FTA Oversight Procedures - Federal Transit Administration - U.S. ...
FTA Oversight Procedures - Federal Transit Administration - U.S. ... FTA Oversight Procedures - Federal Transit Administration - U.S. ...
documents referenced in the SSMP to describe the recipient’s approach to performing specific safety and security management activities. Based on the degree of satisfaction with the requirements, the PMOC should rate each Item as: • Compliant (C), • Marginal (M), or • Noncompliant (N). An N rating means the FTA’s intent was not adequately addressed and revision is required before the SSMP can be recommended for acceptance. An M rating means the FTA’s intent was addressed but that the content is inconsistent with other SSMP sections or other plans, or that the deficiency is not so serious that it prevents acceptance of the SSMP at the current phase but should be corrected in later phases of the project. A C rating means that FTA’s intent was addressed in the SSMP or referenced documents. For each Item rated M or N, the PMOC should describe the noncompliance or deficiency and, if possible, make recommendations or suggestions to bring it to full compliance. Appendix A of Circular 5800.1 provides additional guidance regarding the types of activities FTA expects of recipients during various project phases. 6.1.3 SSMP Adherence Review To assess the recipient’s implementation of the SSMP for specific project phases, the PMOC must conduct an SSMP Adherence Review. This Review can be divided into five activities: • Planning the review – based on activities, documentation, committees, and responsibilities identified in the SSMP, prepare a list of documents and materials to review, individuals to interview, and sites to visit; materials not in possession of the PMOC should be requested and a delivery schedule and a schedule for the interviews and site visits should be developed • Reviewing plans, policies, and procedures – to determine whether they are consistent with the SSMP and with the FTA’s intent for management of safety and security programs • Reviewing documentation, including memoranda, reports, records, and minutes of safety- and security-related committees – to verify that the program has been implemented and plans and procedures are being followed • Interviewing recipient and consultant staff (senior and middle managers and consultant personnel identified in the SSMP and others with safety and security responsibilities in the agency and throughout the project) – to verify that personnel charged with carrying out the safety and security programs are aware of the SSMP and their responsibilities and are capable of meeting them • Inspecting selected sites – to view evidence that safety and security programs are being implemented throughout the project area 6.1.3.1 Planning the Review OP 22 Safety and Security Management Plan Review Revision 0, June 2008 Page 6 of 11
The recipient will be asked to supply a considerable amount of material and to schedule interviews and site visits over a relatively short time span. Based on the volume of documents and the number of people to be interviewed, the PMOC may perform the review using a small team of safety and security experts working under a project manager. The PMOC may consider an orientation and alignment tour led by the recipient’s senior project staff members, including safety and security personnel, to assist in preparation of a Document Review Plan and Checklist of Documents (see Appendix B) 1 and to identify interviewees. These should be discussed with the recipient and the logistics of document review and interviews resolved. It is a good practice to document this step with an informal progress report to the FTA Task Order Manager (TOM). If the project is a rail transit or commuter rail extension or addition, or a rehabilitation or modernization project, the recipient’s System Safety Program Plan (SSPP) and System Security Plan (SSP) should be reviewed to assure that the SSMP and referenced documents cover all required safety and security management activities for the project. Similar documents, which may be differently titled, should be reviewed for bus agency projects; these might include an SSPP in the states requiring one, or other safety and security related documents. A number of documents to be reviewed may be labeled Security Sensitive Information (SSI) in conformance with 49 CRF Part 15. Since the TO will not authorize access to SSI materials, the PMOC must obtain clearance from the TOM. Once this has been approved, the recipient will be expected to provide the material, usually with password protection or a similar safeguard. Non-SSI documents can sometimes be distributed on a file transfer protocol (ftp) site if recipient and PMOC have that capability. The schedule of site visits should be prepared after the PMOC has reviewed documents to gain a sufficient understanding of the safety and security issues of the project. 