• A New Age of Enforcement: Adjusting to Remote and Offsite Investigations & How to Prepare By:

    Presented as part of ABA’s BISC & BusMARC 2021 Virtual Safety & Maintenance Series The American Bus Association’s Bus Industry Safety Council (BISC) and Bus Maintenance Repair Council’s (BusMARC) 2021 Virtual Safety & Maintenance Series offered a sequence of educational webinars early this year, covering a variety of industry-related topics. As part of its ongoing webinar series, the ABA hosted a virtual meeting with presenters Catterson Oh and Danielle Smith, transportation specialists with the Federal Motor Carrier Safety Administration’s (FMCSA) Compliance Division. Oh and Smith focused on COVID-19 national emergency investigative process updates including changes to the FMCSA investigative procedures due to COVID-19, recordkeeping and documentation as the result of COVID-19, and providing accurate documentation for FMCSA investigations. Changes to Investigative Procedures as a Result of the COVID-19 Health Emergency In May 2020, the FMCSA released guidance allowing investigators to conduct remote onsite investigations. These remote onsite investigations are intended to follow the same general process as offsite investigations with the exception that most of the investigation is now completed remotely. According to Oh, May 2020 resulted in a significant expansion to the FMCSA’s remote functionality. While motorcoach operators may not have seen any investigations in the last year, Oh noted that due to this expanded functionality, companies should expect a considerable increase in the number of investigations moving forward. “In terms of the offsite investigations with this pandemic, the policy with this particular type of investigation has not changed,” Oh said. “The offsite investigation will still be recommended for carriers that meet the appropriate criteria for this population of carriers.” Although carriers will not receive a rating from an offsite investigation, offsite investigations may be converted to onsite remote investigations under certain circumstances. Carriers with investigations that are converted onsite may be issued a Safety Fitness Rating. Overview of Investigation Process   Safety Investigator (SI) will conduct an initial phone call with the carrier to introduce themselves, and review the reason for the investigation and next steps.  2. SI will email the carrier an Initial Contact Letter that will go over initial documents being requested.  3. Carrier will upload the initial documents to the Safety Measurement System (SMS).  4. After SI receives the initial documents, they may request additional documents via a Document Request Letter.  5. SI may contact the carrier via phone and email throughout the investigation.  6. Once SI has completed the investigation, they will request a closeout meeting with the carrier, which can be done via phone, Microsoft Teams, Skype, or other platform.  7. Carrier may receive a Safety Rating upon completion of the Remote Onsite Investigation. According to Oh, carriers subject to investigation will receive a phone call, followed by an initial contact letter, from an FMSCA Safety Investigator (SI) introducing themselves, the reason for investigation and next steps. Once a carrier has received this letter, that carrier’s information will need to be uploaded into the FMCSA Safety Measurement System (SMS). After receiving the initial documents, an SI will review the content to determine if additional documentation is required. If additional documentation is needed the SI will issue a “document request letter.” “This is where things start kind of diverting from the normal way of doing things,” Oh explained. “Especially when you have performed onsite investigations.” An SI will start contacting the carrier via phone and e-mail throughout the investigation. In a normal onsite investigation, the SI would be with the carrier in person to answer questions and provide additional guidance.  Once the SI has completed their investigation, they will request a close out meeting with the carrier. This can be done over the phone or, more likely, in a video conferencing setting. At this point, the carrier may receive a safety rating upon completion of the remote onsite investigation.  Once the SMS has processed the information, the carrier will be able to access their dashboard, track investigation progress, check due dates and required documents, view call-to-action reminders, upload documentation, and learn to use data to increase safety performance. After the SI has reviewed all of the required documents, they will send the carrier a request for a meeting to close out the investigation. Typically, this is done onsite, face-to-face however, since the onset of the pandemic, closeouts are now performed virtually. Reinstatement After Voluntary Revocation of Operating Authority In March 2020, the FMCSA issued multiple exemptions in response to the national health emergency. One of those exemptions included waiving the $80 reinstatement fee for carriers who opted to voluntarily revoke their Passenger Operating Authority.  Carriers with a USDOT pin can login into their profile, update their registration information, and complete an MCSA-5889 form, a Motor Carrier Records Change.  Carriers without a USDOT pin, can register and request a pin number through the FMCSA website. Before submitting a request, carriers will need to file a BOC-3 (Designation of Process Agent), confirm insurance filings are up to date, and make sure that their USDOT number is reinstated and activated. Once these items are completed, the reinstatement request is going to be put on hold until the carrier has everything submitted properly. “If all is submitted and you do have to pay that fee, then you’ll get it reinstated no later than the fourth business day after the payment is processed,” Smith explained. “You can request that the fee is waived, you’re just going to submit it through EMC’s e-mail address rather than doing it through the normal process online.”  FMCSA Ratings The FMCSA issues three types of ratings. Satisfactory, conditional, or unsatisfactory. Satisfactory means that there are safety systems in place and they all appear to be working. Conditional means that there are safety systems in place, but there are breakdowns within some of those systems. While carriers are still able to operate with a conditional rating, some choose not to do so and would rather upgrade their score. Unsatisfactory ratings mean a carrier is considered unfit and are not allowed to operate after that time.  “All of the critical violations are listed within the Read More >

