Merrimack Valley Transit (MeVa) did not ensure that employees of its contracted operating companies completed required newly hired employee safety training or de-escalation training. Specifically, we identified the following issues:
- For required newly hired employee safety training during onboarding, MeVa could not demonstrate that any of the 10 sampled newly hired employees of MeVa’s contracted operating companies had completed all required safety trainings that were applicable to their positions. In some instances, MeVa provided us with signed acknowledgments of receipt of employee handbooks and other company policies; however, these documents do not demonstrate that employees completed all the required safety trainings relevant to their roles.
- For quarterly safety refresher trainings, MeVa could not demonstrate that any training was provided for six out of the eight quarters in the audit period.
- For de-escalation training, MeVa could not demonstrate that 21 out of the 122 employees of its contracted operating companies who were hired before July 2023 had completed the initial de-escalation training. In addition, MeVa could not demonstrate that any of the 13 employees who were hired after July 2023 had completed de-escalation training during onboarding.
Additionally, we reviewed discipline log entries maintained by MeVa’s contracted operating companies for the audit period and identified 31 employees who had documented preventable accidents that required them to complete retraining in accordance with the “Progressive Discipline Policy” for each of MeVa’s contracted operating companies. However, MeVa could not demonstrate that any of these 31 employees completed the required retraining. MeVa provided a spreadsheet that listed post-accident retraining dates for some of the sampled employees. However, this documentation does not demonstrate that the required retraining was actually completed.
A lack of training could jeopardize the safety of riders and the general public. It also increases the risk to MeVa’s safety and operations, putting employees of MeVa’s contracted operating companies at risk because they are sent into the field without being fully equipped to perform their jobs safely and effectively.
Authoritative Guidance
According to Section 673.29(a)(1) of Title 49 of the Code of Federal Regulations (CFR),
A transit agency must establish and implement a comprehensive safety training program that includes de-escalation training, safety concern identification and reporting training, and refresher training for all operations transit workers and transit workers directly responsible for safety in the transit agency’s public transportation system. The training program must include refresher training, as necessary.
According to MeVa’s Public Transportation Agency Safety Plan,
Quarterly refresher training is provided. Bus and van vehicle operator retraining for recertification or return to work is provided. Retraining is also administered for the drivers after preventable accidents. The length and type training depend on the nature of the accident and how many accidents the employee has had previously. General refresher training is also administered throughout the year based on specific safety issues that have arisen.
According to Merrimack Valley Area Transportation Company’s (MVATC’s) “Progressive Discipline Policy,”
Operators will be subject to disciplinary action, up to and including discharge, for accidents which are judged to be preventable. The following is the process for administering progressive discipline for preventable accidents occurring within a twelve (12) month rolling period:
- 1st Occurrence—written warning with a minimum of one (1) hour of paid retraining for cause of accident.
- 2nd Occurrence—1 day working suspension with a minimum of two (2) hours paid retraining for cause of accident.
- 3rd Occurrence—5 day suspension without pay and final warning, with eight (8) paid hours of overall bus operator retraining.
- 4th Occurrence—Discharge.
According to Special Transportation Services’ (STS’s) “Progressive Discipline Policy,” the progressive discipline process is the same for preventable accidents, but it applies to preventable accidents that occur within a rolling 24-month period.
Reasons for Issue
MeVa did not have sufficient policies and procedures, including a monitoring component, to ensure that employees of MeVa’s contracted operating companies completed required safety trainings or that the contracted operating companies retained, for each employee, a record of their training assignment and completion. According to MeVa officials, the MVATC assistant general manager during the audit period did not want individual sign-in sheets to be included in employee files for post-accident retraining because he believed it could lead to a union grievance. This approach changed under the new MVATC general manager hired after the audit period.
Recommendations
- MeVa should develop, document, and implement sufficient policies and procedures, including a monitoring component, to ensure that employees of its contracted operating companies complete required safety trainings. This should include newly hired employee safety training, quarterly refresher trainings, de-escalation training, and any required retraining resulting from documented preventable accidents.
- MeVa should ensure that it retains records of training assignments and completions for all employees of its contracted operating companies.
Auditee’s Response
In regards to training, the snapshot in time ([fiscal year 2023 and fiscal year 2024]) does not reflect current practices. Both the General Manager (GM) and Assistant General Manager (AGM) during the review period, who are essential to the success of proper employee file documentation, were replaced in July 2024 ([fiscal year 2025]). New policies and procedures for training were put into place during late [fiscal year 2024] and [fiscal year 2025] to ensure better documentation, and verifiable proof that the trainings took place. The lack of documentation, although giving the appearance that the trainings did not take place, does not mean that the trainings actually did not take place. The importance of this documentation was expressed to the Training Officers and the new Operations Management Team in 2024 and practices to rectify [the issues] were established. . . .
MeVa has put the training monitoring activities into a policy to document actions that have been implemented since [fiscal year 2025]. MVATC has already implemented documentation that would be accepted as attendance evidence since meeting with the audit staff this past year. Review of this documentation will be part of the monitoring activities.
Auditor’s Reply
We acknowledge that the audit review period may not reflect MeVa’s current practices or any updates made since then, including changes in management and training procedures. However, without proper documentation, we cannot confirm that the required training took place during the audit period. Without adequate supporting documentation, such as training sign-in sheets or certificates of completion, there is inadequate assurance that all applicable employees completed the required trainings. Proper documentation is a fundamental internal control to demonstrate compliance with training requirements and to provide verifiable proof that trainings were delivered and completed. As part of our post-audit review process, we will follow up on this matter in approximately six months.
| Date published: | May 5, 2026 |
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