and/or excellent customer service skills. A copy of the letter will be included in the MCOs OPS personnel file.
ATTACHMENT 4
BBB TAM FINAL PLAN
Transit Asset Management
Plan
11/9/23
DocuSign Envelope ID: 730D8629-9F86-462B-AF29-21B9BAC3A87D C:\ProgramData\activePDF\Temp\DocConverter\API\Input\$0f01d35db4dd$7547BD57BC12451EAE31A 9594EF1714D.docx Page 1 of 36
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Contents
Introduction ..................................................................................................................................................6 Overview...................................................................................................................................................6 Purpose .....................................................................................................................................................7 Benefits.....................................................................................................................................................7 Inventory of Capital Assets...........................................................................................................................8 Overview...................................................................................................................................................8 Equipment.................................................................................................................................................8 Rolling Stock..............................................................................................................................................9 Facilities ....................................................................................................................................................9 BBB1 Facility History .................................................................................................................................9 Condition Assessment.................................................................................................................................10 Purpose of Condition Assessment ..........................................................................................................10 Equipment...............................................................................................................................................10 Rolling Stock............................................................................................................................................11 Facility (TERM/Facility Condition Assessment).......................................................................................11 Decision Support Tool.................................................................................................................................12 Overview.................................................................................................................................................12 Equipment...............................................................................................................................................12 Rolling Stock............................................................................................................................................13 Facilities ..................................................................................................................................................13 Facility Condition Assessment ....................................................................................................................13 Investment Prioritization ............................................................................................................................13 Overview.................................................................................................................................................13 Equipment...............................................................................................................................................14 Rolling Stock............................................................................................................................................14 Facilities ..................................................................................................................................................15 TAM and SGR Policy (High Level)................................................................................................................15 Departmental Vision, Mission and Core Values......................................................................................15 Executive Sponsor...................................................................................................................................16 Documented Commitment to Achieving SGR.........................................................................................16 Defined TAM Objectives .....................................................................................................................16 DocuSign Envelope ID: 730D8629-9F86-462B-AF29-21B9BAC3A87D C:\ProgramData\activePDF\Temp\DocConverter\API\Input\$0f01d35db4dd$7547BD57BC12451EAE31A 9594EF1714D.docx Page 3 of 36
Roles and Responsibilities...................................................................................................................17 Implementation Strategy............................................................................................................................17 Key Annual Activities...................................................................................................................................17 Itemization of Annual Order...................................................................................................................17 Identification of Resources.........................................................................................................................18 Evaluation Plan............................................................................................................................................18 Performance Targets...................................................................................................................................18 Overview.................................................................................................................................................18 Rolling Stock............................................................................................................................................18 Equipment...............................................................................................................................................19 Facilities ..................................................................................................................................................19 Infrastructure..........................................................................................................................................19 Appendix A: Equipment List........................................................................................................................21 Appendix B: Service Vehicles......................................................................................................................23 Appendix C: Rolling Stock ...........................................................................................................................25 Appendix D: Facilities..................................................................................................................................31 Appendix E: FTA Useful Life Benchmarks (ULB)..........................................................................................32 Appendix Y: FTA TAM Example ...................................................................................................................33 Appendix Z: Technical Assistance ...............................................................................................................36 DocuSign Envelope ID: 730D8629-9F86-462B-AF29-21B9BAC3A87D C:\ProgramData\activePDF\Temp\DocConverter\API\Input\$0f01d35db4dd$7547BD57BC12451EAE31A 9594EF1714D.docx Page 4 of 36
Table of Figures
Figure 1-Tier Classification............................................................................................................................6 Figure 2-TAM Requirements.........................................................................................................................7 Figure 3-Equipment Classification ................................................................................................................8 Figure 4-Equipment Condition Requirements............................................................................................10 Figure 5-Facility Condition Assessment Criteria .........................................................................................11 Figure 6-Facility Condition Assessment Ratings .........................................................................................12 Figure 7-Capital prioritization process........................................................................................................14 Figure 8-Bus replacement schedule............................................................................................................15 Figure 9-BBB performance Targets.............................................................................................................19 Table of Tables
Table 1-Rolling Stock Performance Targets................................................................................................19 Table 2-Equipment Performance Targets...................................................................................................19 Table 3-Facilities Performance Targets.......................................................................................................19 DocuSign Envelope ID: 730D8629-9F86-462B-AF29-21B9BAC3A87D C:\ProgramData\activePDF\Temp\DocConverter\API\Input\$0f01d35db4dd$7547BD57BC12451EAE31A 9594EF1714D.docx Page 5 of 36
Approval
NAME TITLE SIGNATURE DATE
Author David Nanjo Transit
Maintenance
Administrator
Reviewer Jesus Ocampo Transit Vehicle
Maintenance
Superintendent
Authorizer Eric O’Connor Assistant
Director of
Transportation
Revision and Review Record
Ver no.
Effective
Date Significant Changes PreviousSOP no.
1 10/31/2023 Initial Version NA
DocuSign Envelope ID: 730D8629-9F86-462B-AF29-21B9BAC3A87D 11/9/2023
11/10/2023
11/10/2023
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Introduction
Overview
In accordance to the Moving Ahead for Progress in the 21st Century Act (MAP-21), all recipients and subrecipients of federal financial assistance under 49 U.S.C. Chapter 53 that own, operate, or manage capital assets used in the provision of public transportation must develop a Transportation Asset Management (TAM) Plan. TAM is a business model that uses the condition of assets to guide the optimal prioritization of funding at transit properties in order to keep our transit networks in a State of Good Repair (SGR).
SGR is the condition in which a capital asset is able to operate at a full level of performance. This means the asset:
1. Is able to perform its designed function
2. Does not pose a known unacceptable safety risk
3. Its lifecycle investments have been met or recovered Each transit provider must designate an Accountable Executive. Tier I providers must also develop their own TAM Plan. Tier II providers may participate in a Group Plan or develop its own. Group Plan participants must collaborate with the sponsor in the development of the plan. Tier definitions can be found in the figure below. The City of Santa Monica’s transportation department known as the Big Blue Bus (BBB) is considered to be a Tier I provider.
Figure 1-Tier Classification
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As a Tier 1 provider, BBB has developed a comprehensive TAM Plan and considers this to be a living document. The plan will be edited as needed to reflect our continuous development of our condition assessments, software, and business processes supporting asset management. At a minimum, it will be updated in its entirety at least every four years as required. The TAM Plan will also coincide with relevant Statewide Transportation Improvement Plans, cover four years, and amended during the horizon period when there is a significant change. The first plan was issued in October 2018. The elements of BBBs plan reflect all nine (9) requirement elements of the TAM requirements.
Figure 2-TAM Requirements
Purpose
To help achieve and maintain a state of good repair for the City of Santa Monica’s Transportation department aka the Big Blue Bus, fulfilling the Federal Requirement.
Benefits
1. Improved transparency and accountability
2. Optimized capital investment and maintenance decisions
3. More data-driven maintenance decisions
4. Potential safety benefits
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Inventory of Capital Assets
Overview
The first element of BBB’s TAM plan is to maintain an inventory of all capital assets. The Federal TAM plan categorizes all assets into four asset categories as seen in the image below. BBB’s capital assets categories include Equipment (non-service vehicles and maintenance supporting equipment with an acquisition value greater than $50,000), Rolling Stock (revenue fleet & paratransit) and our Facilities.
BBB does not have any Infrastructure, per the definition below.
Figure 3-Equipment Classification
Equipment
BBB’s equipment list includes its 17 service vehicles and maintenance equipment. This includes, but is not limited to, Bus Wash and Fuel Island, Charging Stations, etc. The full list can be found in the Appendices listed below.
The equipment list will come from two sources. The maintenance department will generate the list of service vehicles from the ‘BBB Fleet Inventory’ via the Enterprise Asset Management (EAM) system, and the remainder of the equipment list is generated the City’s fixed assets schedule for the Big Blue Bus.
Service vehicles use FTA’s Useful Life Benchmark (ULB) of five years, as per 2017 Asset Inventory Module Reporting Manual, Pg. 53. An assessment of the condition and performance targets are set for BBB service vehicles. Regular assessments will be created in the future business process improvement of EAM.
A condition assessment of all equipment was performed by an outside consultant in 2022 based on the Transit Economic Requirement Model (TERM). A plan is being developed to do a regular condition assessment of Facility supporting and Maintenance equipment.
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Appendix A: Equipment List with TERM condition code
Appendix B: Service Vehicles with ULB
Rolling Stock
BBB currently operates 194 fixed-route buses, and 4 MODE (Mobility On Demand for Everyone) paratransit vans. The buses have a ULB of 12 years. The Paratransit vans have a ULB of 5 years. BBB is using the default ULB’s as per 2017 Asset Inventory Module Reporting Manual, Pg. 53.
The Rolling Stock list of buses and vehicles will be generated by the Maintenance division from the EAM system report. An assessment was done for each bus and paratransit van and recorded for each piece of equipment for the original plan. With the upcoming business process upgrade of our EAM, BBB will be creating a process for a regular assessment and updating of the condition of each bus and van. a. Buses (12 years ULB)
Appendix C: Rolling Stock
Facilities
BBB has one main facility designated as BBB1. (1660 7th Street) BBB1 has an administrative building, a bus wash & fuel island, and a maintenance building with 21 bays on the property.
1. BBB1
a. 1660 7th Street.
i. 1-Administrative Building
ii. 1-Maintenance Building
iii. 1-Bus Wash & Fuel Island
iv. 1-External Fuel Facility
v. 1-Bus Yard
BBB1 Facility History
This facility originally built on approximately 1 acre was expanded in 1962 to the existing 6.7 acres to accommodate up to 201 buses.
The administrative building constructed in 1983 and its interior remodeled in 2011 to improve the interior aesthetics. Primarily used for operations and business needs, this building houses the Operations, Finance & Administration, Safety & Training, Planning, and Customer Service divisions. The administrative building has two floors of office space and includes two parking areas, including a basement underground garage. The building has a gross square footage of 19,000 SF.
The Bus Was & Fuel Island is located on the South-West corner of the property and includes an 11,000 SF building on the interior of the property, and a 6,000 SF external fueling station accessible by the public on Olympic boulevard. The interior fuel and wash building has two lanes to allow for buses to be fueled, cleaned and to have their fare revenue vaulted for counting. These facilities were constructed in 2002 and the interior Fuel & Wash facilities were upgraded in 2011 to accommodate liquefied and compressed natural gas (LCNG). The island also includes fuel storage vessels of (1) 12,000-gallon unleaded fuel, (2) 30,000-gallon LNG tanks, and 6 CNG storage pressure vessels. The island has 2,300 square feet of administrative offices, which includes the City of Santa Monica money counting room. In 2014, the underground diesel fuel tanks were removed. In 2017, the bus wash and offices were upgraded. An DocuSign Envelope ID: 730D8629-9F86-462B-AF29-21B9BAC3A87D C:\ProgramData\activePDF\Temp\DocConverter\API\Input\$0f01d35db4dd$7547BD57BC12451EAE31A 9594EF1714D.docx Page 10 of 36
upgrade to the LCNG system is scheduled for calendar year 2018.
The Maintenance building is located on the North East side of the property, constructed in 2009 and its gross square footage is 66,000 SF. There are 21 working bays, two chassis wash bays, and a body shop.
Shop bays are equipped with post hoist to accommodate all length of buses including articulated coaches. Bay #6 has an inspection pit, and bays #6, #7, and #8 are designed to have drive-thru capabilities. The maintenance building contains approximately 6,000 square feet of maintenance administrative offices and common areas for support. It also houses an 8,000 square foot warehouse.
Appendix D: Facilities
Condition Assessment
Purpose of Condition Assessment
MAP-21 created a requirement that conditions of facility, infrastructure, rolling stock, and equipment be added to the National Transit Database (NTD). The data set is also needed for BBB to be in compliance for TAM plans and used to calculate SGR related measures. BBB conducts and reports condition assessments for transit assets for which BBB has a direct capital responsibility. The image below provides an overview of how each category is assessed, what will be assessed, and how they are measured.
Figure 4-Equipment Condition Requirements
Equipment
BBB’s 17 non-revenue service vehicles are assessed using FTA’s default ULB as per 2017 Asset Inventory Module Reporting Manual, Pg. 53. The ULB for service vehicles is five years from the purchase date.
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A condition assessment was performed on Maintenance Equipment by an independent consultant in January and February of 2022 (See Facility section below).
Rolling Stock
BBB’s 194 fixed-route buses will be assessed using FTA’s default ULB as per 2017 Asset Inventory Module Reporting Manual, Pg. 53. The ULB for buses is 12 years from the in-service date.
Facility (TERM/Facility Condition Assessment)
In April 2022, Roy Jorgensen Associates (Consultant), conducted a facility condition assessment following the State of Good Repair (SGR) methodology. The Consultant calculated the Condition Assessment Measure using the Transit Economics Requirement Model (TERM) scale. Primary and secondary facility ratings were established for the Maintenance and Administrative Facilities. BBB has facilities that require a condition assessment including any equipment with an acquisition value greater than $50,000. The preliminary review included all assets over $10,000.
The consultant assessed BBB facilities for deficiencies and the overall usability and reliability of eight of the building systems. These systems (as well as business unit support equipment) are defined in the table below.
Figure 5-Facility Condition Assessment Criteria
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The eight systems elements were each assigned an objectively-defined condition code (1-5) that reflects its overall condition and usability. These codes are defined in the table below. BBB will assess its facilities on a rotating three-year cycle. The facilities must have a rating of 3 or above to be considered in a SGR, which is set by the FTA.
Figure 6-Facility Condition Assessment Ratings
In the Facility condition assessment performed by the consultant in 2022, most condition codes for the BBB facilities and systems fall into the range of 3.0 – 4.0 (Good). The systems of concern are the HVAC systems in the Maintenance and Administration facilities which show moderate to heavy wear. SMDOT is currently in the design phase of a project to replace its existing HVAC equipment. The complete facility asset management report is maintained by the BBB Transit Maintenance Administrator, including tables listing the detailed score for each system.
Decision Support Tool
Overview
Each Transit Agency must be able to have an analytical process(es) used to estimate capital investment needs over time and assist in prioritization. BBB has developed a process to create a decision tool for its equipment, Rolling Stock and Facilities.
Equipment
BBB will simply use the default Useful Life Benchmark (ULB) to assist in the replacement of its service vehicles.
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Rolling Stock
BBB uses its asset management system and a bus replacement schedule excel document to track the age of its rolling stock against their ULB, and to plan for replacement of vehicles.
Facilities
BBB will use a combination of the ULB of the equipment and facility, along with result of the condition assessment. On an annual basis, the facilities officer will look at all assets coming up for replacement and assess their replacement date considering the condition and costs of assets. The facility officer will create a list of capital projects by system as well as by individual maintenance and facility supporting equipment.
Facility Condition Assessment
As a result of the condition assessment, we were able to obtain a current facility condition index code for our facilities and equipment, further develop our asset inventory and hierarchy, reconcile current preventative maintenance plans with further recommended plans, and begin a long-term capital replacement plan for assets.
The facility condition index code will be useful in making decisions for priorities and scheduling of capital repairs, improvements, upgrades and replacement of assets. We will also use the index code to drill further into the frequency and depth of preventative maintenance we are conducting on equipment and facilities. In addition the 20 year forecast laid out will help us to structure our future budgets and personnel to support the best maintenance practices and state of good repair.
The assessment will also serve to update our asset inventory within our maintenance asset software.
This will assist us in being more in line with the values and frequency of maintenance for all of our equipment and assets.
The assessment also validated our preventative maintenance schedules for facility operations. The total amount of preventative maintenance inspections is close to 300.
The capital improvement plans will be helpful in planning and budgeting for deficiencies in the equipment and facilities. Along with the 3 year current schedule this report will help us develop our 10- 20 year plans.
Investment Prioritization
Overview
BBB has an investment prioritization process that aligns with its strategic focus. BBB’s strategic focus revolves around replacing its fleet, maintaining assets, projects that positively impact customers, and upgrading technology.
The capital planning process takes place every 2nd year and results in capital programming for a two-year capital budget. In preparation for this process, division managers review their previous budget cycle projects and determine which projects need to be carried forward and which projects have been completed. The division managers then evaluate the need for new projects for the upcoming two-year capital budget period and add them to the list of on-going projects. This list is kept in a spreadsheet to facilitate a discussion regarding where to allocate resources for capital projects. BBB’s internal Capital DocuSign Envelope ID: 730D8629-9F86-462B-AF29-21B9BAC3A87D C:\ProgramData\activePDF\Temp\DocConverter\API\Input\$0f01d35db4dd$7547BD57BC12451EAE31A 9594EF1714D.docx Page 14 of 36
Improvement Projects (CIP) team will review the recommendations and prioritize projects based on BBB strategic goals and recommend projects to the Executive Leadership Team (ELT). BBB’s ELT will make the final determination on the prioritization of investments. The project list is then submitted to City Council for final approval.
Figure 7-Capital prioritization process
Equipment
Equipment over $50,000 will be prioritized based on the number of years until the equipment has met its useful life. The useful life for automobiles, trucks, and other rubber tire vehicles is set at five years.
Rolling Stock
Revenue Vehicles in the High Priority are to be scheduled for replacement within the next year, Medium Priority vehicles are scheduled to be replaced within the next three years, while Low Priority indicates no immediate action is required.
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Figure 8-Bus replacement schedule
Facilities
This section includes all facilities and any equipment with an acquisition value of $50,000. BBB will use the recently completed Facility Condition Assessment, which evaluated facilities asset’s condition and made recommendations for asset replacement to determine when replacement should occur.
TAM and SGR Policy (High Level)
Departmental Vision, Mission and Core Values
BBB is a service department of the City of Santa Monica and uses its vision, mission and core values to guide the business on a day-to-day basis.
Vision - BBB is a leading resource for innovative and environmentally friendly transportation options with a team of employees committed to continuous improvement and excellent service.
Mission – BBB provides opportunities for customer mobility and community well-being as part of an active, accessible, congestion-relieving, multi-modal transportation network.
Core Values are the foundation on which we live and conduct ourselves. The values underlie our work and how we interact with each other. The core values are broken up into three categories outlining our service, our people, and our culture.
In providing transportation services – the first category of our values further defines service to be safe, reliable, sustainable, user-friendly, and relevant. All these categories can and do refer and require the regular procurement, maintenance, rehabilitation, and retirement of assets to perform the service. It is the responsibility of the team to maintain all assets in a state of good repair. The Maintenance divisions are responsible for asset management and have adopted the following Transit Asset Management policy.
BBB will effectively and efficiently provide safe, clean, reliable, and environmentally sound assets through its entire life-cycle, balancing our financial resources and maintaining them in a state of good repair while meeting our organizational strategic goals.
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Executive Sponsor
1. Assistant Director of Department of Transportation
a. Self-Certification
Documented Commitment to Achieving SGR
Defined TAM Objectives
To implement the TAM policy, five goals were established based on the core values of service to promote asset management principles throughout the department. For each goal, objectives with corresponding measurable outcomes are listed in the table below.
Area TAM Goal Objectives
Safe Maintain BBB assets in a State
of Good Repair to support a
safe operating environment
Maintain equipment, rolling stock and facilities in a State of Good Repair
Measure and manage TAM-related risks as it relates
to the criticality of assets
Develop root cause analysis for asset failures
Reliable Perform routine inspections of
assets to keep systems
operating to meet day-to-day
services
Design and implement a comprehensive
preventative maintenance program to keep assets
operating efficiently
Develop condition-based approaches, and predictive
maintenance strategies to reduce overall costs and
provide a reliable transportation system
Sustainable Build and promote financial
sustainability through
implementation of asset
management best practices
Develop objective method to prioritize capital
projects and assess trade-offs between competing
investments
Develop performance measures and baselines to
monitor and improve efficiency of operations
User-Friendly Invest in innovative technology
to improve our customer
experience
Improve the service operations and on-time
performance of vehicles through effective asset
monitoring
Maintain focus on technology systems that improves
the customer experience
Relevant Build a comprehensive
collaborative capital planning
process for BBB assets to meet
current and future customer
needs
Implement TAM Plan and policy consistent with
MAP-21 requirements
Establish clear capital and rehabilitation plans and
monitor performance through quarterly reviews
Assess and implement tools to support data driven
asset management decisions
Advance awareness for TAM across all levels at the
City of Santa Monica
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Roles and Responsibilities
1. Assistant Director of Transit Services
a. Facility, Revenue, and Service Vehicle Inventory
b. Condition Assessment
c. Prioritization
d. Capital Asset Inventory
e. Grants Funding
Implementation Strategy
BBB will use Trapeze Enterprise Asset Management (EAM), State of Good Repair (SGR) and Maintenance Connection systems to manage its inventory of core assets, prioritize planned and unplanned maintenance, monitor its performance and forecast the agencies future asset needs. Within each business process system documentation, a continuous improvement plan has been created on improving the asset management systems, supporting our five goals in delivering service.
Key Annual Activities
Itemization of Annual Order
1. FY22-23
a. Bi-Annual Capital Call (FYE23 & FYE24)
i. Bi-Annual Priorities
1. HVAC system replacement per Facility Condition Assessment recommendations
2. BEB Charging infrastructure design needed to replace CNG buses with additional BEBs
3. CAD-AVL system replacement program – based on Technology roadmap a. Includes updated dispatching system
b. New Yard Management System
ii. Executive Approval
iii. Council Approval
b. Quarterly Capital Update
c. Upgrade of Asset Management system in accordance with Maintenance Agreement d. NTD Submission and Narrative
2. FY23-24
a. Quarterly Capital Update
b. Complete installation of replacement HVAC system
c. Charging Infrastructure project
i. Complete design documents
ii. Permit designs
iii. Open procurement for construction contractor
d. Complete Installation of Yard Management component of CAD-AVL project e. NTD Submission and Narrative
3. FY24-25
a. Quarterly Capital Update
b. Updated Facility Condition Assessment
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c. Charging Infrastructure project
i. Award contract for construction of charging infrastructure ii. Place orders for chargers and capital electrical equipment d. Complete CAD-AVL project
e. Complete design work for SMDOT campus greening project and space planning study f. Begin construction for upgrades to external fuel facility and 7th Street bus layover g. Place order for (30) 40’ BEBs to replace (9) 40’ and (21) 60’ CNG buses h. NTD Submission and Narrative
Identification of Resources
1. Maintenance
a. Fleet Maintenance Staff
i. Transit Maintenance Administrator
ii. Transit Vehicle Maintenance Superintendent
iii. Quality Assurance Coordinator
b. Facilities Maintenance Staff
i. Transit Facilities Maintenance Supervisor
c. Operations Planning Staff
i. Transit Operations Manager
ii. Principal Admin Analyst
iii. City ISD Department Systems Analyst
2. Finance Staff
a. Grants Administrator
b. City Finance Department
Evaluation Plan
1. Monitor
2. Evaluation
3. Continuous Improvement
Performance Targets
Overview
BBB must set targets annually for each asset class. The targets must be supported by the most recent condition data and provide reasonable financial projections. The targets are also to be reported to the NTD annually within four months from the end of BBB’s fiscal year. In the event, BBB’s performance targets decrease, BBB must provide a narrative for the decline. It is also important to remember, there are no penalties for not reaching the performance target.
Rolling Stock
Revenue Asset ULB
(Age
in
Years)
Target (% that have
reached ULB)
Articulated Bus 12 75%
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Bus 12 14%
Cutaway 8 100%
Table 1-Rolling Stock Performance Targets
Equipment
Equipment Asset ULB
(Age
in
Years)
Target
(%)
Automobile UL + 2 50%
Trucks and other rubber tire vehicles UL + 2 0%
Table 2-Equipment Performance Targets
Facilities
Facility Asset TERM
Scale
Target
(%)
Facilities Less
than
3 20
Table 3-Facilities Performance Targets
Infrastructure
BBB does not own any rail fixed guideways and therefore not required to set performance targets for infrastructure.
Asset
Type Measure Asset Description
Default ULB
(in years) Performance Comments
Rolling
Stock
Met or
Exceed ULB
Bus 12 9% 2010 & 2011 Eldorado buses expected to be
replaced by Calendar Year 2025
Rolling
Stock
Met or
Exceed ULB Articulated Bus 12 75%
2011 NABI buses expected to be replaced by
Calendar year 2026 after Charging System
construction
Equipment
Met or
Exceed ULB Automobile UL (5) + 2 53%
Non-Revenue vehicles expected to be
replaced in Calendar year 2024
Equipment
Met or
Exceed ULB
Trucks and Other
rubber tire
vehicles UL (5) + 2 0%
Facility
Rated 3 or
above
Admin/Maint
Facilities 100%
Facility
Rated 3 or
above Transit Store N/A
Figure 9-BBB performance Targets
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Appendix A: Equipment List
# BBB Class Desc Asset Number Asset name Purchase Date Purchase Cost 1 EDP Equipments 000000006771 MICROWAVE PATH SURVEY 7/1/1999 $ 294,640.73 2 EDP Equipments 000000008961
RUNCUTTING & SCHEDULE SOFTWARE-BID
ADVER 1/1/2002 $ 773,138.59
3 EDP Equipments 000000009084 INFO SYSTEM REPLACEMENT-BID ADV. 3/1/2000 $ 3,067,157.31 4 EDP Equipments 000000009814 WEB SITE-PHOTOGRAPHY 2/1/2001 $ 79,074.18 5 EDP Equipments 000000012234 HASTUS/LICENSE & SERVICE FEES 12/1/2003 $ 228,431.81 6 EDP Equipments 000000013084 PASSENGER INFO. SYSTEMS/KIOSK INFRASTRUC 2/1/2005 $ 339,228.66 7 EDP Equipments 000000013307 FLEETWATCH-MAINT. SYS. 7/1/2005 $ 262,900.17 8 EDP Equipments 000000014038 WEB WATCH - ACQUIRE, CONFIGURE SIEMENS 4/1/2006 $ 97,120.21 9 EDP Equipments 000000014320 ELLIPSE CONVERSION - PLAN DESIGN 7/1/2006 $ 263,020.29 10 EDP Equipments 000000016707 DISASTER RECOVERY IS/FAREBOX 5/1/2008 $ 84,663.94 11 EDP Equipments 000000016850 TRAFFIC SIGNAL PRIORITY 7/1/2008 $ 389,794.40 12 EDP Equipments 000000017283 INTERACTIVE VOICE RESPONSE - BID ADS 11/1/2008 $ 289,631.02 13 EDP Equipments 000000017319
KRONOS WORKFORCE TIME KEEPER -
SOFTWARE 11/1/2008 $ 55,336.02
14 EDP Equipments 000000017392 HASTUS - UPG TO VERS 08 LICENSE FEES/SVC 12/1/2008 $ 194,887.20 15 EDP Equipments 000000017711
CUSTOMER RELATIONS MGMT SYSTEM - BID
ADS 3/1/2009 $ 61,824.23
16 EDP Equipments 000000017996 SOFTWARE - PRODUCTIVE SOLUTIONS DAL 6/1/2009 $ 169,536.06 17 EDP Equipments 000000018316 STORAGE AREA NETWORK - N3600 A20 8/1/2009 $ 160,129.05 18 EDP Equipments 000000018317 STORAGE AREA NETWORK - N3600 A20 8/1/2009 $ 160,129.05 19 EDP Equipments 000000019422 BBB BUS STOP DATABASE - DEVELOPMENT 10/1/2010 $ 72,393.76 20 EDP Equipments 000000020002 NETWORK SWITCH - CORE SWITCH MLX4 3/1/2011 $ 98,446.25 21 EDP Equipments 000000020487 MEMORY - IBM EXN300 STORAGE EXPANSION 8/1/2011 $ 73,566.98 22 EDP Equipments 000000020847 STORAGE - IBM SYSTEM X3690 X5 XEON E7285 12/1/2011 $ 113,426.16 23 EDP Equipments 000000020848 STORAGE - IBM SYSTEM X3690 X5 XEON E7285 12/1/2011 $ 113,426.16 24 EDP Equipments 000000020849 STORAGE - IBM SYSTEM X3690 X5 XEON E7285 12/1/2011 $ 113,426.15 25 EDP Equipments 000000020892 ELLIPSE - LICENSE FEE FOR MINCOM 1/1/2012 $ 90,772.54 26 EDP Equipments 000000020934 ELLIPSE 8 - IMPLEMENTATION 1/1/2012 $ 2,493,797.11 27 EDP Equipments 000000021689 FLEETWATCH - UPGRADE 64 GILL BUSES 11/1/2012 $ 51,057.94 28 EDP Equipments 000000021778 PERIMETER VIDEO SECURITY SYSTEM 12/1/2012 $ 88,314.58 29 EDP Equipments 000000022331 DATA - IBM SYSTEM STORAGE N3240 5/1/2013 $ 223,183.95 30 EDP Equipments 000000022606 SOFTWARE - UPGRADE TRANSITMASTER 27.1V 9/1/2013 $ 79,424.11 31 EDP Equipments 000000023020 PHONE SYSTEM - CISCO 2014 3/1/2014 $ 132,337.11 32 EDP Equipments 000000023021 PHONE SYSTEM - CISCO 3/1/2014 $ 103,335.60 33 EDP Equipments 000000024804 CAMERAS - AXIS SEC SURVEILLANCE (125#) 1/1/2016 $ 158,330.25 34 EDP Equipments 000000024808 LABOR - SEC SURVEILLANCE @ TVIC 1/1/2016 $ 222,643.00 35 EDP Equipments 000000024908 LABOR - SEC SURVEILLANCE @ BBB2 3/1/2016 $ 84,192.00 36 EDP Equipments 000000025130 IBM PWR 8 AIX ELLPS 6-HRDWR 7/1/2016 $ 55,820.56 37 EDP Equipments 000000025359 STORAGE AREA NETWORK REPLCMNT PROJ 10/1/2016 $ 231,809.50 38 EDP Equipments 000000025388 ASSET MGT INVENTORY CONDN ASSESSMNT 10/1/2016 $ 52,500.00 39 Farebox Equipment 000000011727 FAREBOX SYSTEM REPLACE.- 5% CONTRACT FEE 6/1/2003 $ 3,829,988.11 DocuSign Envelope ID: 730D8629-9F86-462B-AF29-21B9BAC3A87D C:\ProgramData\activePDF\Temp\DocConverter\API\Input\$0f01d35db4dd$7547BD57BC12451EAE31A 9594EF1714D.docx Page 22 of 36
