The Massachusetts Bay Transportation Authority Did Not Ensure That Block by Block Employees Were Trained on Operations and Safety Before Being Assigned to Subway Station Locations.

Due to the importance of the safety and operational provisions in this contract, the MBTA should ensure that its contracted service provider’s employees complete these trainings before being assigned to subway station locations.

Overview

The Massachusetts Bay Transportation Authority (MBTA) did not ensure that Block by Block (BBB) employees were trained on MBTA operations and safety before being assigned to MBTA subway station locations. Specifically, for our sample of 60 BBB employees who were employed during the audit period, we identified the following issues:

• The MBTA could not demonstrate that 2 (3%) out of the 60 BBB employees in our sample had completed MBTA safety training.
• The MBTA did not train an additional 16 (27%) BBB employees in our sample of 60 on MBTA safety before assignment to a subway station location.              
• The MBTA could not demonstrate that any of the 60 BBB employees in our sample received MBTA operations training.
• The MBTA could not demonstrate that 2 BBB employees in our sample of 60 had completed the operations and safety trainings before being assigned to subway station locations because the MBTA was unable to provide documentation supporting the BBB employees’ initial subway station location assignment dates.

Due to the importance of the safety and operational provisions in this contract, the MBTA should ensure that its contracted service provider’s employees complete these trainings before being assigned to subway station locations.

A lack of training or untimely completion of training increases risk to the safety and operations of MBTA subway station locations. This could jeopardize the safety of riders and the general public, while putting contracted employees at risk because they are sent into the field without being properly equipped to perform their jobs safely and effectively.

Authoritative Guidance

The MBTA’s Request for Proposal No. 41-17 for  In-Station Customer Service requires that BBB staff MBTA subway station locations with “trained and qualified individuals.” Under this request for proposal, the MBTA is responsible for training BBB employees on MBTA operations and safety.

Section 2.7 (see Appendix B) in the Scope of Work document of the MBTA’s Request For Proposal No. 3-22 for In-Station Customer Service Operations states, “For the duration of the contract term, all subsequent [BBB employee] hires are required to complete MBTA initial training before being deployed to a station post.”

Reasons for Issue

The MBTA did not have sufficient policies and procedures, including a monitoring component, to ensure that BBB employees were trained on MBTA operations and safety before being assigned to a subway station location and that it retained a record of training assignment and completion for each such employee.

Recommendations

1. The MBTA should develop, document, and implement sufficient policies and procedures, including a monitoring component, to ensure that BBB employees are trained on MBTA operations and safety before being assigned to a subway station location to promote safe and effective operations for its riders and employees.
2. The MBTA should ensure that it retains records of training assignment and completion for all employees assigned to MBTA subway station locations.
3. The MBTA should ensure that it maintains accurate personnel and operational records (including but not limited to staffing levels per subway station, dates, and location of deployment) for employees.             
4. The MBTA should consider collaborating with BBB to reevaluate the training curriculum for newly hired BBB employees to ensure that it is sufficient.

Auditee’s Response

The MBTA provided documentation that all sixty (60) of the sampled BBB employees were trained on operations and safety before being assigned to any independent shifts at subway stations. Specifically, the MBTA produced and maintains tracking spreadsheets and data from BBB’s scheduling systems that document the training dates for all Transit Ambassadors (“TA”) [throughout this report, the Office of the State Auditor (OSA) refers to TAs as BBB employees].

From the sample, the MBTA was unable to provide the sign in sheets requested by the [OSA] to satisfy their request for documentation. The MBTA was, however, able to provide other documentation that all sixty (60) TAs completed operations training. This is also true for the safety training for the sixty (60) TAs within the sample. The MBTA was able to produce tracking spreadsheets and data from BBB’s scheduling system for the sixty (60) TAs within the sample and sign-in sheets documenting safety training dates for all but two (2) TAs within the sample. BBB would not deploy any TA to the field without the appropriate and necessary operations and safety training. Without the required trainings, the TAs would not be able to perform the essential functions of their job.

The audit also found that [16] of the TAs from the sample did not receive safety training prior to their individual assignment to a subway station. The MBTA disputes this finding. Specifically, the MBTA provided information to the [OSA] that showed for three (3) of the [sixteen (16)] TAs the deployment date information initially provided was incorrect, with one TA being assigned to an on-the-job training shift with an experienced TA and the two additional TAs having errors in their deployment dates.

