The Massachusetts Bay Transportation Authority (MBTA) did not ensure the timely completion of preventive maintenance (PM) work orders for visual inspections of its subway track. Our analysis of 6,373 subway track visual inspection work orders revealed that some work orders remained open for several days or even weeks after the scheduled completion date. In addition, we found that some inspection work orders were closed before the scheduled inspection dates, suggesting that either the work was completed before being formally assigned or that the work orders were closed prematurely without the necessary inspections being conducted. Specifically, we noted the following:
- Of these 6,373 work orders, 1,026 (16%) work orders remained open for 6 to 40 days beyond the scheduled PM completion date.
- Of these 6,373 work orders, 26 (0.41%) work orders were closed 1 to 10 days before the date that the PM was scheduled to be completed.
In addition, from our extended sample of 60 scheduled PM work orders, we found 26 (43%) instances where the MBTA had performed the actual inspection on a date other than the date the inspection was scheduled. In 23 of these instances, the inspection had occurred after the scheduled inspection date, meaning that track inspections, including re-inspections of known problems, were delayed. For the remaining 3 instances, the inspection had occurred before the scheduled inspection date.
Open work orders can skew the accuracy of the MBTA’s enterprise asset management system, on which it relies to monitor the condition of its infrastructure. This makes it difficult to track whether these PM tasks have actually been carried out and whether any potential maintenance trends and/or backlogs exist. This undermines the reliability of the MBTA’s enterprise asset management system. Further, not performing inspections on their scheduled date increases risks to people and the MBTA’s physical assets and increases the risk of noncompliance with regulatory requirements, particularly those related to inspection frequency.
Authoritative Guidance
According to Section 151.11 (2)(a) of Title 220 of the Code of Massachusetts Regulation, each track inspection must be made according to the following schedule:
| Type of Track | Required Frequency |
|---|---|
| Light Rail Passenger-service Track | Three times per week with at least one calendar day interval between inspections |
| Heavy Rail Passenger-service Track | Twice weekly with at least one calendar day interval between inspections |
Reasons for Noncompliance
We asked MBTA employees for an explanation regarding the issues identified with their work order management system, but they failed to provide a response. The MBTA has not established a formal policy or procedure detailing the expected time frames for opening and closing PM work orders. We asked MBTA officials on multiple occasions to provide clarity on the expected time frames, but they failed to do so. The MBTA did not have adequate monitoring controls to ensure that visual inspections of passenger service track occur on the scheduled date of inspection.
Recommendations
- The MBTA should ensure that visual inspections of its subway tracks are conducted on time.
- The MBTA should establish a formal policy or procedure that provides clear guidelines for when PM work orders should be opened, completed, and closed. The MBTA should ensure that its staff members adhere to this policy when performing PM activities.
- Once the PM work order system is an accurate reflection of the MBTA’s work in this regard, management should use the PM work order system to effectively monitor ongoing performance and progress in addressing related maintenance of its physical assets.
Auditee’s Response
As discussed in the Draft Report, the MBTA was in the process of implementing a new digital system for the recording and documentation of track inspections throughout the calendar year 2021, the first year of the audit period. As such, and due to the level of effort in retrieving paper records, the SAO’s team was only able to review digital records for the audit period. Over the course of 2021 and 2022, and continuing, the MBTA did a significant amount of training with the Maintenance of Way (“MOW”) teams to ensure that all personnel understood the use of the mobile application and the Enterprise Asset Management System (“EAMS”). Therefore, the MBTA attributes the majority of the non-compliance raised in the Draft Report to training and on-boarding issues in moving to the new digital system. The MBTA acknowledges and agrees with SAO’s recommendations and over the past 3 years the MBTA has addressed these findings and advanced its use of the EAMS and mobile track inspection applications significantly. For each of the SAO’s recommendations for Finding 1, the MBTA provides the following responses:
- SAO Recommendation: The MBTA should ensure that visual inspections of its subway tracks are conducted on time.
- MBTA Response: In the draft report, the SAO provided the following analysis: Of the 6,373 work orders, 1,026 (16%) remained open for 6 to 40 days beyond the scheduled preventative maintenance (“PM”) completion date and 26 (0.41%) of work order were closed 1 to 10 days before the date that the PM was scheduled to be completed. The MBTA notes the audit period coincides with the training and implementation period for the EAMS, so data in this system may not be an accurate representation of all inspections conducted in the field. Since the audit period concluded, the MBTA and MOW employees have significantly advanced their use of the EAMS and mobile track inspections. Over the last 90 days, the same statistics are: Of the 1,203 visual track inspection work orders completed, 35 (2.91%) were finished 6 to 40 days beyond the PM completion date and 23 (1.91%) were finished earlier than the scheduled completion date. The MBTA notes that a schedule deviation does not always indicate non-compliance. As stated in the Draft Report, the requirement for light and heavy track inspections is three and two times per week respectively with at least one calendar day interval between inspections. Inspection schedules may shift at times due to weather, staff availability, or other circumstances.
- SAO Recommendation: The MBTA should establish a formal policy or procedure that provides clear guidelines for when PM work orders should be opened, completed, and closed. The MBTA should ensure that its staff adhere to this policy when performing PM activities.
- MBTA Response: In September 2023, the MBTA issued a Standard Operating Procedure (“SOP”) for Visual Track Inspections. The MBTA has provided the SAO a copy of this SOP with this response.
- SAO Recommendation: Once the PM work order system is an accurate reflection of the MBTA’s work in this regard, management should use the PM work order system to effectively monitor ongoing performance and progress in addressing related maintenance of its physical assets.
- MBTA Response: The MBTA maintains a preventative maintenance and inspection (“PM&I”) dashboard that is reviewed weekly and monthly at various meetings with MOW leadership. The PM&I dashboard includes all safety critical and system critical PM&I that are completed digitally across all infrastructure divisions. The MBTA has provided the SAO with a screenshot of the PM&I dashboard with this response.
Auditor’s Reply
Given its response, including the enhanced training for Maintenance of Way employees on the use of critical information systems, the development of a standard operating procedure document for visual inspections, and the implementation of a PM and inspection dashboard used to monitor the completion and on-time status of safety-critical inspections, we believe that the MBTA is taking appropriate steps to resolve this issue. We will review progress on this issue, including the sufficiency of any new policies and procedures developed by the MBTA, in our post-audit review in six months.
| Date published: | March 10, 2025 |
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