Massachusetts Bay Transportation Authority - Finding 2

The Massachusetts Bay Transportation Authority did not ensure that defects identified during inspections of subway tracks were remediated in accordance with its Track Maintenance Standards.

The MBTA did not ensure that subway track defects were remediated in accordance with its Track Maintenance Standards. Specifically, we found the following issues:

• For 42 out of 60 track defects (70%), the MBTA could not demonstrate that it had assessed and verified the condition of the previously identified defect.
• For 22 out of 60 defects (37%), the MBTA could not demonstrate that the required speed restriction had been recorded in the MBTA’s enterprise asset management system.
• For 21 out of the 60 defects (35%), the expected remedial action was not completed within the required time frame.

Recent incidents involving derailments on the MBTA’s Red and Green Lines, which caused injuries and significant delays for passengers, highlight the importance of promptly remediating track defects to prevent future occurrences. The MBTA may be unable to effectively prioritize and address safety hazards if it does not address track defects discovered during inspections according to its Track Maintenance Standards, or if it does not subsequently verify that the defects have not deteriorated further. This could ultimately lead to safety hazards for both MBTA riders and employees.

Authoritative Guidance

According to Section T213.3 of the MBTA’s Track Maintenance Standards,

Green coded track conditions are not exceptions to the MBTA Track Maintenance Standards and do not necessarily require immediate remedial action. Green coded conditions, which have degraded and are approaching the Yellow level should be, at a minimum, verbally communicated to the responsible Section Foreperson and/or Supervisor. Green coded conditions should be monitored on an ongoing basis to prevent deterioration to the next level.

Yellow coded track conditions (or Y) have reached or are closely approaching the maintenance limit for train operation at normal posted speed. As such, Yellow coded conditions are classified as track defects and remedial action should be scheduled to correct the deficiency before it escalates to the next level.

Red coded track conditions (or R) are defects which in every case generate speed restrictions (slow orders) and at the most severe level are grounds for removing effected track from service until repairs can be made. In most cases, Red coded defects should be scheduled for immediate remedial action. These defects are by definition the highest repair priority.

According to the MBTA’s Defect Module Mobile Training Manual, “If [the previously identified defect] has already been recorded, users need to verify the existing defect record is accurately reflected in the field.”

Reasons for Noncompliance

We found inconsistencies between the track maintenance defect codes in the MBTA’s enterprise asset management system and the symptom codes¹³ outlined in the MBTA’s Track Maintenance Standards. The MBTA could not explain why the codes do not match. Additionally, the MBTA does not use the tools available within its enterprise asset management system to document and monitor speed restrictions when necessary. During our audit work, MBTA officials provided contradictory information regarding the process for verifying existing defects. Multiple times throughout the audit, MBTA officials indicated that defect verifications were being recorded electronically in the MBTA defect module. However, when the issue was raised during testing, they suggested that these verifications could have been completed visually and did not necessarily need to be documented in the MBTA defect module. Lastly, the MBTA did not have adequate monitoring controls to ensure that expected remedial action was completed within the required time frame.

Recommendations

1. The MBTA should ensure that defect codes in the MBTA’s enterprise asset management system are able to be traced to its Track Maintenance Standards to ensure the consistent remediation of each type of defect.
2. The MBTA should ensure that speed restrictions for defects that require them are documented in its enterprise asset management system and that systems are in place to ensure that trains abide by these restrictions.
3. The MBTA should ensure that its track inspectors are consistently documenting the verification (physical condition) of existing track defects.
4. The MBTA should implement adequate monitoring controls to ensure that expected remedial action is completed within the required time frame and that this performance is reviewed by appropriate management.

Auditee’s Response

As discussed in the Draft Report and above, the MBTA was in the process of implementing the new digital system for the recording and documentation of track inspections and integrating that with EAMS throughout the calendar year 2021. Over the course of 2021 and 2022, and continuing, the MBTA did a significant amount of training with the MOW teams to ensure that all personnel understood the use of the mobile application and 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 significantly. For each of the SAO’s recommendations for Finding 2, the MBTA provides the following responses:

• SAO Recommendation: The MBTA should ensure that defect codes in the MBTA’s enterprise asset management system are able to be traced to its Track Maintenance Standards to ensure the consistent remediation of each type of defect.
  • MBTA Response: The MBTA was in the process of implementing new priority coding systems during the audit period to ensure defect codes are aligned with the MBTA’s track standards. The MBTA is currently in the process of revising its track standards, with the update scheduled to be completed in the summer of 2025. EAMS will be updated to ensure all defect codes align with any updates to track standards.
• SAO Recommendation: The MBTA should ensure that speed restrictions for defects that require them are [documented] in its enterprise asset management system and that systems are in place to ensure that trains abide by these restrictions.
  • MBTA Response: Between 2022 and 2024, the MBTA has made significant improvements in documentation and monitoring of speed restrictions. This work culminated in the creation of the Track Conditions Dashboard, which allows employees throughout the MBTA, from the MOW division to Senior Leadership such as the COO and General Manager to monitor speed restrictions throughout the system.
• SAO Recommendation: The MBTA should ensure that its track inspectors are consistently documenting the verification (physical condition) of existing track defects.
  • MBTA Response: The MBTA agrees with the SAO’s position on the importance of documenting existing track defects. The MOW division has formally incorporated defect verification into the training curriculum and recertified all systems repairpersons, who are responsible for visual track inspections, throughout the calendar year 2024.
• SAO Recommendation: The MBTA should implement adequate monitoring controls to ensure that expected remedial action is completed within the required timeframe and that this performance is reviewed by appropriate management.
  • MBTA Response: As discussed above, the MBTA is in the process of revising its track standards and anticipate completing the update in the summer of 2025. This revision will contain updates to expected remedial actions and timeframes based on defects identified. 

Auditor’s Reply

Based on its response, the MBTA is taking measures to address our concerns in this area. We will review progress on this issue in our post-audit review in six months. 

13. Symptom codes are the specific codes the MBTA uses to identify and categorize various issues or conditions observed on subway tracks during inspections.

Date published:	March 10, 2025