  • Back to Basics: Handling Open Campaigns By:

    Presented as part of ABA’s BISC & BusMARC 2021 Virtual Safety & Maintenance Series The American Bus Association’s Bus Industry Safety Council (BISC) and Bus Maintenance Repair Council’s (BusMARC) 2021 Virtual Safety & Maintenance Series offered a sequence of educational webinars early this year, covering a variety of industry-related topics.   As part of their ongoing educational webinar series, the American Bus Association (ABA) hosted a virtual meeting with presenter Mike McDonal, BusMARC chair and director of regulatory compliance and industry relations at Saucon Technologies. Panel members included industry experts Robert Hitt (Prevost), David Mailhot (MCI), Michael Anstead (ABC Companies), Ben Kopp (Coach USA), and Anilcan Kapucu (TEMSA). Panel discussion topics covered types of campaigns, campaign process and documentation, customer complaints or requests, identifying vehicles involved in a campaign, notification process of an National Highway Traffic Safety Administration (NHTSA) recall campaign, filing a claim, purchasing, and selling of processed coaches, availability of parts, reimbursement, warranty and campaign management, and internal warranty tracking. What is the difference between a campaign and a recall? Robert Hitt: If it is isolated to one customer, I look at that as something that we are campaigning to improve. When I look at recalls, I look at things like warranty bulletins, national highway transportation safety boards, and safety recalls that notify the customers of all affected coaches. When you look at our bulletins, we have instruction sheets and maintenance information. If a component is changed on a coach and you receive a replacement kit to that particular component, that would involve an instruction sheet. If a fluid has changed or there is an improved product, not necessarily to change under warranty, but something that is going to improve the performance of the coach, then we call that maintenance information. Then of course we have our safety recalls, where we notify customers both by snail mail and email. We also track those coaches in our system, so if they pop up someplace, we are able to notify the operator of any current recalls. How does an OEM identify the vehicles that should be involved in a campaign or a recall?  Anilcan Kapucu: Recalls or service campaigns can come from the factory itself, from a design department by R&D, or can arise from the field, like a customer complaint. After that, the affected vehicle list is prepared by the related department at the factory.   Say there is a faulty headlight which goes off after five days of use, and the manufacturer of that headlight finds a problem in their production or manufacturing process. The bus manufacturer is the one alerting the manufacturer of that specific OEM. At that point that specific OEM may come up with their own findings, identifying the date of the product, the date of the production that starts the fault, parts created from the production line, and the date that the manufacturing process was improved.   Anything between those days should have serial components on the vehicles that were sold. So, with that serial number or the production dates, the affected vehicle list is prepared.   If there is an inconsistency coming from two different departments, then those two vehicles should be checked on the field to be sure that there is no service bulletin, campaign or recall guide.     Who is responsible for initiating a campaign? David Mailhot: Anything can drive or initiate a campaign. A failed parts report, an increase in failed components returned under warranty, complaints, or requests from customers are all considered triggers. Once the data is correlated and evaluated, there are varying levels of campaigns. We have a service information letter, like a product improvement, where we see that if you add a certain component then you might increase the vehicle’s lifespan.  Then we have internal procedures which are what our field staff and service centers use to take care of certain issues. We also have Fleet Campaign Programs or non-safety related campaigns, as well as NHTSA campaigns. How does the initiation of recall differ from that of a campaign? Michael Anstead: Typically, recalls are initiated from the manufacturer. They may notice a product issue that is related to safety or the environment and take it upon themselves to come up with and fill out the form that is required by NHTSA to initiate the campaign. They provide NHTSA with the necessary information regarding the complaint, what they intend to do with the complaint, and expected start date. From there we will report back to NHTSA, informing them that they have been completed every quarter, and the number of vehicles that have been completed. That can last up to two years. Customers can also file a complaint with NHTSA, and NHTSA would end up taking that back to the manufacturer and discussing it with the manufacturer, requesting information pertaining to the failures. Subsequently the manufacturer will then comply and supply NHTSA with that information, whether it is good, bad, or indifferent, as to what their findings are. As an operator, how are you notified that you have vehicles in a campaign or in a recall? Ben Kopp: As a first step, the manufacturer is legally required to notify us of a NHTSA campaign. They will then send an official letter. We normally receive an email before the letter, with the affected bus list, and the manufacturer’s plan of action. From that point we load all the information by vehicle number into our maintenance software and automatically open work orders for every single one of those vehicles. We load the procedure in with the work orders as warranty procedures, so that we know we must follow up with the manufacturer to verify completion with proof of install. As we close work orders, we receive completion data and match it to the manufacturer specifications. We audit ourselves monthly based on that information. Being such a large company, we move our fleet around frequently. With this process it is much easier to track which buses have had work done. Read More >