40 Farebox Equipment 000000012342 ALMEX/TRANSFER MACHINE SFTWRE UPGRADE 1/1/2004 $ 56,595.86 41 Farebox Equipment 000000013406 RADIO INTERFACE - SIEMENS 10/1/2005 $ 149,376.40 42 Farebox Equipment 000000013489 FAREBOX - SERVICE FEES 11/1/2005 $ 162,895.22 43 Farebox Equipment 000000015723 TICKET ISSUING MACHINES & TAP CARD - CON 6/1/2007 $ 2,068,101.88 44 Farebox Equipment 000000021293 TAP CONVERSION 6/1/2012 $ 83,086.76 45 Farebox Equipment 000000024040 FAREBOX - REHAB GFI ODYSSEY 3/1/2015 $ 102,288.38 46 Farebox Equipment 000000024732 TAP-GFI INTEGRATION 12/1/2015 $ 50,568.69 47 Furn & Office Equip 000000014245 MONEY RM SEC. SURVEILLANCE UPGRADE 7/1/2006 $ 102,600.06 48 Furn & Office Equip 000000016187 ENGINES & TRANSMISSION FOR TRAINING 12/1/2007 $ 80,134.60 49 Furn & Office Equip 000000017318 MONEY RM SEC. SURVEILLANCE UPG LJ - EQUI 11/1/2008 $ 57,834.18 50 Furn & Office Equip 000000017597 SURV CAMERA - EQUIPMENT/MATERIAL TICII 2/1/2009 $ 125,120.60 51 Furn & Office Equip 000000018363 FACILITY SURVEILLANCE CAMERA SYS AA 9/1/2009 $ 122,508.67 52 Furn & Office Equip 000000018364 FACILITY SURVEILLANCE CAMERA SYS LJ 9/1/2009 $ 117,484.04 53 Furn & Office Equip 000000023396 PHONE SYSTEM - CISCO 2014 RECPT CONSOLE 9/1/2014 $ 52,587.37 54 Radio Equipment 000000008159 RADIO UPGRADE - PROGRESS PAYMENT 6/1/2000 $ 301,078.11 55 Radio Equipment 000000008949
COMMUNICATIONS-CONSULTANT BID
ADVTSMENT 10/1/1999 $ 6,142,092.77
56 Radio Equipment 000000017396 RADIO - TRUEPOINT 5200 11GHZ DIGITAL MIC 12/1/2008 $ 148,343.08 57 Radio Equipment 000000021041 RADIO - RADIO FREQUENCY REBANDING 2/1/2012 $ 411,420.74 58 Radio Equipment 000000021499 RADIO - RADIO KIT CONVERSION 60 FT COACH 8/1/2012 $ 95,868.79 59 Shop & Garage Equip 000000001346 EMERGENCY GENERATOR BLUEPRINTS 2/1/1991 $ 409,273.03 60 Shop & Garage Equip 000000002084 HOIST VEHICLE 6/1/1987 $ 57,294.00 61 Shop & Garage Equip 000000002143
LIFT RENOVATION MAGNUM WEST PAYMENT-
# 2 10/1/1987 $ 107,729.36
62 Shop & Garage Equip 000000005350 BRAKE LATHE - MODEL 53/DS 5/1/1995 $ 52,929.92 63 Shop & Garage Equip 000000006958 BUS WASH- BID ADVERTISING 7/1/1999 $ 381,568.80 64 Shop & Garage Equip 000000006959 SHELVING WAREHOUSE- BID ADVERTISEMENT 7/1/1999 $ 157,221.88 65 Shop & Garage Equip 000000006968 BUS VACUMM 7/1/1999 $ 133,181.42 66 Shop & Garage Equip 000000007246 BRAKE LATHE - STAR MODEL 5305 7/1/1999 $ 56,092.22 67 Shop & Garage Equip 000000008608 STEAM BAY SCISSORS LIFT - BID ADV 4/1/1999 $ 112,525.82 68 Shop & Garage Equip 000000016946 GENERATOR - BID AD - LJ GENERATOR 8/1/2008 $ 107,357.02 69 Shop & Garage Equip 000000017876 DRIVER TRAINING SIMULATOR - BID ADS 5/1/2009 $ 275,645.98 70 Shop & Garage Equip 000000018138 LIFT - DGS CONTRACT FEE FOR LIFT 7/1/2009 $ 112,463.10 71 Shop & Garage Equip 000000018139 LIFT - DGS CONTRACT FEE FOR LIFT 7/1/2009 $ 112,463.10 72 Shop & Garage Equip 000000018140 EMERG GEN PROJ LJ (NEW) - PRINTING CHG 7/1/2009 $ 839,169.29 73 Shop & Garage Equip 000000018288 LJ BUS WASH - ELEC/PLUMBING/DEMOLITION 8/1/2009 $ 105,600.00 74 Shop & Garage Equip 000000018380 BUS WASHER LJ - N/S CORPORATION 9/1/2009 $ 298,151.03 Grand Total $ 29,201,486.91
DocuSign Envelope ID: 730D8629-9F86-462B-AF29-21B9BAC3A87D C:\ProgramData\activePDF\Temp\DocConverter\API\Input\$0f01d35db4dd$7547BD57BC12451EAE31A 9594EF1714D.docx Page 23 of 36
Appendix B: Service Vehicles
# Unit ID Make Model
License
Plate
Purchase
Cost In-Service Date
1 FM1101 FORD F-150 1055053 $17,568.00 12/16/2010
2 13010T FORD F-550 1386566 $181,000.00 11/6/2013
3 18002T FORD Interceptor 1547931 $32,841.00 10/2/2018
4 18003T FORD Interceptor 1547930 $32,841.00 10/3/2018
5 20001T FORD Interceptor 1591403 $35,514.60 10/1/2018
6 18001T FORD Interceptor 1547888 $32,841.00 10/1/2018
7 20002T FORD Interceptor 1591405 $35,514.60 10/2/2018
8 13020T TOYOTA PRIUS 1397254 $26,429.00 8/20/2013
9 13030T TOYOTA PRIUS 1397255 $26,429.00 8/20/2013
10 14010T TOYOTA PRIUS 1433431 $26,429.00 12/1/2013
11 16010T TOYOTA PRIUS 1476311 $29,410.00 8/1/2016
12 16020T TOYOTA PRIUS 1476309 $29,410.00 8/1/2016
13 16030T TOYOTA PRIUS 1476310 $29,410.00 8/1/2016
14 9002T TOYOTA PRIUS 1160603 $22,000.00 4/1/2004
15 1201T GMC Sierra 2500 HD 1384219 $24,373.00 9/4/2012 16 23001T FORD F250 CR42U49 $76,195.12 6/26/2023
17 23002T FORD F250 CR42V18 $76,195.12 6/26/2023
# Unit ID Make Model
License
Plate
Purhcase
Cost
In-Service
Date
1 9001T TOYOTA PRIUS 1160604
$
21,779.49 4/1/2004
2 9002T TOYOTA PRIUS 1160603
$
21,779.49 4/1/2004
3 1081T CHEVROLET W-SERIES 1054989
$
67,732.78 11/16/2007
4 0901T TOYOTA HIGHLANDER 1227307
$
37,168.00 10/25/2008
5 0902T TOYOTA HIGHLANDER 1227308
$
37,168.00 10/28/2008
6 0903T TOYOTA HIGHLANDER 1227309
$
37,168.00 10/28/2008
7 FM0904 FORD F350 1328119
$
62,270.85 10/5/2009
8 FM1101 FORD F-150 1055053
$
19,280.88 12/16/2010
9 1201T GMC
Sierra 2500
HD 1384219
$
24,373.67 9/4/2012
10 13010T FORD F-550 1386566
$
180,905.38 11/6/2013
DocuSign Envelope ID: 730D8629-9F86-462B-AF29-21B9BAC3A87D C:\ProgramData\activePDF\Temp\DocConverter\API\Input\$0f01d35db4dd$7547BD57BC12451EAE31A 9594EF1714D.docx Page 24 of 36
11 13020T TOYOTA PRIUS 1397254
$
26,429.27 8/20/2013
12 13030T TOYOTA PRIUS 1397255
$
26,429.27 8/20/2013
13 14010T TOYOTA PRIUS 1433431
$
26,429.27 12/1/2013
14 1402T HONDA CIVIC 1403863
$
30,273.46 9/22/2014
15 1403T HONDA CIVIC 1403864
$
30,273.46 9/22/2014
16 1404T HONDA CIVIC 1403865
$
30,273.46 9/22/2014
17 16010T TOYOTA PRIUS 1476311
$
29,410.60 8/1/2016
18 16020T TOYOTA PRIUS 1476309
$
29,410.60 8/1/2016
19 16030T TOYOTA PRIUS 1476310
$
29,410.60 8/1/2016
DocuSign Envelope ID: 730D8629-9F86-462B-AF29-21B9BAC3A87D C:\ProgramData\activePDF\Temp\DocConverter\API\Input\$0f01d35db4dd$7547BD57BC12451EAE31A 9594EF1714D.docx Page 25 of 36
Appendix C: Rolling Stock
# Bus Series Bus # Make Year Model License Plate VIN #
1 2100s 2101 GILLIG 2021 G28D 1605796 15GGD281XM3194836 2 2100s 2102 GILLIG 2021 G28D 1621141 15GGD2811M3194837 3 2100s 2103 GILLIG 2021 G28D 1621140 15GGD2813M3194838 4 2100s 2104 GILLIG 2021 G28D 1621191 15GGD2815M3194839 5 2100s 2105 GILLIG 2021 G28D 1621176 15GGD2811M3194840 6 2100s 2106 GILLIG 2021 G28D 1621183 15GGD2813M3194841 7 2100s 2107 GILLIG 2021 G28D 1621171 15GGD2815M3194842 8 2100s 2108 GILLIG 2021 G28D 1621177 15GGD2817M3194843 9 2100s 2109 GILLIG 2021 G28D 1621178 15GGD2819M3194844 10 2100s 2110 GILLIG 2021 G28D 1621192 15GGD2810M3194845 11 2100s 2111 GILLIG 2021 G28D 1621181 15GGD2812M3194846 12 2100s 2112 GILLIG 2021 G28D 1621182 15GGD2814M3194847 13 2100s 2113 GILLIG 2021 G28D 1621179 15GGD2816M3194848 14 2100s 2114 GILLIG 2021 G28D 1621180 15GGD2818M3194849 15 2100s 2115 GILLIG 2021 G28D 1621193 15GGD2814M3194850 16 2100s 2116 GILLIG 2021 G28D 1621194 15GGD2816M3194851 17 2100s 2117 GILLIG 2021 G28D 1621298 15GGD2818M3194852 18 2100s 2118 GILLIG 2021 G28D 1621195 15GGD281XM3194853 19 1800E 1827 GILLIG 2019 G28D 1567354 15GGD2810K3192218 20 1800s 1801 GILLIG 2018 G31E102N2 1535136 15GGE3119J3093330 21 1800s 1802 GILLIG 2018 G31E102N2 1535137 15GGE3110J3093331 22 1800s 1803 GILLIG 2018 G31E102N2 1535138 15GGE3112J3093332 23 1800s 1804 GILLIG 2018 G31E102N2 1535139 15GGE3114J3093333 24 1800s 1805 GILLIG 2018 G31E102N2 1535140 15GGE3116J3093334 25 1800s 1806 GILLIG 2018 G31E102N2 1535141 15GGE3118J3093335 26 1800s 1807 GILLIG 2018 G31E102N2 1535142 15GGE311XJ3093336 27 1800s 1808 GILLIG 2018 G31D 1280251 15GGD3110J3191035 28 1800s 1809 GILLIG 2018 G31D 1280259 15GGD3112J3191036 29 1800s 1810 GILLIG 2018 G31D 1280256 15GGD3114J3191037 30 1800s 1811 GILLIG 2018 G31D 1280257 15GGD3116J3191038 31 1800s 1812 GILLIG 2018 G31D 1280252 15GGD3118J3191039 32 1800s 1813 GILLIG 2018 G31D 1280258 15GGD3114J3191040 33 1800s 1814 GILLIG 2018 G31D 1557202 15GGD3116J3191041 34 1800s 1815 GILLIG 2018 G31D 1557203 15GGD3118J3191042 35 1800s 1816 GILLIG 2018 G31D 1557204 15GGD311XJ3191043 36 1800s 1817 GILLIG 2018 G31D 1557205 15GGD3111J3191044 37 1800s 1818 GILLIG 2018 G31D 1557206 15GGD3113J3191045 38 1800s 1819 GILLIG 2018 G31D 1557207 15GGD3115J3191046 39 1800s 1820 GILLIG 2018 G31D 1557208 15GGD3117J3191047 DocuSign Envelope ID: 730D8629-9F86-462B-AF29-21B9BAC3A87D C:\ProgramData\activePDF\Temp\DocConverter\API\Input\$0f01d35db4dd$7547BD57BC12451EAE31A 9594EF1714D.docx Page 26 of 36
40 1800s 1821 GILLIG 2018 G31D 1557225 15GGD3119J3191048 41 1800s 1822 GILLIG 2018 G31D 1534722 15GGD3110J3191049 42 1800s 1823 GILLIG 2018 G31D 1534723 15GGD3117J3191050 43 1800s 1824 GILLIG 2018 G31D 1534724 15GGD3119J3191051 44 1800s 1825 GILLIG 2018 G31D 1534725 15GGD3110J3191052 45 1800s 1826 GILLIG 2018 G31D 1534726 15GGD3112J3191053 46 1700s 1707 GILLIG 2017 G31D102N4 1493882 15GGD3114H1188242 47 1700s 1708 GILLIG 2017 G31D102N4 1493883 15GGD3116H1188243 48 1700s 1709 GILLIG 2017 G31D102N4 1493884 15GGD3118H1188244 49 1700s 1710 GILLIG 2017 G31D102N4 1493885 15GGD311XH1188245 50 1700s 1711 GILLIG 2017 G31D102N4 1493886 15GGD3111H1188246 51 1700s 1712 GILLIG 2017 G31D102N4 1493922 15GGD3113H1188247 52 1700s 1713 GILLIG 2017 G31D102N4 1493923 15GGD3115H1188248 53 1700s 1714 GILLIG 2017 G31D102N4 1493924 15GGD3117H1188249 54 1700s 1715 GILLIG 2017 G31D102N4 1493925 15GGD3113H1188250 55 1700s 1716 GILLIG 2017 G31D102N4 1493935 15GGD3115H1188251 56 1700s 1717 GILLIG 2017 G31D102N4 1493926 15GGD3117H1188252 57 1700s 1718 GILLIG 2017 G31D102N4 1493927 15GGD3119H1188253 58 1700s 1719 GILLIG 2017 G31D102N4 1493928 15GGD3110H1188254 59 1700s 1720 GILLIG 2017 G31D102N4 1493929 15GGD3112H1188255 60 1700s 1721 GILLIG 2017 G31D102N4 1493948 15GGD3114H1188256 61 1700s 1722 GILLIG 2017 G31D102N4 1493957 15GGD3116H1188257 62 1700s 1723 GILLIG 2017 G31D102N4 1493947 15GGD3118H1188258 63 1700s 1724 GILLIG 2017 G31D102N4 1493958 15GGD311XH1188259 64 1700s 1725 GILLIG 2017 G31D102N4 1493949 15GGD3116H1188260 65 1700s 1701 GILLIG 2016 G27D102N4 1493833 15GGD2719G1188236 66 1700s 1702 GILLIG 2016 G27D102N4 1493832 15GGD2710G1188237 67 1700s 1703 GILLIG 2016 G27D102N4 1493831 15GGD2712G1188238 68 1700s 1704 GILLIG 2016 G27D102N4 1493830 15GGD2714G1188239 69 1700s 1705 GILLIG 2016 G27D102N4 1493829 15GGD2710G1188240 70 1700s 1706 GILLIG 2017 G27D102N4 1493887 15GGD2710H1188241 71 1600s 1600 GILLIG 2015 G27E102N2 1469487 15GGR2711F1093097 72 1600s 1601 GILLIG 2015 G27E102N2 1469488 15GGE2713F1093098 73 1600s 1602 GILLIG 2015 G27E102N2 1469489 15GGE2715F1093099 74 1600s 1603 GILLIG 2015 G27E102N2 1469490 15GGE2718F1093100 75 1500s 1500 GILLIG 2015 G27D102N4 1362172 15GGD2710F1185367 76 1500s 1501 GILLIG 2015 G27D102N4 1362174 15GGD2712F1185368 77 1500s 1502 GILLIG 2015 G27D102N4 1362175 15GGD2714F1185369 78 1500s 1503 GILLIG 2015 G27D102N4 1362176 15GGD2710F1185370 79 1500s 1504 GILLIG 2015 G27D102N4 1462440 15GGD2712F1185371 80 1500s 1505 GILLIG 2015 G27D102N4 1462441 15GGD2714F1185372 DocuSign Envelope ID: 730D8629-9F86-462B-AF29-21B9BAC3A87D C:\ProgramData\activePDF\Temp\DocConverter\API\Input\$0f01d35db4dd$7547BD57BC12451EAE31A 9594EF1714D.docx Page 27 of 36
81 1500s 1506 GILLIG 2015 G27D102N4 1462442 15GGD2716F1185373 82 1500s 1507 GILLIG 2015 G27D102N4 1362178 15GGD2718F1185374 83 1500s 1508 GILLIG 2015 G27D102N4 1362179 15GGD271XF1185375 84 1500s 1509 GILLIG 2015 G27D102N4 1362201 15GGD2711F1185376 85 1500s 1510 GILLIG 2015 G27D102N4 1462573 15GGD2713F1185377 86 1560s 1560 NEW
FLYER 2015 XN60 1462286 5FYC8YC14FC046883
87 1560s 1561 NEW
FLYER 2015 XN60 1362173 5FYC8YC16FC046884
88 1560s 1562 NEW
FLYER 2015 XN60 1362177 5FYC8YC18FC046885
89 1560s 1563 NEW
FLYER 2015 XN60 1462660 5FYC8YC1XFC046886
90 1560s 1564 NEW
FLYER 2015 XN60 1462443 5FYC8YC11FC046887
91 1560s 1565 NEW
FLYER 2015 XN60 1462571 5FYC8YC13FC046888
92 1560s 1566 NEW
FLYER 2015 XN60 1462572 5FYC8YC15FC046889
93 1300s 1300 GILLIG 2012 G27D102N4 1055074 15GGD2717C1182218 94 1300s 1301 GILLIG 2013 G27D102N4 1055078 15GGD2717D1182219 95 1300s 1302 GILLIG 2013 G27D102N4 1055075 15GGD2713D1182220 96 1300s 1303 GILLIG 2013 G27D102N4 1055079 15GGD2715D1182221 97 1300s 1304 GILLIG 2013 G27D102N4 1055077 15GGD2717D1182222 98 1300s 1305 GILLIG 2013 G27D102N4 1055080 15GGD2719D1182223 99 1300s 1306 GILLIG 2013 G27D102N4 1055076 15GGD2710D1182224 100 1300s 1307 GILLIG 2013 G27D102N4 1055081 15GGD2712D1182225 101 1300s 1308 GILLIG 2013 G27D102N4 1304324 15GGD2714D1182226 102 1300s 1309 GILLIG 2013 G27D102N4 1304325 15GGD2716D1182227 103 1300s 1310 GILLIG 2013 G27D102N4 1304326 15GGD2718D1182228 104 1300s 1311 GILLIG 2013 G27D102N4 1304327 15GGD271XD1182229 105 1300s 1312 GILLIG 2013 G27D102N4 1304328 15GGD2716D1182230 106 1300s 1313 GILLIG 2013 G27D102N4 1304329 15GGD2718D1182231 107 1300s 1314 GILLIG 2013 G27D102N4 1304330 15GGD271XD1182232 108 1300s 1315 GILLIG 2013 G27D102N4 1055084 15GGD2711D1182233 109 1300s 1316 GILLIG 2013 G27D102N4 1055083 15GGD2713D1182234 110 1300s 1317 GILLIG 2013 G27D102N4 1055082 15GGD2715D1182235 111 1300s 1318 GILLIG 2013 G27D102N4 1055085 15GGD2717D1182236 112 1300s 1319 GILLIG 2013 G27D102N4 1055086 15GGD2719D1182237 113 1300s 1320 GILLIG 2013 G27D102N4 1304334 15GGD2710D1182238 114 1300s 1321 GILLIG 2013 G27D102N4 1304337 15GGD2712D1182239 115 1300s 1322 GILLIG 2013 G27D102N4 1304339 15GGD2719D1182240 116 1300s 1323 GILLIG 2013 G27D102N4 1304340 15GGD2710D1182241 DocuSign Envelope ID: 730D8629-9F86-462B-AF29-21B9BAC3A87D C:\ProgramData\activePDF\Temp\DocConverter\API\Input\$0f01d35db4dd$7547BD57BC12451EAE31A 9594EF1714D.docx Page 28 of 36
117 1300s 1324 GILLIG 2013 G27D102N4 1304335 15GGD2712D1182242 118 1300s 1325 GILLIG 2013 G27D102N4 1304336 15GGD2714D1182243 119 1300s 1326 GILLIG 2013 G27D102N4 1304338 15GGD2716D1182244 120 1300s 1327 GILLIG 2013 G27D102N4 1304342 15GGD2718D1182245 121 1300s 1328 GILLIG 2013 G27D102N4 1304341 15GGD271XD1182246 122 1300s 1329 GILLIG 2013 G27D102N4 1055096 15GGD2711D1182247 123 1300s 1330 GILLIG 2013 G27D102N4 1055092 15GGD2713D1182248 124 1300s 1331 GILLIG 2013 G27D102N4 1055093 15GGD2715D1182249 125 1300s 1332 GILLIG 2013 G27D102N4 1055094 15GGD2711D1182250 126 1300s 1333 GILLIG 2013 G27D102N4 1055095 15GGD2713D1182251 127 1300s 1334 GILLIG 2013 G27D102N4 1304343 15GGD2715D1182252 128 1300s 1335 GILLIG 2013 G27D102N4 1304344 15GGD2717D1182253 129 1300s 1336 GILLIG 2013 G27D102N4 1304345 15GGD2719D1182254 130 1300s 1337 GILLIG 2013 G27D102N4 1304346 15GGD2710D1182255 131 1300s 1338 GILLIG 2013 G27D102N4 1304347 15GGD2712D1182256 132 1300s 1339 GILLIG 2013 G27D102N4 1055097 15GGD2714D1182257 133 1300s 1340 GILLIG 2013 G27D102N4 1055098 15GGD2716D1182258 134 1300s 1341 GILLIG 2013 G27D102N4 1055099 15GGD2718D1182259 135 1300s 1342 GILLIG 2013 G27D102N4 1362150 15GGD2714D1182260 136 1300s 1343 GILLIG 2013 G27D102N4 1362151 15GGD2716D1182261 137 1300s 1344 GILLIG 2013 G27D102N4 1362152 15GGD2718D1182262 138 1300s 1345 GILLIG 2014 G27D102N4 1362182 15GGD2718E1182263 139 1300s 1346 GILLIG 2014 G27D102N4 1362183 15GGD271XE1182264 140 1300s 1347 GILLIG 2014 G27D102N4 1362184 15GGD2711E1182265 141 1300s 1348 GILLIG 2014 G27D102N4 1362185 15GGD2713E1182266 142 1300s 1349 GILLIG 2014 G27D102N4 1362186 15GGD2715E1182267 143 1300s 1350 GILLIG 2014 G27D102N4 1362188 15GGD2717E1182268 144 1300s 1351 GILLIG 2014 G27D102N4 1362189 15GGD2719E1182269 145 1300s 1352 GILLIG 2014 G27D102N4 1362190 15GGD2715E1182270 146 1300s 1353 GILLIG 2014 G27D102N4 1362164 15GGD2717E1182271 147 1300s 1354 GILLIG 2014 G27D102N4 1362165 15GGD2719E1182272 148 1300s 1355 GILLIG 2014 G27D102N4 1362166 15GGD2710E1182273 149 1300s 1356 GILLIG 2014 G27D102N4 1362167 15GGD2712E1182274 150 1300s 1357 GILLIG 2014 G27D102N4 1362168 15GGD2714E1182275 151 5300s 5300 NABI 2010 60BRT-14.02 1055045 1N960214XAA140396 152 5300s 5301 NABI 2011 60BRT-14.02 1055047 1N9602141AA140397 153 5300s 5302 NABI 2011 60BRT-14.02 1055048 1N9602143AA140398 154 5300s 5303 NABI 2011 60BRT-14.02 1304274 1N9602145AA140399 155 5300s 5304 NABI 2011 60BRT-14.02 1055049 1N9602148AA140400 156 5300s 5305 NABI 2011 60BRT-14.02 1055050 1N960214XAA140401 157 5300s 5306 NABI 2011 60BRT-14.02 1055051 1N9602141AA140402 DocuSign Envelope ID: 730D8629-9F86-462B-AF29-21B9BAC3A87D C:\ProgramData\activePDF\Temp\DocConverter\API\Input\$0f01d35db4dd$7547BD57BC12451EAE31A 9594EF1714D.docx Page 29 of 36
158 5300s 5307 NABI 2011 60BRT-14.02 1304273 1N9602143AA140403 159 5300s 5308 NABI 2011 60BRT-14.02 1304275 1N9602145AA140404 160 5300s 5309 NABI 2011 60BRT-14.02 1055056 1N9602147AA140405 161 5300s 5310 NABI 2011 60BRT-14.02 1055057 1N9602149AA140406 162 5300s 5311 NABI 2011 60BRT-14.02 1055055 1N9602144BA140251 163 5300s 5312 NABI 2011 60BRT-14.02 1055054 1N9602146BA140252 164 5300s 5314 NABI 2011 60BRT-14.02 1304276 1N960214XBA140254 165 5300s 5315 NABI 2011 60BRT-14.02 13078218 1N9602141BA140255 166 5300s 5316 NABI 2011 60BRT-14.02 1304309 1N9602149BA140357 167 5300s 5317 NABI 2011 60BRT-14.02 1055067 1N9602140BA140358 168 5300s 5318 NABI 2011 60BRT-14.02 1055068 1N9602142BA140359 169 5300s 5319 NABI 2011 60BRT-14.02 1055070 1N9602149BA140360 170 5300s 5320 NABI 2011 60BRT-14.02 1055069 1N9602140BA140361 171 3800s 3868 NABI 2011 40LFW14.01 1055058 1N9405118BA140266 172 3800s 3869 NABI 2011 40LFW14.01 1304283 1N940511XBA140267 173 3800s 3870 NABI 2011 40LFW14.01 1055060 1N9405111BA140268 174 3800s 3871 NABI 2011 40LFW14.01 1055061 1N9405113BA140269 175 3800s 3872 NABI 2011 40LFW14.01 1055062 1N940511XBA140270 176 3800s 3873 NABI 2011 40LFW14.01 1055065 1N9405111BA140271 177 3800s 3874 NABI 2011 40LFW14.01 1055059 1N9405113BA140272 178 3800s 3875 NABI 2011 40LFW14.01 1055064 1N9405115BA140273 179 3800s 3876 NABI 2011 40LFW14.01 1055063 1N9405117BA140274 180 2900s 2900 EL
DORADO 2010 EZR II- BRT 32' 1303947 1N9MNAE49AC084050
181 2900s 2901 EL
DORADO 2010 EZR II- BRT 32' 1303948 1N9MNAE40AC084051
182 2900s 2902 EL
DORADO 2010 EZR II- BRT 32' 1304304 1N9MNAE42AC084052
183 2900s 2903 EL
DORADO 2010 EZR II- BRT 32' 1338033 1N9MNAE44AC084053
184 2900s 2904 EL
DORADO 2010 EZR II- BRT 32' 1378226 1N9MNAE46AC084054
185 2900s 2905 EL
DORADO 2011 EZR II- BRT32' 1376959 1N9MNALG3CC084061
186 2900s 2906 EL
DORADO 2011 EZR II- BRT 32' 1376958 1N9MNALG5CC084062
DocuSign Envelope ID: 730D8629-9F86-462B-AF29-21B9BAC3A87D C:\ProgramData\activePDF\Temp\DocConverter\API\Input\$0f01d35db4dd$7547BD57BC12451EAE31A 9594EF1714D.docx Page 30 of 36
187 2900s 2907 EL
DORADO 2011 EZR II- BRT 32' 1376957 1N9MNALG7CC084063
188 2900s 2908 EL
DORADO 2011 EZR II- BRT 32' 1376967 1N9MNALG9CC084064
189 2900s 2909 EL
DORADO 2011 EZR II- BRT 32' 1376962 1N9MNALG0CC084065
190 2900s 2910 EL
DORADO 2011 EZR II- BRT 32' 1376964 1N9MNALG2CC084066
191 2900s 2911 EL
DORADO 2011 EZR II- BRT 32' 1376963 1N9MNALG4CC084067
192 2900s 2912 EL
DORADO 2011 EZR II- BRT32' 1376965 1N9MNALG6CC084068
193 2900s 2913 EL
DORADO 2011 EZR II- BRT 32' 1376966 1N9MNALG8CC084069
194 2900s 2914 EL
DORADO 2011 EZR II- BRT 32' 1376968 1N9MNALG4CC084070
DocuSign Envelope ID: 730D8629-9F86-462B-AF29-21B9BAC3A87D Appendix D: Facilities
Facility and/or System Condition Code
BBB Site
SITE 4
Maintenance facility
STRUC 4
EXT 4.5
ROOF 4.5
HVAC 2.5
ELEC 3.5
PLUMB 4
CONV 3
INTF 4
Administration Facility
STRUC 4
EXT 3.5
ROOF 4
HVAC 2.5
ELEC 3
PLUMB 2.5
CONV 2.5
INTF 3.5
Fuel & Wash Facility
STRUC 4
EXT 4
ROOF 3.5
HVAC 3
ELEC 3.5
PLUMB 3.5
INTF 4
Exterior Fuel Island
STRUC 3.5
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Appendix E: FTA Useful Life Benchmarks (ULB)
DocuSign Envelope ID: 730D8629-9F86-462B-AF29-21B9BAC3A87D Appendix Y: FTA TAM Example
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Appendix Z: Technical Assistance
1. https://www.transit.dot.gov/TAM
2. TERM-Lite
3. TAM Guide
4. Asset Inventory Development and Integration Guide
5. Training and Webinar
6. Facility Condition & Rail Guideway Guidebook
DocuSign Envelope ID: 730D8629-9F86-462B-AF29-21B9BAC3A87D ATTACHMENT 5
Drug and Alcohol Policy/Procedures for
Employees in Safety-Sensitive Job Functions
Drug & Alcohol
Policy/Procedures
For Employees in Safety-Sensitive Job Functions
Adopted January 24, 2017
1st Revision: July 24, 2018
2nd Revision: August 1, 2023
In accordance with the U.S. Department of Transportation, Federal Transit Administration
(49 CFR Parts 40 and 655)
City of Santa Monica’s
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 2 I. Table of Contents
I. INTRODUCTION.................................................................................................................................4 A. Policy Statement...............................................................................................................................4 B. Purpose .............................................................................................................................................4 II. PROHIBITED SUBSTANCES.................................................................................................................5 III. PROHIBITED CONDUCT .....................................................................................................................5 IV. COVERED EMPLOYEES.......................................................................................................................6 V. TYPES OF TESTING AND REQUIREMENTS .........................................................................................7 A. Pre-Employment Testing...................................................................................................................7 B. Random Testing ................................................................................................................................8 C. Post-Accident Testing .......................................................................................................................9 D. Reasonable Suspicion Testing.........................................................................................................11 E. Return-to-Duty Testing ...................................................................................................................13 F. Follow-up Testing............................................................................................................................13 G. Annual/Periodic Physicals...............................................................................................................14 VI. TESTING PROCEDURES....................................................................................................................14 VII. REFUSALS TO TEST AND UNCOMPLETED TESTS .............................................................................17 VIII. CONSEQUENCES OF ENGAGING IN PROHIBITED BEHAVIOR ..........................................................18 A. Pre-Employment Test .....................................................................................................................18 B. Random, Reasonable Suspicion, Post-Accident, and Periodic Physical Tests.................................18 C. Alcohol Concentration Levels Between 0.02 and 0.39 percent......................................................18 IX. ADDITIONAL GROUNDS FOR DISCIPLINARY ACTION ......................................................................18 X. EVALUATION / REHABILITATION.....................................................................................................19 XI. RETURN-TO-WORK..........................................................................................................................21 XII. MEDICAL REVIEW OFFICER (MRO)..................................................................................................21 XIII. TESTING LABORATORY....................................................................................................................22 XIV. EMPLOYEE/SUPERVISOR TRAINING................................................................................................22 XV. RECORDKEEPING.............................................................................................................................23 XVI. CONTRACTORS HIRED BY THE CITY.................................................................................................24 XVII. CONFIDENTIALITY............................................................................................................................25 City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 3 XVIII. GLOSSARY OF ACRONYMS ..............................................................................................................26 XIX. TERMS AND DEFINITIONS ...............................................................................................................26 XX. EMPLOYEE INFORMATION ON THE EFFECTS OF ALCOHOL MISUSE/DRUG USE ............................28 XXI. ATTACHMENTS................................................................................................................................30 A. Fact Sheets: Alcohol, Amphetamines, Cocaine, Marijuana, Opioids and Phencyclidine (PCP) ......30 B. POST-ACCIDENT RECORD OF DECISION..........................................................................................39 C. Reasonable Suspicion Record of Decision ......................................................................................41 D. Notification of Required Testing Form............................................................................................42 E. Acknowledgement of Training and Receipt of Policy .....................................................................43 City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 4 City of Santa Monica’s Big Blue Bus
I. INTRODUCTION
The City of Santa Monica (“City”) has implemented the Drug and Alcohol Policy/Procedures for Employees in Safety-Sensitive Job Functions for covered Big Blue Bus employees to ensure compliance with federal regulations of the Department of Transportation (DOT). This policy supplements the City’s Drug-Free Workplace Program. If federal regulations conflict with the City policies, the federal regulations shall prevail. If federal regulations fail to provide language for a particular situation, the employee shall be subject to other applicable City policies. DOT allows the City’s policy to be stricter than their regulations as long as language specific to the City’s policy is identified. Therefore, where this policy goes beyond the requirements of DOT, the text is highlighted in bold print.
A. Policy Statement
The City is committed to maintaining a safe and productive work environment and providing safe, dependable and efficient transportation services to our customers. We recognize that our safety-sensitive employees' potential use of illegal drugs and misuse of alcohol poses a significant risk to public safety, as well as the employee’s health and well-being, and can cause loss of efficiency and productivity or a disruptive work environment. In view of this, the City, on behalf of the Big Blue Bus, has adopted this policy that is designed to:
1. Provide a drug and alcohol-free work environment;
2. Deter and detect employees’ use of illegal drugs and misuse of alcohol;
3. Prohibit the unlawful manufacture, distribution, dispensing, possession, or use of drugs; and
4. Encourage employees to seek professional assistance anytime personal problems, including drug or alcohol dependency, may adversely affect their ability to safely perform their assigned duties.
B. Purpose
The purpose of this policy is to ensure worker fitness for duty and to protect our employees, passengers, and the public from safety and health risks posed by the misuse of alcohol and drugs. This policy is intended to comply with all applicable State and Federal regulations governing workplace anti-drug use and alcohol misuse programs in the transportation industry.
The regulations include Department of Transportation (DOT) regulations, 49 CFR Parts 40 and 655. Part 655 requires that Transit Employees who maintain, operate, or control the movement of public transportation vehicles be tested for drugs and alcohol. Part 40 sets the standards for the collection and testing of urine and breath specimens. This policy incorporates the DOT requirements for DOT-covered safety-sensitive employees.
Participation in this program is a requirement of all safety-sensitive employees, and therefore, is a condition of employment. All covered employees are required to submit to drug and alcohol testing administered in accordance with Part 655.
Any questions in relation to this program should be directed to the DOT Program Manager at (310) 458-1975, or the Human Resources Department. Additional information regarding DOT City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 5 regulations can also be found at http://transitsafety.volpe.dot.gov/DrugAndAlcohol/Regulations/default.asp.
This policy applies to safety-sensitive employees only, as defined in this policy. It applies to offsite lunch periods or breaks when an employee is scheduled to return to work or is on-call.
Visitors, invitees, and vendors are prohibited from entering City premises or from conducting any work on behalf of the Big Blue Bus when illegal substances are present in their system, or when they are under the influence of alcohol.
II. PROHIBITED SUBSTANCES
A. Drugs: Covered employees are prohibited by the Department of Transportation (DOT) from using marijuana (including all hemp products), cocaine, opiates (including hydrocodone, oxycodone, hydromorphone, and oxymorphone), phencyclidine (PCP), and amphetamines at any time. For the purpose of this policy, the term “drugs” and “controlled substances” have the same meaning.
B. Alcohol: The consumption/use of beverages containing alcohol or substances including any medication, mouthwash, food, candy, or any other substances such that alcohol is present in the body while performing safety-sensitive functions is prohibited.
III. PROHIBITED CONDUCT
Any covered employee who engages in the following prohibited conduct will be immediately removed from performing safety-sensitive functions and may be subject to disciplinary action, up to and including termination.
(1) All covered employees are prohibited from using drugs at all times as required by Section 655.21.
(2) Each covered employee is prohibited from possessing or consuming alcohol while performing safety-sensitive job functions or consuming alcohol while on-call to perform safety-sensitive job functions. If a covered employee is on-call and has consumed alcohol while on-call, the employee must acknowledge the use of alcohol at the time that he/she is called to report for duty. And, if the covered employee claims ability to perform his or her safety-sensitive function, the covered employee must first take and pass an alcohol test before performing any safetysensitive function. (3) The Big Blue Bus shall not permit any covered employee to perform or continue to perform safety-sensitive functions if it has actual knowledge that the employee is using alcohol. (4) Each covered employee is prohibited from reporting to work and from performing, or continuing to perform a safety sensitive function while having an alcohol concentration of 0.04 or greater.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 6 (5) No covered employee shall consume alcohol or any drug within for eight hours following involvement in an accident or until he/she submits to the post-accident drug/alcohol test, whichever occurs first.
(6) No covered employee shall perform safety-sensitive job functions within four hours of consuming alcohol.
(7) Consistent with the Drug-Free Workplace Act of 1988, all covered employees are prohibited from engaging in unlawful manufacturing, distributing, dispensing, possessing, or using prohibited substances in the workplace, including City premises and vehicles. In addition, covered employees are required to notify the City of any criminal drug conviction for a violation occurring in the workplace within five days after conviction.
The appropriate use of certain legally prescribed drugs and non-prescription medication may not be prohibited. It is the employee’s responsibility to inform his/her physician of the employee’s job duties and determine from the physician, or other health care professional, whether the prescribed drug or non-prescription medication may impair the safe and effective performance of job functions, or mental or motor function. The employee shall immediately advise his/her supervisor when the physician, or other health care professional, has indicated that the employee’s safe and effective performance of job functions, or mental or motor function, may be impaired while taking the medication.
A prescription is considered valid only if it is legally obtained; in writing; and indicates the employee’s name, date, the name of the substance, quantity or amount to be taken, and the period of authorization. Medication or any controlled substances or drugs obtained illegally outside the United States are not considered valid medical prescriptions under this policy. It is a violation of this policy to use any drug in a manner that is inconsistent with the prescription.
If an employee’s drug screen comes back positive due to a prescription drug, it shall be the employee’s responsibility to provide the Medical Review Officer with proof of a valid prescription.
IV. COVERED EMPLOYEES
This policy applies to (1) every employee whose position is covered by the DOT regulations; requires the possession of a commercial driver’s license (CDL); and involves performing a “safety-sensitive function” as defined herein; and (2) any person applying for such positions.
Under the Federal Transit Administration (FTA), you are performing a safety-sensitive function if you perform any of the following:
• Operation of a revenue service vehicle, in or out of revenue service. • Operation of a non-revenue vehicle requiring a CDL.
• Controlling movement or dispatch of a revenue service vehicle. • Security personnel who carry firearms.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 7 • Maintenance (including repairs, overhaul and rebuilding) of a revenue service vehicle or equipment used on revenue service.
Supervisors are considered safety-sensitive only if they perform, or may be called upon to perform any of the above safety-sensitive functions.
The City has analyzed actual job duties performed, or may be called upon to be performed, by Big Blue Bus employees and has determined that the following job classifications are considered safetysensitive for the purposes of this policy. • Motor Coach Operator
• Motor Coach Operator Trainee
• Motor Coach Operator Supervisor
• Transit Operations Dispatcher
• Transit Mechanic I
• Transit Mechanic II
• Transit Mechanic Supervisor
• Transit Maintenance Training Coordinator
• Transit Maintenance Worker
• Senior Transit Maintenance Worker
• Motor Coach Cleaner
• Transit Safety and Security Coordinator
• Transit Training Coordinator
• Lead Transit Training Coordinator
• Any laborer holding a commercial driver’s license (CDL) Covered employee means a person, including an applicant or transferee, who performs or will perform a safety-sensitive function. This includes any time-period in which a covered employee is “on call” or on a “split shift.” When designated safety-sensitive employees are contacted by their supervisor or manager to perform “call-out” emergency duty, they shall not be coerced or otherwise ordered to report for such duty when they inform their supervisor/manager of consumption of alcohol in violation of this policy.
Contracted employees, or any other person that stands in the shoes of a Transit employee and performs or will perform a safety-sensitive function, are also considered covered employees.
V. TYPES OF TESTING AND REQUIREMENTS
Covered employees and applicants are subject to following types of tests:
A. Pre-Employment Testing
a) Applicants: A pre-employment drug and alcohol test will be conducted after making a contingent offer of employment or transfer, subject to the applicant passing the pre- City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 8 employment drug and alcohol test. Said individual will not perform covered safety-sensitive functions until he/she passes the pre-employment drug test and the BAC test indicates an alcohol concentration of less than 0.02.
b) Current Employees: A pre-employment drug and alcohol test will be conducted when a current employee transfers from a position not covered by this policy into a safety-sensitive position covered in this policy. The employee will not perform covered safety-sensitive functions until he/she passes the pre-employment drug test and the BAC test indicates an alcohol concentration of less than 0.02.
All safety-sensitive employees who have not performed a safety-sensitive function for 90 or more consecutive calendar days, regardless of the reason, and have been out of the random testing pool during that time period, are subject to and must successfully pass a preemployment drug and alcohol test before performing any safety-sensitive function.
If a pre-employment test is canceled, the applicant will be required to submit to and pass another pre-employment test with verified negative results before performing a safety-sensitive function.
