From our sample of 60 out of 5,681 rail car PM work orders, we identified a total of 390 deferred defects. Our review of these 390 deferred defects found the following:
- Of these 390 deferred defects, 26 (7%) were documented on the rail car PM inspection report were not documented in the MBTA’s enterprise asset management system, making it impossible for us or the MBTA to verify that the necessary repairs were completed.
- Of these 390 deferred defects, 59 (15%) were documented in the MBTA’s enterprise asset management system were not documented on the rail car PM inspection report, meaning that work was conducted without having been identified by inspectors as being required. Additionally, 160 deferred defect priority codes (41%) did not match between the rail car PM inspection report and the MBTA’s enterprise asset management system.
We also found that the MBTA did not follow its Preventive Maintenance Inspection and Documentation Policy for all Green Line subway car PM inspections. All codes were considered Code A, regardless of severity, instead of assigning the appropriate severity codes for serviceable deferred defects.
If the MBTA does not accurately and consistently document deferred defects and their associated severity codes found during subway car PM inspections, it cannot ensure that all deferred defects are monitored and addressed in a timely manner and in accordance with its Preventive Maintenance Inspection and Documentation Policy. In addition, if the MBTA does not ensure the accuracy of this information, the MBTA’s ability to evaluate the effectiveness of its employees’ efforts to identify and address maintenance needs is limited.
Authoritative Guidance
According to Figure 8 in Section 8 of the MBTA’s Subway Operations Preventive Maintenance Inspection and Documentation Policy, Heavy Rail and Light Rail, the following are the defect severity codes:
Code A Safety Critical / Hold for Repair | This status is assigned to defects that would pose an immediate safety threat to the passengers, operators or others, as determined by the Car House Foreperson. A vehicle with this type of defect is not returned to service until the safety critical / Code A defect(s) is (are) repaired. |
Code B Schedule for Repair (45 days) | Class B repairs need to be completed within 45 days from the inspection. These defects are not a safety concern but must be addressed in the near term to avoid reducing the vehicle’s reliability. This Class indicates that the vehicle may be returned to service temporarily but is scheduled for repair of the defect in the short term. An example of a Code B maybe wheel truing for a flat spot that is not condemnable, but needs to be scheduled for a future date. |
Code C Serviceable | Code C repairs are for cars awaiting delivery of parts that may take longer than 45 days to deliver. This is assigned to defects that are not expected to have a significant effect on safety or reliability, but which are recommended to be addressed to keep the vehicle in a state of good repair. This indicates that the vehicle may be returned to service and the defect will be repaired at the next opportunity. |
According to Section 11.1 of MBTA’s Subway Operations Preventive Maintenance Inspection and Documentation Policy, Heavy Rail and Light Rail, “The Inspection Foreperson will review hard copies and verify that all information was entered into [the MBTA’s enterprise asset management system] correctly.”
Reasons for Noncompliance
The MBTA indicated that, upon completion of a PM inspection, a foreperson reviews the inspection report to ensure the accuracy of the findings. If any updates or corrections are required, the foreperson will make those changes in the enterprise asset management system. However, it was noted that these updates are not always reflected in the actual inspection report itself. This creates a discrepancy between the data in the MBTA’s enterprise asset management system and the inspection report. We were also told that the physical inspection report was the most reliable information concerning PM inspections, rather than the MBTA’s enterprise asset management system. This requires the MBTA to rely on paper records, not its technology system, as the system of record.
Recommendations
- The MBTA should enhance its monitoring controls to ensure accurate and consistent documentation of deferred defects and their associated severity codes found during PM inspections of its subway cars.
- The MBTA should use technology systems to improve the efficiency and effectiveness of its work, including maintenance, to ensure that it has ready access to maintenance, cost, performance, and other data.
Auditee’s Response
The MBTA agrees that it can improve the documentation for deferred defects found during subway car inspections. As discussed with the SAO’s team during the audit, most of the issues with respect to both documentation and properly applying severity codes can be traced to the use of paper inspection forms. These paper inspection forms were completed by hand and discrepancies arose due to different documentation standards at the various car houses. To address these issues, the MBTA is in the process of implementing a Digital Periodic Mileage Inspection to have a consistent process for documenting all inspections across all lines. This will ensure consistency between car houses. This new tool was demonstrated for the SAO’s team and the SAO’s team stated that this was an appropriate solution to address the issues raised.
Auditor’s Reply
Based on its response, the MBTA is taking measures to address our concerns regarding this matter. We believe the effective use of technology tools, along with consistent monitoring of the documentation process, will help address our concerns regarding the inconsistent documentation of the deferred defects in each car house. As part of our post-audit review process, we will follow up on these matters in approximately six months.
| Date published: | March 10, 2025 |
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