  • Las Vegas RTC Implements System-Wide Asset Management By:

    By Emma Green Overseeing public transportation, traffic management, roadway design, construction funding, transportation planning and regional planning efforts, the Regional Transportation Commission (RTC) of Southern Nevada serves as both the transit authority and the transportation-planning agency for Southern Nevada. As RTC continues to expand its many services, the physical infrastructure it is responsible for grows increasingly more complex, relying on collaboration between multiple departments.  Historically this has meant each utilizing their own method of tracking, preventative maintenance, and numbering conventions for assets. “It is about breaking down barriers between departments, and even our own business partners,” said Theresa Rand, RTC senior system administrator of enterprise asset management (EAM). “There are tons of asset management systems out there, but for our needs, Trapeze was the right product.” Unlike asset management software used to manage factories or manufacturing plants, Trapeze EAM is catered specifically to the transit market. Trapeze’s EAM solution covers rolling stock such as bus, rail, and paratransit vehicles, as well as facilities, bus stops, and all infrastructure. According to Satpal Bamrah, EAM implementation lead at Trapeze, there are many workflows seen in transit that are not common in other industries. “Because these are unique needs which we see in the transit space, our system is set up and able to support those needs natively,” Bamrah said. Screens and features are specially designed for transit roles such as asset manager, supervisor, technician, or warranty administrator and those associated workflows. Other features focus on asset availability and condition, state of good repair, inspection compliance, incident management, National Transit Database (NTD) reporting, and more.   During the procurement process, RTC staff conducted multiple site visits to a variety of transit agencies using various EAM solutions. Rand noted that during their demo, Trapeze EAM showed a higher success rate than the other vendors due to its transit-specific features and use of organizational change management as part of their deployment approach.  “Our leadership realized what a big implementation EAM would be, and how it would lead to some significant changes in each of the departments’ business processes,” Rand said. Having formal change management is a key success factor of the project, and with all Trapeze staff “speaking transit fluently,” RTC leadership felt that would significantly reduce project risk and lead to a more successful project.  The decision was made to move forward with Trapeze EAM, and RTC’s fixed route and paratransit contractors were quickly looped in as part of the change management system, providing a streamlined reporting process between allied businesses. Accessing automated compliance reporting has enabled RTC to easily oversee various Operating & Maintaining (O&M) partners, all based on specific contract requirements for each.  “It touches our entire agency and business partners,” Rand explained. “Many of our departments are utilizing the system on a daily basis, using it to record the work that’s performed for our assets including fleet buses, paratransit, facilities departments, all of our buildings and everything in them. It has become a very important tool for our entire agency.” The system also includes a robust preventive maintenance (PM) program, easily tailored to fit RTC’s inspection type. The program provides RTC with the ability to report on individual PM checklist items, automate work requests from failed items, and view and report scheduling charts. “In transit, it can be hard to get a perspective on, ‘am I doing things in the most efficient way?’” Bamrah said. “But if you can learn one thing from one department and apply it to another, then you can put that all into one system and generate a huge amount of data that will lead to insights that you may not have had before.”