For the remaining 15 TAs, they were deployed to the Green Line after completing the in-class safety training modules but prior to completing the hands-on-module of safety training. The primary purpose of the hands-on module training is to teach TAs how to deploy a bridge plate. The Green Line does not utilize bridge plates and as such, the lack of this training did not present any risk to Green Line customers or the TAs serving the Green Line.

The reason for the delay of the hands-on module of safety training was due to the scheduling availability between the in-classroom module, conducted by [Massachusetts Department of Transportation] instructors and the hands-on module, conducted by MBTA Training School instructors. The . . . safety training requirement was implemented during the audit period by the Transportation Safety Administration (TSA). The TSA required all transit workers to complete [safety] training. All current and new TAs were required to complete the new [safety] training, including those who had previously completed the MBTA Safety and Security training. Given the large number of people needing to complete [safety] training, including MBTA employees and contractors, it was not possible to get everyone trained in a timely manner. This created staffing challenges and required BBB to assign new hires to the Green Line, prior to the completion of a training module not relevant to the Green Line, but after receiving in-class safety training and operations training. These 15 TAs did ultimately attend the hands-on-module of safety training and were then eligible to be assigned to stations throughout the system. As existing TAs have been retrained and BBB has improved recruiting and training of TAs, this practice of deploying TAs to the Green Line prior to the completion of the hands-on-safety training module is no longer occurring.

Auditor’s Reply

The MBTA asserts in its reply that it provided training documentation for all 60 employees in our sample; however, that evidence was not sufficient, despite the Office of the State Auditor (OSA) providing multiple opportunities for the MBTA to support that it provided this training. While we received documentation to support that some of the 60 employees sampled completed safety training, we did not receive documentation to support that any of the 60 employees obtained operations training. Specifically, as explained above in our finding, (1) the MBTA could not demonstrate that 2 (3%) out of the 60 BBB employees in our sample had completed MBTA safety training; (2) the MBTA did not train an additional 16 (27%) BBB employees in our sample of 60 on MBTA safety before assignment to a subway station location; (3) the MBTA could not demonstrate that any of the 60 BBB employees in our sample received MBTA operations training; and (4) the MBTA could not demonstrate that 2 BBB employees in our sample of 60 had completed the operations and safety trainings before being assigned to subway station locations.

In April 2024, the MBTA provided us with sign-in sheets documenting the date of safety training along with each BBB employee’s signature. We were able to trace all but two BBB employees to sign-in sheets. The MBTA also provided us four Microsoft Excel spreadsheets, one of which was created in April 2024, as purported evidence of operations training that the MBTA indicated occurred in 2021 and 2022. The remaining three had been edited in April 2024. We were unable to substantiate whether these spreadsheets were altered prior to receiving them. This is unsatisfactory, as one of the documents was created two to three years after the training was reportedly conducted, while the others were edited prior to delivery to OSA and do not provide proof that the training occurred. Such proof might include sign-in sheets, certificates of completion, or other documentation that evidences the completion of training, rather than an attestation without evidence.

The MBTA also states in its response that 15 of the BBB employees were deployed to the Green Line after completing the in-class safety training modules but before completing the hands-on-safety training module, and that it did not perceive this as a risk to Green Line customers. However, because MBTA does not have policies or procedures that verify that this is an active practice, and given that the request for proposal (RFP) /contract states that subway station locations will be staffed with “trained and qualified individuals,” we could not accept this statement as satisfactory evidence for why the BBB employees were not trained before being assigned to subway station locations. In short, the practice communicated to us by the MBTA—deploying untrained staff to the field—was in violation of its own rules. If the MBTA believed that it was appropriate to deploy untrained staff members to the field, it should have adopted policies and procedures to permit this and should have notified BBB and others that this change occurred. By failing to take these steps, the MBTA’s statement cannot be viewed as policy or something that was approved by the MBTA, but rather noncompliance that is being justified as appropriate after the fact, without evidence.

The MBTA also mentions in its response that there were training delays due to scheduling availability, staffing challenges, and a large number of BBB employees who needed to be trained during the audit period; however, given the importance of ensuring the safety of riders, contracted employees, and the general public, we strongly encourage the MBTA to implement our recommendations in this area.

Date published:	July 7, 2024