6.1.3.2 Review of Plans, Policies, and Procedures Upon receipt, the PMOC should review in-depth all plans, policies, and procedures that make up the safety and security programs referenced in the SSMP. The PMOC must determine whether the SSMP and its supporting documents describe consistent, comprehensive, and effective safety and security programs. Supporting documents should be identified in the SSMP and the content consistent with the SSMP and with sound safety and security practice and principles. FTA will assess the SSMPs using criteria identified in items 1 through 12 below that are also listed in Circular 5800.1, Pages II-4 and II-5. FTA gives each criterion equal weight in the review process. (1) The assignment of responsibility for safety and security, including the process for maintaining responsibility over safety and security tasks it delegates to outside consultants and/or contractors. 1 Appendix B lists documents and other materials the PMOC may want to examine. It is a guide; not all materials will be relevant to all projects or recipients and it is possible that some relevant materials may not be listed. The Appendix indicates which materials should be relevant at each phase and which documents are generally agency-wide or project specific. OP 22 Safety and Security Management Plan Review Revision 0, June 2008 Page 7 of 11
- Page 19 and 20: 5. Act in a manner consistent with
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The recipient will be asked to supply a considerable amount of material and to schedule interviews and<br />
site visits over a relatively short time span. Based on the volume of documents and the number of people<br />
to be interviewed, the PMOC may perform the review using a small team of safety and security experts<br />
working under a project manager.<br />
The PMOC may consider an orientation and alignment tour led by the recipient’s senior project staff<br />
members, including safety and security personnel, to assist in preparation of a Document Review Plan<br />
and Checklist of Documents (see Appendix B) 1 and to identify interviewees. These should be discussed<br />
with the recipient and the logistics of document review and interviews resolved. It is a good practice to<br />
document this step with an informal progress report to the <strong>FTA</strong> Task Order Manager (TOM).<br />
If the project is a rail transit or commuter rail extension or addition, or a rehabilitation or modernization<br />
project, the recipient’s System Safety Program Plan (SSPP) and System Security Plan (SSP) should be<br />
reviewed to assure that the SSMP and referenced documents cover all required safety and security<br />
management activities for the project. Similar documents, which may be differently titled, should be<br />
reviewed for bus agency projects; these might include an SSPP in the states requiring one, or other safety<br />
and security related documents.<br />
A number of documents to be reviewed may be labeled Security Sensitive Information (SSI) in<br />
conformance with 49 CRF Part 15. Since the TO will not authorize access to SSI materials, the PMOC<br />
must obtain clearance from the TOM. Once this has been approved, the recipient will be expected to<br />
provide the material, usually with password protection or a similar safeguard. Non-SSI documents can<br />
sometimes be distributed on a file transfer protocol (ftp) site if recipient and PMOC have that capability.<br />
The schedule of site visits should be prepared after the PMOC has reviewed documents to gain a<br />
sufficient understanding of the safety and security issues of the project.<br />
6.1.3.2 Review of Plans, Policies, and <strong>Procedures</strong><br />
Upon receipt, the PMOC should review in-depth all plans, policies, and procedures that make up the<br />
safety and security programs referenced in the SSMP. The PMOC must determine whether the SSMP and<br />
its supporting documents describe consistent, comprehensive, and effective safety and security programs.<br />
Supporting documents should be identified in the SSMP and the content consistent with the SSMP and<br />
with sound safety and security practice and principles.<br />
<strong>FTA</strong> will assess the SSMPs using criteria identified in items 1 through 12 below that are also listed in<br />
Circular 5800.1, Pages II-4 and II-5. <strong>FTA</strong> gives each criterion equal weight in the review process.<br />
(1) The assignment of responsibility for safety and security, including the process for maintaining<br />
responsibility over safety and security tasks it delegates to outside consultants and/or contractors.<br />
1 Appendix B lists documents and other materials the PMOC may want to examine. It is a guide; not all materials will be<br />
relevant to all projects or recipients and it is possible that some relevant materials may not be listed. The Appendix indicates<br />
which materials should be relevant at each phase and which documents are generally agency-wide or project specific.<br />
OP 22 Safety and Security Management Plan Review<br />
Revision 0, June 2008<br />
Page 7 of 11
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