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Safety Performance Monitoring and Measuring – 673.27(b)

As the first step in the PBT SA program, PBT collects and monitors data on safety performance indicators through a variety of mechanisms described in the following sections. Safety performance indicators can provide early warning signs about safety risks. PBT currently relies primarily on lagging indicators representing negative safety outcomes that should be avoided or mitigated in the future. However, initiatives are underway to adopt a more robust set of leading indicators that monitor conditions that are likely to contribute to negative outcomes in the future. In addition to the day-to-day monitoring and investigation procedures detailed below, PBT will review and document the safety performance monitoring and measuring processes as part of the annual update of this ASP.

Monitoring Compliance and Sufficiency of Procedures - 673.27 (B)(1)

PBT monitors our system for personnel compliance with operations and maintenance procedures and also monitors these procedures for sufficiency in meeting safety objectives. A list of documents describing the safety-related operations and maintenance procedures cited in this ASP is provided in Appendix A of this document.

Supervisors monitor employee compliance with PBT SOPs through direct observation and review of information from internal reporting systems such as the Customer & Operator Complaint Forms (Appendix).

PBT addresses non-compliance with standard procedures for operations and maintenance activities through a variety of actions, including revisions to training materials and delivery of employee and supervisor training if the non-compliance is systemic. If the non-compliance is situational, then activities may include supplemental individualized training, coaching, and heightened management oversight, among other remedies.

Sometimes personnel are fully complying with the procedures, but the operations and maintenance procedures are inadequate and pose the risk of negative safety outcomes. In this case, the cognizant person submits the deficiency or description of the inadequate procedures to the SRM process. Through the SRM process, the SRM team will then evaluate and analyze the potential organizational hazard and assign the identified hazard for mitigation and resolution, as appropriate. The SRM team will also conduct periodic self-evaluation and mitigation of any identified deficiencies in the SRM process itself. 

Monitoring Operations - 673.27(B)(2)

Supervisors/managers, dispatchers, and/or coordinators are required to monitor investigation reports of safety events and SRM resolution reports to monitor the department's operations to identify any safety risk mitigations that may be ineffective, inappropriate, or not implemented as intended within the department's operations. If it is determined that the safety risk mitigation did not bring the risk to an acceptable level or otherwise failed to meet safety objectives, then the supervisor resubmits the safety risk/hazard to the SRM process. The CSO will work with the supervisor, along with subject matter experts, to reanalyze the hazard and consequences, to identify additional mitigation or alternative approaches to implementing the mitigation.

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