MBTA Releases Independent Audit, Publishes Internal Safety Review

Boston’s Massachusetts Bay Transportation Authority (MBTA) GM/CEO Phillip Eng addressed the release of two pivotal reports focused on track maintenance safety evaluation: an independent report conducted by Carlson Transport Consulting LCC and an internal review by the MBTA Safety Department.

The investigations revealed deficiencies in track inspection processes, including inconsistencies in documentation and oversight. Both concluded improvements are imperative in terms of leadership, standardizing procedures, increasing staffing and training, and clearly outlining roles and responsibilities.

Since safety restrictions were put in place in March, the MBTA has already been taking measures to address track issues, including hiring seasoned veteran engineers and establishing standard operating procedures for inspections and documentation practices.

“These reports validate what I anticipated and observed since I first joined in April, and having seen similar challenges over my career across other agencies striving to change longstanding practices, I know the changes we have made to date are the building blocks to the organizational changes needed here,” said Eng.

Track Maintenance Safety Evaluations

In March 2023, the Department of Public Utilities inspected the Red Line and found insufficient documentation of track repairs, which led the MBTA to commission an independent investigation into track inspection failures that prompted systemwide speed restrictions. The investigation revealed inconsistent defect identification, lack of defect verification, inadequate oversight of inspections, and inappropriate track geometry criteria.

Additionally, the internal review by the MBTA Safety Department, conducted in an effort to be thorough and ensure accuracy, aligned with these findings. Both reports concluded that improvements are needed in track inspection processes and standards.

The independent report makes recommendations in three categories: Process & Procedures, Staffing, and Roles & Responsibilities:

• Process & Procedures: The MBTA should develop and issue Standard Operating Procedures for both visual and third-party inspections that include documentation requirements. The MBTA should also involve appropriate personnel in witnessing the third-party track inspections, consider alternative track geometry criteria that more closely fit the MBTA system, and develop a long-range track improvement plan.
• Staffing: The MBTA should increase staffing levels in the Maintenance of Way (MOW) division and evaluate compensation and responsibility parity across departments.
• Roles & Responsibilities: The MBTA should elevate inspection positions within the MOW division, modify the selection process and qualification requirements for roles with inspection responsibilities, and enhance training, certification, and recertification for roles with inspection responsibilities.  

Findings Match with FTA’s

The systemic issues identified in the independent report align with those already published in the FTA’s Safety Management Inspection, which the MBTA is actively addressing through its Quality, Compliance, & Oversight Office. The goals of these efforts, which include staffing assessments, hiring plans, documentation of procedures, and quality management, to name a few, include the following areas of focus:

• Enhancing selection/qualifications: To ensure that only the most qualified individuals are hired for track inspection positions and that inspectors have the knowledge and skills necessary to identify and report defects.
• Increasing Maintenance of Way staffing: To ensure that all track inspection needs are met and to improve the efficiency of the inspection process.
• Improving training: To help inspectors to stay up to date on the latest inspection techniques and technologies and help them develop the skills they need to identify and report defects in a timely and accurate manner.
• Ensuring Section Foremen can witness vendor testing: To ensure that vendor testing is conducted properly and that defects are not missed.

Recently, the MBTA announced its strategic values, goals, and metrics to improve safety, service, equity, sustainability, and culture, which builds on Eng’s vision and mission to strengthen systems to better support a diverse and qualified workforce.

The MBTA’s Progress

The MBTA’s progress is already underway, as the agency has been taking the following steps to address track inspection and maintenance: 

Documentation and Training

• Conducted a comprehensive inspection documentation and records audit following the March Geometry records finding to identify additional gaps.
• Issued a Standard Operating Procedure (SOP) for track geometry testing in June 2023 to standardize documentation and defect resolution. Draft SOPs for other inspection types are currently under final review.
• Enhanced the training program for System Repairpersons: Implemented updated program curricula in June 2023 by adding an additional week to the existing two-week program, increasing the training by 50%, consisting of supplementary fieldwork, specific digital reporting tool training, and an eight-week OJT program. A revised and enhanced recertification program for the System Repairpersons will begin by December 2023.
• Increased instruction staff by hiring three new track instructors and is hiring three more. This will bring the total number of track instructors to six in the near term. The MOW Department is also increasing training space by procuring two classroom trailers.

Staffing

• Hired 30 new track laborers since December 2022 and are striving to hire for as many as 50 more track positions in the coming months.
• Recruited a new Senior Director of Maintenance of Way and Chief of Infrastructure, both with extensive track inspection, maintenance, and construction experience in August 2023. The MBTA will continue to recruit Director and Deputy Director positions to fill track department leadership positions.  
• Workforce assessments are underway within the FTA Safety Management Inspection (SMI) program to determine optimal staffing levels for inspection, maintenance, and capital initiatives. 

Inspections

• Issued a directive to address critical “black condition” defects immediately. (Track defects are logged using a color-coded guide: green, yellow, red, and black. Green is the best rating, and black is the worst. A defect rated green is considered minor and does not require immediate attention. A defect rated yellow is considered moderate and should be repaired soon. A defect rated red is considered severe and should be fixed quickly. A defect rated black is considered critical and requires immediate attention.) Speed restrictions are a mitigation measure used to address red and yellow conditions that require repairs.
• Updated the new geometry testing SOP to set expectations for MOW staff requiring real-time reporting of critical defects to Section Forepersons for immediate verification and resolution.
• Issued a Request for Information (RFI) in August 2023 to gather industry feedback on geometry testing requirements and criteria.
• Implemented a program for tandem inspections utilizing external experts to provide real-time mentoring for internal inspection staff.

Preventative Maintenance

• Improved preventative maintenance scheduling and planning to optimize the efficiency of regular repairs and upkeep.
• Procured additional inspection vehicles/equipment to expand coverage and access.
• The findings in the independent report align with systemic issues identified in the FTA's recent Safety Management Inspection. In response to the FTA report, the MBTA has already been actively working to fix these problems through its Quality, Compliance & Oversight Office. The MBTA has made strides this summer on the FTA response, closing another CAP on August 18, 2023, under another Special Directive (Special Directive 22-6, CAP 4), bringing the total number of closed CAPs to 3 of 39 and 6 of the 42 findings under the SMI Report. 

Over the past several months, these efforts include the following:

• Track Maintenance and MOW Management Practices: The MBTA has corrected specific track defects and is developing the processes, tools, reporting equipment, resources, and budget to fix maintenance backlogs and establish proactive maintenance management practices.
• Managing the Impact of Operations, Maintenance, and Capital Project Requirements on the Existing Workforce: The MBTA is documenting its workforce requirements across the organization with a specific focus on understanding the interdependencies between operations, maintenance, and capital projects. The MBTA will also develop a five-year hiring plan to address the outcomes from the workforce assessment.
• Operating Conditions and Policies, Procedures, and Training: The MBTA will develop an understanding of training gaps for its workforce, develop and implement that training, and develop a centralized training governance program to ensure appropriate quality, tracking, and administration of training across the authority.

“We are deeply committed to making the MBTA the safest and most reliable transit system in the country,” added Eng. “Systemic process and infrastructural failures do not happen overnight; as a result, we need a strong commitment to addressing longstanding issues. That’s why we are reviewing the entire organization and clarifying responsibilities and accountability across the leadership team. The status quo is unacceptable, and we are rebuilding the workforce as we rebuild our infrastructure. It is our responsibility to put our workforce in positions to succeed with clear direction, appropriate training, and resources.”