In accordance with the revised 49 CFR Part 40, the City must, after written consent, check on the drug and alcohol testing record of an individual seeking to begin performing safety-sensitive duties for the first time (i.e., a new hire, an employee transferring into a safety-sensitive position). If the individual refuses to provide written consent, the City must not permit the individual to perform safety-sensitive functions. In addition, if the individual has had a positive pre-employment drug or alcohol test, or has refused such a test, he or she will not be hired until and unless the individual has provided documentation of successful completion of the return-toduty process, which includes SAP referral, evaluation and treatment plan.
All pre-employment alcohol tests must be conducted using the alcohol testing procedures set forth in 49 CFR Par 40.
B. Random Testing
a) All covered employees are subject to unannounced testing based on random selection. A covered employee may be randomly tested for prohibited drug use anytime while on duty.
An employee shall only be tested for alcohol while the employee is performing, just before the employee is to perform, or just after the employee has performed safety-sensitive functions.
b) The annual FTA minimum testing requirement is to perform drug tests on 25% and alcohol tests on 10% of the average number of safety-sensitive employees. The minimum testing requirement percentages may change pursuant to applicable DOT regulations. c) All persons will be subject to be randomly picked for drug testing at each unannounced random testing date. A person may be randomly picked more than once or not picked at all during the annual period. Employees remain in the random selection pool at all times, regardless of whether or not they have been previously selected for testing.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 9 d) The random selection procedure will be a computer-based number generator. Every covered employee will have an equal probability of being selected each time the random selection procedure is performed.
e) Random testing will be done on a weekly basis. Testing will be conducted on different days of the week and throughout all hours of the work day during the annual cycle to prevent employees from matching their drug use patterns to the schedule for collection. Selected employees will not be notified until immediately prior to the time that they are required to proceed to the collection site.
f) If an employee is temporarily unavailable, or it is their day off, the name will be held until their next shift within the same testing period. No employee shall be excused because of operational difficulties.
g) Random notifications should be conducted as discreetly as possible in order to ensure the confidentially and integrity of the process.
h) The testing dates and times are unannounced and employees are required to immediately proceed to the designated collection site following notification. A supervisor or other appropriate personnel will transport and accompany the employee to the collection site.
C. Post-Accident Testing
Covered employees shall be tested for alcohol and drugs following an accident pursuant to the following guidelines. The decision to test a covered employee shall be based on the City’s determination.
a) Qualifying Accidents for Post-Accident Testing for Public Transportation Vehicle (1) Whenever there is a loss of human life, drug and alcohol testing is mandatory for any surviving covered employee operating the public transportation vehicle at the time of the accident, without any consideration of the employee’s performance as a contributing factor. Each covered employee whose performance could have contributed to the accident as determined by the City using the best information available at the time of the decision, shall also be tested for alcohol and drugs. (2)
Whenever there is a non-fatal accident (i.e., not involving the loss of human life) in which a public transportation vehicle is involved, each covered employee operating the vehicle shall be tested for drugs and alcohol unless the employee’s performance can be completely discounted as a contributing factor. In addition, any other covered employee whose performance could have contributed to the accident as determined by the City using the best information available at the time of the decision, shall be tested for drugs and alcohol.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 10 b) Timeframe for Testing Employees Following Accident (1) Because certain drugs or drug metabolites do not remain in the body for extended periods of time, testing should be conducted as soon as possible after the accident or occurrence. The employee will be tested for drugs as soon as possible, but no later than 32 hours after the accident. Alcohol tests should be conducted within two hours and must be performed within eight hours. Any employee involved in an accident must refrain from using alcohol for eight hours or until he/she undergoes a post-accident alcohol test.
(2) As soon as practicable following an accident, the City shall test each surviving covered employee for alcohol if that employee’s performance of a covered function either contributed to the accident or cannot be completely discounted as a contributing factor to the accident. If an alcohol test is required, but is not administered within two hours following the accident, the Supervisor shall prepare and maintain on file a record stating the reasons the test was not promptly administered. If a required test is not administered within eight hours following the accident, the Supervisor shall cease attempts to administer an alcohol test and shall state in the record the reasons for not administering the test. These records shall be made available to FTA upon request. (3) The decision not to administer a test shall be based on the Supervisor’s determination, using the best available information at the time of the determination that the covered employee’s performance can be completely discounted as a contributing factor to the accident. The Supervisor’s justification for his/her decision must be maintained in the file.
(4) A covered employee who is subject to post-accident testing who fails to remain readily available for such testing, including notifying the on-scene supervisor of his/her location if he/she leaves the scene of the accident prior to submission to such test, may be deemed by the City to have refused to submit to testing. Nothing in this section shall be construed to require the delay of necessary medical attention for an injured employee accident for the period necessary to obtain assistance in responding to the accident or to obtain necessary emergency medical care.
(5) All reasonable steps will be taken to obtain a urine sample for the drug testing from an employee after an accident. In case of a conscious but hospitalized employee, the hospital or medical facility will be requested to obtain a sample and if necessary, reference will be made to the DOT drug testing requirements.
If an employee who is subject to post-accident testing is conscious, able to urinate normally (in the opinion of a medical professional) and refuses to be tested, that is a test refusal. c) Process for Obtaining Specimen Collection/Documentation Following Accident (1) Supervisor shall discreetly inform the employee that the employee is required to be tested for drugs and alcohol.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 11 (2) The employee will not be allowed to proceed alone to or from the collection site. A Supervisor or other appropriate personnel shall accompany him/her to and from the collection site.
(3) FTA regulations stipulate that the results of breath or blood test for the use of alcohol or a urine test for the use of drugs, conducted by Federal, State or local officials having independent authority for the test, shall be considered to meet the requirements of 49 CFR Part 655, provided such tests conform to applicable Federal, State, or local requirements, and that the results of the tests are obtained by the employer. In the event that the City is unable to conduct a FTA post-accident alcohol and/or drug test due to circumstances beyond its control (i.e. employee is unconscious, incarcerated, etc.), results from local or state law enforcement officers may be used in lieu of FTA tests if provided results are consistent with state and local law.
D. Reasonable Suspicion Testing
a) When there is reasonable suspicion to believe that a covered employee has used a prohibited drug and/or engaged in alcohol misuse, the employee will be required to take a reasonable suspicion test for drugs and/or alcohol. The determination that reasonable suspicion exists shall be based on specific, contemporaneous, articulable observations concerning the appearance, behavior, speech, or body odors of the covered employee. A supervisor(s), or other company official(s) who is trained in detecting the signs and symptoms of drug use and alcohol misuse must make the required observations. (Section 655.43)
b) The required observations for alcohol and/or drug testing shall be made by a Supervisor/Manager or City official who is trained in detecting the signs and symptoms of drug use or alcohol misuse. The Supervisor/Manager will complete the Reasonable Suspicion Record of Decision Form (Attachment C) and document the circumstances and observations that support the determination to conduct a reasonable suspicion test. A reasonable suspicion test for alcohol is authorized only just before, during, or just after the employee’s performance of safety-sensitive duties.
c) If an alcohol test is required, but is not administered within two hours following the observations triggering the request for the test, the Supervisor/Manager shall prepare and maintain on file a written record stating the reasons the test was not promptly administered. If a required test is not administered within eight hours following the request, the Supervisor/Manager shall cease attempts to administer an alcohol test and shall state in the record the reasons for not administering the test. These records shall be completed by the employee’s supervisor and forwarded to the DOT Program Manager for inclusion in the drug and alcohol files. These records shall also be made available to FTA upon request.
d) If a drug test is required, but not administered within 32 hours following the observations triggering the request for the test, the Supervisor/Manager shall cease attempts to administer a drug test and shall state in the record the reasons for not administering the City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 12 test. These records shall be completed by the employee’s supervisor and forwarded to the DOT Program Manager for inclusion in the drug and alcohol files. These records shall also be made available to FTA upon request.
e) Process for Obtaining Specimen Collection/Documentation 1) The Supervisor/Manager shall discreetly inform the covered employee that there is reasonable suspicion to believe that the employee is using or under the influence of a drug or alcohol while on duty. The Supervisor/Manager will also inform the employee that the employee will be accompanied by the Supervisor/Manager or other appropriate personnel to the specimen collection site to provide a urine/breath specimen, and that the consequence of refusal to submit to testing is equivalent to having a positive test result.
2) A Supervisor/Manager or other appropriate personnel shall accompany the employee to and from the collection site. The employee may have a representative accompany him/her to the collection site if he/she desires. However, there will be no unreasonable delay in proceeding to the collection site (i.e., waiting for employee representative to arrive before proceeding to collection site), and conducting the drug and/or alcohol analysis.
3) After returning from the collection site, the employee shall not be allowed to perform covered functions pending the results of the drug and/or alcohol test. The employee shall not be allowed to operate any public transportation vehicle, City vehicle or equipment due to the reasonable suspicion that the employee may be using or under the influence of drugs or alcohol while on duty.
f) No employee shall report for duty or remain on duty while the employee is under the influence of or impaired by alcohol or drugs. Nor shall the City permit the employee to perform or continue to perform safety-sensitive functions until: 1) negative drug test results are reported; and/or 2) an alcohol test is administered and the driver’s breath alcohol concentration measures less than 0.02; or 3) eight hours have elapsed following the determination that there was a reasonable suspicion to believe that the employee had violated the alcohol prohibitions under this policy.
g) Under City policy, evidence of alcohol or illegal drug use, sale or delivery shall be considered a basis for reasonable suspicion testing, as well as behaviors which may result in flagrant violations of established safety, security, or other operating procedures, altercations with others, or erratic or violent behavior. If an employee refuses to submit to a drug/alcohol test, such refusal to submit to testing is equivalent to having a positive test result, and the employee may be subject to disciplinary action, up to and including termination of employment with the City. Supervisors and Managers are required by City policy to notify the appropriate law enforcement agency when they have reason to believe that an employee may have illegal drugs in his or her possession or control.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 13 E. Return-to-Duty Testing
The consequences for a covered employee who has a verified positive drug or a confirmed alcohol test result with an alcohol concentration of 0.04 or greater, or who refused to submit to a test under the part, including the mandatory requirements that the covered employee be removed immediately from his or her safety sensitive function and be evaluated by a substance abuse professional, as required by 49 CFR Part 40.
Where a covered employee refuses to submit to a test, has a verified positive drug test result, and/or has a confirmed alcohol test result of 0.04 or greater, the employer, before returning the employee to duty to perform a safety-sensitive function, shall follow the procedures outlined in 49 CFT Part 40.
Before a covered employee may return to work and begin performing safety-sensitive functions after engaging in prohibited conduct under this policy, the employee must:
(1) Have been referred to a Substance Abuse Professional (SAP) for treatment and subsequently recommended by the SAP for return to duty; and (2) Undergo a return-to-duty drug test that results in a verified negative test result; and/or (3) Undergo a return-to-duty alcohol test with a result indicating an alcohol concentration of less than 0.02.
(4) Return-to-duty tests must be collected under direct observation of the employee if the drug test is a return-to-duty or a follow-up test.
F. Follow-up Testing
a) The City shall conduct follow-up testing of each employee who returns to duty, as specified in 49 CFR Part 40, subpart O.
b) Follow-up tests must be collected under direct observation of the employee if the drug test is a return-to-duty or a follow-up test.
c) An employee who is referred to a substance abuse professional (SAP) pursuant to this policy shall be subject to unannounced follow-up alcohol and/or drug testing as directed by the SAP.
d) A minimum of six unannounced, follow-up tests must be administered within the first 12 months after the employee has returned to duty. The SAP can direct additional testing during this period or for an additional period up to a maximum of 60 months from the date that the employee returned to duty. The SAP may modify the requirement for the follow-up testing in excess of the minimum at any time, if the SAP determines that the testing is no longer necessary.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 14 e) Follow-up testing for prohibited drug use may be conducted anytime the covered employee is on duty. An employee shall only be tested for alcohol while the employee is performing, just before the employee is to perform, or just after the employee has performed safetysensitive functions. f) An employee who is undergoing follow-up testing shall remain in the random pool and be randomly rested if his/her number is selected.
G. Annual/Periodic Physicals
It is City policy to conduct a drug and alcohol test as part of the periodic physical exam undergone by each safety-sensitive employee, and the following conditions apply:
a) Depending upon the employee’s prior drug and alcohol testing record, a positive drug or alcohol test may result in disciplinary action, up to and including termination. b) An employee who tests positive for one or more of the drugs listed in Section VI (Testing Procedures) shall be given the opportunity to discuss the test result with the Medical Review Officer.
c) If the drug and/or alcohol test result is deemed positive, the employee will be referred to the City’s Employee Assistance Program (EAP) for evaluation by a counselor. The City will provide further EAP services only if the employee is not subject to termination.
VI. TESTING PROCEDURES
Analytical urine drug testing and breath testing for alcohol may be conducted pursuant to this policy or as required by law. Drug tests can be performed any time an employee is on duty. An alcohol test can be performed when the employee is actually performing a safety-sensitive duty, just before, or just after the performance of a safety-sensitive duty.
Testing shall be conducted in a manner to ensure a high degree of accuracy and reliability and using techniques, equipment, and laboratory facilities that have been approved by the U.S. Department of Health and Human Services (DHHS). All DOT-required testing will be conducted in accordance with the procedures set forth in 49 CFR Part 40. The procedures will be performed in a private, confidential manner and every effort will be made to protect the employee, the integrity of the testing procedure, and the validity of the test result.
Upon notification that a drug test is required, an employee will report immediately after notification to the drug collection site and provide a specimen of his/her urine.
Drug Tests: The drugs that will be tested for include marijuana, cocaine, opiates, amphetamines including ecstasy (MDMA), and phencyclidine (PCP). Urine specimens will be collected using the split specimen collection method described in 49 CFR Part 40. Each specimen will be accompanied by a DOT Custody and Control Form and identified using a unique identification number that City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 15 attributes the specimen to the correct individual. Any non-Federal testing under City authority will be on non-Federal forms. An initial drug screen will be conducted on the primary specimen. For those specimens that are not negative, a confirmatory Gas Chromatography/Mass Spectrometry (GC/MS) or Liquid Chromatography/Mass Spectrometry (LC/MS) test will be performed. The test will be considered positive if the amounts present are above the minimum thresholds established in 49 CFR Part 40. The current cut-off limits expressed in nanograms per milliliter (ng/ml) are as follows:
Drug or Metabolite Initial Test
Level
Confirmation Test Level
Marijuana Metabolites
a. THC 50 ng/ml 15 ng/ml
Cocaine Metabolites
(Benzoylecgonine) 150 ng/ml 100 ng/ml
Phencyclidine (PCP) 25 ng/ml 25 ng/ml
Amphetamines
a. Amphetamine
b. Methamphetamine
c. MDMA (Ecstasy)
d. MDA (Ecstasy)
e. MDEA (Ecstasy)
500 ng/ml
500 ng/ml
500 ng/ml
500 ng/ml
500 ng/ml
250 ng/ml
250 ng/ml (specimen must also contain
amphetamine at a concentration ≥ 100
ng/ml)
250 ng/ml
250 ng/ml
250 ng/ml
Opiate Metabolites
a. Codeine
b. Morphine
c. 6 acetylmorphine
d. Hydrocodone
e. Oxycodone
f. Hydromorphone
g. Oxymorphone
2000 ng/ml
2000 ng/ml
10 ng/ml
300 ng/ml
100 ng/ml
100 ng/ml
100 ng/ml
2000 ng/ml
2000 ng/ml
10 ng/ml
100 ng/ml
100 ng/ml
100 ng/ml
100 ng/ml
The test results from the laboratory will be reported to a Medical Review Officer (MRO). The MRO will review the test results to determine whether there is a legitimate medical explanation for a confirmed positive, adulterated, substituted or invalid test result. The MRO will contact the employee, notify the employee of the non-negative laboratory result, and provide the employee with an opportunity to explain the confirmed test result. If there is contact with the employee and the employee provides medical information to explain the test result, the MRO will subsequently review the employee’s relevant medical history/medical records to determine whether there is a legitimate medical explanation for the confirmed laboratory result. If no legitimate medical explanation is found, the test will be verified positive, adulterated, substituted or invalid, and reported to the Program Manager. If a legitimate explanation is found, the MRO will report the test result as negative.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 16 The split specimen will be stored at the initial laboratory until the analysis for the same period that the primary specimen is retained and under the same storage conditions.
If the split test confirms the initial test results, the City may seek reimbursement for the cost of the test from the employee.
In instances where the employee produces a dilute specimen, he or she must undergo a second test.
Should this second test result in a negative dilute result, the test will be considered a negative and no additional testing will be required unless directed to do so by the MRO.
Alcohol Tests: Tests for breath alcohol concentration will be conducted utilizing a National Highway Traffic Safety Administration (NHTSA)-approved testing device operated by a trained technician. If the initial test indicates an alcohol concentration of 0.02 or greater, a second test will be performed to confirm the results of the initial test. The confirmatory test will be performed using a NHTSA-approved evidential breath testing device (EBT) operated by a trained Breath Alcohol Technician (BAT). The EBT will identify each test by a unique sequential identification number. This number, time, and unit identifier will be provided on each EBT printout. The EBT printout along with an approved alcohol testing form will be used to document the test, the subsequent results, and to attribute the test to the correct employee. The test will be performed in a private, confidential manner as required by 49 CFR Part 40, as amended. The procedure will be followed as prescribed to protect the employee and to maintain the integrity of the alcohol testing procedures and validity of the test result.
Under the FTA rule, an employee who has confirmed breath alcohol concentration of 0.02 or greater but less than 0.04 will be removed from his/her position for eight hours, or until a retest result in a concentration measure of less than 0.02. Employees with a BAC of 0.04 or greater will be removed from a covered function and referred to the SAP for evaluation.
Observed collections are required in the following circumstances:
• All return-to-duty tests;
• All follow-up tests;
• Anytime the employee is directed to provide another specimen because the temperature on the original specimen was out of the accepted temperature range of 90°F - 100°F; • Anytime the employee is directed to provide another specimen because the original specimen appeared to have been tampered with;
• Anytime a collector observes employee conduct that clearly indicates an attempt to tamper with a specimen;
• Anytime the employee is directed to provide another specimen because the laboratory reported to the MRO that the original specimen was invalid and the MRO determined that there was not an adequate medical explanation for the result (example: super dilute); • Anytime the employee is directed to provide another specimen because the MRO determined that the original specimen was positive, adulterated, or substituted, but had to be cancelled because the test of the split specimen could not be performed.
The observer shall be the same gender as the employee. The collector need not be the same gender as the employee. The observer is responsible for ensuring that the specimen goes from the employee’s body into the collection container.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 17 VII. REFUSALS TO TEST AND UNCOMPLETED TESTS
Compliance with this policy and specifically the drug/alcohol testing procedures is a condition of employment. Refusal to take a required drug/alcohol test or failure of a drug/alcohol test shall result in removal from performing covered functions. Behavior that constitutes a refusal to test is treated equivalent to a positive test.
A. You have refused to take a test if you:
• Fail to appear for any test (except a pre-employment test) at the collection site within a reasonable time;
• Fail to provide a breath or urine sample without a valid medical reason (confirmed by a physician);
• Fail to provide sufficient volume without a valid medical explanation; • Leave the scene of an accident without just cause prior to submitting to a test; • Fail to permit the observation or monitoring of specimen collection when it is required; • Fail to take a second test when required;
• Fail to undergo a medical examination when required by the MRO or Designated Employer Representative (DER);
• Fail to cooperate with any part of the testing process; • Fail to sign the alcohol test form, “Notification of Required Testing”; • Fail to remain at the test site until the testing process is completed and a specimen is provided;
• Provide an adulterated/substituted sample;
• Fail to follow the observer’s instructions during an observed collection including 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; • Possess or wear a prosthetic or other device that could be used to interfere with the collection process;
• Admit to the collector or MRO that you adulterated or substituted the specimen.
B. Shy Bladder
If an employee is unable to provide at least 45 milliliters of urine collection site personnel shall urge the individual to drink not more than 40 ounces of fluid and, distributed reasonably within a three-hour time period, or until the individual has provided sufficient urine specimen, whichever comes first. If the employee is still not able to give an adequate sample within three hours of the initial attempt, the City, after consultation with the MRO, shall refer the individual for a medical evaluation within five business days to determine if the individual’s inability to provide a sample is due to a genuine medical condition or constitutes a refusal to test. An employee’s refusal to be examined by a physician shall be regarded as a refusal to a test.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 18 VIII. CONSEQUENCES OF ENGAGING IN PROHIBITED BEHAVIOR A. Pre-Employment Test
1) Applicants: An applicant who refuses or fails a pre-employment drug or alcohol test will not be hired for any covered position. The applicant will be referred to the City’s EAP for SAP consultation (at the individual’s expense).
2) Current Employees: An employee who refuses or fails a pre-employment drug or alcohol test will not be eligible for assignment to a covered position.
B. Random, Reasonable Suspicion, Post-Accident, and Periodic Physical Tests An employee who refuses or fails the drug/alcohol test will be immediately removed from his/her safety-sensitive position, and referred to the City’s EAP for evaluation by a SAP or substance abuse counselor, as appropriate. The employee will be removed from his/her safety-sensitive position until the City receives written documentation from the SAP or substance abuse counselor that the employee has successfully completed a referral, evaluation and treatment plan meeting DOT requirements and passed a return-to-work drug/alcohol test.
In addition, the employee may be subject to disciplinary action, up to and including termination.
C. Alcohol Concentration Levels Between 0.02 and 0.39 percent An employee whose alcohol test indicates an alcohol concentration level between 0.02 and
0.039 will be removed from his/her job duties for at least eight hours for FTA-covered employees, and at least 24 hours for FMSCA-covered employees. The employee may be subject to progressive discipline for occurrences between 0.02 and 0.039. The supervisor/manager shall arrange to have an employee transported home safely if that employee tests positive for alcohol at 0.02 percent or greater.
IX. ADDITIONAL GROUNDS FOR DISCIPLINARY ACTION
Employees may be subject to disciplinary action, up to and including termination, for violating this policy and/or the following prohibited conduct:
A. Drinking alcohol while on duty or in uniform
Employees are prohibited from drinking alcohol at any time while in uniform, on duty or in City vehicles.
B. Sale, purchase, transfer or possession with intent to Deliver City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 19 Employees are prohibited from engaging in the sale or attempted sale, purchase, transfer or possession with intent to deliver illegal drugs and unauthorized substances while on City premises, in City vehicles, or on City business. In addition, law enforcement authorities will be notified.
C. Simple possession or use
Employees are prohibited from possessing or using illegal drugs or unauthorized substances while in uniform, on duty, on City premises, or in City vehicles. In addition, law enforcement will be notified.
D. Providing false information or attempting to contaminate or alter a urine specimen Such conduct is considered a test refusal and the equivalent of a positive test.
E. Refusal or failure to comply with treatment recommendations X. EVALUATION / REHABILITATION
The Substance Abuse Professional (SAP) must meet the DOT qualification requirements, including having one of the following credentials: licensed physician (medical doctor or doctor of osteopathy); licensed or certified psychologist; licensed or certified social worker; licensed or certified employee assistance professional; state-licensed or certified marriage and family therapist; or a drug and alcohol counselor certified by the National Association of Alcoholism and Drug Abuse Counselors Certification Commission, the International Certification Reciprocity Consortium/Alcohol and other Drug Abuse, or by the National Board for Certified Counselors, Inc., and Affiliates/Master Addictions Counselor.
The SAP will perform responsibilities and retain confidential records as required by 49 CFR Part 40.
An employee who fails a drug and/or alcohol test, or refuses to be tested will be referred to a Substance Abuse Professional who shall determine what assistance the employee needs in resolving problems associated with alcohol misuse or drug use. Applicants not hired or employees who have been terminated as a result of a violation of this policy shall also be referred to the SAP. Each employee identified as needing assistance in resolving problems associated with alcohol misuse or drug use shall be evaluated by a Substance Abuse Professional to determine that the employee has properly followed any rehabilitation program and shall be subject to unannounced follow-up alcohol and drug tests. Return to work following an SAP referral will require a follow-up test as scheduled by the SAP for a time period not to exceed 60 months.
The City offers services through its comprehensive Employee Assistance Program (EAP). Refer to Human Resources or Safety & Training for information on the current EAP provider. The employee may arrange for assistance either directly with the EAP provider, through the department staff, or through the bargaining unit representative. The City provides the EAP at very City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 20 little, if any, cost to employees. Former employees (not currently employed) are not eligible for City financial support of their EAP treatment program.
Employees needing help in dealing with drug or alcohol problems are encouraged to use the City’s EAP or health insurance plans, as appropriate. Conscientious and voluntary efforts made by the employee, and not required under this policy, to seek such help will not be noted in his or her personnel file. Being directed to attend a program, as required by this policy, is not considered a conscientious or voluntary effort on the part of the employee.
Employees may enter the EAP in one of the following ways:
1) Voluntary participation;
2) Referral by his/her bargaining unit; or
3) Mandated by the City for violation of this policy, unless that violation leads to termination of employment with the City.
Any employee who believes that he or she has a drug or alcohol abuse problem may voluntarily request assistance from the City by contacting his or her Supervisor, Manager or the Human Resources Department. The following conditions and procedures apply to an employee’s requests:
• The Supervisor, Manager or the Human Resources Department, when informed by the employee of a substance abuse problem, will refer the employee to a substance abuse counselor through the EAP.
• The City may allow the employee to take a leave of absence and to charge accrued vacation leave, or if vacation is unavailable, other leave credits (e.g. sick leave) while the employee participates in rehabilitation or treatment program. If no leave credits are available to the employee, he or she may, if necessary, be placed on a leave of absence without pay for the period of the rehabilitation or treatment.
• In order to return to active service, the employee must agree to undertake and to successfully complete a course of treatment as deemed appropriate by the substance abuse counselor. • After successful completion of the rehabilitation or treatment program, the employee will return to active service. Return to service also may occur earlier when the City is satisfied that the employee continues successful participation in a recommended program. Such return is contingent on the City receiving satisfactory documentation of compliance from a treating agency and from the substance abuse counselor; and the completion of a return-to-work medical examination, including federally-required drug and alcohol tests. • Unannounced non-DOT follow-up drug and alcohol testing may be required 60 months after completion of the rehabilitation or treatment program. The frequency and duration will be based on the recommendation of the substance abuse counselor. Any follow-up positive test or test refusal may result in disciplinary action, up to and including termination.
If the employee is being referred to the EAP by his or her employee bargaining unit, the employee must notify his or her Supervisor or Manager. The same conditions and procedures outlined above will also apply to referrals made by the employee’s bargaining unit.
If the employee’s participation in the EAP is mandated as a result of a DOT violation, the Human Resource Department will work with the employee to contact the EAP and schedule the City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 21 employee’s initial EAP session. This initial session will involve an assessment by the SAP of the substance abuse problem, with a determination being made as to the recommended course of rehabilitation, treatment or education. The same procedures and conditions outlined above for a voluntary referral will apply. In addition, the Human Resources Department will receive progress reports from the substance abuse counselor regarding the employee’s progress in his or her rehabilitation or treatment program.
XI. RETURN-TO-WORK
A. After Mandatory Referral
An employee wishing to return to work after a mandatory referral to a Substance Abuse Professional (SAP) must agree to the terms of a Return-to-Work Agreement which shall be established by the City. That Agreement may include, but is not limited to, the following:
1) A release to work statement from an approved treatment specialist and the SAP. 2) A plan, designed by the SAP, setting out after-care and follow-up treatment procedures through the SAP and the EAP.
3) A review and release for work from the City’s Medical Review Officer (MRO). 4) A negative return-to-work test for drugs and/or alcohol. 5) Consent to submit to continued follow-up periodic drug and/or alcohol testing as established by the SAP.
6) A statement of expected work-related behaviors.
7) Signed acknowledgement by employee that violation of the agreement will be grounds for termination.
Failure to successfully complete a treatment program and comply with the return-to-work agreement, and pass a drug and/or alcohol tests after return-to-work, may be grounds for termination.
B. After Self-Referral
Employees self-referring to a substance abuse treatment program with the prior knowledge of their Supervisor or Manager, and who utilize City benefits, must agree to a return-to-work agreement, which will include:
1) A release to work statement from an approved treatment specialist. 2) An evaluation from the substance abuse counselor.
XII. MEDICAL REVIEW OFFICER (MRO)
A. The MRO must be a licensed physician or doctor of osteopathy who meets the qualification requirements of the DOT regulations. The MRO is responsible for receiving laboratory results generated by the drug testing program, has knowledge of substance abuse disorders, and has City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 22 approved medical training to interpret and evaluate an individual’s confirmed positive test result together with his/her medical history and any other relevant biomedical information.
B. The MRO will perform responsibilities, perform notifications, and retain confidential records as required by 49 CFR Part 40.
XIII. TESTING LABORATORY
The City shall use a drug testing laboratory certified under DHHS Mandatory Guidelines for Federal Workplace Drug Testing Programs.
The testing laboratory will comply with all methods and procedures of 49 CFR Part 40. The laboratory shall have a qualified individual to assume professional, organizational, educational, and administrative responsibility for the laboratory’s urine drug testing facility.
XIV. EMPLOYEE/SUPERVISOR TRAINING
The education and ongoing awareness component of this policy includes display of posters, distribution to all employees of the drug and alcohol policy and other informational materials, and periodic information seminars.
The City provides to all safety-sensitive employees a minimum of 60 minutes of training on the effects and consequences of prohibited drug use on personal health, safety and the work environment, and on the signs and symptoms that may indicate prohibited drug use.
A. Every covered employee will receive the following drug use/alcohol misuse education:
1. Drug/alcohol information will be periodically distributed and displayed in the work areas.
2. Copies of this policy will be displayed in the work area. This information will be discussed at the time that it is handed out so that the employees understand its content. Every new employee receives a copy of the entire policy.
3. Brochure from the City-sponsored Employee Assistance Program.
B. Supervisors will receive 60 minutes of training on drug indicators and 60 minutes of training on alcohol indicators.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 23 XV. RECORDKEEPING
1. A. The City shall maintain the following records as required by applicable law and regulations. The records shall be maintained in a secure location with controlled access.
The following records shall be maintained for five years:
a) Records of employee alcohol test results that indicate an alcohol concentration of 0.02 or greater;
b) Records of verified positive drug test results and refusals; c) Documentation of refusals to take required alcohol and/or drug tests (including substituted or adulterated drug test results;
d) Employee SAP evaluation and referrals, SAP reports, follow-up tests, and scheduled for follow-up tests; and
e) Annual Management Information System (MIS) reports summary.
2. Information obtained for employees from previous employers under 49 CFR 40.25 concerning drug and alcohol test information shall be maintained for three years due to triennial audit.
3. The following records shall be maintained for two years:
a) Records related to the drug collection process;
b) Records related to the inspection, maintenance, and calibration of evidential breath testing (EBT) devices; and
c) Education and training records.
4. Records of negative and canceled drug test results and alcohol test results with a concentration of less than 0.02 shall be maintained for one year.
B. Access to Facilities and Records
1. Except as required by law or expressly authorized or required by DOT, the City shall not release covered employee information that is contained in the records required to be maintained.
2. A covered employee is entitled, upon written request, to obtain copies of any records pertaining to the employee’s use of drugs or misuse of alcohol, including any records pertaining to his or her drug or alcohol tests. The City shall promptly provide the records requested by the employee. Access to employee’s records shall not be contingent upon payment for records other than those specifically requested.
3. For covered employees who seek to perform safety-sensitive functions, the City is required to obtain from the employee’s previous DOT-covered employers who employed the employee during any period during the preceding two years, pursuant to an employee’s consent, information on the employee’s alcohol tests with a concentration result of 0.04 or greater, positive drug test results, refusals to be tested, other violations of DOT agency drug and alcohol testing regulations, and documentation of the employee’s successful completion of DOT return-to-duty requirements.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 24 If it is not feasible to obtain the information prior to the driver performing safety-sensitive functions:
a) this information shall be obtained and reviewed by the City as soon as possible. The City shall not permit the employee to perform safety-sensitive functions after 30 days from the date on which the employee first performed safety-sensitive functions, unless it has obtained or made and documented a good faith effort to obtain this information. b) If the employee stops performing safety-sensitive functions for the City before the expiration of the 30-day period or before the City has obtained the required information, the City must still obtain the information. c) The City must provide to each of the employee’s DOT-covered employers within the two preceding years the employee’s specific, written authorization for release of the information.
d) The release of any information may take the form of personal interviews, telephone interviews, letters, or any other method of obtaining information that ensures confidentiality. The City shall maintain a written, confidential record with respect to each past employer contacted.
e) The covered employee may not perform safety-sensitive functions if the City obtains information on the employee’s alcohol test with a BAC of 0.04 or greater; verified positive drug test result; or the employee’s refusal to be tested; unless and until the City obtains information on a subsequent substance abuse professional evaluation and/or determination under 49 CFR Part 40 §40.25.
XVI. CONTRACTORS HIRED BY THE CITY
A. Contractors hired by the City that fall under 49 CFR Part 655 are required to submit a copy of their Anti-Drug/Alcohol Misuse Program and may also be required to submit quarterly reports that state: Number of employees tested, Type of test, Number of positive drug tests and resulting action; and Number of alcohol tests that indicated a BAC of 0.02 or greater, but less than 0.039 and resulting action for that period. The Contractor shall make clear the job titles of employees who will perform any work or functions covered by Part 655 under said contract.
Names may also be included if clarification is necessary. Failure to submit an Anti-Drug/Alcohol Misuse Program that complies with Part 655 and Part 40 may result in the rejection of offerer’s bid. Failure to submit quarterly reports or annual MIS reports may result in a default of contract as stated in the project’s specifications and contract documents.
B. The Contractor shall allow access to property and records to a City representative, the FTA or any DOT agency with regulatory authority over the operator for the purpose of monitoring the operator’s compliance with the requirements of 49 CFR Parts 40 and 655.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 25 XVII. CONFIDENTIALITY
A. Each individual’s record of testing and results under this policy will be maintained private and confidential to the extent authorized by law and DOT regulations. Except as provided by law or expressly authorized by DOT regulations, the results of individual drug/alcohol tests will not be released to anyone without the specific, written consent of the individual authorizing release of the information to an identified person. Prior to testing, the individual will be informed about who will receive test data (e.g., testing laboratory, MRO, Program Manager, Supervisor).
B. All written records will be stored in locked containers or in a secure location with access available only by the Program Manager or his/her designee, and the DOT upon request.
C. Drug and alcohol testing and/or rehabilitation records shall only be released to subsequent DOT-covered employers upon written consent from the covered employee. Then only the specific information requested by the employee shall be released.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 26 XVIII. GLOSSARY OF ACRONYMS
BAC - Breath Alcohol Concentration
BAT - Breath Alcohol Technician
CCF - Custody and Control Form
CFR - Code of Federal Regulations
CPL - Conforming Products List
DAPM - Drug & Alcohol Program Manager
DER - Designated Employer Representative
DHHS - Department of Health and Human Services
DOT - Department of Transportation
EAP - Employee Assistance Program
EBT - Evidential Breath Testing (Device)
FMCSA - Federal Motor Carrier Safety Administration
FTA - Federal Transit Administration
GC/MS - Gas Chromatography/Mass Spectrometry
LC/MS - Liquid Chromatography/Mass Spectrometry
MIS - Management Information System
MRO - Medical Review Officer
NHTSA - National Highway Traffic Safety Association
NTSB - National Transportation Safety Board
QAP - Quality Assurance Plans (for EBTs)
SAP - Substance Abuse Professional
XIX. TERMS AND DEFINITIONS
Accident – An occurrence associated with the operation of a vehicle, if as a result: (1) an individual dies; or (2) an individual suffers bodily injury and immediately receives medical treatment away from the scene of the accident; or (3) with respect to an occurrence in which the mass transit vehicle involved is a bus, electric bus, van, or automobile, one or more vehicles (including non-FTA funded vehicles) incurs disabling damage as the result of the occurrence and such vehicle or vehicles are transported away from the scene by a tow truck or other vehicle; or (4) with respect to an occurrence in which the public transportation vehicle involved is a rail car, trolley car, trolley bus, or vessel, the public transportation vehicle is removed from operation.. (49 CFR §655.4.) Air Blank – A reading by an EBT of ambient air containing no alcohol.
Alcohol Concentration – The alcohol in a volume breath expressed in terms of grams of alcohol per 210 liters of breath as indicated by an evidential breath testing device.
