June 26, 2023, was the Federal Transit Administration’s (FTA) deadline for the public to respond to their Notice of Public Rule Making (NPRM) on forming new Public Transportation Agency Safety Plans (PTASPs.)

FTA requested public comments on how to keep bus operators safe on the job, and as a union SMART Transportation Division answered the bell.

The National Legislative Department would like to thank all of our bus members for their time, efforts, and the quality of the ideas shared while we were putting together our response. SMART-TD reached out to you, and you answered. We truly are an organization that can only be as strong as our members and your assistance was highly appreciated.

As a result of the feedback we received from multiple bus members, Bus Vice Presidents Calvin Studivant and Alvy Hughes, as well as Anthony Petty, representing our members from SEPTA in Philadelphia, Pa., SMART-TD’s team submitted a strong response.

Unlike many responses they received, ours was fueled by information and creativity that came straight from the front lines.

Thank you all for your efforts to keep yourself as well as your union brothers and sisters safe at work and both represented as well as respected in the PTASP development process.

Read the submission to FTA (PDF)

On April 26, the Federal Transportation Agency (FTA) posted a Notice of Proposed Rule Making (NPRM) regarding public transportation agency safety plans. The agency is seeking feedback and suggestions from bus employees and other interested parties on what changes federal overseers can make in public transportation that would result in safety improvements for bus operators, riders and pedestrians alike.

The SMART Transportation Division intends to file a public comment on behalf of our bus members. We need our members in bus service to help us tell your story. The stakes get no higher than keeping you and your riders safe. We hope all our bus members take the time to consider and share what changes in regulations, training, maintenance practices and bus design would be most vital in keeping you as safe as possible as you do your incredibly valuable work.

SMART-TD’s National Legislative Department is working with both vice presidents of the Bus Department to build the best argument possible; however, SMART-TD is fully aware that you are ultimately the experts on this topic, and we are asking for your input and ideas on this project.

Topics currently being considered for inclusion in our NPRM response include the items listed below. These topics have not been decided on at this point and are in no way ordered by priority.

Pedestrian Safety

  • Changing the rearview mirror and camera placement to eliminate blind spots;
  • Addressing windshield design;
  • Addressing fare box placement to get them out of the operator’s line of sight;
  • Audible announcements telling pedestrians the bus is turning and in which direction.

Operator Safety

  • Mandating the installation of driver barriers that do not have access points allowing riders to physically touch operators;
  • Having doors built into the left side of the bus allowing the operator to exit the bus separate from the riders;
  • Disallow transit companies from disciplining operators for leaving their seats in the case of an emergency or in the use of their de-escalation training;
  • Additional de-escalation training;
  • Two-way radios;
  • Silent alarms;
  • Public Address posters in the cab of all public transit vehicles describing elevated criminal penalties for assaulting transit workers.

Rider Safety

  • Passenger education ad campaigns;
  • Announcements over loudspeakers at bus terminals;
  • Transit police funding for both large- and mid-sized markets;
  • Rider ambassador programs;
  • “Call 9-1-1” alerts to be displayed on destination or next stop signs.

Mechanics’ Safety

  • Training and certification in repairing electric and alternative fuel buses safely;
  • Federal intervention on bus manufacturers voiding warranties when our mechanics make repairs.

Public Policy

  • Increased federal penalties for assaults on transit workers;
  • Federal requirements for all bus carriers to report rider incidents reported by operators, and FTA compiling these into reports made available at regular intervals.

Health Safety

  • Cashless fares;
  • Mask mandates.

If you would like to contribute additional topics for us to consider, please reach out to SMART-TD Government Affairs Representative Dan Banks by June 2. He can be reached by email at dbanks@smart-union.org, or by phone at (216) 227-5450. Please engage in this process and allow SMART-TD to fight for you armed with the best information and ideas possible.