PVTA could not demonstrate that contracted operating company employees who were considered qualified maintenance employees completed electrical safety training before performing preventative maintenance on BEBs. Specifically, regarding the population of 19 qualified maintenance employees actively employed during the audit period, we found the following:
- Six (32%) out of the 19 qualified maintenance employees did not complete CPR, first aid, and bloodborne pathogen training.
- Eight (42%) out of the 19 qualified maintenance employees did not complete training on the National Fire Protection Association’s 70E (Standard for Electrical Safety in the Workplace).
- Two (11%) out of the 19 qualified maintenance employees did not complete vehicle-specific training for Proterra BEBs.
- Three (16%) out of the 19 qualified maintenance employees did not complete vehicle-specific training for New Flyer BEBs.
If PVTA cannot demonstrate that qualified maintenance employees complete required training on BEB maintenance, then there is a higher risk that PVTA may not detect initial warning signs of electrical and other hazards, leading to vehicle damage and potential injuries to employees and members of the public. Maintenance employees who have not completed the required training may face a higher risk of injury when maintaining BEBs and, without completing CPR, first aid, and bloodborne pathogen training, may not be able to assist others who have been injured.
Authoritative Guidance
According to the Springfield Area Transit Company and Valley Area Transit Company’s (SATCo/VATCo’s) “Electrical Safety Plan,”
Qualified workers must have specific training and equipment to work on or near an exposed, energized electrical sources greater than 50 volts.
Qualified workers employed by PVTA/SATCo must possess the following training qualifications, as well as training specified by their Department Head based on the task and/or equipment being worked on:
- Must have formal [National Fire Protection Association] 70E training within the last 3 years.
- Training must be current for all site safety policies. . . .
- Must maintain First Aid, CPR, [bloodborne pathogen] Certification . . .
- Must have formal training on specified vehicles.
Reasons for Issue
According to PVTA officials, the employees identified in our finding were not required to take electrical safety training because SATCo/VATCo’s “Electrical Safety Plan” only requires electrical safety training when employees work on or are near exposed energized electrical sources that are greater than 50 volts. However, our review of preventative maintenance tasks performed by the 19 employees in our sample found that inspections of high-voltage components (greater than 50 volts) on Proterra and New Flyer BEBs were routine parts of the preventative maintenance schedules that they completed.
Recommendations
- PVTA should establish monitoring controls over its training program to ensure that qualified maintenance employees who work on BEBs receive required electrical safety training, including CPR, first aid, and bloodborne pathogen training.
- PVTA should ensure that qualified maintenance employees complete the electrical safety training required by SATCo/VATCo’s “Electrical Safety Plan.”
Auditee’s Response
PVTA disagrees with the statement regarding: “the sample found that inspection of high voltage components on BEBs were routine part of the preventive maintenance completed.”
It is important to understand that there are no tasks associated with the scheduled preventive maintenance [(PM)] inspections which expose a technician to energized electrical sources greater than 50 volts. No task in the preventative maintenance schedule of the BEBs creates this condition/hazard thus, the technician conducting the PM inspection is not required to be a qualified electrical worker (QEW) as indicated in the SATCo/VATCo Electrical Safety Plan. The hazards and necessary precautions related to high voltage work were understood by PVTA and its contracted operators when the buses were delivered. PVTA contractors have been maintaining Hybrid-Electric buses for over 15 years. These buses have high voltage systems on board that share many of the same components as a BEB, requiring the same precautions and skills when performing certain maintenance tasks.
The PM inspection procedure is as follows:
- Foreman generates the work order and prints the appropriate 6000-mile inspection sheet and assigns it to a technician and a service bay.
- Technician performs the various PM, safety and [Americans with Disabilities Act] compliance inspections listed and annotates any deficiencies on the inspection sheet.
- Mechanic may communicate at various times with the foreman to determine whether defects identified should be corrected immediately or scheduled. For BEBs, defects identified as related to the high voltage, high voltage propulsion, or energy storage systems are scheduled for repair by the foreman. Any Specific work on BEBs, besides the scheduled PM inspection, generate a work order than is assigned to a QEW technician if related to the high voltage, high voltage propulsion, or energy storage systems.
- Once all activities are complete and the mechanic has performed a satisfactory road test, the inspection and work order are returned to the foreman for final review.
Source: SATCo/VATCo/[University of Massachusetts (UMass)] Maintenance Plans
In November of 2021, New Flyer [provided] Maintenance Orientation training (8hrs) to SATCo, VATCo, and UMASS maintenance teams. The “Maintenance Orientation” training covered basic maintenance needs as well as high voltage safety and awareness providing sufficient knowledge for the visual inspections and routine maintenance associated with BEB PMs. To date, the only work requiring a Qualified Worker is repair maintenance. PVTA follows its Electrical Safety Plan when conducting repair maintenance.
Training is offered to all mechanics to transition them into QEWs as the alternative fuel vehicle program is developed regardless of whomever is eventually designated as the “Qualified Electrical Worker” within the department. However, contract operators cannot force an existing mechanic to train to be a QEW.
Auditor’s Reply
We acknowledge PVTA’s position that scheduled preventative maintenance inspections do not expose technicians to energized electrical sources greater than 50 volts. However, we respectfully disagree. Preventative maintenance schedules for BEBs include routine inspections of energized high-voltage components such as a 620-volt lithium-ion battery, a 230-volt HVAC unit, and cables and their connections, and technicians must be in close proximity to these components to conduct said inspections. Therefore, we believe that preventative maintenance technicians who are near high-voltage electrical components qualify as “qualified workers,” as defined in the “PVTA Agency Safety Plan.” We emphasize the importance of PVTA ensuring that qualified maintenance employees complete the required BEB maintenance training, which will help them detect initial warning signs of electrical and other hazards that can lead to vehicle damage and/or potential injuries to employees and members of the public.
As part of our post-audit review process, we will follow up on this matter in approximately six months.
| Date published: | July 1, 2026 |
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