Alcohol Use – The consumption of any beverage, mixture, or preparation, including any medication, containing alcohol.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 27 Breath Alcohol Technician – An individual who instructs and assists individuals in the alcohol testing process and operates an EBT.
Canceled or Invalid Test – In drug or alcohol testing, a test that has a problem identified that cannot be or has not been corrected, or which is required to be cancelled.
Chain of Custody – Procedures to account for the integrity of each urine specimen by tracking its handling and storage from point of specimen collection to final disposition of the specimen. These procedures shall require that an appropriate drug testing custody form from a Department of Health & Human Services (DHHS) certified laboratory be used from time of collection to receipt by the laboratory.
Collection Site – A place designated by the employer where individuals present themselves for the purpose of providing a specimen of their urine to be analyzed for the presence of drugs.
Confirmation Test – For alcohol testing means a second test, following a screening test with a result of 0.02 or greater, that provides quantitative data of alcohol concentration. For controlled substances testing it means a second analytical procedure to identify the presence of a specific drug or metabolite which is independent of the screen test and which uses a different technique and chemical principle from that of the screen test in order to ensure reliability and accuracy.
Contractor – A person or organization that provides a service for a recipient, sub-recipient, employer, or operator consistent with a specific understanding or arrangement.
Covered Function (Safety-Sensitive) – means (a) operating a revenue service vehicle, including when not in service (FTA); (b) operating a non-revenue service vehicle, when required to be operated by a holder of a Commercial Driver’s License; (c) controlling dispatch or movement of a revenue service vehicle; (d) maintaining (including repairs, overhaul and rebuilding) a revenue service vehicle or equipment used in revenue service, unless the recipient receives funding under 49 U.S.C. 5307 or 5309, is in an area with less than 200,000 in population, and contracts out such services; (e) carrying a firearm for security purposes.
Dilute Specimen – A specimen with creatinine and specific gravity values that are lower than expected for human urine.
Drug Metabolite – The specific substance produced when the human body metabolizes a given drug as it passes through the body and is excreted in the urine.
Employee Assistance Program (EAP) – A program provided to assist employees in identifying and resolving personal concerns, including drug or alcohol dependency. Rehabilitation and re-entry to the work force are usually arranged through an EAP.
Evidential Breath Testing Device (EBT) – an EBT approved by the National Highway Traffic Safety Administration (NHTSA) for evidential testing of breath and placed on NHTSA’s conforming products list of evidential breath measurement devices (CPL), and identified on the CPL as confirming with the model specifications available from the National Highway Traffic Safety Administration, Office of Alcohol and State Programs.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 28 Medical Review Officer (MRO) – A licensed physician (medical doctor or doctor of osteopathy) responsible for receiving laboratory results generated by an employer’s drug testing program and who has knowledge of substance abuse disorders and has appropriate medical training to interpret and evaluate an individual’s confirmed positive test result together with his or her medical history and any other relevant biomedical information.
Post-Accident Test – a drug and alcohol test administered to a covered employee following an accident.
Pre-Employment Test – a drug and alcohol test administered to an applicant or covered employee who is being considered for a safety-sensitive position.
Random Test – an unannounced drug or alcohol test of covered employees based on random selection.
Refuse to Submit or Test – failure by a covered employee to comply with the drug and/or alcohol testing process, and such refusal to submit to testing is equivalent to having a positive test.
Return-to-Duty Test – an initial drug or alcohol test prior to return-to-duty and additional unannounced drug tests (i.e., follow-up tests) given to covered employees who are returning to safety-sensitive positions.
Split Specimen – a part of the urine specimen that is sent to a first laboratory and retained unopened, and which is transported to a second laboratory in the event that the employee requests that it be tested following a verified positive test of the primary specimen or a verified adulterated or substituted test result.
Substance Abuse Professional (SAP) – a person who evaluates employees who have violated DOT drug and alcohol regulation and makes recommendation concerning education, treatment, and follow-up testing and aftercare.
Verified Positive (drug test result) – a drug test result reviewed by a Medical Review Officer and determined to have evidence of prohibited drug use.
XX. EMPLOYEE INFORMATION ON THE EFFECTS OF ALCOHOL
MISUSE/DRUG USE
A. Effects of alcohol and drugs on a person’s health, work, and personal life include, but are not limited to: disruption of sleep; changes in eating patterns, commonly not eating as much; weight loss; mood swings; depression; increased physical ailments (e.g., headaches, colds, stomach problems); decreased motivation; withdrawal from family and friends; quicker to anger; neglects obligations and is not as attentive; does not handle stress well; changes friends; and excuses uses of drugs/alcohol.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 29 B. Signs and symptoms of drug use or alcohol misuse which could affect work performance include, but are not limited to: reporting to work late; calling in sick often; unauthorized absences; smell of alcohol on a person; taking long or frequent breaks; change in personality – more angry or less friendly; decreased motivation; an “I don’t care” attitude; thinking and concentration not as sharp; more prone to accidents; forgetfulness; less attentive to appearance; appearing tired; sleeping on the job.
For additional information, see Attachment A – Drug and Alcohol Fact Sheets.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 30 XXI. ATTACHMENTS
A. Fact Sheets: Alcohol, Amphetamines, Cocaine, Marijuana, Opioids and Phencyclidine(PCP)
Alcohol Fact Sheet
Alcohol is a socially acceptable, legal substance that has been consumed throughout the world for centuries. It is considered a recreational beverage when consumed in moderation for employment and relaxation during social gatherings. However, when consumed primarily for its physical and moodaltering effects, alcohol can be a substance of abuse. As a depressant, it slows down physical responses and progressively impairs mental functions.
Signs and Symptoms of Use
• Dulled mental processes
• Lack of coordination
• Odor of alcohol on breath
• Possible constricted pupils
• Sleepy or stuporous condition
• Slowed reaction rate
• Slurred speech (Note: except for the odor, these are general signs and symptoms of any depressant substance)
Health Effects
The chronic consumption of alcohol (average of three servings per day of beer [12 ounces per serving], whiskey [1 ounce per serving], or wine [6 ounces per serving]) over time may result in the following health hazards:
• Decreased sexual functioning
• Dependency (up to 10 percent of all people who drink alcohol become physically and/or mentally dependent on alcohol and can be termed “alcoholic”)
• Fatal liver diseases including cirrhosis and fibrosis • Heart diseases such as cardiomyopathy, arrhythmias, high blood pressure, and stroke • Cancers of the mouth, tongue, pharynx, esophagus, rectum, breast, and malignant melanoma • Kidney disease
• Pancreatitis
• Spontaneous abortion and neonatal mortality
• Ulcers
• Birth defects (up to 54 percent of all birth defects are alcohol related) • Immune system suppression leading to pneumonia and tuberculosis • Mental health problems, including depression and anxiety Social Issues
• Two-thirds of all homicides are committed by people who drink prior to the crime.
Attachment A
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 31 • Two to three percent of the driving population is legally drunk at one time. This rate is doubled at night and on weekends.
• Two-thirds of all Americans will be involved in an alcohol-related vehicle accident during their lifetimes.
• The rate of separation and divorce in families with alcohol dependency problems is seven times the average.
• Forty percent of family court cases are alcohol problem related. • Alcoholics are 15 times more likely to commit suicide than other segments of the population. • More than 60 percent of burns, 40 percent of falls, 69 percent of boating accidents, and 76 percent of private aircraft accidents are alcohol related.
The Annual Toll
• 10,000 will die in alcohol-impaired driving crashes
• 90,000 will die due to alcohol-related health issues
Workplace Issues
• It takes one hour for the average person (weighing 150 pounds) to process one serving of an alcoholic beverage from the body.
• Impairment in coordination and judgment can be objectively measured with as little as two drinks in the body.
• A person who is legally intoxicated is six times more likely to have an accident than a sober person.
Amphetamine Fact Sheet
Amphetamines are central nervous system stimulants that speed up the mind and body. The physical sense of energy at lower doses and the mental exhilaration at higher doses are the reason for their abuse. Although widely prescribed at one time for weight reduction and mood elevation, the legal use of amphetamines is now limited to a very narrow range of medical conditions. Most amphetamines that are abused are illegally manufactured in foreign countries and smuggled into the U.S. or clandestinely manufactured in crude laboratories.
Description
• Amphetamine is sold in counterfeit capsules or as white, flat, doubled-scored “minibennies.” It is usually taken by mouth.
• Methamphetamine is often sold as a creamy white and granular powder or in lumps and is packaged in aluminum foil wraps or sealable plastic bags. Methamphetamine may be taken orally, injected, or snorted into the nose.
• Trade/street names include Biphetamine, Delcobese, Desotyn, Detedrine, Chetrol, Ritalin, Speed, Meth, Crank, Crystal, Monster, Black Beauties, Rits and Ecstasy.
Signs and Symptoms of Use
• Hyperexcitability, restlessness
• Dilated pupils
• Increased heart rate and blood pressure
• Heart palpitations and irregular beats
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 32 • Profuse sweating
• Rapid respiration
• Confusion
• Panic
• Talkativeness and incoherence
• Inability to concentrate
• Heightened aggressive behavior
Health Effects
• Regular use produces strong psychological dependence and increasing tolerance to drug. • High doses may cause toxic psychosis resembling schizophrenia. • Intoxication may induce a heart attack or stroke due to spiking of blood pressure. • Chronic use may cause heart and brain damage due to severe constriction of capillary blood vessels.
• Long-term use can cause anxiety, confusion, paranoia, hallucinations, delusions, and severe dental problems.
• The euphoric stimulation increases impulsive and risk-taking behaviors, including bizarre and violent acts.
• Withdrawal from the drug may result in severe physical symptoms such as fatigue, insomnia, psychomotor agitation, anxiety, and mental depression.
Workplace Issues
• Since amphetamines alleviate the sensation of fatigue, they may be abused to increase alertness because of failure to get rest.
• Low-dose amphetamine use will cause a short-term improvement in mental and physical functioning. With greater use or increasing fatigue, the effect reverses and has an impairing effect. Hangover effect is characterized by physical fatigue and depression, which may make operation of equipment or vehicles dangerous.
Cocaine Fact Sheet
Cocaine is used medically as a local anesthetic. It is abused as a powerful physical and mental stimulant.
The entire central nervous system is energized. Muscles are more tense, the heart beats faster and stronger, and the body burns more energy. The brain experiences an exhilaration caused by a large release of neurohormones associated with mood elevation.
Description
• The source of cocaine is the coca bush, grown almost exclusively in the mountainous regions of northern and central South America.
• Cocaine Hydrochloride – “snorting coke” is a white to creamy granular or lumpy powder that is chopped into a fine powder before use. It is snorted into the nose, rubbed on the gums, or injected in veins. The effect is felt within minutes and lasts 40-50 minutes per “line” (about 60 to 90 milligrams). Common paraphernalia include a single-edged razor blade and small mirror or piece of smooth metal, a half straw or metal tube, and a small screw cap vial or folded paper packet containing the cocaine.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 33 • Cocaine Base – a small crystalline rock about the size of small pebble. It boils at a low temperature, is not soluble in water, and is up to 90 percent pure. It is heated in a glass pipe and the vapor is inhaled. The effect is felt within seven seconds. Common paraphernalia includes a “crack pipe” (a small glass smoking device for vaporizing the crack crystal) and a lighter, alcohol lamp, or small butane torch for heating. • Trade/street names include: Coke, Rock, Crack, Free Base, Flake, Snow, Smoke, and Blow.
Signs and Symptoms of Use
• Financial problems
• Frequent and extended absences from meetings or work assignment • Increased physical activity and fatigue
• Isolation and withdrawal from friends and normal activities • Secretive behaviors, frequent nonbusiness visitors, delivered packages, phone calls •Unusual defensiveness, anxiety, agitation
• Wide mood swings
• Runny or irritated nose
•Difficulty in concentration
•Dilated pupils and visual impairment
• Restlessness
• Formication (sensation of insects crawling on skin)
•High blood pressure, heart palpitations, and irregular rhythm •Hallucinations
•Hyperexcitability and overreaction to stimulus
• Insomnia
• Paranoia and hallucinations
• Profuse sweating and dry mouth
• Talkativeness
Health Effects
• Research suggests that regular cocaine use may upset the chemical balance of the brain. As a result, it may speed up the aging process by causing irreparable damage to critical nerve cells.
The onset of nervous system illnesses such as Parkinson’s disease could also occur. • Cocaine use causes the heart to beat faster and harder and rapidly increases blood pressure. In addition, cocaine causes spasms of blood vessels in the brain and heart. Both effects lead to ruptured vessels causing strokes or heart attacks.
• Strong psychological dependency can occur with one “hit” of crack. Usually, mental dependency occurs within days (crack) or within several months (snorting coke). Cocaine causes the strongest mental dependency of any known drug.
• Treatment success rates are lower than for other chemical dependencies. • Cocaine is extremely dangerous when taken with depressant drugs. Death due to overdose is rapid.
• 7,000 people died from cocaine overdose in 2015
Workplace Issues
• Extreme mood and energy swings create instability. Sudden noises can cause a violent reaction. • Lapses in attention and ignoring warning signals greatly increase the potential for accidents.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 34 • The high cost of cocaine frequently leads to workplace theft and/or dealing. • A developing paranoia and withdrawal create unpredictable and sometimes violent behavior. • Work performance is characterized by forgetfulness, absenteeism, tardiness, and missed assignments.
Cannabinoids (Marijuana) Fact Sheet
Marijuana is one of the most misunderstood and underestimated drugs of abuse. People use marijuana for the mildly tranquilizing and mood –and perception – altering effects it produces.
Description
• Leaf marijuana will range in color from green to light tan. The leaves are usually dry and broken into small pieces. The seeds are oval with one slightly pointed end. Less prevalent, hashish is a compressed, sometimes tarlike substance ranging in color from pale yellow to black. It is usually sold in small chunks wrapped in aluminum foil. It may also be sold in an oily liquid. • Marijuana has a distinctly pungent aroma resembling a combination of sweet alfalfa and incense. • Cigarette papers, roach clip holders, and small pipes made of bone, brass, or glass are commonly found. Smoking “bongs” (large bore pipes for inhaling large volumes of smoke) can easily be made from soft drink cans and toilet paper rolls.
• Trade/street names include: Marinol, THC, Pot, Grass, Joint, Reefer, Acapulco Gold, Sinsemilla, Thai Sticks, Hash, and Hash Oil.
Signs and Symptoms of Use
Reddened eyes (often masked by eye drops), slowed speech, distinctive odor on clothing, lackadaisical “I don’t care” attitude, chronic fatigue and lack of motivation, irritating cough, and chronic sore throat.
Health Effects
• When marijuana is smoked, it is irritating to the lungs. Chronic smoking causes emphysema-like conditions.
•One joint causes the heart to race and be overworked. People with undiagnosed heart conditions are at risk.
• Marijuana is commonly contaminated with the fungus Aspergillus, which can cause serious respiratory tract and sinus infections.
• Marijuana smoking lowers the body’s immune system response, making users more susceptible to infection.
Pregnancy Problems and Birth Defects
• The active chemical, tetrahydrocannabinol (THC), and 60 other related chemicals in marijuana concentrate in the ovaries and testes.
• Chronic smoking of marijuana in males causes a decrease in sex hormone, testosterone, and an increase in estrogen, the female sex hormone. The result is a decrease in sperm count, which can lead to temporary sterility. Occasionally, the onset of female sex characteristics including breast development occurs in heavy users.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 35 • Chronic smoking of marijuana in females causes a decrease in fertility and an increase in testosterone.
• Pregnant women who are chronic marijuana smokers have a higher than normal incidence of stillborn births, early termination of pregnancy, and higher infant mortality rate during the first few days of life.
• In test animals, THC causes birth defects, including malformations of the brain, spinal cord, forelimbs, and liver and water on the brain and spine.
• Offspring of test animals who were exposed to marijuana have fewer chromosomes than normal, causing gross birth defects or death of the fetus. Pediatricians and surgeons are concluding that the use of marijuana by either or both parents, especially during pregnancy, leads to specific birth defects of the infant’s feet and hands.
• One of the most common effects of prenatal cannabinoid exposure is underweight newborn babies
• Fetal exposure may decrease visual functioning and causes other ophthalmic problems.
Mental Function
Regular use can cause the following effects:
• Delayed decision-making
• Diminished concentration
• Impaired short-term memory, interfering with learning • Impaired signal detection (ability to detect a brief flash of light), a risk for users who are operating machinery
• Impaired tracking (the ability to follow a moving object with the eyes) and visual distance measurements
• Erratic cognitive function
• Distortions in time estimation
• Long-term negative effects on mental function known as “acute brain syndrome,” which is characterized by disorders in memory, cognitive function, sleep patterns, and physical condition Acute Effects
• Aggressive urges
• Anxiety
• Confusion
• Fearfulness
• Hallucinations
• Heavy sedation
• Immobility
• Mental dependency
• Panic paranoid reaction
• Unpleasant distortions in body image
Workplace Issues
• The active chemical, THC, stores in body fat and slowly releases over time. Marijuana smoking has a long-term effect on performance.
• Combining alcohol or other depressant drugs and marijuana can produce a multiplied effect, increasing the impairing effect of both the depressant and marijuana.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 36 Opiates (Narcotics) Fact Sheet
Opiates (also called narcotics) are drugs that alleviate pain, depress body functions and reactions, and when taken in large doses, cause a strong euphoric feeling.
Description
• Natural and natural derivatives – opium, morphine, codeine, and herion • Synthetics – meperidine (Demerol), oxymorphone (Numorphan), and oxycodone (Percodan) • May be taken in pill form, smoked, or jected, depending upon the type of narcotic used • Trade/street names include: Smack, Horse, Emma, Big D, Dollies, Juice, Syrup, and China White Signs and Symptoms of Use
• Mood changes
• Impaired mental functioning and alertness
• Constricted pupils
• Depression and apathy
• Impaired coordination
• Physical fatigue and drowsiness
• Nausea, vomiting, and constipation
• Impaired respiration
Health Effects
• IV needle users have a high risk for contracting hepatitis and AIDS due to sharing of needles. • Narcotics increase pain tolerance. As a result, people could more severely injure themselves or fail to seek medical attention after an accident due to the lack of pain sensitivity. • In combination with alcohol and other depressant drugs, heroin use can lead to a dangerous slowdown of heart rate and breathing, coma, and death.
• Long-term heroin users may develop collapsed veins, infection of the heart lining and valves, abscesses, liver or kidney disease, and lung complication.
Social Issues
• There are over 500,000 heroin addicts in the U.S., most of whom are IV needle users. • An even greater number of medicinal narcotic-dependent persons obtain their narcotics through prescriptions.
• Because of tolerance, there is an ever-increasing need for more narcotic to produce the same effect.
• Strong mental and physical dependency occurs.
• The combination of tolerance and dependency creates an increasing financial burden for the user.
Costs for heroin can reach hundreds of dollars a day.
Workplace Issues
• Unwanted side effects such as nausea, vomiting, dizziness, mental clouding, and drowsiness place the legitimate user and abuser at higher risk for an accident. • Narcotics have a legitimate medical use in alleviating pain. Workplace use may cause impairment of physical and mental functions.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 37 • Work performance is characterized by forgetfulness, absenteeism, tardiness, missed appointments, and missed assignments.
Phencyclidine (PCP) Fact Sheet
Phencyclidine (PCP) was originally developed as an anesthetic, but the adverse side effects prevented its use except as a large animal tranquilizer. Phencyclidine acts as both a depressant and a hallucinogen, and sometimes as a stimulant. It is abused primarily for its variety of mood-altering effects. Low doses produce sedation and euphoric mood changes. The mood can change rapidly from sedation to excitation and agitation. Larger doses may produce a coma-like condition with muscle rigidity and a blank stare with the eyelids half closed. Sudden noises or physical shocks may cause a “freak out” in which the person has abnormal strength, extremely violent behavior, and an inability to speak or comprehend communication.
Description
• PCP is sold as a creamy, granular powder and is often packaged in one-inch square aluminum foil or folded paper “packets.”
• It may be mixed with marijuana or tobacco and smoked. It is sometimes combined with procaine, a local anesthetic, and sold as imitation cocaine.
• Trade/street names include: Angel Dust, Dust, and Hog.
Signs and Symptoms of Use
• Impaired coordination
• Severe confusion and agitation
• Extreme mood shifts
• Muscle rigidity
• Nystagmus (jerky eye movements)
• Dilated pupils
• Profuse sweating
• Rapid heartbeat
• Dizziness
• Delusions, hallucinations, paranoia
Health Effects
• The potential for accidents and overdose emergencies is high due to the extreme mental effects combined with the anesthetic effect on the body.
• PCP is potentiated by other depressant drugs, including alcohol, increasing the likelihood of an overdose reaction.
• Misdiagnosing the hallucination as LSD induced, and then treating with Thorazine, can cause a fatal reaction.
• Use can cause irreversible memory loss, personality changes, and other mental disorders.
There are four phases to PCP abuse. The first phase is acute toxicity. It can last up to three days and can include combativeness, catatonia, convulsions, and coma. Distortions of size, shape, and distance perception are common. The second phase, which does not always follow the first, is a toxic psychosis.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 38 Users may experience visual and auditory delusions, paranoia, and agitation. The third phase is a druginduced schizophrenia that may last a month or longer. The fourth phase is PCP-induced depression.
Suicidal tendencies and mental dysfunction can last for months.
Workplace Issues
• PCP abuse is less common today than in recent years. It is also not generally used in a workplace setting because of the severe disorientation that occurs.
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 39 B. POST-ACCIDENT RECORD OF DECISION
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 40 City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 41 C. Reasonable Suspicion Record of Decision
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 42 D. Notification of Required Testing Form
City of Santa Monica’s Big Blue Bus
Adopted by City Council on January 24, 2017 ** Revised on August 1, 2023** 43 E. Acknowledgement of Training and Receipt of Policy FTA Covered Employee
CITY OF SANTA MONICA’S BIG BLUE BUS
My signature below certifies that I have received a copy of the following materials:
1. City of Santa Monica’s Big Blue Bus Drug and Alcohol Policy/Procedures for Employees in Safety-Sensitive Job Functions;
2. The brochure from the City-sponsored Employee Assistance Program.
In addition, I certify that I have received 60 minutes of training on the effects and consequences of alcohol misuse and prohibited drug use on health, safety, personal life, and the work environment, and on the signs and symptoms that may indicate such use.
I understand that it is my responsibility to become familiar with the information contained in these documents. I further understand that if any of the information is unclear or if I have any questions, it is my responsibility to ask for clarification from my Supervisor, Manager, the Designated Employer Representative, or the Human Resources Department.
Employee Name (Print) Signature Date
Employee ID Hire Date
Department Job Title
ATTACHMENT 6
INJURY AND ILLNESS PREVENTION
WRITTEN PROGRAM
1 Reviewed/Revised: March 2024
INJURY AND
ILLNESS
PREVENTION
PROGRAM
2 CITY OF SANTA MONICA
INJURY & ILLNESS PREVENTION PROGRAM
PURPOSE: In accordance with labor code 6407.1 and Title 8 of the California Code of Regulations - section 3203 of the General Industry Safety Orders, this is the City of Santa Monica’s written Injury & Illness Prevention Program to provide a safe and healthy workplace for all employees.
The Injury & Illness Prevention Program is designed to accomplish the following objectives:
o Identify individuals responsible for implementing the Injury & Illness Prevention Program and its various components.
o Provide a system for identifying and evaluating workplace hazards, including scheduled periodic inspections to identify unsafe or unhealthy working conditions or work practices.
o Establish methods and procedures for correcting unsafe or unhealthy working conditions or work practices in a timely manner based upon the severity of the hazard.
o Occupational safety and health training programs designed to instruct employees in safe work practices and job specific instruction with respect to any possible hazards of an employee’s job assignment. o System for communicating with employees on health and safety issues, with provisions designed to encourage employees to inform the Department of hazards at the workplace without fear of reprisal. o Establish procedures for ensuring that employees know safety rules and expectations; and comply with safe and healthy work practices, which may include recognition as well as disciplinary action. o Establish on-going documentation / record keeping of the steps taken to implement and maintain the effectiveness of the City’s Injury & Illness Prevention Program.
The success of the Injury & Illness Prevention Program in providing a safe and healthy workplace for all employees starts with a commitment from management, supervisors, Risk Management, and employees in supporting this effort. Learning what the City’s workplace safety expectations are, and providing the proper personal protective equipment, safety training, and safe work practices; are the keys in having a sustained and effective safety program.
MANAGEMENT RESPONSIBILITY:
3 City Department Directors are responsible for implementing the Injury & Illness Prevention Program. Department Directors will do so by supporting this program at the highest level, and through delegating authority to Managers and Supervisors in supporting and carrying out the requirements of the Injury & Illness Program for their Departments.
SUPERVISOR RESPONSIBILITY:
Department Supervisors are responsible for the job specific safety training of employees, ensuring the employee is aware of the Injury and Illness Prevention Program and where to access it, providing regular safety tailgate meetings, and enforcing the tenets of the Injury & Illness Prevention Program during day-to-day operations. Supervisors will assist in “near miss” and accident investigations. Supervisors will lead by example and by sharing their expectations with employees in their effort to meet the requirements of the Injury & Illness Program for their Departments.
RISK MANAGEMENT/SAFETY ADMINISTRATOR RESPONSIBILITY:
The Safety Administrator is responsible for oversight and updating of City safety programs and keeping up to date with Cal OSHA regulations and requirements. The Safety Administrator will perform periodic inspections of facilities/operations and will investigate accidents and provide injury prevention solutions. These duties also include assisting to set the training curriculum for staff and helping to deliver or procure safety training to supplement Department specific training to ensure staff receive applicable training as required by Cal OSHA. The Safety Administrator will assist Departments with Job Safety/Job Hazard Analysis when new procedures or hazards are identified, as well as coordinate Environmental Studies when the need arises.
EMPLOYEE RESPONSIBILITY:
Employees are responsible for supporting the Injury & Illness Prevention Program by:
1. Reading and understanding the written Injury & Illness Prevention Program.
2. Attending and participating in the safety training programs provided.
3. Being safety aware and following all safety rules and regulations.
4. Reporting unsafe conditions or unsafe acts to their immediate Supervisor.
EMPLOYEE SAFETY COMPLIANCE AND PERFORMANCE EVALUATION
Employees will have a safety performance component as part of their overall annual performance reviews. The safety performance component will evaluate the employee’s compliance with the City’s Injury & Illness Prevention Program as detailed under employee commitment in this document.
• Recognition of safe work practices will be performed on a Departmental level with 4 support and assistance from Risk Management. Adverse safety performance will be addressed in concert with existing Department and Human Resources Department disciplinary guidelines.
• Remedial training needs will be identified and provided by the Department with the assistance of Risk Management where applicable.
• Adverse safety performance will be addressed in concert with existing Department and Human Resources Department disciplinary guidelines.
EMPLOYEE SAFETY COMMUNICATION AND AWARENESS
Employees are kept aware of City and Department safety information by several methods including but not limited to:
• Bulletin board information centers that include Cal-OSHA regulatory posters, safety handbooks, pamphlets, written memorandums, safety posters., and safety committee minutes.
• Tailgate meetings
• Standard Operating Procedure (SOP) documents
• The City’s email notifications with frequent safety information provided by the City Manager all staff email.
• The City’s online portal for staff information (currently The Hub) • Material Safety Data Sheets, where applicable, to alert employees to precautions associated with handling chemicals.
UNSAFE CONDITION OR PRACTICE - REPORTING
Avenues for employees to communicate Department safety issues to Management without fear of reprisal include:
• The employee’s immediate Supervisor, Manager, or Department Head • City / Department Safety Committees conducted periodically • The Risk Management Safety Administrator (310.458.4908) Employees are required to report unsafe workplace conditions or practices they observe to their immediate Supervisor.
The Report of Unsafe Condition or Practice Form is to be used by employees to report unsafe conditions or practices to their supervisor. (Access the Report of Unsafe Condition or Practice Form on the City’s “Hub” intranet site under: Departments/Risk 5 Management/Safety/Policies Programs Plans and Forms
These forms are to be used whenever:
• An employee observes an existing or suspected existence of an unsafe condition or unsafe practice.
The employee section of the Report of Unsafe Condition or Practice Form includes:
• The location of the unsafe condition or practice observed. • The date and time the unsafe condition or practice was observed. • Recommendations to correct the unsafe condition or practice observed.
Supervisors are required to respond to employee submitted Report of Unsafe Condition or Practice forms and correct the unsafe conditions or practices as soon as possible.
Supervisors shall request assistance from Department Management Staff, or the Risk Management Division of the Finance Department if necessary.
The employee submitted Report of Unsafe Condition or Practice Form is to be used by Supervisors to respond to unsafe conditions or practices. The Supervisor response section includes:
• The name of the Supervisor investigating the report.
• The results of the investigation.
• The steps taken to correct the unsafe condition or practice.
The Report of Unsafe Condition or Practice Forms that are used for identifying and reporting unsafe conditions or practices are to be maintained on file for one year at the site where the hazard was identified and corrected.
SAFETY INSPECTIONS
Facility safety inspection program is designed to be conducted periodically to identify and correct hazardous conditions in the workplace as necessary over the course of the year.
The Facility Safety Inspection Checklist will assist the facility safety inspector in determining what areas to inspect and how to evaluate the existing conditions at the site with regards to Cal -OSHA compliance criteria (Access the Facility Safety Inspection Checklist on the City’s “Hub” intranet site under: Departments/Risk Management/Safety/Policies Programs Plans and Forms.
Those conditions not in compliance with regards to Cal - OSHA criteria must be addressed and corrected in a timely manner.
Inspections will be conducted at least annually by the Risk Management Safety 6 Administrator with assistance from the Department administration. The Facility Safety Inspection Checklists are to be maintained on file by the Supervisor for one year at the site where the inspection was completed.
JOB SAFETY ANALYSES
The purpose of a Job Safety Analysis is to identify, inform, and prepare employees with labor intensive job classifications for:
• Physical duties required of the job.
• Safety hazards associated with the job.
• Personal protective equipment required of the job.
Supervisors and the Risk Management Safety Administrator are responsible for conducting a job safety analysis whenever new substances, processes, procedures, or equipment are introduced to the workplace that represent a new occupational safety and health hazard and/or whenever the employer is made aware of a new or previously unrecognized hazard.
Supervisors and the Safety Administrator may use the Job Safety Analysis Form to conduct the analysis. (Access the Job Safety Analysis Form on the City’s “Hub” intranet site under: Departments/Risk Management/Safety/Policies Programs Plans and Forms Supervisors shall provide a copy of the job safety analysis (or the resulting Standard Operating Procedure form) to employees required to perform the job and provide any required employee safety training to perform the job in accordance with the job safety analysis.
ACCIDENT INVESTIGATIONS
Supervisors are required to perform a thorough and complete accident investigation involving employees under their supervision using the Supervisors Report of Accident Investigation form on the City’s “Hub” intranet site under: Departments/Risk Management/Worker’s Compensation/Online Reporting of Work-Related Injury or Illness The Risk Management Safety Administrator may also conduct or assist in workplace accident investigation.
The purpose of accident investigation is to identify unsafe conditions and practices, and the underlying root causes of workplace accidents.
Root causes may include:
• Administrative Safety Polices
• Safety Procedures and Practices
• Personal Protective Equipment
7 • Lack of Safety Training
• Environmental Conditions
• Equipment Conditions
CORRECTING UNSAFE/ UNHEALTHY CONDITIONS
Unsafe or unhealthy conditions, work practices and work procedures should be discontinued or remedied as soon as they are discovered. If a device is to be found unsafe it should be removed from service and locked out and tagged out until it may be operated in a safe manner. A review and revision of the Job Safety Analysis and/or Standard Operating Procedures should be completed.
When an imminent hazard exists which cannot be immediately abated without endangering employee(s) and/or property, remove all exposed personnel from the area except those necessary to correct the existing condition. Employees necessary to correct the hazardous condition shall be provided the necessary safeguards.
EMPLOYEE SAFETY TRAINING
Safety training for employees is the joint responsibility of:
• Department Supervisors
• The Risk Management Division (Safety Administrator)
• The Fire Department Training Office
• The Police Department Training Office
• The Big Blue Bus Training Office
Safety training will be provided for applicable subjects:
• Upon Hire
• When refresher training is required per Cal OSHA regulation schedule • To all employees given new job assignments for which training has not previously been received
• Whenever new substances, processes, procedures, or equipment are introduced to the workplace and represent a new hazard
• Whenever the employer is made aware of a new or previously unrecognized hazard • For supervisors to familiarize themselves with the safety and health hazards to which employees under their immediate direction and control may be exposed Department Supervisors:
Department Supervisors will make their staff aware of the Injury & Illness Prevention Program as part of their initial safety training.
8 Department Supervisors with employee in labor intensive job classifications should train their employees at a minimum of once every 10 working days on safety topics pertinent to operations; and whenever new, potentially hazardous substances, processes, and procedures are introduced in the workplace.
Communicating safety issues with employees may also include safety posters / banners, safety handbooks, or written safety communications to train or alert employees to these changing conditions in the workplace.
If specific Department safety training is identified, the Supervisor will provide what is necessary internally, or seek Risk Management assistance to provide the safety training.
Department Supervisors are responsible for providing Department and Cal-OSHA required safety training for all employees internally, with the assistance of Risk Management, the Fire Department, or qualified outside vendor.
Risk Management Division:
The Safety Administrator is responsible for ensuring that Cal-OSHA and City required safety training is provided to all permanent or as-needed employees by:
• Conducting the safety training as required by Cal-OSHA or by City policy when necessary, or as requested by Supervisors or Management. • Procuring the safety training services of a qualified outside contractor as necessary, or as requested by Supervisors or Management.
• Verifying internal Departmental safety training and Divisional safety training provided by Supervisors throughout the year.
PROGRAM ACCESS
Staff will be made aware of the IIPP and its contents during their new hire training through their City new hire orientation and by their Department Supervisor.
A written copy (or electronic if requested) of the IIPP will be provided to a staff member or their designated representative upon request. This will be provided as soon as possible, and 9 no longer than 5 business days after the request is made.
The IIPP will also be available to all staff on the City’s “Hub” intranet site under:
Departments/Risk Management/Safety/Policies Programs Plans and Forms
RECORD KEEPING
Safety inspection records will be retained for at least one year and will contain the persons conducting the inspections, the unsafe conditions and work practices identified, and the actions taken to correct the unsafe conditions or practices.
Employee safety training records from safety training provided by Department Supervisors will be maintained for a period of at least 3 years at the responsible Supervisor’s office.
Employee safety training records from safety training provided by the Risk Management Division of the Finance Department will be maintained for a period of at least 3 years at Risk Management offices.
Department safety training divisions at the Fire Department, Police Department, and Big Blue Bus will maintain their employee safety training records for a period of at least 3 years on-site.
Accident and injury records (Cal-OSHA form 300 and 300A) for all fiscal years are maintained at the Risk Management Division of the Finance Department, with the 300A form printed and posted on employee bulletin boards each year from February 1 through April 30th.
PROGRAM MAINTENANCE
The City’s Injury and Illness Prevention Program will be reviewed and revised annually by the Safety Administrator to assure compliance with any revisions to the regulation from CalOSHA as necessary. .
City of Santa Monica
IIPP - COVID-19 Supplement
This section is now covered by the City of Santa Monica COVID-19 Prevention Program and may be found on “the Hub” under:
10 Departments/Risk Management/Safety/Policies Programs Plans and Forms Or at this link: https://bit.ly/3mU8BVr
ATTACHMENT 7
CITY OF SANTA MONICA'S COVID-19
PREVENTION PROGRAM
City of Santa Monica
COVID-19 Prevention
Program (CPP)
February 2023
2 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you.
I. PURPOSE:
The purpose of the City of Santa Monica’s (City) COVID-19 Prevention Program (“CPP”) is to provide employees a healthy and safe workplace as required under the California Occupational Safety and Health Act (Labor Code §§ 6300, et seq.) and associated regulations (8 C.C.R. § 3205).
Nothing in this CPP precludes the City from complying with federal, state, or local laws or guidance that recommends or requires measures that are more prescriptive and/or restrictive than are provided herein.
II. SCOPE
This CPP applies to all City employees except for City employees who are teleworking.
