Lapsed Certifications
MBTA personnel must have up-to-date certifications to safely access the right of way (ROW) as well as operate and supervise train movements. Training and certifications are renewed regularly, and personnel cannot perform safety-sensitive duties if they have lapsed (expired) certifications. For example, anyone who needs to access the ROW is required to take the training course and receive a ROW Certification Card.
The MBTA is improving its training and certification processes to ensure that personnel operating and supervising train movements:
- Complete required training and are certified
- Cannot operate or supervise train movements if they are not certified
- Have electronic access to up-to-date training materials and rulebooks for all train lines
- Have access to all temporary and permanent orders
FTA Safety Management Inspection Response
FTA Special Directive 22-07
During their Safety Management Inspection (SMI), the Federal Transit Administration (FTA) issued Special Directive (SD) 22-07 and found that MBTA personnel responsible for rail car movement are not:
- Ensured to meet operational training and recertification requirements
- Effectively trained and certified
In response, the MBTA has created processes, procedures, policies, and assurance activities to prevent any personnel with a lapsed certification from working on MBTA property.
We are formalizing technical training and updating our learning management system, so we can better track and manage employees’ learning and certification needs. We’re also working to better document and distribute changes that operators need to be aware of in our operating environment through Special Orders.
Finding 1
SD 22-07 finding 1, issued on June 15, 2022, requires the MBTA to regularly submit information to the FTA and DPU.
| Finding | Status | ||
|---|---|---|---|
| Finding | SD 22-07 finding 1 requires the MBTA to submit documentation confirming that staff operating passenger service trains and supervising train movements and passenger service trains are certified. | Status | In progress |
Corrective Action Plans (CAPs)
The MBTA developed CAPs to address SD 22-07 findings. CAPs are made up of action items at different stages of progress:
- Not yet submitted: The action item has not been completed.
- Under FTA review: The MBTA completed the action item and submitted documentation to the FTA. The FTA is reviewing the MBTA's submission.
- Resubmissions in progress: The MBTA completed the action item and submitted documentation to the FTA. The FTA requested additional information from the MBTA.
- Submissions accepted by the FTA: The MBTA completed the action item and submitted documentation to the FTA. The FTA accepted the MBTA’s submission.
| CAP | Status | ||
|---|---|---|---|
| CAP | SD 22-07 CAP 2 develops and implements procedures to ensure that all training and safety certifications are current for all required personnel. | Status | In progress |
| CAP | SD 22-07 CAP 3 ensures that employee training materials are up to date, readily available, and completed on time. | Status | In progress |
