Massachusetts Bay Transportation Authority - Finding 3

The Massachusetts Bay Transportation Authority did not always perform preventive maintenance inspections on its subway cars at the required intervals.

The MBTA did not always perform required PM inspections on its subway cars at the required intervals. Our analysis revealed that 24 (0.5%) out of the 4,965 completed work orders we examined failed to meet the required inspection intervals based on either time or mileage. Specifically, we found the following:

• One Green Line Number 8¹⁴ car was not inspected within the 90-day interval.
• Seven Green Line Number 8 cars were not inspected within the 10,000 mile or 180-day interval.
• One Green Line Number 9 car was not inspected within the 10,000-mile interval.
• Six Green Line Presidents’ Conference Committee cars were not inspected within the 30-day interval.
• Three Red Line Number 1 cars were not inspected within the 8,500-mile interval.
• Three Red Line Number 2 cars were not inspected within the 8,500-mile interval.
• Two Red Line Number 3 cars were not inspected within the 15,000-mile interval.
• One Orange Line Number 14 car was not inspected within the 15,000-mile interval.

Regular inspections of subway cars are critical to ensuring the safe and efficient operation of the MBTA’s subway system. Without timely inspections, mechanical issues could go unnoticed, increasing the likelihood of equipment failures, potentially leading to accidents or derailments. This could jeopardize the safety of riders and the general public. Failure to conduct timely inspections can also increase the complexity and cost of addressing problems that exist.

Authoritative Guidance

According to the MBTA’s Equipment Engineering and Quality Assurance Vehicle Inspection Guidelines, the following is the lifecycle management strategy for inspection and PM for subway cars:

Lifecycle Management Strategy	Frequency
Red Line PM Inspections—Number 1 and 2 cars	8,500 miles
Red Line PM Inspections—Number 3 cars	15,000 miles
Orange Line PM Inspections—Number 12 cars	12,000 miles or 90 days
Orange Line PM Inspections—Number 14 cars	15,000 miles
Blue Line PM Inspections—Number 4 cars	7,500 miles
Blue Line PM Inspections—Number 5 cars	12,000 miles
Green Line PM Inspections—Number 7 cars	7,500 miles
Green Line PM Inspections—Number 8 cars	90 days (effective until September 30, 2021)
Green Line PM Inspections—Number 8 cars	10,000 miles or 180 day (effective as of September 30, 2021)
Green Line PM Inspections—Number 9 cars	10,000 miles
Green Line PM Inspections—Presidents’ Conference Committee cars	30 days

Reasons for Noncompliance

The MBTA did not have adequate monitoring controls to ensure that inspections of its subway cars occurred at the required intervals. According to MBTA officials, the Federal Transit Administration (FTA) allows for a 10% compliance variance for PM activities. Although the MBTA was operating well below this threshold during the audit period—with a variance of only 0.5%—we believe that any level of noncompliance increases risk to the safety of riders and employees and indicates that the process in place during the audit period needed improvement. We also note that the MBTA did not adopt this 10% standard as its own standard, meaning that the MBTA failed to meet its own standard, regardless of what was permitted by the federal government’s more lax standards.

Recommendation

The MBTA should implement adequate monitoring controls to ensure that inspections of its transit subway rail cars occur at the required intervals.

Auditee’s Response

The MBTA disagrees with the SAO’s finding that the MBTA performed preventative maintenance on its subway cars at the required interval “to an unsatisfactory extent.” The MBTA agrees that regular inspections of subway cars are critical to ensure the safe and efficient operation of the MBTA’s system and the SAO’s themselves have made it clear that the MBTA is [overwhelmingly] successful in completing its preventative maintenance inspections. Understanding the practical realities of operating a transportation system, especially one as large as the MBTA’s system, the Federal Transit Administration (“FTA”) allows for a 10% variance in conducting preventative maintenance inspections on subway cars. Nonetheless, over the two-year audit period, the MBTA completed 4,941 out of 4,965 or 99.5% of preventative maintenance inspections. The MBTA disagrees with the SAO’s statement that the MBTA “failed to meet its own standard.” The FTA standard and allowance of 10% variance is the standard the MBTA must meet for the preventative maintenance of subway cars, which the MBTA far and away exceeded. Further, the subway cars referenced in the Draft Report were immediately removed from service upon discovery of the need for the required preventative maintenance inspections. Finally, in line with the SAO’s recommendation, the MBTA now has a system in place which notifies the maintenance team when any subway car gets within certain mileage ranges of the next required preventative maintenance. 

Auditor’s Reply

We acknowledge that the FTA allows for a 10% variance in conducting PM inspections of its subway cars. However, the MBTA’s Equipment Engineering and Quality Assurance Vehicle Inspection Guidelines state that “mileage-based inspections are to be conducted within 1,000 miles of that scheduled” and “time-based inspections are to be conducted within 10 days of that scheduled.” The MBTA developed these guidelines to satisfy the requirements of the Department of Public Utilities (DPU), which regulates the preventive maintenance that is audited by the FTA. This standard is, at times, more and less stringent than the FTA’s 10% variance. For example, for Red Line PM inspections for number 1 and 2 cars, the MBTA standard allows for up to 9,500 miles (8,500¹⁵ + 1,000) before an inspection is considered noncompliant. However, using the FTA’s 10% variance, it is allowed up to 9,350 miles (8,500 + 850) before an inspection is considered noncompliant. Additionally, for Blue Line PM inspections for number 5 cars, the MBTA standard allows for up to 13,000 miles (12,000¹⁶ + 1,000) before an inspection is considered noncompliant. However, using the FTA’s 10% variance, it is allowed up to 13,200 miles (12,000 + 1,200) before an inspection is considered noncompliant. If the MBTA intends to adhere to the FTA’s 10% variance guidance, its own standards should not contradict this allowance. In the examples provided, the MBTA’s standards for Red Line number 1 and 2 cars permit a greater variance than the FTA’s guidelines, making them less stringent. However, for Blue Line number 5 car, the MBTA’s standard is more stringent and does not meet the 10% variance allowed by FTA.

We appreciate the MBTA’s acknowledgment of our recommendation and commend the agency for installing a system that addresses our concerns regarding the PM inspections of its subway cars, which were not being performed at the required intervals. As part of our post-audit review process, we will follow up on this matter in approximately six months.

14. The MBTA uses a sequential numbering system for its subway car fleet based on the vehicle’s date of implementation. For example, the first fleet of Red Line rail cars deployed are designated as Number 1 cars, the next fleet of cars would be Number 2, and so on.
15. Red Line PM Inspections—Number 1 and 2 cars have a frequency of 8,500 miles between PM inspections.
16. Blue Line PM Inspections—Number 5 cars have a frequency of 12,000 miles between PM inspections.

Date published:	March 10, 2025