III. DEFINITIONS:
For the purposes of the CPP, the following definitions shall apply:
“Close contact” means the following, unless otherwise defined by regulation or order of the California Department of Public Health (CDPH), in which case the CDPH definition shall apply: (A) In indoor spaces of 400,000 or fewer cubic feet per floor, a close contact is defined as sharing the same indoor airspace as a COVID19 case for a cumulative total of 15 minutes or more over a 24-hour period during the COVID-19 case’s infectious period, as defined by this section, regardless of the use of face coverings. (B) In indoor spaces of greater than 400,000 cubic feet per floor, a close contact is defined as being within six feet of the COVID-19 case for a cumulative total of 15 minutes or more over a 24-hour period during the COVID-19 case’s infectious period, as defined by this section, regardless of the use of face coverings (C) Offices, suites, rooms, waiting areas, break or eating areas, bathrooms, or other spaces that are separated by floor-to-ceiling walls shall be considered distinct indoor spaces. EXCEPTION: Employees have not had a close contact if they wore a respirator required by the employer and used in compliance with section 5144 whenever they would otherwise have had a close contact under subsections 3205(b)(1)(A) or (b)(1)(B).
“COVID-19” (Coronavirus Disease 2019) means the disease caused by SARSCoV-2 (severe acute respiratory syndrome coronavirus 2). “COVID-19 case” means a person who: (A) Has a positive COVID-19 test; or (B) Has a positive COVID-19 diagnosis from a licensed health care provider; or (C) Is subject to a COVID-19-related order to isolate issued by a local or state health official; or (D) Has died due to COVID-19, in the determination of a local health department or per inclusion in the COVID-19 statistics of a county. 3 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you. “COVID-19 hazard” means potentially infectious material that may contain SARSCoV-2, the virus that causes COVID-19. Potentially infectious materials include airborne droplets, small particle aerosols, and airborne droplet nuclei, which most commonly result from a person or persons exhaling, talking or vocalizing, coughing, or sneezing, or from procedures performed on persons which may aerosolize saliva or respiratory tract fluids.
“COVID-19 symptoms” means fever of 100.4 degrees Fahrenheit or higher, chills, cough, shortness of breath or difficulty breathing, fatigue, muscle or body aches, headache, new loss of taste or smell, sore throat, congestion or runny nose, nausea or vomiting, or diarrhea, unless a licensed health care professional determines the person’s symptoms were caused by a known condition other than COVID-19.
“COVID-19 test” means a test for SARS-CoV-2 that is: (A) Cleared, approved, or authorized, including in an Emergency Use Authorization (EUA), by the United States Food and Drug Administration (FDA) to detect current infection with the SARS-CoV-2 virus (e.g., a viral test); and (B) Administered in accordance with the authorized instructions. (C) To meet the return to work criteria set forth in subsection 3205(c)(5), a COVID-19 test may be both self-administered and selfread only if another means of independent verification of the results can be provided (e.g., a time-stamped photograph of the results). “Exposed group” means all employees at a work location, working area, or a common area at work, within employer-provided transportation covered by section 3205.3, or residing within housing covered by section 3205.2, where an employee COVID-19 case was present at any time during the infectious period. A common area at work includes bathrooms, walkways, hallways, aisles, break or eating areas, and waiting areas. The following exceptions apply: (A) For the purpose of determining the exposed group, a place where persons momentarily pass through, without congregating, is not a work location, working area, or a common area at work. (B) If the COVID-19 case was part of a distinct group of employees who are not present at the workplace at the same time as other employees, for instance a work crew or shift that does not overlap with another work crew or shift, only employees within that distinct group are part of the exposed group. (C) If the COVID-19 case visited a work location, working area, or a common area at work for less than 15 minutes during the infectious period, and the COVID-19 case was wearing a face covering during the entire visit, other people at the work location, working area, or common area are not part of the exposed group. NOTE: An exposed group may include the employees of more than one employer. See Labor Code sections 6303 and 6304.1.
4 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you. “Face covering” means a surgical mask, a medical procedure mask, a respirator worn voluntarily, or a tightly woven fabric or non-woven material of at least two layers that completely covers the nose and mouth and is secured to the head with ties, ear loops, or elastic bands that go behind the head. If gaiters are worn, they shall have two layers of fabric or be folded to make two layers. A face covering is a solid piece of material without slits, visible holes, or punctures, and must fit snugly over the nose, mouth, and chin with no large gaps on the outside of the face. A face covering does not include a scarf, ski mask, balaclava, bandana, turtleneck, collar, or single layer of fabric. This definition includes clear face coverings or cloth face coverings with a clear plastic panel that otherwise meet this definition and which may be used to facilitate communication with people who are deaf or hardof-hearing or others who need to see a speaker’s mouth or facial expressions to understand speech or sign language respectively.
“Infectious period” means the following time period, unless otherwise defined by CDPH regulation or order, in which case the CDPH definition shall apply: (A) For COVID-19 cases who develop COVID-19 symptoms, from two days before the date of symptom onset until: (1) Ten days have passed after symptoms first appeared, or through day five if testing negative on day five or later; and (2) Twenty-four hours have passed with no fever, without the use of fever-reducing medications, and symptoms have improved. (B) For COVID-19 cases who never develop COVID-19 symptoms, from two days before the positive specimen collection date through 10 days (or through day five if testing negative on day five or later) after the date on which the specimen for their first positive test for COVID19 was collected. “Respirator” means a respiratory protection device approved by the National Institute for Occupational Safety and Health (NIOSH) to protect the wearer from particulate matter, such as an N95 filtering facepiece respirator. “Returned case” means a COVID-19 case who was excluded from work but returned pursuant to subsection 3205(c)(5)(A) and did not develop any COVID-19 symptoms after returning. A person shall only be considered a returned case for 30 days after the initial onset of COVID-19 symptoms or, if the person never developed COVID-19 symptoms, for 30 days after the first positive test. If a period of other than 30 days is required by a CDPH regulation or order, that period shall apply. (12) “Worksite,” for the limited purposes of this section and section 3205.1, means the building, store, facility, agricultural field, or other location where a COVID-19 case was present during the infectious period. It does not apply to buildings, floors, or other locations of the employer that a COVID-19 case did not enter.
5 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you.
IV. PROGRAM
A. SYSTEM FOR COMMUNICATING WITH CITY EMPLOYEES
1. Reporting COVID-19 Symptoms, Possible COVID-19 Close Contact Exposures, and Possible COVID-19 Hazards at City Worksites and Facilities
City policy requires that City employees immediately report to their manager or supervisor and to the Designated Infection Control Officer (DICO) any of the following: (1) the employee’s presentation of COVID-19 symptoms; (2) the employee’s possible COVID-19 close contact exposures; (3) possible COVID-19 hazards at City worksites or facilities.
The City will not discriminate or retaliate against any City employee who makes such a report.
2. Accommodations Process for City Employees with Medical or Other Conditions that put them at Increased Risk of Severe COVID-19 Illness
City policy provides for an accommodation process for employees who have a medical or other condition identified by the Centers for Disease Control and Prevention (“CDC”) or the employees’ health care provider as placing or potentially placing the employees at increased risk of severe COVID-19 illness, and as a result, may be in need of reasonable accommodations in order to perform the essential functions of their job.
The CDC identifies the following medical conditions and other conditions as placing or potentially placing individuals at an increased risk of severe COVID-19 illness
1. Cancer
2. Chronic kidney disease
3. COPD (chronic obstructive pulmonary disease)
4. Heart conditions, such as heart failure, coronary artery disease, or cardiomyopathies
5. Immunocompromised state (weakened immune system) from solid organ transplant
6. Obesity (body mass index [BMI] of 30 kg/m2 or higher but < 40 kg/m2)
7. Severe Obesity (BMI ≥ 40 kg/m2)
8. Pregnancy
9. Sickle cell disease
10. Smoking
6 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you.
11. Type 2 diabetes mellitus
The CDC guidance also provides that adults of any age with the following conditions might be at an increased risk for severe illness from the virus that causes COVID-19:
1. Asthma (moderate-to-severe)
2. Cerebrovascular disease (affects blood vessels and blood supply to the brain)
3. Cystic fibrosis
4. Hypertension or high blood pressure
5. Immunocompromised state (weakened immune system) from blood or bone marrow transplant, immune deficiencies, HIV, use of corticosteroids, or use of other immune weakening medicines
6. Neurologic conditions, such as dementia
7. Liver disease
8. Overweight (BMI > 25 kg/m2, but < 30 kg/m2)
9. Pulmonary fibrosis (having damaged or scarred lung tissues)
10. Thalassemia (a type of blood disorder)
11. Type 1 diabetes mellitus
The City will periodically review the following web address in order to account for any additional medical conditions and other conditions that the CDC has identified as placing or potentially placing individuals at an increased risk of severe COVID-19:
https://www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/people-with-medicalconditions.html.
City employees are encouraged to review the list of medical conditions and other conditions provided above in order to determine whether they have such a condition. The list is not exclusive for purposes of requesting an accommodation as described above.
City employees are not required to disclose their medical condition in order to support a request for an accommodation.
To request an accommodation under the City policy, employees may make a request with their manager or supervisor or the Department of Human Resources. If an employee submits such request to their manager or supervisor, the manager or supervisor must contact Human Resources. See Administrative Instruction III-4-3, Reasonable Accommodations Regarding Employment.
7 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you.
3. COVID-19 Testing
The City possesses authority to require that employees who report to work at City worksites or facilities be tested for COVID-19.
Where the City requires that City employees be tested, the City will inform employees of the reason that testing is required.
The City will also inform City employees of the possible consequences of a positive COVID-19 test, which may include, but is not limited to, a requirement that employees not report to City during the high-risk exposure period and satisfying the minimum criteria to return to work.
Where the City requires testing, the City has adopted policies and procedures that ensure the confidentiality of employees and comply with the Confidentiality of Medical Information Act (“CMIA”). Specifically, the City will keep confidential all personal identifying information of COVID-19 cases or persons with COVID-19 symptoms unless expressly authorized by the employee to disclose such information or as otherwise permitted or required under the law.
4. COVID-19 Hazards
The City will notify City employees and subcontracted employees of any potential COVID19 exposure at a City worksite or facility where a COVID-19 case and City employees were present on the same day. The City will notify City employees of such potential exposures within one (1) business day, in a way that does not reveal any personal identifying information of the COVID-19 case.
The City will also notify City employees of cleaning and disinfecting measures the City is undertaking in order to ensure the health and safety of the City worksite or facility where the potential exposure occurred.
B. IDENTIFICATION AND EVALUATION OF COVID-19 HAZARDS AT CITY
WORKSITES AND FACILITIES
1. Screening City Employees for COVID-19 Symptoms
City employees will self-screen for COVID-19 symptoms prior to reporting to any City worksite or facility.
2. Responding to City Employees with COVID-19 Symptoms
8 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you.
Should a City employee present COVID-19 symptoms during a self-screen, the City will instruct the employee to remain at or return to their home or place of residence and not report to work until such time as the employee satisfies the minimum criteria to return to work.
The employee must contact their manager or supervisor and the Infection Control Nurse:
Keystone Medical (Infection Control Nurse)
866-593-1923 [email protected]
The Infection Control Nurse will review the case and advise on testing and return to work status.
The City will advise employees of any leaves to which they may be entitled during this self-quarantine period through Human Resources, [email protected] .
Further, the City has adopted policies and procedures that ensure the confidentiality of employees and comply with the CMIA and will not disclose to other employees the fact that the employees presented COVID-19 symptoms.
3. City’s Response to COVID-19 Cases
In the event that City employees test positive for COVID-19 or are diagnosed with COVID19 by a health care provider, the City will instruct the employees to remain at or return to their home or place of residence and not report to work until such time as they satisfy the minimum criteria to return to work.
The City will advise employees of any leaves to which they may be entitled during this self-isolation period.
The City will comply with all reporting and recording obligations as required under the law, including, but not limited to, reporting the COVID-19 case to the following individuals and institutions as required based on the individual circumstances: (1) the local health department; (2) Cal/OSHA; (3) employees who were present at a City worksite or facility when the COVID-19 case was present; (4) the employee organizations that represent those employees at the City worksite or facility who were present at a City worksite or facility when the COVID-19 case was present; (5) the employers of subcontracted employees who were present at the City worksite or facility when the COVID-19 case was present; and (6) the City’s workers’ compensation plan administrator.
The City’s Infection Control Nurse will interview the COVID-19 cases in order to ascertain the nature and circumstances of any contact that the employees may have had with other employees during the high-risk exposure period. If the City determines that there were any close contact COVID-19 exposures, the City will notify them as soon as possible and provide instructions for implementation of close contact measures. 9 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you.
The City has adopted policies and procedures that ensure the confidentiality of employees and comply with the CMIA. Specifically, the City will not disclose to other employees, except for those who need to know, the fact that the employees tested positive for or were diagnosed with COVID-19. Further, the City will keep confidential all personal identifying information of COVID-19 cases or persons unless expressly authorized by the employees to disclose such information or as otherwise permitted or required under the law.
4. Workplace-Specific Identification of COVID-19 Hazards The City conducted a workplace-specific assessment of all interactions, areas, activities, processes, equipment, and materials that could potentially expose employees to COVID19 hazards with a specific Job Hazard Analysis (JHA) completed by supervisors and staff in each Division.
5. Maximization of Outdoor Air and Air Filtration
For indoor City worksites and facilities, the City evaluated how to maximize the quantity of outdoor air and whether it is possible to increase filtration efficiency to the highest level compatible with the worksites and facilities’ existing ventilation systems.
6. City Compliance with Applicable State and Local Health Orders The City monitors applicable orders and guidance from the State of California and the local health department related to COVID-19 hazards and prevention, including information of general application and information specific to the City’s location and operations.
The City fully and faithfully complies with all applicable orders and guidance from the State of California and the local health department.
7. Evaluation of Existing COVID-19 Prevention Controls and Adoption of Additional Controls
Periodically, the City will evaluate existing COVID-19 prevention controls at the workplace and assess whether there is a need for different and/or additional controls.
This includes evaluation of controls related to the correction of COVID-19 hazards, physical distancing, face coverings, engineering controls, administrative controls, and personal protective equipment (PPE).
8. Periodic Inspections
The City will conduct periodic inspections of City worksites and facilities as needed to identify unhealthy conditions, work practices, and work procedures related to COVID-19 and to ensure compliance with the City’s COVID-19 policies and procedures. 10 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you.
C. INVESTIGATING AND RESPONDING TO COVID-19 CASES IN CITY
WORKSITES AND FACILITIES
1. Procedure to Investigate COVID-19 Cases
The City has a procedure for investigating COVID-19 cases in the workplace. As provided below, the procedure provides for the following: (1) the verification of COVID-19 case status; (2) receiving information regarding COVID-19 test results; (3) receiving information regarding the presentation of COVID-19 symptoms; and (4) identifying and recording all COVID-19 cases.
2. Response to COVID-19 Cases
As provided above at Section IV.B.3., in the event that City employees test positive for COVID-19 or are diagnosed with COVID-19 by a health care provider, the City will instruct the employees to remain at or return to their home or place of residence and not report to work until such time as the employees satisfy the minimum criteria to return to work. a. Contact Tracing
The City’s Infection Control Nurse will interview the COVID-19 cases in order to ascertain the following information: (1) the date on which the employees tested positive, if asymptomatic, or the date on which the employees first presented COVID-19 symptoms, if symptomatic; (2) the COVID-19 cases’ recent work history, including the day and time they were last present at a City worksite or facility; and (3) the nature and circumstances of the COVID-19 cases’ contact with other employees during the high-risk exposure period, including whether there were any close contact COVID-19 exposure.
If the City determines that there were any close contact COVID-19 exposures, the City will provide instructions for implementation of close contact measures Reporting the Potential Exposure to Other Employees.
The City will comply with all reporting and recording obligations as required under the law, including, but not limited to, reporting the COVID-19 case to the following individuals and institutions as required based on the individual circumstances: (1) employees who were present at a City worksite or facility when the COVID-19 case was present; and (2) subcontracted employees who were present at the City worksite or facility. b. Free COVID-19 Testing for Close Contact Exposures
The City will provide direction on receipt of COVID-19 testing at no cost to employees during their working hours to all employees who had potential close contact COVID-19 exposure at a City worksite or facility.
In the event of a cluster at a work location (i.e., 3 COVID-19 positive cases within 14 days at one location), the City will implement the procedure as outlined in CCR Title 8 section 3205.1 (See appendix A)
11 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you. c. Leave and Compensation Benefits for Close Contact
Exposures
The City will provide these employees with information regarding COVID-19-related benefits to which the employees may be entitled under applicable federal, state, or local laws. This includes any benefits available under workers’ compensation law, the federal Families First Coronavirus Response Act (FFCRA), Labor Code sections 248.1 and 248.5, Labor Code sections 3212.86 through 3212.88, local governmental requirements, the City’s own leave policies, and leave guaranteed by contract.
The City may require that these employees use employer-provided employee sick leave benefits for this purpose and consider benefit payments from public sources in determining how to maintain earnings, rights and benefits, where permitted by law and when not covered by workers’ compensation or any other federal or state paid leave that may be available.
d. Investigation to Determine Whether Workplace Conditions Contributed to COVID-19 Exposure
The City will conduct an investigation in order to determine whether any workplace conditions could have contributed to the risk of COVID-19 exposure and what could be done to reduce exposure to COVID-19 hazards.
3. Confidential Medical Information
The City will protect the confidentiality of the COVID-19 cases and will not disclose to other employees the fact that the employees tested positive for or were diagnosed with COVID-19.
The City will keep confidential all personal identifying information of COVID-19 cases unless expressly authorized by the employees to disclose such information or as otherwise permitted or required under the law.
D. CORRECTION OF COVID-19 HAZARDS AT CITY WORKSITES AND
FACILITIES
The City will implement effective policies and procedures for correcting unsafe or unhealthy conditions, work practices, policies, and procedures in a timely manner based on the severity of the hazard.
This includes, but is not limited to, implementing controls and/or policies and procedures in response to the evaluations conducted related to the identification and evaluation of COVID-19 hazards and investigating and responding to COVID-19 cases in the workplace. This also includes implementing controls related to physical distancing, face 12 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you. coverings, engineering controls, administrative controls, and personal protective equipment (PPE).
E. TRAINING AND INSTRUCTION OF CITY EMPLOYEES
The City will provide COVID-19 training to all City employees through the online MySMI portal, by virtual instructor lead training, or in-person. The training will cover the following topics.
1. COVID-19 Symptoms
The City provided employees training and instruction on the COVID-19 symptoms, including advising employees of COVID-19 symptoms, which include the following: (1) fever of 100.4 degrees Fahrenheit or higher or chills; (2) cough; (3) shortness of breath or difficulty breathing; (4) fatigue; (5) muscle or body aches; (6) headache; (7) new loss of taste or smell; (8) sore throat; (9) congestion or runny nose; (10) nausea or vomiting; or (11) diarrhea, unless a licensed health care professional determines the person’s symptoms were caused by a known condition other than COVID-19.
The City monitors and adheres to guidance by the CDC concerning COVID-19 symptoms, including guidance provided at the following web address:
https://www.cdc.gov/coronavirus/2019-ncov/symptoms-testing/symptoms.html The City will advise employees in the event that the CDC makes any changes to its guidance concerning such symptoms.
The City provided employees instruction on the importance of not coming to work and obtaining a COVID-19 test if the employees have COVID-19 symptoms.
2. City’s COVID-19 Policies and Procedures
The City provides regular updates to employees on the City’s policies and procedures to prevent COVID-19 hazards at City worksites and facilities and to protect City employees.
3. COVID-19 Related Benefits
The City advised City employees of the leaves to which the employees may be entitled under applicable federal, state, or local laws. This includes any benefits available under workers’ compensation law, the FFCRA, Labor Code sections 248.1 and 248.5, Labor Code sections 3212.86 through 3212.88, any applicable local governmental requirements, the City’s own leave policies, and leave guaranteed by contract.
Further, when employees require leave or are directed not to report to work by the City, the City will advise the employees of the leaves to which the employees may be entitled for that specific reason.
13 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you.
4. Spread and Transmission of the Virus that Causes COVID-19 The City advised City employees that COVID-19 is an infectious disease that can be spread through the air when an infectious person talks or vocalizes, sneezes, coughs, or exhales; that COVID-19 may be transmitted when a person touches a contaminated object and then touches their eyes, nose, or mouth, although that is less common; and that an infectious person may have no symptoms.
The City further advised City employees of the fact that particles containing the virus can travel more than six (6) feet, especially indoors. High quality face coverings, hand hygiene, including hand washing, are effective ways of mitigating exposure.
5. Methods and Importance of Face Coverings, Ventilation, and Hand Hygiene
The City advised City employees of the methods and importance of face coverings, and hand hygiene, including hand washing.
Specifically, the City trained and instructed City employees on the importance of frequent hand washing with soap and water for at least 20 seconds and using hand sanitizer when employees do not have immediate access to a sink or hand washing facility, and that hand sanitizer does not work if the hands are soiled.
Further, the City trained and instructed City on the proper use of face coverings and the fact that nuisance level face coverings are not certified respiratory protective equipment.
F. PHYSICAL DISTANCING
The City will follow the latest LA DPH Health Officer Orders regarding physical distancing and occupancy levels
As of June15th 2021, physical distancing is not required by Cal OSHA, CDC, or LA County Department of Health
Should physical distancing be required by the Cal OSHA, CDC, or LA County Department of Health the City has adopted several methods by which it increases physical distancing including, but not limited to, the following: (1) Where approved by Departments, providing City employees the opportunity to telework or engage in other remote work arrangements; (2) Where suitable, reducing the number of persons in an area at one time, including visitors; (3) posting visual cues such as signs and floor markings to indicate where employees and others should be located.
Where staff will be working in the same area as others, face masks are mandatory, and ventilation is maximized.
14 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you.
1. Shared Occupancy Vehicles
In the event of an outbreak in a certain department the City recommends a single occupant in vehicles whenever possible. If this is not possible due to a safety concern or a specific associated task requiring two people in a vehicle then occupants must wear face coverings at all times, keep the windows rolled down/maximize fresh air intake, and should be assigned the same team as much as possible to reduce exposure.
G. FACE COVERINGS
1. Face Covering Requirement
City policy meets or exceeds orders and guidance provided by the CDPH, Cal OSHA, and the local health department, including as provided at the following web address:
https://www.cdph.ca.gov/Programs/CID/DCDC/Pages/COVID-19/guidance-for-facecoverings.aspx As of March 4th 2022, face coverings are strongly recommended but not required by Cal OSHA, CDC, or LA County Department of Health in most circumstances (transit, healthcare, and some locations may still require face masks).
The City provides face coverings to City employees where required as well as by request.
2. Respirators
Upon request, employers shall provide respirators for voluntary use in compliance with subsection 5144(c)(2) to all employees who are working indoors or in vehicles with more than one person. Whenever an employer makes respirators for voluntary use available, the employer shall encourage their use and shall ensure that employees are provided with a respirator of the correct size and that employees are trained how to properly wear the respirator provided; how to perform a user seal check according to the manufacturer’s instructions each time a respirator is worn; and the fact that facial hair interferes with a seal. The City’s policy requires that face coverings are clean and undamaged. The City’s policy allows for face shields to be used to supplement, and not supplant, face coverings.
Should face covering be required of a specific exposed group due to close contact status or by CCR Title 8 3205.1:
The City’s policy provides for the following exceptions to the face coverings requirement for unvaccinated staff:
15 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you.
1. When an employee is alone in a private office/room.
2. Operating a single occupant vehicle
3. While eating and drinking at the workplace, provided employees are at least six (6) feet apart and outside air supply to the area, if indoors, has been maximized to the extent possible.
4. Employees wearing respiratory protection in accordance with section 5144 or other title 8 safety orders (8 C.C.R. 5144 is available at the following web address: https://www.dir.ca.gov/title8/5144.html).
5. Employees who cannot wear face coverings due to a medical or mental health condition or disability, or who are hearing-impaired or communicating with a hearing-impaired person. Such employees will be referred through the accommodation process in accordance with City policy as referenced in Section IV.A.2.
6. Specific tasks which cannot feasibly be performed with a face covering. This exception is limited to the time period in which such tasks are actually being performed, and the unmasked employee shall be at least six (6) feet away from all other persons unless unmasked employees are tested at least twice weekly for COVID-19.
3. Required Use of Effective Non-Restrictive Alternative for Employees Exempted from Face Covering Requirement
The City’s policy requires that City employees who are unable to wear a face covering due to a medical condition, mental health condition, or disability wear an effective nonrestrictive alternative, such as a face shield with a drape on the bottom, if their condition or disability permits it. Such employees will be referred through the accommodation process in accordance with City policy as referenced in Section IV.A.2.
4. Physical Distancing Required If Employee Is Not Wearing Face Covering or Non-Restrictive Alternative
This section is no longer applicable as of 3/4/22
5. Prohibition on Preventing Employees from Wearing Face Covering
The City does not prevent any City employee from wearing a face covering when wearing a face covering is not required by this section, unless not wearing a face covering would create a safety hazard, such as interfering with the safe operation of equipment. 16 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you.
6. Communication to Non-Employees Regarding Face Covering Requirement
This section is no longer applicable as of 3/4/22
7. Policies to Reduce COVID-19 Hazards Originating from Persons Not Wearing Face Coverings
This section is no longer applicable as of 3/4/22
H. OTHER ENGINEERING CONTROLS, ADMINISTRATIVE CONTROLS
AND PERSONAL PROTECTIVE EQUIPMENT (PPE)
1. Installation of Solid Partitions Between Workstations Where Physical Distancing is Not Possible
The City has installed cleanable solid partitions that effectively reduce aerosol transmission between the employees and other persons at locations where City staff will be serving the public. This is no longer required and can be left in place or removed at the discretion of the operating department.
2. Maximization of Outdoor Air
As provided above at Section IV.B.5., for indoor City worksites and facilities, the City evaluated how to maximize the quantity of outdoor air.
Further, for City worksites and facilities with mechanical or natural ventilation, or both, the City has maximized the quantity of outside air provided to the extent feasible, except when the United States Environmental Protection Agency (“EPA”) Air Quality Index is greater than 100 for any pollutant or if opening windows or letting in outdoor air by other means would cause a hazard to City employees, for instance from excessive heat or cold.
3. Cleaning and Disinfecting Procedures
The City’s cleaning and disinfecting policy requires the following:
1. Identifying and regularly cleaning and disinfecting frequently touched surfaces and objects, such as doorknobs, elevator buttons, equipment, tools, handrails, handles, controls, bathroom surfaces, and steering wheels.
The City will inform employees and authorized employee representatives of cleaning and disinfection protocols, including the planned frequency and scope of regular cleaning and disinfection.
2. Prohibiting the sharing of personal protective equipment and to the extent feasible, items that employees come in regular physical contact with such as 17 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you. phones, headsets, desks, keyboards, writing materials, instruments, and tools. When it is not feasible to prevent sharing, sharing will be minimized and such items and equipment shall be disinfected between uses by different people. Sharing of vehicles will be minimized to the extent feasible, and high touch points (e.g., steering wheels, door handles, seatbelt buckles, armrests, shifter, etc.) shall be disinfected between users.
3. Cleaning and disinfection of areas, material, and equipment used by a COVID-19 case during the high-risk exposure period.
Further, the City requires that cleaning and disinfecting must be done in a manner that does not create a hazard to City employees or subcontracted employees.
4. Evaluation of Handwashing Facilities
In order to protect City employees, the City evaluated its handwashing facilities in order to determine the need for additional facilities, encourage and allow time for employee handwashing, and provide employees with an effective hand sanitizer.
The City encourages City employees to wash their hands for at least 20 seconds each time.
The City does not provide hand sanitizers with methyl alcohol.
5. Personal Protective Equipment (PPE)
City policy provides for PPE.
The City evaluates the need for PPE, such as gloves, goggles, and face shields, to prevent exposure to COVID-19 hazards and provide such PPE as needed.
In accordance with applicable law, the City evaluates the need for respiratory protection when the physical distancing requirements, as provided herein, are not feasible or are not maintained.
In accordance with applicable law, the City will provide and ensure use of respirators in accordance when deemed necessary by Cal/OSHA through the Issuance of Order to Take Special Action.
In accordance with applicable law, the City will provide and ensure use of eye protection and respiratory protection when City employees are exposed to procedures that may aerosolize potentially infectious material such as saliva or respiratory tract fluids. 18 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you.
I. REPORTING, RECORDKEEPING AND ACCESS
1. Reporting COVID-19 Cases to the Local Health Department In accordance with applicable law, when required the City will report information about COVID-19 cases at the workplace to the local health department or Cal OSHA.
Further, the City will provide any related information requested by the local health department.
2. Reporting Serious COVID-19 Illnesses and Deaths to Cal/OSHA In accordance with applicable law, the City will immediately report to Cal/OSHA any serious COVID-19-related illnesses or deaths of City employees occurring at a City worksite or facility or in connection with any employment.
Further, in accordance with applicable law, the City will record any serious work-related COVID-19-related illnesses or deaths.
3. Maintenance of Records Related to the Adoption of the CPP In accordance with applicable law, the City will maintain records of the steps taken to implement this CPP for at least 2 years.
4. Availability of the CPP for Inspection
The City will make this written CPP available to employees and employee organizations at City worksites or facilities.
Further, the City will make this written CPP available to Cal/OSHA representatives immediately upon request.
5. Records Related to COVID-19 Cases
The City will keep a record of and track all COVID-19 cases with the following information:
(1) employee’s name; (2) contact information; (3) occupation; (4) location where the employee worked: (5) the date of the last day at the workplace; and (6) the date of a positive COVID-19 test.
In accordance with the Confidentiality of Medical Information Act (CMIA) and applicable law, the City will keep the employees’ medical information confidential.
In accordance with the CMIA and applicable law, the City will make this information available to employees and employee organizations with personal identifying information removed. The City will also make this information available as otherwise required by law. 19 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you.
J. EXCLUSION OF COVID-19 CASES
1. Exclusion of COVID-19 Cases from City Worksites and Facilities The City will ensure that COVID-19 cases are excluded from the workplace until the individual satisfies the minimum return to work criteria provided for in Section IV.K.
2. Exclusion of Employees with Close Contact COVID-19
Exposures from City Worksites and Facilities
a. Contact Exclusion Period (regardless of vaccine status) Per LADPH HOO 4/13/22, general public persons (EMS and Jail/Custody staff must follow job specific HOO requirements) with a close contact exposure are not required to quarantine for COVID-19, regardless of vaccination status, so long as they remain asymptomatic. However, these individuals must follow the orders below:
(1) The employee who had the close contact COVID-19 exposure received a COVID19 test on day 3-5 following the close contact COVID-19 exposure; (2) The employee wears a high quality face mask at all times during work indoors and when around others; and
(3) The employee maintains a distance from others when able; self-monitors for COVID-19 symptoms; and if symptoms do appear, immediately isolates, contacts the local health department or health care provider, and seeks testing. (4) The employee continues to avoid contact with COVID-19 positive individuals until COVID-19 positive individuals have completed their isolation period.
3. Provision of Benefits to City Employees Excluded from Work as a Result of a Positive COVID-19 Test or Diagnosis or a Close Contact COVID-19 Exposure
a. Employees Who Are Able to Telework During Isolation or Quarantine Period
The City will allow employees who are able to telework, and are able and available to work, to telework during the isolation or quarantine period. The City will provide these employees their normal compensation for the work that they perform for the City during the isolation or quarantine period.
20 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you. b. Employees Who Are Unable to Telework During Isolation or Quarantine Period
The provision of benefits described below does not apply to either: (1) City employees who the City can demonstrate that the close contact COVID-19 exposure was not workrelated; and (2) City employees who are unable to work for reasons other than protecting employees and non-employees at City worksites and facilities from possible COVID-19 transmission. Such employees may still use paid sick leave for the purpose of receiving compensation during the isolation or quarantine period if they elect to do so.
Unless an employee’s applicable MOU provides otherwise, for other employees, the City will require that employees who are unable to telework, but are otherwise able and available to work, to use paid sick leave in order to receive compensation during the isolation or quarantine period; and City employees retain their entitlement to elect not to use other earned or accrued paid leave during this time. The City may provide such employees who are unable to telework, but who do not have any paid sick leave available, paid administrative leave in order to receive compensation during the isolation or quarantine period.
For all employees who are subject to an isolation or quarantine because of a COVID-19 case or a close contact COVID-19 exposure, the City will maintain the employees’ seniority and all other employee rights and benefits, including the employees’ right to their former job status, during the isolation or quarantine period. 21 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you.
4. Adherence with Laws, Policies, and/or Agreements Providing Excluded Employees Greater Protections
The obligations set forth in this section do not limit any other applicable law, City policy, or collective bargaining agreement that provides City employees with greater protections or benefits.
5. Provision of Information Concerning Benefits to Excluded Employees
At the time of exclusion, the City will provide the excluded employees the information on benefits to which the employees may be entitled under applicable federal, state, or local laws.
This includes any benefits available under workers’ compensation law, the FFCRA, Labor Code sections 248.1 and 248.5, Labor Code sections 3212.86 through 3212.88, any applicable local governmental requirements, the City’s own leave policies, and leave guaranteed by contract.
K. RETURN TO WORK CRITERIA
1. Minimum Criteria to Return to Work for
Symptomatic/Asymptomatic COVID-19 Cases
City policy requires that COVID-19 cases with COVID-19 symptoms remain at their home or place of residence and not report to any City worksite or facility until they satisfy each of the following conditions:
1. At least 24 hours have passed since a fever of 100.4 or higher has resolved without the use of fever-reducing medications;
2. COVID-19 symptoms have improved; and
3. Receive a negative COVID-19 test result on day 5 or later since COVID-19 symptoms first appeared or their positive test results, whichever happened first.
4. If all the above are satisfied, the staff member may be cleared by the Infection Control Nurse to return to work on the 6th day.
5. Staff may be cleared to return to work after day 10 without the requirement to test if they are symptom free and cleared by the Infection Control Nurse.
2. COVID-19 Testing Not Required in Order to Return to Work In accordance with CDC guidance concerning symptom-based strategies for the discontinuation of isolation, the City does not require employees submit to a COVID-19 test, or produce a negative COVID-19 test result, in order to return to work after 10 days. 22 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you.
3. Minimum Criteria to Return to Work for Employees Directed to Self-Quarantine or Isolate by a State or Local Health Official If employees are subject to an isolation or quarantine order issued by a state or local health official, City policy requires that the employees not report to any City worksite or facility until the period of isolation or quarantine is completed or the order is lifted.
If the order did not specify a definite isolation or quarantine period, then the period shall be 10 days from the time the order to isolate was effective, or 10 days from the time the order to quarantine was effective.
4. Allowance by Cal/OSHA for an Employee to Return to Work If there are no violations of state or local health officer orders for isolation or quarantine, Cal/OSHA may, upon request, allow employees to return to work on the basis that the removal of employees would create undue risk to a community’s health and safety.
In such cases, the City will develop, implement, and maintain effective control measures to prevent transmission in the workplace including providing isolation for the employees at the City worksite or facility and, if isolation is not possible, the use of respiratory protection in the workplace.
23 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you.
Appendix A
PROPOSED STATE STANDARD, TITLE 8, DIVISION 1, CHAPTER 4 Adopt Section 3205.1 to read:
§ 3205.1. COVID-19 Outbreaks.
(a) Scope. This section applies until [OAL insert date two years after effective date]. (1) This section applies to a workplace covered by section 3205 if three or more employee COVID-19 cases within an exposed group, as defined by subsection 3205(b)(7), visited the worksite during their infectious period at any time during a 14-day period, unless a California Department of Public Health (CDPH) regulation or order defines outbreak using a different number of COVID-19 cases and/or a different time period, in which case this section applies when the number of cases at the worksite constitutes an outbreak under CDPH’s definition. (2) This section shall apply until there are one or fewer new COVID-19 cases detected in the exposed group for a 14-day period.
(b) COVID-19 testing.
(1) Immediately upon being covered by this section, the employer shall make COVID-19 testing available at no cost to its employees within the exposed group, regardless of vaccination status, during employees’ paid time, except for returned cases and employees who were not present at the workplace during the relevant 14-day period(s) under subsection 3205.1(a).
(2) Employer shall then make testing available on a weekly basis to all employees in the exposed group who remain at the workplace.
(3) Employees who had close contacts shall have a negative COVID-19 test taken within three to five days after the close contact or shall be excluded and follow the return to work requirements of subsection 3205(c)(5) starting from the date of the last known close contact. (c) Face coverings. Employees in the exposed group, regardless of vaccination status, shall wear face coverings when indoors, or when outdoors and less than six feet from another person, unless one of the exceptions in subsection 3205(f)(2) applies.
(d) Respirators. Employers shall notify employees of their right to request and receive a respirator for voluntary use under subsection 3205(g).
(e) COVID-19 investigation, review, and hazard correction. The employer shall perform a review of potentially relevant COVID-19 policies, procedures, and controls and implement changes as needed to prevent further spread of COVID-19 when this section initially applies and 24 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you.
PROPOSED STATE STANDARD, TITLE 8, DIVISION 1, CHAPTER 4 periodically thereafter. The investigation, review, and changes shall be documented and shall include:
(1) Investigation of new or unabated COVID-19 hazards including the employer's leave policies and practices and whether employees are discouraged from remaining home when sick; the employer’s COVID-19 testing policies; insufficient supply of outdoor air to indoor workplaces; insufficient air filtration; and insufficient physical distancing. (2) The review shall be updated every 30 days that this section continues to apply, in response to new information or to new or previously unrecognized COVID-19 hazards, or when otherwise necessary.
(3) Any changes implemented to reduce the transmission of COVID-19 based on the investigation and review, which may include: moving indoor tasks outdoors or having them performed remotely; increasing the outdoor air supply when work is done indoors; improving air filtration; increasing physical distancing to the extent feasible; requiring respiratory protection in compliance with section 5144; and other applicable controls. (f) Ventilation. In buildings or structures with mechanical ventilation, employers shall filter recirculated air with Minimum Efficiency Reporting Value (MERV)-13 or higher efficiency filters if compatible with the ventilation system. If MERV-13 or higher filters are not compatible with the ventilation system, employers shall use filters with the highest compatible filtering efficiency. The employer shall use High Efficiency Particulate Air (HEPA) air filtration units in accordance with manufacturers’ recommendations in indoor areas occupied by employees for extended periods, where ventilation is inadequate to reduce the risk of COVID-19 transmission. (g) Major outbreaks. If 20 or more employee COVID-19 cases in an exposed group, as defined by subsection 3205(b)(7), visited the worksite during their infectious period within a 30-day period, the employer shall do the following while section 3205.1 applies:
(1) The COVID-19 testing described in subsection 3205.1(b) shall be required of all employees in the exposed group, regardless of vaccination status, twice a week or more frequently if recommended by the local health department with jurisdiction over the 25 ©2020 Liebert Cassidy Whitmore | This document is provided complimentary as a benefit to Liebert Cassidy Whitmore clients. The information contained within is a template only and was legally accurate at the time of publication. It is not designed to address the specific and unique issues, internal rules, practices, and/or governing documents that might be in place at your organization. You should always consult with legal counsel prior to implementation of any documents. Should you need assistance customizing this policy, please email [email protected] and a member of our team will contact you.
PROPOSED STATE STANDARD, TITLE 8, DIVISION 1, CHAPTER 4 workplace. Employees in the exposed group shall be tested or shall be excluded and follow the return to work requirements of subsection 3205(c)(5). (2) The employer shall report the outbreak to the Division. This subsection does not limit the employer’s obligation to report employee deaths, serious injuries, or serious illnesses when required by subsection 342(a).
(3) The employer shall provide respirators for voluntary use in compliance with subsection 5144(c)(2) to employees in the exposed group, shall encourage their use, and shall train employees provided respirators for voluntary use, as set forth in subsection 3205(g). (4) Any employees in the exposed group who are not wearing respirators required by the employer and used in compliance with section 5144 shall be separated from other persons by at least six feet, except where an employer can demonstrate that at least six feet of separation is not feasible, and except for momentary exposure while persons are in movement. Methods of physical distancing include: telework or other remote work arrangements; reducing the number of persons in an area at one time, including visitors; visual cues such as signs and floor markings to indicate where employees and others should be located or their direction and path of travel; staggered arrival, departure, work, and break times; and adjusted work processes or procedures, such as reducing production speed, to allow greater distance between employees. When it is not feasible to maintain a distance of at least six feet, individuals shall be as far apart as feasible.
Note: Authority cited: Section 142.3, Labor Code. Reference: Sections 142.3 and 144.6, Labor Code
ATTACHMENT 8
City of Santa Monica’s ATBP and
Communicable Disease Exposure Control
Plan
CITY OF SANTA MONICA
AEROSOL TRANSMISSIBLE,
BLOODBORNE PATHOGEN AND
COMMUNICABLE DISEASE
EXPOSURE CONTROL PLAN
Administration Instruction Revision History
Number Date Approval
III-5-8 6-2015 Revision
III-5-8 6-2019 FINAL Review
Prepared in accordance and in compliance with California General Industry Safety Order Group 16, Article 109 Sections 5193, 5199 and 5199.1 requirements, current reference sources, and accepted industrial safety and health principles and practices. They reflect the operating and working conditions noted on the day(s) of service(s) and relate only to those conditions specifically discussed herein.
2 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY Contents
INTRODUCTION AND PURPOSE ................................................................................................................................... 4 SCOPE.......................................................................................................................................................................... 5 REFERENCES ................................................................................................................................................................ 5 RESPONSIBILITIES ........................................................................................................................................................ 6 City Manager and Department Heads........................................................................................................................... 6 Safety Officer/Risk Management................................................................................................................................... 6 DICO (Designated Infection Control Officer) for Sworn Employees................................................................................ 6 DICO (Designated Infection Control Officer) for Non-Sworn Employees........................................................................ 7 Department Managers and Supervisors ........................................................................................................................ 7 Education/Training Coordination................................................................................................................................... 7 The Cities Occupational Health Care Provider................................................................................................................ 7 Employees...................................................................................................................................................................... 8 DEFINITIONS................................................................................................................................................................ 8 WORK PRACTICE PROCEDURES..................................................................................................................................12 Universal Precautions – Aerosol Transmissible and Bloodborne Pathogens................................................................ 13 Engineering Controls.................................................................................................................................................... 13 Work Practice Procedures- ATD Exposure Control ....................................................................................................... 14 Work Practice Procedures- Bloodborne Pathogen Exposure Control........................................................................... 14 Work Practice Procedures- Zoonotic Exposure Control................................................................................................ 15 Biohazardous Spill Clean-up Procedures...................................................................................................................... 16 Biohazard Containers and Labels................................................................................................................................. 16 Personal Protective Equipment.................................................................................................................................... 16 RESPIRATORY PROTECTION.......................................................................................................................................18 DISEASE VACCINATION PROGRAM ............................................................................................................................19 Required Vaccinations.................................................................................................................................................. 19 Tuberculosis (TB) Testing/Screening ............................................................................................................................ 20 POST-EXPOSURE EVALUATION AND FOLLOW-UP ......................................................................................................21 TRAINING ..................................................................................................................................................................22 3 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY DOCUMENTATION AND RECORDKEEPING .................................................................................................................23 Medical Recordkeeping................................................................................................................................................ 23 Training Records........................................................................................................................................................... 24 Additional Records....................................................................................................................................................... 24 SURGE PROCEDURES .................................................................................................................................................24 APPENDIX A: Primary/Secondary Job Classifications................................................................................................. 25 APPENDIX B: Vaccination Consent/Declination Form ................................................................................................29 APPENDIX C: Aerosol Transmissible and Communicable Disease Exposure Notification............................................32 APPENDIX D: Post Exposure Management Procedure ...............................................................................................34 APPENDIX E: Tasks Requiring Respiratory Protection from Aerosol Transmissible Disease........................................36 APPENDIX F: Biohazard Spill Kit Supplies...................................................................................................................38 APPENDIX G: Aerosol Transmissible Diseases/Pathogens..........................................................................................40 ECP1: EMS Procedures...............................................................................................................................................43 ECP2: Emergency Medical Equipment Decontamination Procedures.........................................................................45 ECP3: Police Patrol Procedures..................................................................................................................................47 ECP4: Jail ATD Case Transfer Procedures...................................................................................................................49 ECP5: Exposure Incidents Procedures........................................................................................................................51 ECP6: Biohazard Spill Clean Up Procedure.................................................................................................................54 ECP7: Animal Control Procedures..............................................................................................................................56 4 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY
INTRODUCTION AND PURPOSE
The Aerosol Transmissible, Bloodborne Pathogen and Communicable Disease Exposure Control Plan ( Henceforth known as “The Plan”) has been developed to provide guidance to the City of Santa Monica departments and employees to minimize the risk of occupationally acquired aerosol transmissible diseases (ATD’s), blood borne pathogens (BBP’s) and communicable diseases including Tuberculosis (TB). This Plan meets the California Occupational Safety and Health Administration (Cal/OSHA) requirements to develop a plan to prevent the spread of ATD’s, BBP’s, TB and other communicable diseases within the City operations.
This Plan focuses on source control, control of the environment, safe work practices and the use of respiratory protective devices when needed.
Included in the Plan are:
• A comprehensive infection prevention program to prevent transmission of all infectious agents among employees, patients, clients, and inmates.
• An on‐going employee medical surveillance program
• An employee training program
All identified City employees are responsible for complying with this Plan. Employees are strongly encouraged to comply with the TB screening and medical surveillance program, including the recommended vaccinations. Participation in the TB screening is mandatory for all employees identified to be working in at‐risk classifications (Appendix A), high‐risk facilities or in positions where compliance is determined to be mandatory.
The intent of the Plan is to eliminate or reduce employee occupational exposures to ATD’s, BBP’s, TB and/or waterborne diseases, including influenza / novel influenza, tuberculosis and other airborne viral or bacterial diseases; bloodborne diseases such as Hepatitis B Virus (HBV), Hepatitis C Virus (HCV), Human Immunodeficiency Virus (HIV), and other bloodborne diseases; Hepatitis A, a non-bloodborne disease; and Tetanus. To assure compliance with this Plan the City will:
• Provide protection for employees whose job classifications may seasonally, frequently, or occasionally place them in contact with ATD’s, BBP’s , TB and/or waterborne diseases; through universal precautions training, a voluntary vaccination program, engineering controls, work practice controls, housekeeping controls, and use of approved Personal Protective Equipment (PPE) where applicable. • Provide protection for all employees whose job classifications do not place them in contact with ATD’s, BBP’s, TB and/or waterborne diseases, but may on rare occasion encounter ATD’s, BBP’s, TB, and/or waterborne disease exposures while at work, through awareness training, including how to safeguard themselves’ in the event of ATD, BBP, TB and/or waterborne disease exposures while at work or at home.
5 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY • Provide appropriate testing, treatment, follow-up, and counseling to employees who have been exposed to ATD’s, BBP, TB and/or waterborne diseases while performing their duties for the City.
SCOPE
This Plan applies to all the City of Santa Monica’s departments which have personnel (Appendix A) who may be exposed to individuals with ATD’s, BBP’s, TB or where procedures may be utilized which would result in the spread of airway secretions in the air. It is inclusive of all full‐time, part‐time and extra‐help employees who have been identified as being at higher risk for exposure or disease than the general employee population.
Providing up-to-date information starts with initial training for all new employees and continues with annual refresher training by Risk Management for those employees in identified job classifications (Appendix A) or, by the Fire Department Designated Infection Control Officer for Sworn Fire and Police employees, or by the Aquatics Staff for the Swim Center.
The majority of job classifications at the City have little or no exposure to airborne, bloodborne, and/or waterborne diseases. Job classifications with potential for exposure to Bloodborne Pathogens or ATD’s have been identified in Appendix A. These employees will require in-depth training, a voluntary program for ATD’s, BBP’s and communicable disease vaccinations, engineering controls, work practice controls, housekeeping controls, and the use of Personal Protective Equipment (PPE), when / where applicable.
This Plan also requires that:
• Source control measures be implemented.
• Procedures for identification and isolating suspected cases be implemented. • Procedures for exposure incidents be implemented.
• Procedures for communication with employees and affected personnel regarding exposure incidents be implemented.
• Procedures be developed for those employees designated to provide services duringsurge events.
REFERENCES
California General Industry Safety Order Group 16, Article 109 • CCR Title 8 §5193. Bloodborne Pathogens.
• CCR Title 8 §5199. Aerosol Transmissible Diseases
o §5199.1
o §5199 A
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IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY o §5199 C1
o §5199 D
RESPONSIBILITIES
City Manager and Department Heads
The City Manager and Department Heads are responsible for supporting and complying with the City’s Plan and providing a safe and healthy work environment for affected employees in the department.
The responsibility for the effective implementation and maintenance of the City’s Plan include:
• Safety Officer/Risk Management
• Designated Infection Control Officer (DICO) for sworn employees • Designated Infection Control Officer (DICO) for non-sworn employees • Department Managers and Supervisors
• Education/Training Instructors at Police, Fire and Risk Management • Employees
Safety Officer/Risk Management
The Safety Officer/Risk Management Division will be responsible for the development, support, annual regulatory review and revision if necessary of the Plan.
Risk Management is responsible for:
• Updating the City of Santa Monica’s Planas changes occur. • Administering the TB screening and required vaccinations through the designated medical facility. (In coordination with Human Resources)
• Administering the medical surveillance and vaccination program for employees. • Ensuring post‐exposure follow‐ups with the Cities Occupational Health provider. • Maintaining required medical records.
• Assisting departments with the development of written ATD Exposure Control Plans.
DICO (Designated Infection Control Officer) for Sworn Employees 7 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY The EMS Educator of the Fire Department will serve as the Designated Infection Control Officer of the Plan for sworn employees at the Fire Department and Police Department. Responsibilities include liaison duties between City employees and treating medical facilities and physicians regarding ATD’s. BBP’s, TB and communicable disease exposures and post-exposure management.
DICO (Designated Infection Control Officer) for Non-Sworn Employees The Workers’ Compensation Administrator from the Risk Management Division will serve as the Designated Infection Control Officer of the Plan for non-sworn employees. Responsibilities include liaison duties between City employees and treating medical facilities and physicians regarding ATD’s, BBP’s, TB and communicable disease exposures and post-exposure management.
Department Managers and Supervisors
Department Managers and Supervisors are responsible for informing employees of the City’s Plan. When new or transferred employees are introduced into a work area that may include the possibility of exposure to blood and airborne diseases, the Supervisor will discuss the work practice controls that apply in that area. They will work directly with the Safety Officer and / or Designated Infection Control Officers to ensure that training programs, PPE, medical equipment (where applicable), and exposure control procedures are in place and available to employees. Departments will keep vaccination tracking records in their confidential employee records.
Education/Training Coordination
The Human Resources Department, Safety Officer, Fire Department and outside contractors may all contribute to employee training for the exposure control Plan. Training may be given through new employee orientation, current airborne, bloodborne, and / or waterborne disease information from handouts and booklets, safety meetings and through safety committees.
Technical training for the primary/secondary job exposure classifications will be provided by the Safety Officer, the Fire Department Designated Officer, Aquatic Staff, and/or outside consultants.
Primary/secondary job exposure classifications will be given annual refresher training on current information regarding ATD;s. BBP’s, TB and/or waterborne diseases, and regulatory changes to the law as indicated.
The Cities Occupational Health Care Provider
The City’s Occupational Health Care Provider will be responsible for:
• Notifying Public Health and Risk Management of any positive TB cases, ATD, BBP or water borne diseases.
• Providing medical follow‐up after an exposure.
• Maintaining required medical records.
8 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY • Communicating with employees’ primary medical providers.
Employees
The City employees who are listed in Appendix A are responsible for:
• Becoming familiar with the contents of the department’s Plan. • Utilizing safe and healthful work practices.
• Reporting potential exposure incidents.
• Complying with the procedures and work practices learned through training. • Compliance with medical surveillance and follow‐up procedures. • Compliance with vaccination program.
DEFINITIONS
Aerosol Transmissible Disease (ATD) means an epidemiologically significant disease that is transmitted via droplet or airborne route. A list of these diseases is included in Appendix G. When a person coughs, sneezes or speaks, particles that may contain viable aerosol transmissible pathogens are expelled from the respiratory tract of the infected person. Droplets are larger particles that fall out of the air rather quickly.
The smaller particles are carried in normal air currents and can remain airborne for prolonged periods of time (hours) until they are removed by building ventilation. Transmission occurs when a susceptible person inhales these particles containing viable pathogens. Anyone who breathes in air containing these pathogens is at risk of acquiring infection. Various City departments provide services for a population who are at high risk for ATD and BBP’s.
Airborne Infection Isolation (AII) means infection control procedures that are designed to reduce the transmission of airborne infectious pathogens. Airborne infection isolation procedures apply to patients known or suspected to be infected with epidemiologically important pathogens that can be transmitted by the airborne route.
Airborne Infection Isolation Room or Area (AIIR) means a room, area, booth, tent or other enclosure that is maintained at negative pressure to adjacent areas in order to control the spread of aerosolized M.
Tuberculosis or other airborne infectious pathogens, and that meets the requirements of title 24, Part 4, for Isolation Rooms.
Airborne Infectious Disease (AirID) Either: (1) an ATD transmitted through dissemination of airborne droplet nuclei, small particle aerosols, or dust particles containing the disease agent for which AII is recommended by the CDC or CDPH, as listed in Appendix G or (2) the disease process caused by a novel or unknown pathogen for which there is no evidence to rule out with reasonable certainty the possibility that 9 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY it is transmissible through dissemination or airborne droplet nuclei, small particle aerosols, or dust particles containing novel or unknown pathogens.
Bacille Calmette‐Guerin Vaccine (BCG) is a vaccine for TB disease. BCG is used in many countries with a high prevalence of TB to prevent TB, however, it is not generally recommended for use in the U.S. because of the variable effectiveness.
Biohazardous Material potentially contaminated with a biological agent, such as an infectious microorganism that constitutes a threat to humans or to the environment.
Bloodborne Pathogens Microorganisms present in human blood that are capable of causing disease in humans. These pathogens include, but are not limited to, hepatitis B virus (HBV), Hepatitis C virus (HCV), and Human Immunodeficiency virus (HIV).
Cal/OSHA means the California Division of Occupational Safety and Health that protects workers and the public from safety hazards.
CDC means the United States Centers for Disease Control and Prevention.
CDPH means the California Department of Public Health and its predecessor, the Department of Health Services (CDHS).
Confirmed Case means an individual who meets the definition of a confirmed case of an ATD under diagnostic criteria accepted by the CDC, CDHS or the infection control physician or other licensed health care professional.
Droplet Precautions means infection control procedures designed to reduce the risk of transmission of infectious agents through contact of the conjunctivae or mucous membranes of the nose or mouth of a susceptible person with large‐particle droplets containing microorganisms generated from a person who has a clinical disease or who is a carrier of the microorganism.
Exposure Incident means an event in which employee or other personnel has had an exposure to an individual with a diagnosed reportable disease or condition for which droplet precautions or airborne infection isolation is recommended.
Hepatitis A (Non-bloodborne disease) A viral infection of the liver caused by the hepatitis A virus (HAV).
Hepatitis A is not spread via blood. Transmission occurs through direct person-to-person contact, through exposure to contaminated water, ice, or shellfish, or from fruits, vegetables, or other foods eaten uncooked that were contaminated during harvesting. A yeast-based HAV vaccine is available for those employees in identified job classifications.
Hepatitis B is a viral infection of the liver caused by the hepatitis B virus (HBV). Hepatitis B is spread by direct or indirect contact with infected blood or other body fluids. Complications of HBV infection include cirrhosis of the liver, liver cancer, liver failure, and death. Infection from Hepatitis B can be prevented, by 10 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY taking the 3 shot series Hepatitis B vaccine. The yeast derived Hepatitis B vaccine will be offered to employees in exposure identified job classifications.
Hepatitis C is a viral infection of the liver caused by the hepatitis C virus (HCV) which is found in the blood of persons who have the disease. HCV is spread by direct or indirect contact with the blood of an infected person. Approximately 50% of infected persons develop chronic liver disease. There is no HCV vaccine available at this time.
High Hazard Procedures means procedures performed on an individual with a suspected or confirmed ATD in which the potential for being exposed to aerosol transmissible pathogens is increased due to the reasonably anticipated generation of aerosolized pathogen.
The Human Immunodeficiency Virus (HIV) is a virus that attacks the immune system and destroys its ability to fight infection. HIV that progresses to the later stages of disease is called AIDS (acquired immunodeficiency syndrome). In prospective studies of health care workers, the average risk of HIV transmission after a percutaneous exposure to HIV-infected blood has been estimated to be approximately
0.3% and after a mucous membrane exposure, approximately 0.09%. There is no FDA approved vaccine currently available for HIV.
Latent Tuberculosis Infection (LTBI) means a condition in which living M. Tuberculosis bacilli are present in the body without producing clinically active disease. Although the infected individual has a positive TB test, they may have no symptoms related to the infection and are not capable of transmitting the disease.
Local Health Officer means the health officer for the local jurisdiction responsible for receiving reports of communicable diseases, as defined in Title 17 of the California Code ofRegulations.
M. Tuberculosis means Mycobacterium Tuberculosis, the scientific name of the bacillus that causes tuberculosis.
MMR – Measles, Mumps, and Rubella are three ATD’s. There is a vaccine to protect against all three of these diseases and it is delivered by a series of 2 injections.
Negative Pressure means the relative air pressure difference between two areas. A room that is under negative pressure has lower pressure than adjacent areas, which keeps air from flowing out of the room into adjacent rooms or areas.
NIOSH means the National Institute for Occupational Safety and Health. It is the federalagency responsible for conducting research and making recommendations for the prevention of work‐ related injury and illness.
Novel or Unknown ATP means a disease or agent that meets at least one of the following criteria, i.e.: (1) it is a newly recognized pathogen, (2) it is a newly recognized variant of an existing pathogen for which there is reason to believe that the variant differs significantly in virulence or transmissibility, (3) it is a pathogen that has been recently introduced into the human population, or (4) it is an unknown pathogen; and, in addition, meets all of the following criteria: (a) it is capable of causing serious human disease, (b) there is 11 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY credible evidence that itis transmissible to humans by aerosols, and (c) there is insufficient evidence to rule out transmission of the pathogen by the airborne route.
OPIM (Other Potentially Infectious Material) Semen, vaginal secretions, cerebrospinal fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, tissue, organs, and other human body fluid (urine, feces, nasal secretions, vomitus, etc.) that is visibly contaminated with blood.
Occupational Exposure means reasonably anticipated exposure to a source of ATD under conditions that, without protective measures, create a significant risk that the exposed employee other personnel will contract the disease caused by the ATD.
Physician or Other Licensed Health Care Professional (PLHCP) means an individual whose legally permitted scope or practice (i.e., license, registration or certification) allows him or her to independently provide, or be delegated the responsibility to provide, some of or all of thehealth care services required by this section.
Rabies An infectious disease of dogs, cats, and other animals transmitted to humans by the bite of an infected animal and usually fatal if prophylactic treatment is not administered. A vaccine is available for those employees in identified job classifications.
Respiratory Protection P-100, N-100 or N-95 respirators where applicable will be the primary respirators used by employees who may be exposed to ATD’s while performing duties at work, primarily sworn Fire and Police department employees.
Referral means the directing or transferring of a possible ATD case to another facility, service or operation for the purpose of transport, diagnosis, treatment, isolation, housing or care.
Sharps (Contaminated) Contaminated Sharps are any contaminated needle, syringe, or razor type of implement.
Significant Exposure means an exposure to a source of ATD in which the circumstances of the exposure make the transmission of a disease sufficiently likely the employee will require further evaluation by a PLHCP.
Source Control means the use of procedures, engineering controls and other devices or materials to minimize the spread of airborne particles and droplets from an individual who has or exhibits signs or symptoms of having an ATD, such as persistent coughing.
Surge means a rapid expansion beyond normal services to meet the increased demand for qualified personnel, medical care, public health professionals, and all other employees required to continue continuity of operations in the event of large‐scale public health emergencies or disasters, such as in a pandemic or earthquake.
Surge Plan means the Plan that each department must prepare to operationally function during a surge event. Surge Plans deal with both increased demand for services and significant loss of staff able to work. 12 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY Suspected Case means either of the following: (1) a person whom a health care provider believes, after weighing signs, symptoms, and/or laboratory evidence, to probably have a particular disease or condition listed in Appendix G (2) a person who is considered a probable case, or an epidemiologically‐linked case, or who has supportive laboratory findings under the most recent communicable disease surveillance case definition established by CDC and published in the Morbidity and Mortality Weekly Report (MMWR) or its supplements as applied to a particular disease or condition listed in Appendix G.
TB Conversion means a change from negative to positive as indicated by TB test results and based upon current Centers for Disease Control and Prevention or CDHS guidelines.
Test for Tuberculosis Infection (TB Test) means an interferon gamma release assay (IGRAs), a blood assay for M. Tuberculosis. For the purpose of this Plan, it is limited to Quantiferon TB Gold In Tube. As newer tests come on the market, the Local Health Officer will review them for acceptability.
Tetanus is a bacterial disease that affects the nervous system. It is contracted through a cut or wound from a sharp object, like a rusty nail or knife that has tetanus bacteria from soil, dust or manure. There is a combination shot called a Td vaccine that provides protection from tetanus.
Varicella commonly known as chickenpox. Vaccine is available to protect against the Varicella virus when an employee has never been inoculated or has been previously exposed and diagnosed with Chickenpox.
Waterborne diseases that may be found in grey water, stagnant water and sewer water include cholera, polio, dysentery and Hepatitis A. Cholera for example is a bacterial infection spread by drinking dirty water or ingesting contaminated food, affecting the intestines and dehydrating its victims. Hydration that includes clean water and essential nutrients like glucose and salt is the cure.
Zoonotic Disease a disease that can be passed between animals and humans. Zoonotic diseases can be caused by viruses, bacteria, parasites and fungi. There are specific guidelines/protocols, engineering controls and training for the Animal Control Department to address the handling of animals that may be sick, euthanizing of animals and the use of PPE with emphasis on novel influenza/feral animal and bird handling.
WORK PRACTICE PROCEDURES
Specific work practices are required to be used by employees to reduce the risk of potential exposure to ATD’s and BBP’s. These procedures shall include methods to inform individuals entering the facility or otherwise in close contact with employees of the source control practices.
There are a number of areas that must be addressed in order to effectively eliminate or minimize exposure to ATD’s, BBP’s, TB and/or waterborne diseases in City operations. The City's Plan covers:
• The use of Universal Precautions and Body Substance Isolation (BSI) • Establishing appropriate Engineering Controls.
13 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY • Implementing appropriate Work Practice Procedures and Controls. o TB, and other ATD’s.
o Communicable diseases in blood and blood products (BBP’s) • Wearing the required PPE
• Implementing appropriate housekeeping procedures
Universal Precautions – Aerosol Transmissible and Bloodborne Pathogens Universal Precautions involves treating all blood, blood products and body fluids containing blood encountered on the job as if they were infectious, as well as encountering and handling persons with suspected ADT’S from chronic coughing as if they were infectious. Body substance isolation is a practice of isolating all body substances of individuals undergoing medical treatment. This includes the mandatory use of protective barriers that may include barrier creams, respirator masks, aprons, gloves, and face shields.
Engineering Controls
One of the key aspects of the Plan is the use of engineering controls to eliminate or minimize employee exposure to blood and airborne diseases. The Safety Officer works with Department Managers and Supervisors to review tasks and procedures performed by employees. Those tasks that may bring the employee into contact with blood or blood products will be evaluated to ensure that the best PPE, latest medical equipment, disinfectants, biohazard disposal, vacuums/exhausts, fume hoods, and other engineering controls are considered to eliminate or reduce employee exposure. Engineering controls may include:
• Leak proof Contaminated Sharps: containers for contaminated sharps, that are color coded and labeled with a biohazard logo.
• Contaminated Sharps are any contaminated needle, syringe, or razor type of implement. • Engineered Sharps Injury Protection delivery systems for medication administered to patients being serviced by Fire Department Paramedics.
• Hand washing facilities supplied with disinfectant cleansers, barrier creams, and/or packages of antiseptic wipes when water is unavailable.
• Environmentally controlled rooms to isolate, filter, and remove airborne contaminants or diseases. • Biohazard disposal containers are located in all affected Departments and are serviced by the City’s Biohazard Disposal vendor.
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IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY Work Practice Procedures- ATD Exposure Control
Source Control, Respiratory Hygiene, and Cough Etiquette The first line of defense to prevent ATD transmission is Source Control, Respiratory Hygiene, and Cough Etiquette. The following measures to contain respiratory secretions are recommended for all individuals with signs and symptoms of a respiratory infection. Employees, patients and detainees will be asked to comply to the best of their abilities.
• Cover the nose/mouth when coughing or sneezing.
• Use tissues to contain respiratory secretions and dispose of them in the nearest waste receptacle after use.
• Perform hand hygiene (e.g., hand washing with non‐antimicrobial soap and water, alcohol‐ based hand rub, or antiseptic handwash) after having contact with respiratory secretions and contaminated objects/materials
• Offer masks to persons who are coughing if ATD is suspected ATD Screening/Transfer/Isolation
Patients of EMS service shall be screened for ATD’s and transportation procedures shall take place as outlined in EMS Procedures (ECP1). Respiratory protection will be selected and worn according to the respiratory protection task list Appendix E.
Detained/arrested persons shall be screened for potential ATD’s. Persons suspected of having an ATD shall be transferred to the hospital or LA County jail as soon as possible. Persons awaiting transfer shall be isolated to minimize exposure and isolation precautions must be observed. Procedures are outlined in Police Patrol Procedures (ECP3) and Jail ATD Case Transfer Procedures (ECP4).
Work Practice Procedures- Bloodborne Pathogen Exposure Control Universal Precautions should be exercises whenever dealing with blood or OPIM. Upon bodily contact with blood, or products that may contain blood, like wastewater; employees are instructed to wash contact areas with soap and water, antiseptic solutions, or antiseptic wipes. If there is exposure to the eyes, nose or mouth, these areas must be irrigated thoroughly as well. Occupational Exposures should be reported and followed up according to Exposure Incidents Procedures (ECP5) Contaminated clothing and PPE must be removed and placed in a yellow biohazard bag with a red biohazard label, or container for disposal or decontamination (Also see section on PPE for further information). Emergency Medical Equipment Decontamination procedures are outlined in Emergency Medical Equipment Decontamination Procedures (ECP2).
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IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY Contaminated equipment must be inspected and tagged with a biohazardous warning label until it can be disinfected (Also see section on PPE for further information). Fire Department procedures are outlines in Emergency Medical Equipment Decontamination Procedures (ECP2).
Contaminated sharps used as medicinal delivery systems must be safely disposed of in a sharps container after use. Engineered Sharps Injury Protected devices will be used and no shearing, braking, bending, or recapping of needles is permitted. The sharps container must be disposed of when the container is or reaches 3/4 full, but in no case may the sharps container be on-site longer than 30 days.
Storage or consumption of food, application of lip balms, or eye, ear, nasal or throat medicinal products, and all cosmetics is prohibited in work areas where a potential for exposure to blood diseases may exist.
Areas where this may apply include paramedic vehicles, Police property storage room, Police jail work areas, Police ID Tech work areas, and areas containing sharps containers and other bio-hazardous waste products.
Work Practice Procedures- Zoonotic Exposure Control
The City’s Plan shall apply to zoonotic exposures. The City’s Plan will be available to all employees who may have a zoonotic occupational exposure and will include:
• Engineering controls, work practice controls, and exposure monitoring. • Procedures for the safe handling of hazardous substances, including hazardous substances used for disinfection and decontamination.
• Procedures for the application of toxic or asphyxiant gases, if such gases are to be used in the operation.
• Respiratory protection.
• PPE and protective clothing.
• Decontamination procedures.
• Disposal of animal waste and contaminated PPE.
• Medical services.
• Training.
• Recordkeeping.
Employees with an occupational exposure to a zoonotic infectious disease will be referred to a physician that is knowledgeable in zoonotic disease for evaluation. For procedures specific to Animal Control, please refer to Animal Control Procedures (ECP7).
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IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY Biohazardous Spill Clean-up Procedures
Biohazardous spill clean-up kits are stored in the custodial storage supply rooms located in all the City’s facilities for custodians to access in the event of a spill. Biohazards include human blood, semen, vaginal secretions, cerebrospinal fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, tissue, organs, and other human body fluid (urine, feces, nasal secretions, vomitus, etc.) that is visibly contaminated with blood. Procedures for cleaning up a biohazard spill are outlined in the Biohazard Spill Clean-Up Procedure (ECP6).
It is the responsibility of the custodial staff at each City facility to ensure that the biohazardous spill cleanup kit is always stocked with the appropriate supplies. (Appendix F) Fire/EMS will maintain their own field supplies.
Sharps containers must be replaced when the container becomes three-quarters full or monthly. Biohazard disposal containers are located in all affected Departments and are serviced by the City’s Biohazard Disposal vendor.
Biohazardous wastes generated from a blood clean up or medical waste other than sharps shall be disposed of properly. The container must be closable, labeled and leak-proof. Should the outside of the container become contaminated, it shall be placed in a second container that is closable, labeled and leak-proof.
Biohazard disposal containers are located in all affected Departments and are serviced by the City’s Biohazard Disposal vendor.
Biohazard Containers and Labels
Biohazard Sharps containers and biohazard bags are red in color and identified by the biohazard warning label. Containers of this regulated waste are placed in areas where blood waste may be generated, and easily accessible to employees. Disposing of blood and blood product waste from sharps containers and biohazard bags are to be handled by qualified employees.
Yellow biohazardous bags with red biohazardous labels are provided to store clothing that needs to be decontaminated. Biohazard labels may also be placed on storage sites such as Police Property Room refrigerators to warn employees when blood evidence is stored within. Storage refrigerators for blood evidence cannot store food or other consumable products.
Personal Protective Equipment
The use of disposable PPE is required to be worn by the identified job classifications when they perform tasks that involve exposure to ATD’s, BBP’s, TB or body fluids containing blood. Disposable of PPE may include but is not limited to:
• Antiseptic barrier creams or lotions
• Latex, nitrile, or vinyl gloves impervious to biohazards 17 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY • Safety glasses, goggles, and face shields
• P-100 and N-100, and N-95 respirators w/ training and fit testing • Coveralls, lab coats, and aprons impervious to bio-hazards Managers and Supervisors who have employees in the identified job classifications, susceptible to ATD’s, BBP’s, TB are responsible for ensuring that all work areas (including vehicles) have the appropriate PPE and disposal equipment available for use.
The use of respirators to protect against the transmission of ATD’s will be in full compliance with Title 8, CCR, 5144 and will require training, medical clearance, and initial and annual fit testing. Respirator selection for tasks and high hazard procedures can be referenced in Appendix E.
To ensure that PPE is not contaminated by blood, or blood products, the following work practices apply:
• All PPE is to be inspected immediately after use and disinfected, repaired, disposed of properly, or replaced as necessary.
• All PPE that has been used in the past must be inspected prior to reusing the equipment for possible contamination or defects. The PPE must be decontaminated or disposed of properly if damaged beyond use.
• Single use PPE must be removed and disposed of properly after use. Masks, shields, and aprons are to removed first, followed by removal of gloves. Gloves are to be removed properly in a manner to prevent further contamination. Gloves should be turned inside out to protect exposed skin during removal and disposed of properly.
To ensure that PPE is used properly, the following work practices apply:
• Latex, nitrile, or vinyl gloves impervious to biohazards must be worn whenever employees come upon the scene of a blood exposure, or anticipate hand contact with blood, blood products, or bodily fluids containing blood. A paramedic response call would be a time when hand contact with blood would be anticipated.
• Latex, nitrile, or vinyl gloves must be inspected when donned to make certain that the barrier is not compromised by a puncture or tear. If the barrier has been compromised, another pair of gloves must be used.
• Respirator masks, glasses, goggles and face shields must be inspected prior to use if they are not single use PPE to determine if the protection they provide is still effective and that they are free from contamination.
• Clothing that has been penetrated by blood or blood products must be removed immediately or as soon as practical to avoid contact with the skin. Clothing must be disposed of properly or 18 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY decontaminated. Saturated clothing must be disposed of in a biohazardous bag or container or stored in a yellow biohazardous bag with a red biohazardous label or container for decontamination. Soaking the garment in a 10% bleach solution will decontaminate any bloodborne pathogens present.
Laundering with hot water (at least 140° F) and detergent will also decontaminate bloodborne pathogens. Gloves should be worn when laundering contaminated articles and the contaminated articles should not be comingled with non-contaminated items.
Housekeeping Procedures
In work areas for the primary/secondary job classifications such as a Paramedic vehicle, Police vehicle, Police ID Tech Lab, Police Property Room, Police Jail, Animal Control and Santa Monica Swim Center, maintaining these areas in a clean and sanitary condition is an important part of the City’s Plan.
RESPIRATORY PROTECTION
All City departments that have employees whose occupational exposure is based on entering work settings to perform tasks that put them at risk for exposure to ATDs must include these job classifications and duties in their department ATD Exposure Control Plan. Departments must also implement and maintain an effective written Respiratory Protection Program.
Respiratory protection procedures will be required in all high‐risk work areas, such as:
• An isolation room in which a confirmed or suspected infectious ATD patient/inmate is housed or a facility where an airborne infectious disease suspect or confirmed case is known to be present. • An enclosed transport vehicle in which a suspect or confirmed case is being transported. Respiratory PPE (PPE), such as a N95 rated respirator, will be provided and used by suspect individuals being transported.
• In direct contact and close proximity of a patient undergoing high‐risk procedures. Respiratory protection is not required in the exterior areas during such procedures if the patient is located within an enclosed room or booth.
• During decontamination procedures after the person has left the isolation room or area. • In an area during the performance of aerosol generating procedures on patients and/or cadavers that are suspected of, or confirmed as, being infected with airborne infectious pathogens. • For employees who are repairing or maintaining air systems or equipment that may be anticipated to contain or generate aerosolized pathogens.
Where respirators are required, they will be NIOSH approved N95 or higher. A power air purifying respirator (PAPR) with a high efficiency particulate aerosol (HEPA) cartridge or full-face elastomeric respirator with an N, P or R 100 cartridge shall be provided to employees who conduct, or are present, during high‐hazard procedures on ATD suspect or confirmed cases. 19 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY Initial and Annual Medical Evaluations and Fit Testing must be done in accordance with Title 8, Section 5144 (e) Respiratory Protection. Please refer to the cities Respiratory Protection Program for further information on these requirements.
If an N95 is used in the care of a patient with an ATD infection, it must be disposed of after use. If using a powered air‐purifying respirator, it is to be cleaned and maintained according to the manufacturer’s recommendations.
During surges, measures should be implemented to conserve respirator supplies to an extent that is reasonably possible, including re‐donning of used respirators. All required departments under this Plan should prepare for conservation measures and take advantage of opportunities to use a wide variety of NIOSH certified respirators and obtain respirators through a variety of suppliers.
DISEASE VACCINATION PROGRAM
All employees in identified at‐risk positions (Appendix A) shall be provided with medical surveillance for ATD’s, BBP’s, TB and other aerosol transmissible pathogens.
Required Vaccinations
All employees in identified at‐risk positions will be provided the MMR, Varicella, Tetanus, Diphtheria, and Pertussis (TDAP), and seasonal flu vaccines as required by this Plan. Identified employees who do not wish to receive TDAP or seasonal flu vaccinations must sign a declination form.
Any new vaccines that may become required under the Aerosol Transmissible Diseases Standard shall be made available to employees within 120 days of the issuance of new CDC guidelines and will be included in the City’s Plan.
The City has in place a voluntary vaccination program for employees whose identified job classification (Appendix A) places them at greater risk of exposure to ATD’s or BBP’s including:
• T-Dap - Tetanus / Diphtheria / Pertussis (Whooping Cough) • Influenza / Novel influenzas
• MMR – Measles, Mumps, Rubella
• Varicella – Chicken pox
• Hepatitis A, Hepatitis B, or Hepatitis A + B combination shots (Twinrix) • Rabies
Vaccinations are offered initially within 10 working days and the employee may elect to receive at any point thereafter as long as they remain employed under one of the identified job classifications. 20 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY Employees who decline the vaccination offerings at the time of hire must sign a letter of declination. (Appendix B). Departments will keep vaccination tracking records in their confidential employee records. If for some reason a vaccine is unavailable, efforts to obtain and estimated time of availability will be documented. Availability will be checked at least every 60 days.
Tuberculosis (TB) Testing/Screening
Employees listed in the primary job classifications identified in Appendix A will receive baseline TB screening upon hire or transfer to identified job classification. Additional TB screening will be available at least annually. Employees with baseline positive TB test shall have an annual symptom screen.
Should an employee test positive for TB, they will be referred to a Physician knowledgeable about TB. The Physician will be provided with a copy of Title 8, CCR, 5199, a copy of the employee’s TB test records, and information regarding the source of infection if known.
The Physician will, with the employee’s consent, provide diagnostic tests and inform employee of treatment options.
If the Physician finds that the employee is a TB case or suspected case they will be asked to:
• Inform the employee and the County Health Officer
• Inform the City of any infection control recommendations related to the employee’s activity in the workplace
• Make recommendations regarding precautionary removal from work • Provide a written opinion as described in the “Post-Exposure Evaluation and Follow-Up” section below Positive TB conversions will be recorded and will be investigated if found to be occupational exposures.
The following procedures will be followed for employees who are at‐risk of exposure to TB:
• 1 to 2-year TB screening will be administered and interpreted in accordance with current U.S. Public Health Services recommendations and will be recorded in the employee health record at the cities Occupational Health Clinic
• If an employee chooses to have the TB screening performed by his/her personal physician,they must have an approved TB test as defined in the definition section. • Employees who provide written documentation of a previously positive reaction must still have an approved TB test as defined in the definition section.
• For those requiring chest x‐rays, if the chest x‐ray shows evidence of old or new TB, employment shall be deferred until such time as clearance is obtained from the cities Occupational Health Physician. 21 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY • If an annual TB screening is reported as positive, and the prior screening results have been negative, then a chest x‐ray will be performed and follow‐up treatment will be provided through an infectious disease practitioner, according to the U.S. Public Health Services guidelines. • Employees with a history of a positive TB screening should complete a TB evaluation and questionnaire form during their scheduled TB screening.
• Employees with active pulmonary or laryngeal TB will be excluded from work until documentation has been provided from the treating physician that the staff member is determined to be no longer infectious. Employees must return to work with the above documentation from the cities Occupational Health Care Provider. An evaluation by the Occupational Health Physician and clearance from the Public Health Department will be required prior to returning to work.
POST-EXPOSURE EVALUATION AND FOLLOW-UP
In the event of an occupational exposure, the roles and procedures are outlined in Exposure Incidents Procedures (ECP5) The treating physician will be provided a copy of Title 8, CCR, Section 5193 or 5199, a description of the employee’s duties and circumstances of exposure related to the incident, the employee’s vaccination history, and the sources blood test results if available (in the case of Fire Dept. or Police Dept. exposures, the Designated Officer will act as a liaison for obtaining the source’s blood test).
If an employee is involved in an incident where they are exposed to ATD’s, BBP’s, TB as determined by a treating physician based on the facts of the incident, testing, post exposure prophylaxis and counseling will be made available to the employee.
The City will obtain and provide the employee with a copy of the treating physician’s written opinion within 15 days of the post-exposure evaluation. The written opinion will consist of the need for Hepatitis vaccination, and if employee has received such vaccination, statement indicating the employee has been informed of the results of the evaluation, and verification that the employee has been told of any medical conditions resulting from the exposure that will require further evaluation or treatment. For suspected ATD exposures, recommendations for precautionary removal from assignment will be included. All other findings and diagnoses shall remain confidential and will not be included in the written opinion.
Documentation is important, and a number of forms must be completed including:
• The Aerosol Transmissible and Communicable Disease Exposure and Notification Report (Appendix C) are available from Departments that have primary job classifications, in Police squad cars, in Fire Department vehicles, or through Risk Management. This report and other workers’ compensation reports generated will remain confidential.
• Employee workers’ compensation claim forms, available through the employee’s Supervisor. In order for the City to provide prompt follow up on possible blood and airborne disease exposures, it is the employee’s responsibility to completely fill out this form detailing the circumstances surrounding the exposure.
22 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY • Supervisor Report of Accident Investigation Employee Injury/Illness form is available on-line or internally through the Department or Division. The Supervisor will complete this form after investigating the circumstances surrounding the exposure.
TRAINING
All identified employees under the City’s Plan will participate in a training program at no cost to them and during working hours. Training shall be provided at the time of initial assignment and at least every two years thereafter. Material appropriate in content and vocabulary to the educational level, literacy and language of the employee shall be used. Training will be individualized to the department and or division and will be documented in LMS.
The training program shall contain, at a minimum, the following elements:
• An explanation of the appropriate methods for recognizing tasks and other activities that may expose the employee to ATDs and BBP’s.
• An explanation of the basis for selection of PPE, its uses and limitations and the types, proper use, location, removal handling, cleaning, decontamination and disposal of the items of PPE employees will use.
• Information on the employer’s surge Plan as it pertains to the duty’s employees willperform. • An explanation of the City’s Plan, including the employer’s and employee’s responsibility under this Plan and the means by which an employee canobtain a copy of the written Plan. • Job titles and work tasks in their departments that are at‐risk for occupational exposure to ATDs and BBP’s.
• The basic concepts of transmission and symptoms of ATD’s including the differences between TB infection and active TB disease, and how to minimize infection risk factors. Information on available vaccines for ATD’s and BBP’s and the benefits of being vaccinated. • Use and limitations of methods to prevent exposure, including the hierarchy of infection control measures focusing on source control, safe work practice habits and situations with increased risk of exposure to ATD’s, BBP’s, TB and other communicable diseases, engineering controls and PPE. Site‐ specific control measures will be provided as needed.
• TB screening and chemoprophylaxis, including the significance of a positive result, the requirement for participating in the process, the principles of drug therapy, the difficulty of treating drug‐resistant TB, and the role of incomplete medical treatment in the development of drug‐resistant TB. • Information regarding appropriate actions to take in the event of an emergency orexposure incident. • Information on available vaccines and that they will be offered free of charge. 23 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY • An explanation of the basis for selection of personal equipment in accordance with Section 5144 for those people whose assignments include use of respirators. • An opportunity for interactive questions and answers with the person conducting thetraining session.
The person conducting the training shall be knowledgeable in the subject matter covered in the training program as it relates to the workplace. Training, or a portion of the training, may be made available online but must include department specific information.
DOCUMENTATION AND RECORDKEEPING
Medical Recordkeeping
The Risk Management Division will maintain all medical records pertaining to exposures in confidence.
Medical records will only be released with the consent of the employee involved in the exposure or as required by law.
A Sharps Injury Log will be maintained by Risk Management as a record of each exposure incident involving a sharp and logged within 14 days of notice.
Date and time of the exposure incident
Type and brand of sharp involved in the exposure incident Description of the incident including:
- The job classification of exposed employee
- The Department / Division of exposed employee
- The work area where the exposure occurred
- The procedure was the employee was performing at time of incident - How the incident occurred
- The body part involved in the exposure incident
- Engineered sharp protective mechanism used
- Employee’s opinion if engineering, administrative, or work practice controls could have prevented the injury.
- Other medical records regarding vaccination histories, annual physical examinations, or other medical information will be stored confidentially at Risk Management.
Records will be retained as follows:
24 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY • Training records kept on file for 3 years
• Annual Exposure Control Plan review and summary kept on file for 3 years • Vaccination records kept on file for 30 years plus length of employment • Records of post-exposure examination, testing and follow up, and Physician’s written opinion will be kept on file for 30 years plus length of employment
• Sharps injury log entries will be maintained for 5 years from incident • Flu Vaccination declination will be kept on file for current year Training Records
Departments will maintain and keep on file all ATD Exposure Control Plan training records and send a copy to Risk Management.
Training records will include the following information:
• Dates of training sessions.
• Course outline, content or summary of training sessions. • Names and qualifications of instructors; and names and job categories of persons attending the training.
Additional Records
• Risk Management will maintain medical surveillance records of employees as well as post‐exposure records, including copies of the Employee Claim Form, the Supervisor’s Report, and the Employer’s First Report of Work Injury and proof of medical follow‐up as required by the ATD Plan. • Public Health, if involved, will maintain records pertaining to the contact investigation. • Records of the unavailability of vaccines, isolation rooms and decisions not to transfer patients to another facility shall also be maintained for three years.
Departments will maintain other records of implementation of the ATD and Communicable Diseases Plan, such as the annual review, the person(s) conducting the review, the date the review was conducted and completed, employees involved and a summary of the conclusions.
SURGE PROCEDURES
See the Santa Monica Fire Department Multiple Casualty Incident Management Plan 25 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY APPENDIX A: Primary/Secondary Job Classifications
26 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY Appendix A: Primary Job Classifications based on regular job exposures to multiple aerosol transmissible and blood-borne diseases Job Classifications Potential Exposure Tasks
Asst Fire Marshal Medical Care
Asst Fire Marshal-Haz Mat Medical Care
Battalion Chief - Prevention Medical Care
Battalion Chief - Suppression Medical Care
Community Services Officer First Aid, Jail housing
Deputy Fire Chief Medical Care
Deputy Police Chief First Aid, Transportation, Jail housing Fire Captain Medical Care
Fire Chief Medical Care
Fire Engineer Medical Care
Fire Inspector Medical Care
Fire Marshal Medical Care
Firefighter Medical Care
Firefighter - Lateral Transfer Medical Care
Firefighter Recruit Medical Care
Forensic Section Supervisor Evidence collection, Domicile investigation Forensic Specialist Evidence collection, Domicile investigation Forensic Technician Evidence collection, Domicile investigation Jail Management Supervisor First Aid, Jail housing
Jail Services Attendant Custodial, First Aid, Jail housing Jailer First Aid, Jail housing
Lead Community Svs Officer II First Aid, Jail housing
Lead Forensic Specialist Evidence collection, Domicile investigation Lead Jailer First Aid, Jail housing
Pier & Harbor Services Officer First Aid, Transportation, Jail housing Police Captain First Aid, Transportation, Jail housing
Police Chief First Aid, Transportation, Jail housing
Police Lieutenant First Aid, Transportation, Jail housing Police Officer First Aid, Transportation, Jail housing
Police Officer - Pre-service First Aid, Transportation, Jail housing Police Officer-Lateral Transfer First Aid, Transportation, Jail housing Police Officer-Trainee First Aid, Transportation, Jail housing Police Sergeant First Aid, Transportation, Jail housing Public Services Administrator -- Forensics Evidence collection, Domicile investigation Public Services Administrator -- Jail First Aid, Jail housing Sr Fire Inspector Medical Care
27 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY Appendix A: Secondary Job Classifications based on
job exposures to blood-borne diseases
Job Classification Potential Exposure Task
Airport Maintenance Crew Ldr Custodial, Refuse related
Airport Maintenance Worker Custodial, Refuse related
Aquatics Maintenance Worker Custodial, Refuse related
Aquatic Site Supervisor First Aid
Aquatics Program Coord A/N First Aid
Beach Maintenance Supervisor First Aid
Beach Recreation Ldr As-Needed First Aid
Beach Recreation Supervisor First Aid
Chief Pool Lifeguard First Aid
Community & Cult Svs Asst A/N First Aid
Community & Cult Svs Leader First Aid
Community Svs Pgm Supv First Aid
Community Svs Pgm Supv-Cmty Sp First Aid
Community Svs Pgm Supv-Therapt First Aid
Community Svs Pgm Supv-Volunt First Aid
Community Svs Pgm Supv-Youth First Aid
Community Svs Program Coord First Aid
Community Svs Program Spec First Aid
Cultural Affairs Coord First Aid
Custodial Supervisor Custodial, Refuse related
Custodian I Custodial, Refuse related
Custodian II Custodial, Refuse related
Equipment Operator I Custodial, Refuse related
Equipment Operator II Custodial, Refuse related
Event Attendant II Custodial, Refuse related
Facilities Attendant Custodial, Refuse related
Funeral Services Technician Handling of corpse
Groundskeeper Custodial, Refuse related
Irrigation Crew Leader Custodial, Refuse related
Irrigation Technician Custodial, Refuse related
Jr Lifeguard First Aid
Laborer Trainee Custodial, Plumbing, Refuse related
Lead Motor Coach Cleaner Custodial, Refuse related
Lead Public Services Officer First Aid
Library Services Officer First Aid
Library Services Officer Supv First Aid
Maintenance Crew Leader Custodial, Refuse related
Maintenance Worker Custodial, Refuse related
Mechanic I Refuse vehicle maintenance
Mechanic II Refuse vehicle maintenance
28 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY Motor Coach Cleaner Custodial, Refuse related
Parks Maintenance Crew Leader Custodial, Refuse related Pier Maintenance Worker Custodial, Plumbing, Refuse related Plumber Plumbing
Plumber Crew Leader Plumbing
Police Property Evidence Clerk Handling of evidence
Pool Lifeguard First Aid
Pr Community Svs Sup-Aquatics First Aid
Promenade Maintenance Supv Custodial, Refuse related
Property/Evidence Supervisor Handling of evidence
Public Services Officer First Aid
Public Services Officer Supervisor First Aid
Resource Rec & Recyc Crw Ldr Custodial, Refuse related
Resource Rec & Recyc Equip Op Custodial, Refuse related Resource Rec & Recyc Supv Custodial, Refuse related
Sewer Maintenance Worker I Sewage
Sewer Maintenance Worker II Sewage
Sr Mechanic Refuse vehicle maintenance
Sr Transit Maintenance Worker Custodial, Refuse related Sr Water Resources Protect Spc Sewage
Swim Instructor/Lifeguard First Aid
Trades Intern Custodial, Plumbing, Refuse related
Traffic Services Officer First Aid
Traffic Services Supervisor First Aid
Transit Maintenance Worker Custodial, Refuse related
Wastewater Crew Leader Sewage
Wastewater Supervisor Sewage
Wastewater Treatment Plant Opr Sewage
Water Resources Protect Pgm Cd Sewage
Water Resources Protection Spc Sewage
Welder Fabricator Refuse vehicle maintenance
29 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY APPENDIX B: Vaccination Consent/Declination Form
30 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY Appendix B: Cal OSHA Vaccination Program Consent/Declination Form Aerosol Transmissible Diseases, Bloodborne Diseases and OPIMs Primary or “P” Classification
I understand that due to my potential occupational exposure to aerosol transmissible diseases (ATDs), bloodborne diseases, and other potentially infectious materials (OPIMs), I may be at risk of acquiring:
Hepatitis A and/or B, measles, mumps, rubella, tetanus, diphtheria, pertussis, and varicella (chicken pox). I have been given the opportunity to be vaccinated against these diseases or pathogens at City expense. If I decline the vaccinations at this time, I understand that I continue to be at risk of acquiring the diseases identified above. I also understand that: 1) several of the vaccinations require multiple doses over a prescribed period of time to be effective; 2) each vaccination dose must be administered by the City’s medical provider; and 3) if I leave City employment prior to receiving the required doses, the City will not pay for the remaining vaccinations. Finally, I understand that if, in the future, I continue to have occupational exposures to ATDs, bloodborne diseases, and/or OPIMs, I can request the desired vaccinations and they will be provided to me at City expense.
At this time, I choose to:
• Hepatitis A only (requires two doses):
□ Accept □ Decline
1st Vaccine _______________ 2nd Vaccine ____________________(6 mo after 1st vaccine) • Hepatitis B only (requires three doses):
□ Accept □ Decline
1st Vaccine_______________ 2nd Vaccine _____________________ 3rd Vaccine __________________ (1 mo after 1st vaccine) (6 mo after 1st vaccine)
• Hepatitis A & B -- Twinrix (requires three doses):
□ Accept □ Decline
1st Vaccine_____________ 2nd Vaccine _______________ 3rd Vaccine ___________________ (1 mo after 1st vaccine) (6 mo after 1st vaccine)
• Tetanus, Diphtheria & Pertussis -- Tdap (requires one dose):
□ Accept □ Decline
1st Vaccine: _______________
31 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY Appendix B Consent/Declination Form Page 2
ATDs, Bloodborne Diseases and OPIMs
• Measles, Mumps & Rubella -- MMR (a)
□ Accept □ Decline
1st Vaccine _______________ 2nd Vaccine _____________________ (1 mo after 1st vaccine) (a) sworn fire personnel and Pier and Harbor Patrol Officers receive two doses; all other classification receives one dose
• Vericella – Chicken Pox (requires two doses):
□ Accept □ Decline
1st Vaccine _______________ 2nd Vaccine _____________________ (1 mo after 1st vaccine)
____________________________________ ___________________________________________ Employee Name (Please Print) Employee Signature
____________________________________
Date
If under 18 years of age:
____________________________________ ___________________________________________ Parent/Guardian Name (Please Print) Parent/Guardian Signature ____________________________________
Date
Instructions to Medical Clinic
(1) Please set appointments for follow-up vaccinations prior to employee leaving facility (2) Retain one copy of this form for employee medical file, provide one copy to employee, and return one copy to City Safety Officer
Instructions to Risk Management
(1) Please send one copy of form to Human Resources
32 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY APPENDIX C: Aerosol Transmissible and Communicable Disease Exposure Notification
33 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY Appendix C Aerosol Transmissible and Communicable
Disease Exposure Notification
34 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY APPENDIX D: Post Exposure Management Procedure
35 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY Appendix D: Post Exposure Management Procedure
Request to Medical Facility for Source Patient Testing
The Santa Monica Fire and Police Departments request that the following tests be ordered on any source patient involved in an occupational exposure to blood and/or body fluids to our personnel.
1. Hepatitis B Antigen
2. Hepatitis C Antibody
3. Rapid HIV if available
4. HIV 1 & 2 Antibody
Dr. Wally Ghurabi, Medical Director
Jodi Nevandro MSN, RN, Designated Infection Control Officer Office: 310-458-4929
Pager: 310-201-1071
36 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY APPENDIX E: Tasks Requiring Respiratory Protection from Aerosol Transmissible Disease
37 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY Appendix E: Tasks Requiring Respiratory Protection
from Aerosol Transmissible Diseases
Job Classifications Tasks Protection
Police and Jail • Temporary detention or
transportation of persons
reasonably anticipated to be
suspected ATD’s cases.
• Cleaning/disinfecting area
N95 face mask
Animal Control • Handling of unusually high
bird mortality event
• Entering animal isolation
area
• Handling of animals
suspected of upper
respiratory disease
• Cleaning/disinfecting area
• Exposure to animals giving
birth or associated fluids
N95 face mask
(Half Face with N95 or P100
filters if working with diseased
animals in enclosed areas)
Fire/EMS • Paramedic and medical
transport of persons
reasonably anticipated to be
suspected ATD’s cases.
• Cleaning/disinfecting area
N95 face mask
Fire /EMS High Hazard Procedures:
• Intubation
• Manual ventilation
• Non-invasive ventilation
(e.g., BiPAP, BPAP)
• Tracheostomy insertion
PAPR, N-100, R-100, P-100
38 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY APPENDIX F: Biohazard Spill Kit Supplies
39 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY Appendix F: Biohazard Spill Kit Supplies
Each Biohazardous Spill Clean-up Kit in custodial storage supply room will contain at all times:
• 1 box each of latex and nitrile gloves
• 3 reams of paper towels
• 2-quart sized spray bottles of City approved biocide (1) • 1 leak proof apron
• 1 face shield
• 1 pair of goggles
• 3 Red Bio-bags (2)
• 1 set of tongs
• 1 hand broom / brush w/ plastic dustpan
• 1 plastic scooping device
• 1 extended arm gripping tool
• 1 sharps container (3)
(1) Can be purchased locally
(2) Can be purchased locally
(3) Can be purchased locally or from Fire Department
40 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY APPENDIX G: Aerosol Transmissible Diseases/Pathogens
41 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY Appendix G: Aerosol Transmissible Diseases/Pathogens
This appendix contains a list of diseases and pathogens which are to be considered aerosol transmissible pathogens or diseases for the purpose of Section 5199. Employers are required to provide the protections required by Section 5199 according to whether the disease or pathogen requires airborne infection isolation or droplet precautions as indicated by the two lists below.
Diseases/Pathogens Requiring Airborne Infection Isolation Aerosolizable spore-containing powder or other substance that is capable of causing serious human disease, e.g. Anthrax/Bacillus anthracis
Avian influenza/Avian influenza A viruses (strains capable of causing serious disease in humans) Varicella disease (chickenpox, shingles)/Varicella zoster and Herpes zoster viruses, disseminated disease in any patient. Localized disease in immunocompromised patient until disseminated infection ruled out
Measles (rubeola)/Measles virus
Monkeypox/Monkeypox virus
Novel or unknown pathogens
Severe acute respiratory syndrome (SARS)
Smallpox (variola)/Varioloa virus
Tuberculosis (TB)/Mycobacterium tuberculosis -- Extrapulmonary, draining lesion; Pulmonary or laryngeal disease, confirmed; Pulmonary or laryngeal disease, suspected Any other disease for which public health guidelines recommend airborne infection isolation Diseases/Pathogens Requiring Droplet Precautions
Diphtheria pharyngeal
Epiglottitis, due to Haemophilus influenzae type b
Haemophilus influenzae Serotype b (Hib) disease/Haemophilus influenzae serotype b, Infants and children
Influenza, human (typical seasonal variations)/influenza viruses Meningitis
Haemophilus influenzae, type b known or suspected
Neisseria meningitidis (meningococcal) known or suspected Meningococcal disease sepsis, pneumonia (see also meningitis) Mumps (infectious parotitis)/Mumps virus
Mycoplasmal pneumonia
Parvovirus B19 infection (erythema infectiosum)
Pertussis (whooping cough)
Pharyngitis in infants and young children/Adenovirus, Orthomyxoviridae, Epstein-Barr virus, Herpes simplex virus,
Pneumonia
Adenovirus
Haemophilus influenzae Serotype b, infants and children Meningococcal
Mycoplasma, primary atypical
Streptococcus Group A
Pneumonic plague/Yersinia pestis
Rubella virus infection (German measles)/Rubella virus
Severe acute respiratory syndrome (SARS)
42 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY Streptococcal disease (group A streptococcus)
Skin, wound or burn, Major
Pharyngitis in infants and young children
Pneumonia
Scarlet fever in infants and young children
Serious invasive disease
Viral hemorrhagic fevers due to Lassa, Ebola, Marburg, Crimean-Congo fever viruses (airborne infection isolation and respirator use may be required for aerosol-generating procedures) Any other disease for which public health guidelines recommend droplet precautions 43 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY ECP1: EMS Procedures
44 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY ECP1 EMS Procedures
1. Pre‐response/pre‐patient contact
a. Ensure you have all supplies and equipment available. i. Follow Department PPE resupply and stocking policies and/or procedures. b. Ensure PPE and supplies and equipment are stored in designated locations on vehicles.
2. Initial Contact
a. Use Body Substance Isolation (BSI)
b. Stand 6 feet from patient, assess, and don appropriate PPE i. Visible blood, body fluids, or OPIM = Gloves and Eye protection at minimum ii. Flu‐like symptoms or fever = Gloves, Eye protection, N95 at minimum c. When respiratory protection is required, follow these criteria:
i. Minimum respiratory protection for ATD exposure is N95 mask ii. High hazard procedures for ATD exposure require N100 d. Offer masks to persons who are coughing or show flu‐like symptoms i. For most situations offer a surgical mask surgical mask only N-95 protects patient from provider
ii. Consider non‐rebreather O2 mask for patients requiring O2 e. Perform normal patient care procedures
i. Monitor to ensure the mask will not negatively impact the patient ii. Avoid unnecessary aerosol producing procedures
iii. Utilize employee ‐recommended and selected needle protection and engineered sharps controls
iv. Perform safe handling and disposal of blood, OPIM, and sharps v. Perform all procedures involving blood or OPIM to minimize splashing, spraying, splattering, and generation of droplets of these substances
f. Properly remove and dispose of contaminated PPE
g. Use alcohol based hand rub and Wash hands after removing PPE
3. Transport
a. For patients with any of the following exposures:
i. Visible blood, body fluids, or OPIM
ii. Flu‐like symptoms or fever
iii. Pertinent history indicating possibility of infection with BBP or ATD b. Continue to wear appropriate PPE
c. Alert receiving facility of potential ATD cases
d. If feasible, open windows and allow outdoor air ventilation e. Avoid unnecessary aerosol producing procedures
4. Post Response Procedures
a. Follow procedures for any potential exposures
b. Decontaminate vehicle and equipment
c. Decontaminate clothing
d. Dispose of Medical Waste properly
45 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY ECP2: Emergency Medical Equipment Decontamination Procedures 46 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY ECP2: Emergency Medical Equipment Decontamination Procedures
1. Disinfecting Facilities
a. Shall be separate from the kitchen, living, sleeping, and personal hygiene areas i. Shall be lighted
ii. Shall be vented to outside
iii. Shall be fitted with floor drains to a sanitary sewer iv. Shall be designed to prevent contamination of other areas of the station b. Should have racks or shelving to drip dry equipment, made of non-porous materials c. Should have a washer and dryer dedicated to the sole purpose of cleaning protective ensembles and contaminated uniforms
i. Employees should not take contaminated items home to be washed or into other areas of Fire Station
ii. Non-contaminated laundry must be washed in separate washer and dryer located in an area that is remote from the disinfecting area
2. Contaminated clothing or Reusable PPE
a. Doff contaminated equipment and dispose of in red Biohazard bag or transport in yellow Biohazard bag for decontamination
b. Wash contaminated clothing or turnouts in designated washer and dryer using approved detergent
i. Wear gloves when handling contaminated laundry and wash hands when finished c. Non-porous reusable PPE (i.e., boots, helmet) should be wiped of bulk matter and disinfected with approved disinfecting solution
i. Wear gloves at minimum when disinfecting contaminated PPE ii. Allow for manufacturer recommended contact time for disinfection iii. Properly remove and dispose of contaminated PPE, wash hands
3. Contaminated vehicle or equipment
a. Use gloves, eye protection, and apron
b. Assure proper ventilation
c. Remove all bulk matter with soap and water or approved disinfectant i. All runoff should be drained to a sanitary sewer
d. Apply additional round of disinfectant and allow for manufacturer recommended contact time for disinfection
e. Make sure to use disinfectants that are chemically compatible when disinfecting metal or electrical surfaces
f. Properly remove and dispose of contaminated PPE
g. Wash hands after removing PPE
4. Sanitizing equipment
a. Reusable emergency medical equipment that comes in contact with mucous membranes shall require cleaning and a high level disinfection or sterilization in accordance with the equipment manufacturer’s instructions after each use
47 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY ECP3: Police Patrol Procedures
48 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY ECP3: Police Patrol Procedures
1. Pre‐response/pre‐patient contact
a. Ensure you have all supplies and equipment available. i. Follow Department PPE resupply and stocking policies and/or procedures. b. Ensure PPE and supplies and equipment are stored in designated locations on vehicles.
2. Initial Contact
a. Use universal precautions
b. When feasible, stand 6 feet from detainee/patient, assess, and don appropriate PPE i. Visible blood, body fluids, or OPIM = Gloves and Eye protection at minimum ii. Flu‐like symptoms or fever = Gloves, Eye protection, N95 at minimum c. Perform normal Police procedures
i. Question detainees about ATD’s if signs of illness and be cautious of sharps ii. Perform safe handling and disposal of blood, OPIM, and sharps iii. Perform all procedures involving blood or OPIM to minimize splashing, spraying, splattering, and generation of droplets of these substances iv. Request donning of surgical mask or N95 to persons who are coughing or show flu‐like symptoms
d. Properly remove and dispose of contaminated PPE
e. Wash hands after removing PPE
3. Transport
a. For detainees with any of the following exposures:
i. Visible blood, body fluids, or OPIM
ii. Flu‐like symptoms or fever
iii. Pertinent history indicating possibility of infection with BBP or ATD b. Continue to wear appropriate PPE
c. Alert receiving facility of potential ATD cases
d. If feasible, open windows and allow outdoor air ventilation if suspected ATD e. Avoid unnecessary aerosol producing procedures
4. Post Response Procedures
a. Follow procedures for any potential exposures
b. Contaminated vehicle
i. Isolate vehicle and note/display why it is out of service ii. Contact vehicle maintenance for decontamination service provided by vendor c. Contaminated equipment
i. Wear gloves and wipe off bulk of potentially infectious material, followed by City approved disinfectant for established contact time
ii. If unable to decontaminate, see supervisor for disposal and replacement d. Contaminated clothing
i. Place in biohazard labeled bag, contact watch commander for dry cleaner authorization, drop off at SMPD authorized dry cleaning provider e. Dispose of Medical Waste properly
49 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY ECP4: Jail ATD Case Transfer Procedures
50 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY ECP4: Jail ATD Case Transfer Procedures
1. Screening for Aerosol Transmissible Disease
a. Transfer of arrestee should be coordinated if any of the following apply i. Have a cough for more than 3 weeks that is not explained by non-infectious condition (Suspect TB if they answer yes to the questions below)
1. Unexplained weight loss (>5lbs)?
2. Night sweats?
3. Fever?
4. Chronic fatigue?
5. Coughing up blood?
ii. Exhibit flu-like symptoms from March- October (non- flu season) iii. State that they have an ATD other than a cold or the flu iv. State they have been exposed to an infectious ATD case other than flu v. Severe coughing spasms, especially if persistent; coughing fits may interfere with eating, drinking and breathing
vi. Fever, headache, muscle aches, tiredness, poor appetite followed by painful, swollen salivary glands, one side or both sides of face under jaw vii. Fever, chills, cough, runny nose, watery eyes associated with onset of an unexplained rash (diffuse rash or blister-type skin rash)
viii. Fever, headache, stiff neck, possibly mental status changes
2. Isolation
a. Suspected ATD case should be isolated in an individual cell b. Employee contact should be minimal and proper PPE worn (N95 and gloves minimum) if entering cell
c. Proper hand washing and disinfecting procedures used
3. Transfer
a. Transfer shall take place within 5 hours of identifying suspected ATD case i. If identification happens between the hours of 3:30 pm and 7:00 am, arrestee must be transferred no later than 11:00 am.
b. Notify County Health Services‐Public Health Division, and Receiving Facility of ATD case c. Attempt to have arrestee wear surgical mask or N95
d. If arrestee is transferred in patrol car, officers shall drive with windows down and N95 mask
4. Post Transfer Procedures
a. DICO will evaluate significant exposures and refer employees with significant exposure for medical evaluation within 72 hours. DICO will also notify other facilities of possible employee contact if known
b. Follow procedures for any potential exposures
c. Decontaminate vehicle and cell
d. Decontaminate clothing
e. Dispose of Medical Waste properly
51 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY ECP5: Exposure Incidents Procedures
52 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY ECP5: Exposure Incidents Procedures
1. Exposed Employee Procedure
a. In the case of an Occupational Exposure, notify Supervisor and Designated Infection Control Officer (DICO) immediately and proceed to Emergency Room b. For Police and Fire Occupational exposures where the Source Individual is known i. Go to the receiving facility where the source patient is transported ii. Notify the receiving facility of the potential exposure when the source patient arrives
c. If a suspected ATD exposure has occurred, notify County Health Services‐Public Health Division of the exposure incident
d. Receive a post‐exposure medical evaluation by a Physician as soon as feasible after determination of a significant exposure
i. Provide the Physician with the completed Exposure Report Form ii. Employee shall follow treatment and monitoring as prescribed by the Physician
2. Designated Infection Control Officer(DICO) Procedure a. For BBP exposures, determine occupational exposure and proceed to step “d.” b. Upon notification of an ATD exposure incident:
i. Determine if the exposure incident is a “Significant Exposure” within a timeframe that is reasonable for the specific disease, but not more than 72 hours of notification of the incident and retain the exposure analysis for future reference. ii. Document employees included in the analysis and reasons why they are or are not included in the post exposure follow up, and the name of the person and Physician making this determination.
c. Notify employees who are determined to have had a “Significant Exposure” to an ATD of the date, time and nature of the exposure. Ensure that these employees receive a post exposure medical exam.
d. Assure that the Physician has a copy of CCR, Title 8, Section 5193 or 5199, a description of the employee’s duties and circumstances of exposure related to the incident, the employee’s vaccination history, and the sources blood test results if available e. In the case of suspected ATD, Ensure the County Health Services‐Public Health Division has been notified of the exposure incident
f. Contact the receiving hospital to follow‐up regarding the employee’s involvement in a potential exposure incident.
i. Request ATD and/or BBP testing of the exposed individual ii. If exposure involved Police or Fire personnel, request ATD and/or BBP testing of the source patient
g. Determine if a court order is needed for source patient testing 53 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY h. Obtain the Physician’s recommendation regarding precautionary removal from duty, to be followed by their written opinion.
3. Exposed Employee’s Manager Procedure
a. If notified of a significant exposure, complete and submit any required Worker’s Compensation forms, as well as Supervisor’s Report of Incident b. Ensure the employee has received the Physician’s recommendations regarding precautionary removal from duties/work and a written opinion within 15 days of completion of all medical evaluation
4. Exposure incidents involving employees from other employers a. DICO shall determine whether personnel from any other employers may have been exposed.
b. DICO or representative shall notify these other employers within a time frame that is reasonable for the specific disease, but in no case later than 72 hours of becoming aware of the exposure incident of the nature, date, and time of the exposure, c. DICO shall provide the contact information for the diagnosing Physician d. DICO shall not provide the identity of the source patient to other employers. 54 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY ECP6: Biohazard Spill Clean Up Procedure
55 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY ECP6: Biohazard Spill Clean Up Procedure
1. Spill Discovery
a. Notify your Supervisor immediately. Secure the spill area by posting signs, flagging the area and/or or using barricade tape to secure the area.
b. Once the spill area is secured, only authorized personnel (i.e., custodial staff, fire personnel, or the Safety Officer) with appropriate PPE can enter the spill site. c. Determine the size of the spill.
i. If the spill is less than or equal to two square feet, the custodian will clean up the spill using the Biohazardous spill clean-up procedures noted below. ii. If the spill is larger than two square feet, the custodian will immediately contact the Fire Department – Hazardous Materials Team at 310-458-8671 or 911 to handle the clean-up. The custodian will remain at the spill site until the Fire Department arrives to insure no one is allowed to enter the spill area.
2. Clean-Up
a. Go to the custodian storage supply room and get the Biohazardous spill clean-up kit. b. Open the kit and put on the gloves (latex or nitrile) to protect your hands. Use additional personal protection equipment, as needed (e.g., leak-proof apron, long sleeved arm protection, face shield, goggles, etc.). Goggles must be worn when the possibility of blood splashes can occur.
c. Place absorbent towels over the spill and apply the biocide solution contained in the spill kit to the towels until biocide solution has saturated the towels and soaked the spill. Let the biocide solution soak on the spill for at least ten minutes.
d. Place all contaminated towels and waste into a Red Bio-Bag or other appropriate sealed and labeled (Biohazard symbol or label), leak-proof container located in the spill kit. This is regulated waste.
e. Once the bulk of the spill has been absorbed, apply additional biocide solution to spill area and let sit for at least 10 minutes before wiping up.
f. If the Biohazardous spill clean-up involves sharps, needles or syringes, remove these items with the appropriate tool(s) (e.g., tongs, hand broom/brush, dust pan, scoop, or other extended arm gripping tool located in the spill kit) and place them into the sharps container (located in the spill kit) and secure the lid.
3. Post Clean Up
a. Promptly disinfect (using the biocide solution) all cleaning equipment and reusable PPE. b. Wash hands and arms up to your elbows in warm soapy water, rinse, and wash again. c. Biohazard disposal containers (for red bags or sharps containers) are located in all affected Departments and are serviced by the City’s Biohazard Disposal vendor. d. Follow procedures for any potential exposures
56 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY ECP7: Animal Control Procedures
57 This document is the property of the City of Santa Monica and will not be copied, reproduced, or used for any purpose without written permission.
IF PRINTED AND UNCONTROLLED, THIS DOCUMENT IS FOR REFERENCE ONLY ECP7: Animal Control Procedures
1. Personal Protective actions and Equipment
a. Hand Hygiene- Be sure to follow proper hand washing/alcohol-based hand sanitizer procedures after handling animals or after contact with potentially infectious materials b. Gloves- Wear gloves for cleaning, coming in to contact with potentially infectious materials, or handling infected animals
c. Respirator mask- Wear N95 mask when :
i. Performing any splash producing procedures
ii. When performing procedures dealing with animal birth iii. When animals exhibit signs of respiratory disease
iv. After large mortality events or if Avian Flu is suspected v. When exposed to animal generated dusts
d. Protective outerwear
i. Eye protection when performing any splash producing procedures ii. Protective outer garments when working in isolation or around large amounts of infectious materials
iii. Shoe coverings or boots when heavy quantities of infectious material are expected
2. Zoonotic Environmental Infection Control
a. Isolation- Animals with infectious diseases should be isolated as soon as possible i. Clearly mark the isolation room to describe the status and precautions ii. Only necessary equipment should be left in isolation room, and decontaminated before removal
iii. All PPE should be discarded appropriately before exiting the isolations room iv. Keep a sign-in log of all people who enter (non-employees included) b. Cleaning and disinfecting- Remove all organic matter and then disinfect with approved product i. Clean cages, toys, food/water bowls, between uses and when soiled ii. Clean litter boxes daily
iii. Wet mopping should be used to minimize the creation of dusts iv. Keep checklist and regularly schedule cleaning of other areas c. Laundry- Wear gloves when handling soiled laundry
i. Wash with detergent and dry on highest setting allowed for material ii. Use separate bins for clean and dirty laundry
d. Spill response- See Biohazard Spill Clean-up Procedure (ECP4)
3. Employee Health
a. Pregnant and Immunocompromised personnel are at increased risk from zoonotic diseases and should make their supervisor aware as accommodation may need to be made.
ATTACHMENT 9
49 CFR Part 673-Public Transportation Agency
Safety Plans
Title 49 —Transportation
Subtitle B —Other Regulations Relating to Transportation Chapter VI —Federal Transit Administration, Department of Transportation Part 673 Public Transportation Agency Safety Plans
Subpart A General
§ 673.1 Applicability.
§ 673.3 Policy.
§ 673.5 Definitions.
Subpart B Safety Plans
§ 673.11 General requirements.
§ 673.13 Certification of compliance.
§ 673.15 Coordination with metropolitan, statewide, and non-metropolitan planning processes.
Subpart C Safety Committees and Cooperation With Frontline Transit Worker Representatives
§ 673.17 Cooperation with frontline transit worker representatives. § 673.19 Safety Committees.
Subpart D Safety Management Systems
§ 673.21 General requirements.
§ 673.23 Safety Management Policy.
§ 673.25 Safety Risk Management.
§ 673.27 Safety Assurance.
§ 673.29 Safety Promotion.
Subpart E Safety Plan Documentation and Recordkeeping
§ 673.31 Safety plan documentation.
PART 673—PUBLIC TRANSPORTATION AGENCY SAFETY PLANS
Authority: 49 U.S.C. 5329, 5334; 49 CFR 1.91.
Source: 89 FR 25738, Apr. 11, 2024, unless otherwise noted.
Subpart A—General
§ 673.1 Applicability.
This content is from the eCFR and is authoritative but unofficial. (a) This part applies to any State, local governmental authority, and any other operator of a public transportation system that receives Federal financial assistance under 49 U.S.C. chapter 53. 49 CFR Part 673 (up to date as of 6/28/2024)
Public Transportation Agency Safety Plans
49 CFR Part 673 (June 28, 2024)
49 CFR 673.1(a) (enhanced display) page 1 of 14
§ 673.3 Policy.
The Federal Transit Administration (FTA) has adopted the principles and methods of Safety Management Systems (SMS) as the basis for enhancing the safety of public transportation in the United States. FTA will follow the principles and methods of SMS in its development of rules, regulations, policies, guidance, best practices, and technical assistance administered under the authority of 49 U.S.C. 5329. This part sets standards for the Public Transportation Agency Safety Plan, which will be responsive to FTA's Public Transportation Safety Program, and reflect the specific safety objectives, standards, and priorities of each transit agency. Each Public Transportation Agency Safety Plan will incorporate SMS principles and methods tailored to the size, complexity, and scope of the public transportation system and the environment in which it operates. § 673.5 Definitions.
As used in this part:
(b) This part does not apply to an operator of a public transportation system that only receives Federal financial assistance under 49 U.S.C. 5310, 49 U.S.C. 5311, or both 49 U.S.C. 5310 and 49 U.S.C. 5311 unless it operates a rail fixed guideway public transportation system.
Accountable Executive means a single, identifiable person who has ultimate responsibility for carrying out the Public Transportation Agency Safety Plan of a transit agency; responsibility for carrying out the transit agency's Transit Asset Management Plan; and control or direction over the human and capital resources needed to develop and maintain both the transit agency's Public Transportation Agency Safety Plan, in accordance with 49 U.S.C. 5329(d), and the transit agency's Transit Asset Management Plan in accordance with 49 U.S.C. 5326.
Assault on a transit worker means, as defined under 49 U.S.C. 5302, a circumstance in which an individual knowingly, without lawful authority or permission, and with intent to endanger the safety of any individual, or with a reckless disregard for the safety of human life, interferes with, disables, or incapacitates a transit worker while the transit worker is performing the duties of the transit worker.
CDC means the Centers for Disease Control and Prevention of the United States Department of Health and Human Services.
Chief Safety Officer means an adequately trained individual who has responsibility for safety and reports directly to a transit agency's chief executive officer, general manager, president, or equivalent officer. A Chief Safety Officer may not serve in other operational or maintenance capacities, unless the Chief Safety Officer is employed by a transit agency that is a small public transportation provider as defined in this part, or a public transportation provider that does not operate a rail fixed guideway public transportation system.
Direct recipient means an entity that receives Federal financial assistance directly from the Federal Transit Administration.
Emergency means, as defined under 49 U.S.C. 5324, a natural disaster affecting a wide area (such as a flood, hurricane, tidal wave, earthquake, severe storm, or landslide) or a catastrophic failure from any external cause, as a result of which the Governor of a State has declared an emergency and the Secretary has concurred; or the President has declared a major disaster under section 401 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. 5170). 49 CFR Part 673 (up to date as of 6/28/2024)
Public Transportation Agency Safety Plans
49 CFR 673.1(b)
49 CFR 673.5 “Emergency” (enhanced display) page 2 of 14 Equivalent entity means an entity that carries out duties similar to that of a Board of Directors, for a recipient or subrecipient of FTA funds under 49 U.S.C. chapter 53, including sufficient authority to review and approve a recipient or subrecipient's Public Transportation Agency Safety Plan.
FTA means the Federal Transit Administration, an operating administration within the United States Department of Transportation.
Hazard means 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 a public transportation system; or damage to the environment.
Injury means any harm to persons as a result of an event that requires immediate medical attention away from the scene.
Investigation means the process of determining the causal and contributing factors of a safety event or hazard, for the purpose of preventing recurrence and mitigating safety risk.
Joint labor-management process means a formal approach to discuss topics affecting transit workers and the public transportation system.
Large urbanized area provider means a recipient or subrecipient of financial assistance under 49 U.S.C. 5307 that serves an urban area with a population of 200,000 or more as determined by the most recent decennial Census.
National Public Transportation Safety Plan means the plan to improve the safety of all public transportation systems that receive Federal financial assistance under 49 U.S.C. chapter 53.
Near-miss means a narrowly avoided safety event.
Operator of a public transportation system means a provider of public transportation.
Performance measure means 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.
Potential consequence means the effect of a hazard.
Public transportation means, as defined under 49 U.S.C. 5302, regular, continuing shared-ride surface transportation services that are open to the general public or open to a segment of the general public defined by age, disability, or low income; and does not include:
(1) Intercity passenger rail transportation provided by the entity described in 49 U.S.C. chapter 243 (or a successor to such entity);
(2) Intercity bus service;
(3) Charter bus service;
(4) School bus service;
(5) Sightseeing service;
(6) Courtesy shuttle service for patrons of one or more specific establishments; or (7) Intra-terminal or intra-facility shuttle services.
Public Transportation Agency Safety Plan means the documented comprehensive agency safety plan for a transit agency that is required by 49 U.S.C. 5329 and this part. 49 CFR Part 673 (up to date as of 6/28/2024)
Public Transportation Agency Safety Plans
49 CFR 673.5 “Equivalent entity”
49 CFR 673.5 “Public Transportation Agency Safety Plan” (enhanced display) page 3 of 14 Rail fixed guideway public transportation system means any fixed guideway system, or any such system in engineering or construction, that uses rail, is operated for public transportation, is within the jurisdiction of a State, and is not subject to the jurisdiction of the Federal Railroad Administration. These include but are not limited to rapid rail, heavy rail, light rail, monorail, trolley, inclined plane, funicular, and automated guideway.
Rail transit agency means any entity that provides services on a rail fixed guideway public transportation system.
Recipient means a State or local governmental authority, or any other operator of a public transportation system, that receives financial assistance under 49 U.S.C. chapter 53.
Roadway means land on which rail transit tracks and support infrastructure have been constructed to support the movement of rail transit vehicles, excluding station platforms.
Safety Assurance means processes within a transit agency's Safety Management System that functions 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 Committee means the formal joint labor-management committee on issues related to safety that is required by 49 U.S.C. 5329 and this part.
Safety event means an unexpected outcome resulting in injury or death; damage to or loss of the facilities, equipment, rolling stock, or infrastructure of a public transportation system; or damage to the environment.
Safety Management Policy means a transit agency's documented commitment to safety, which defines the transit agency's safety objectives and the accountabilities and responsibilities for the management of safety.
Safety Management System (SMS) means the formal, 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 hazards and safety risk.
Safety Management System (SMS) Executive means a Chief Safety Officer or an equivalent.
Safety performance target means a quantifiable level of performance or condition, expressed as a value for the measure, related to safety management activities, to be achieved within a specified time period.
Safety Promotion means a combination of training and communication of safety information to support SMS as applied to the transit agency's public transportation system.
Safety risk means the composite of predicted severity and likelihood of a potential consequence of a hazard.
Safety risk assessment means the formal activity whereby a transit agency determines Safety Risk Management priorities by establishing the significance or value of its safety risk.
Safety risk management means a process within a transit agency's Public Transportation Agency Safety Plan for identifying hazards and analyzing, assessing, and mitigating the safety risk of their potential consequences.
Safety risk mitigation means a method or methods to eliminate or reduce the severity and/or likelihood of a potential consequence of a hazard.
49 CFR Part 673 (up to date as of 6/28/2024)
Public Transportation Agency Safety Plans
49 CFR 673.5 “Rail fixed guideway public transportation system”
49 CFR 673.5 “Safety risk mitigation” (enhanced display) page 4 of 14 Subpart B—Safety Plans
§ 673.11 General requirements.
Safety set-aside means the allocation of not less than 0.75 percent of assistance received by a large urbanized area provider under 49 U.S.C. 5307 to safety-related projects eligible under 49 U.S.C. 5307.
Small public transportation provider means a recipient or subrecipient of Federal financial assistance under 49 U.S.C. 5307 that has one hundred (100) or fewer vehicles in peak revenue service across all non-rail fixed route modes or in any one non-fixed route mode and does not operate a rail fixed guideway public transportation system.
State means a State of the United States, the District of Columbia, Puerto Rico, the Northern Mariana Islands, Guam, American Samoa, and the Virgin Islands.
State of good repair means the condition in which a capital asset is able to operate at a full level of performance.
State Safety Oversight Agency means an agency established by a State that meets the requirements and performs the functions specified by 49 U.S.C. 5329(e) and (k) and the regulations set forth in 49 CFR part 674.
Subrecipient means an entity that receives Federal transit grant funds indirectly through a State or a direct recipient.
Transit agency means an operator of a public transportation system that is a recipient or subrecipient of Federal financial assistance under 49 U.S.C. 5307 or a rail transit agency.
Transit Asset Management Plan means 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.
Transit worker means any employee, contractor, or volunteer working on behalf of the transit agency.
Urbanized area means, as defined under 49 U.S.C. 5302, an area encompassing a population of 50,000 or more that has been defined and designated in the most recent decennial census as an urban area by the Secretary of Commerce.
(a) A transit agency or State must establish a Public Transportation Agency Safety Plan that meets the requirements of this part and, at a minimum, consists of the following elements:
(1) The Public Transportation Agency Safety Plan, and subsequent updates, must be signed by the Accountable Executive and approved by—
(i) For a large urbanized area provider, the Safety Committee established pursuant to § 673.19, followed by the transit agency's Board of Directors or an equivalent entity; or (ii) For all other transit agencies, the transit agency's Board of Directors or an equivalent entity. (2) The Public Transportation Agency Safety Plan must document the processes and activities related to Safety Management System (SMS) implementation, as required under subpart D of this part. 49 CFR Part 673 (up to date as of 6/28/2024)
Public Transportation Agency Safety Plans
49 CFR 673.5 “Safety set-aside”
49 CFR 673.11(a)(2) (enhanced display) page 5 of 14
(3) The Public Transportation Agency Safety Plan must include annual safety performance targets based on the safety performance measures established under the National Public Transportation Safety Plan. Safety performance targets for the safety risk reduction program are only required for large urbanized area providers.
(4) The Public Transportation Agency Safety Plan must address all applicable requirements and standards as set forth in FTA's Public Transportation Safety Program and the National Public Transportation Safety Plan. Compliance with the minimum safety performance standards authorized under 49 U.S.C. 5329(b)(2)(C) is not required until standards have been established through the public notice and comment process.
(5) Each transit agency must establish a process and timeline for conducting an annual review and update of the Public Transportation Agency Safety Plan. (6) A rail transit agency must include or incorporate by reference in its Public Transportation Agency Safety Plan:
(i) An emergency preparedness and response plan or procedures that addresses, at a minimum, the assignment of transit worker responsibilities during an emergency; and coordination with Federal, State, regional, and local officials with roles and responsibilities for emergency preparedness and response in the transit agency's service area; (ii) Any policies and procedures regarding rail transit workers on the roadway the rail transit agency has issued; and
(iii) The transit agency's policies and procedures developed in consultation with the State Safety Oversight Agency to provide access and required data for the State Safety Oversight Agency's risk-based inspection program.
(7) The Public Transportation Agency Safety Plan of each large urbanized area provider must include a safety risk reduction program for transit operations to improve safety performance by reducing the number and rates of safety events, injuries, and assaults on transit workers. The safety risk reduction program must, at a minimum:
(i) Address the reduction and mitigation of vehicular and pedestrian safety events involving transit vehicles that includes safety risk mitigations consistent with § 673.25(d)(3); (ii) Address the reduction and mitigation of assaults on transit workers that includes safety risk mitigations consistent with § 673.25(d)(4);
(iii) Include the safety performance targets set by the Safety Committee pursuant to § 673.19(d)(2) for the safety risk reduction program performance measures established in the National Public Transportation Safety Plan. These targets must be set—
(A) Based on a three-year rolling average of the data submitted by the large urbanized area provider to the National Transit Database (NTD);
(B) For all modes of public transportation; and
(C) Based on the level of detail the large urbanized area provider is required to report to the NTD. The Safety Committee is not required to set a target for a performance measure until the large urbanized area provider has been required to report three years of data to the NTD corresponding to such performance measure.
49 CFR Part 673 (up to date as of 6/28/2024)
Public Transportation Agency Safety Plans
49 CFR 673.11(a)(3)
49 CFR 673.11(a)(7)(iii)(C) (enhanced display) page 6 of 14 § 673.13 Certification of compliance.
§ 673.15 Coordination with metropolitan, statewide, and non-metropolitan planning processes.
Subpart C—Safety Committees and Cooperation With Frontline Transit Worker Representatives § 673.17 Cooperation with frontline transit worker representatives. (iv) Include or incorporate by reference the safety risk mitigations identified and recommended by the Safety Committee as described in § 673.25(d)(5).
(b) A transit agency may develop one Public Transportation Agency Safety Plan for all modes of service or may develop a Public Transportation Agency Safety Plan for each mode of service not subject to safety regulation by another Federal entity.
(c) A transit agency must maintain its Public Transportation Agency Safety Plan in accordance with the recordkeeping requirements in subpart E of this part.
(d) A State must draft and certify a Public Transportation Agency Safety Plan on behalf of any small public transportation provider that is located in that State. A State is not required to draft a Public Transportation Agency Safety Plan for a small public transportation provider if that transit agency notifies the State that it will draft its own plan. In each instance, the transit agency must carry out the plan. If a State drafts and certifies a Public Transportation Agency Safety Plan on behalf of a transit agency, and the transit agency later opts to draft and certify its own Public Transportation Agency Safety Plan, then the transit agency must notify the State. The transit agency has one year from the date of the notification to draft and certify a Public Transportation Agency Safety Plan that is compliant with this part. The Public Transportation Agency Safety Plan drafted by the State will remain in effect until the transit agency drafts its own Public Transportation Agency Safety Plan.
(e) Agencies that operate passenger ferries regulated by the United States Coast Guard (USCG) or rail fixed guideway public transportation service regulated by the Federal Railroad Administration (FRA) are not required to develop Public Transportation Agency Safety Plans for those modes of service. (a) Each direct recipient, or State as authorized in § 673.11(d), must certify that it has established a Public Transportation Agency Safety Plan meeting the requirements of this part by the start of operations. A direct recipient must certify that it and all applicable subrecipients are in compliance with the requirements of this part. A State Safety Oversight Agency must review and approve a Public Transportation Agency Safety Plan developed by a rail fixed guideway public transportation system, as authorized in 49 U.S.C. 5329(e) and its implementing regulations at 49 CFR part 674. (b) On an annual basis, a direct recipient or State must certify its compliance with this part. A direct recipient must certify that it and all applicable subrecipients are in compliance with the requirements of this part. (a) A State or transit agency must make its safety performance targets available to States and Metropolitan Planning Organizations to aid in the planning process.
(b) To the maximum extent practicable, a State or transit agency must coordinate with States and Metropolitan Planning Organizations in the selection of State and MPO safety performance targets. (a) Each large urbanized area provider must establish a Safety Committee that meets the requirements of § 673.19.
(b) Each transit agency that is not a large urbanized area provider must:
49 CFR Part 673 (up to date as of 6/28/2024)
Public Transportation Agency Safety Plans 49 CFR 673.11(a)(7)(iv) 49 CFR 673.17(b) (enhanced display) page 7 of 14
§ 673.19 Safety Committees.
(1) Develop its Public Transportation Agency Safety Plan, and subsequent updates, in cooperation with frontline transit worker representatives; and
(2) Include or incorporate by reference in its Public Transportation Agency Safety Plan a description of how frontline transit worker representatives cooperate in the development and update of the Public Transportation Agency Safety Plan.
(a) Establishing the Safety Committee. Each large urbanized area provider must establish and operate a Safety Committee that is:
(1) Appropriately scaled to the size, scope, and complexity of the transit agency; and (2) Convened by a joint labor-management process.
(b) Safety Committee membership. The Safety Committee must consist of an equal number of frontline transit worker representatives and management representatives. To the extent practicable, the Safety Committee must include frontline transit worker representatives from major transit service functions, such as operations and maintenance, across the transit system. (1) The labor organization that represents the plurality of the transit agency's frontline transit workers must select frontline transit worker representatives for the Safety Committee. (2) If the transit agency's frontline transit workers are not represented by a labor organization, the transit agency must adopt a mechanism for frontline transit workers to select frontline transit worker representatives for the Safety Committee.
(c) Safety Committee procedures. Each large urbanized area provider must include or incorporate by reference in its Public Transportation Agency Safety Plan procedures regarding the composition, responsibilities, and operations of the Safety Committee which, at a minimum, must address:
(1) The organizational structure, size, and composition of the Safety Committee and how it will be chaired;
(2) How meeting agendas and notices will be developed and shared, and how meeting minutes will be recorded and maintained;
(3) Any required training for Safety Committee members related to the transit agency's Public Transportation Agency Safety Plan and the processes, activities, and tools used to support the transit agency's SMS;
(4) The compensation policy established by the agency for participation in Safety Committee meetings; (5) How the Safety Committee will access technical experts, including other transit workers, to serve in an advisory capacity as needed; transit agency information, resources, and tools; and submissions to the transit worker safety reporting program to support its deliberations; (6) How the Safety Committee will reach and record decisions; (7) How the Safety Committee will coordinate and communicate with the transit agency's Board of Directors, or equivalent entity, and the Accountable Executive; 49 CFR Part 673 (up to date as of 6/28/2024)
Public Transportation Agency Safety Plans 49 CFR 673.17(b)(1) 49 CFR 673.19(c)(7) (enhanced display) page 8 of 14
Subpart D—Safety Management Systems
§ 673.21 General requirements.
Each transit agency must establish and implement a Safety Management System under this part. A transit agency Safety Management System must be appropriately scaled to the size, scope and complexity of the transit agency and include the following elements:
(8) How the Safety Committee will manage disputes to ensure it carries out its operations. The Safety Committee may use the dispute resolution or arbitration process from the transit agency's Collective Bargaining Agreement, or a different process that the Safety Committee develops and agrees upon, but the Accountable Executive may not be designated to resolve any disputes within the Safety Committee; and
(9) How the Safety Committee will carry out its responsibilities identified in paragraph (d) of this section. (d) Safety Committee responsibilities. The Safety Committee must conduct the following activities to oversee the transit agency's safety performance:
(1) Review and approve the transit agency's Public Transportation Agency Safety Plan and any updates as required at § 673.11(a)(1)(i);
(2) Set annual safety performance targets for the safety risk reduction program as required at § 673.11(a)(7)(iii); and
(3) Support operation of the transit agency's SMS by:
(i) Identifying and recommending safety risk mitigations necessary to reduce the likelihood and severity of potential consequences identified through the transit agency's safety risk assessment, including safety risk mitigations associated with any instance where the transit agency did not meet an annual safety performance target in the safety risk reduction program; (ii) Identifying safety risk mitigations that may be ineffective, inappropriate, or were not implemented as intended, including safety risk mitigations associated with any instance where the transit agency did not meet an annual safety performance target in the safety risk reduction program; and
(iii) Identifying safety deficiencies for purposes of continuous improvement as required at § 673.27(d), including any instance where the transit agency did not meet an annual safety performance target in the safety risk reduction program. (a) Safety Management Policy as described in § 673.23;
(b) Safety Risk Management as described in § 673.25;
(c) Safety Assurance as described in § 673.27; and
(d) Safety Promotion as described in § 673.29.
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Public Transportation Agency Safety Plans 49 CFR 673.19(c)(8) 49 CFR 673.21(d) (enhanced display) page 9 of 14
§ 673.23 Safety Management Policy.
(a) A transit agency must establish its organizational accountabilities and responsibilities and have a written statement of Safety Management Policy that includes the transit agency's safety objectives and a description of the transit agency's Safety Committee or approach to cooperation with frontline transit worker representatives.
(b) A transit agency must establish and implement a process that allows transit workers to report safety concerns, including assaults on transit workers, near-misses, and unsafe acts and conditions to senior management, includes protections for transit workers who report, and includes a description of transit worker behaviors that may result in disciplinary action. (c) The Safety Management Policy must be communicated throughout the transit agency's organization. (d) The transit agency must establish the necessary authorities, accountabilities, and responsibilities for the management of safety amongst the following individuals or groups within its organization, as they relate to the development and management of the transit agency's SMS:
(1) Accountable Executive. The transit agency must identify an Accountable Executive. The Accountable Executive is accountable for ensuring that the transit agency's SMS is effectively implemented throughout the transit agency's public transportation system. The Accountable Executive is accountable for ensuring action is taken, as necessary, to address substandard performance in the transit agency's SMS. The Accountable Executive may delegate specific responsibilities, but the ultimate accountability for the transit agency's safety performance cannot be delegated and always rests with the Accountable Executive.
(i) The Accountable Executive of a large urbanized area provider must implement safety risk mitigations for the safety risk reduction program that are included in the Agency Safety Plan under § 673.11(a)(7)(iv).
(ii) The Accountable Executive of a large urbanized area provider receives and must consider all other safety risk mitigations recommended by the Safety Committee, consistent with requirements in §§ 673.19(d) and 673.25(d)(6).
(2) Chief Safety Officer or Safety Management System (SMS) Executive. The Accountable Executive must designate a Chief Safety Officer or SMS Executive who has the authority and responsibility for day-to-day implementation and operation of a transit agency's SMS. The Chief Safety Officer or SMS Executive must hold a direct line of reporting to the Accountable Executive. A transit agency may allow the Accountable Executive to also serve as the Chief Safety Officer or SMS Executive. (3) Safety Committee. A large urbanized area provider must establish a joint labor-management Safety Committee that meets the requirements of § 673.19.
(4) Transit agency leadership and executive management. A transit agency must identify those members of its leadership or executive management, other than an Accountable Executive, Chief Safety Officer, or SMS Executive, who have authorities or responsibilities for day-to-day implementation and operation of a transit agency's SMS.
(5) Key staff. A transit agency may designate key staff, groups of staff, or committees to support the Accountable Executive, Chief Safety Officer, Safety Committee, or SMS Executive in developing, implementing, and operating the transit agency's SMS.
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Public Transportation Agency Safety Plans 49 CFR 673.23 49 CFR 673.23(d)(5) (enhanced display) page 10 of 14
§ 673.25 Safety Risk Management.
(a) Safety Risk Management process. A transit agency must develop and implement a Safety Risk Management process for all elements of its public transportation system. The Safety Risk Management process must be comprised of the following activities: hazard identification, safety risk assessment, and safety risk mitigation.
(b) Hazard identification.
(1) A transit agency must establish methods or processes to identify hazards and potential consequences of the hazards.
(2) A transit agency must consider, as a source for hazard identification:
(i) Data and information provided by an oversight authority, including but not limited to FTA, the State, or as applicable, the State Safety Oversight Agency having jurisdiction; (ii) Data and information regarding exposure to infectious disease provided by the CDC or a State health authority; and
(iii) Safety concerns identified through Safety Assurance activities carried out under § 673.27. (c) Safety risk assessment.
(1) A transit agency must establish methods or processes to assess the safety risk associated with identified hazards.
(2) A safety risk assessment includes an assessment of the likelihood and severity of the potential consequences of identified hazards, taking into account existing safety risk mitigations, to determine if safety risk mitigation is necessary and to inform prioritization of safety risk mitigations. (d) Safety risk mitigation.
(1) A transit agency must establish methods or processes to identify safety risk mitigations or strategies necessary as a result of the transit agency's safety risk assessment to reduce the likelihood and severity of the potential consequences. For large urbanized area providers, these methods or processes must address the role of the transit agency's Safety Committee. (2) A transit agency must consider, as a source for safety risk mitigation:
(i) Guidance provided by an oversight authority, if applicable, and FTA; and (ii) Guidelines to prevent or control exposure to infectious diseases provided by the CDC or a State health authority.
(3) When identifying safety risk mitigations for the safety risk reduction program related to vehicular and pedestrian safety events involving transit vehicles, including to address a missed safety performance target set by the Safety Committee under § 673.19(d)(2), each large urbanized area provider and its Safety Committee must consider mitigations to reduce visibility impairments for transit vehicle operators that contribute to accidents, including retrofits to vehicles in revenue service and specifications for future procurements that reduce visibility impairments. (4) When identifying safety risk mitigations for the safety risk reduction program related to assaults on transit workers, including to address a missed safety performance target set by the Safety Committee under § 673.19(d)(2), each large urbanized area provider and its Safety Committee must 49 CFR Part 673 (up to date as of 6/28/2024)
Public Transportation Agency Safety Plans 49 CFR 673.25 49 CFR 673.25(d)(4) (enhanced display) page 11 of 14
§ 673.27 Safety Assurance.
consider deployment of assault mitigation infrastructure and technology on transit vehicles and in transit facilities. Assault mitigation infrastructure and technology includes barriers to restrict the unwanted entry of individuals and objects into the workstations of bus operators. (5) When a large urbanized area provider's Safety Committee, as part of the transit agency's safety risk reduction program, identifies and recommends under § 673.19(c)(6) safety risk mitigations, including mitigations relating to vehicular and pedestrian safety events involving transit vehicles or assaults on transit workers, based on a safety risk assessment conducted under § 673.25(c), the transit agency must include or incorporate by reference these safety risk mitigations in its ASP pursuant to § 673.11(a)(7)(iv).
(6) When a large urbanized area provider's Safety Committee recommends a safety risk mitigation unrelated to the safety risk reduction program, and the Accountable Executive decides not to implement the safety risk mitigation, the Accountable Executive must prepare a written statement explaining their decision, pursuant to recordkeeping requirements at § 673.31. The Accountable Executive must submit and present this explanation to the transit agency's Safety Committee and Board of Directors or equivalent entity.
(a) Safety Assurance process. A transit agency must develop and implement a Safety Assurance process, consistent with this subpart. A rail fixed guideway public transportation system, and a recipient or subrecipient of Federal financial assistance under 49 U.S.C. chapter 53 that operates more than one hundred vehicles in peak revenue service, must include in its Safety Assurance process each of the requirements in paragraphs (b), (c), and (d) of this section. A small public transportation provider only must include in its Safety Assurance process the requirements in paragraphs (b) and (d) of this section. (b) Safety performance monitoring and measurement. A transit agency must establish activities to:
(1) Monitor its system for compliance with, and sufficiency of, the transit agency's procedures for operations and maintenance;
(2) Monitor its operations to identify any safety risk mitigations that may be ineffective, inappropriate, or were not implemented as intended. For large urbanized area providers, these activities must address the role of the transit agency's Safety Committee;
(3) Conduct investigations of safety events to identify causal factors; and (4) Monitor information reported through any internal safety reporting programs. (c) Management of change.
(1) A transit agency must establish a process for identifying and assessing changes that may introduce new hazards or impact the transit agency's safety performance. (2) If a transit agency determines that a change may impact its safety performance, then the transit agency must evaluate the proposed change through its Safety Risk Management process. (d) Continuous improvement.
(1) A transit agency must establish a process to assess its safety performance annually. (i) This process must include the identification of deficiencies in the transit agency's SMS and deficiencies in the transit agency's performance against safety performance targets required in § 673.11(a)(3).
49 CFR Part 673 (up to date as of 6/28/2024)
Public Transportation Agency Safety Plans 49 CFR 673.25(d)(5) 49 CFR 673.27(d)(1)(i) (enhanced display) page 12 of 14 § 673.29 Safety Promotion.
Subpart E—Safety Plan Documentation and Recordkeeping
(ii) For large urbanized area providers, this process must also address the role of the transit agency's Safety Committee, and include the identification of deficiencies in the transit agency's performance against annual safety performance targets set by the Safety Committee under § 673.19(d)(2) for the safety risk reduction program required in § 673.11(a)(7). (iii) Rail transit agencies must also address any specific internal safety review requirements established by their State Safety Oversight Agency.
(2) A large urbanized area provider must monitor safety performance against annual safety performance targets set by the Safety Committee under § 673.19(d)(2) for the safety risk reduction program in § 673.11(a)(7).
(3) A large urbanized area provider that does not meet an established annual safety performance target set by the Safety Committee under § 673.19(d)(2) for the safety risk reduction program in § 673.11(a)(7) must:
(i) Assess associated safety risk, using the methods or processes established under § 673.25(c); (ii) Mitigate associated safety risk based on the results of a safety risk assessment using the methods or processes established under § 673.25(d). The transit agency must include these mitigations in the plan described at § 673.27(d)(4) and in the Agency Safety Plan as described in § 673.25(d)(5); and
(iii) Allocate its safety set-aside in the following fiscal year to safety-related projects eligible under 49 U.S.C. 5307 that are reasonably likely to assist the transit agency in meeting the safety performance target in the future.
(4) A transit agency must develop and carry out, under the direction of the Accountable Executive, a plan to address any deficiencies identified through the safety performance assessment as described in this section.
(a) Competencies and training.
(1) A transit agency must establish and implement a comprehensive safety training program that includes de-escalation training, safety concern identification and reporting training, and refresher training for all operations transit workers and transit workers directly responsible for safety in the transit agency's public transportation system. The training program must include refresher training, as necessary.
(2) Large urbanized area providers must include maintenance transit workers in the safety training program.
(b) Safety communication. A transit agency must communicate safety and safety performance information throughout the transit agency's organization that, at a minimum, conveys information on hazards and safety risk relevant to transit workers' roles and responsibilities and informs transit workers of safety actions taken in response to reports submitted through a transit worker safety reporting program. A transit agency must also communicate the results of cooperation with frontline transit worker representatives as described at § 673.17(b) or the Safety Committee activities described in § 673.19. 49 CFR Part 673 (up to date as of 6/28/2024)
Public Transportation Agency Safety Plans 49 CFR 673.27(d)(1)(ii) 49 CFR 673.29(b) (enhanced display) page 13 of 14
§ 673.31 Safety plan documentation.
At all times, a transit agency must maintain documents that set forth its Public Transportation Agency Safety Plan, including those related to the implementation of its SMS, and results from SMS processes and activities. A transit agency must maintain documents that are included in whole, or by reference, that describe the programs, policies, and procedures that the transit agency uses to carry out its Public Transportation Agency Safety Plan. These documents must be made available upon request by FTA or other Federal entity, or a State or State Safety Oversight Agency having jurisdiction. A transit agency must maintain these documents for a minimum of three years after they are created.
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