Purpose
The purpose of this white paper is to analyze the hazard of cell phone use while operating a transit vehicle, by examining system safety principles, available information in the public domain, recent transit incidents and policies.
This paper has been arranged into sections, including: background, getting a perspective on the magnitude of the problem, statistics and data from recent studies, transit industry responses, a probability/severity hazard analysis summary of the hazard and, finally, my conclusions.
Background
According to our mission statement, we at Metro Transit deliver environmentally sustainable transportation choices that link people, jobs and community conveniently, consistently and safely. Safety is the cornerstone of what we do. To provide
a safe operation, we must pay attention to the sensitive relationship between safety and operational efficiency. We cannot succeed in our mission unless we consider these aspects inextricably entwined and work to maximize them concurrently.
Metro Transit is a common carrier, and is therefore responsible for providing a level of care that the very prudent and cautious person would undertake for the safety of another. This places a higher legal duty on transit operations than the standard of due care that the reasonable person would exercise for the safety of another.
So then, as a common carrier, it is appropriate for Metro Transit to go to greater lengths to protect its employees, patrons, and the public at large while carrying out its core mission. Furthermore, Metro Transit has a responsibility to do this with
an eye toward its operating, liability and accident damage cost, inasmuch as the taxpayers of Minnesota (and the Federal Government, for that matter) provide a certain amount of funding for transit operations. Operating a transit vehicle is a complex task. It involves multitasking and processing of visual, manual, and mental tasks that enable drivers to assess their temporal and spatial circumstances in order to establish their situational awareness. And it doesn’t stop there. Once a driver has established their situational awareness, they must then use that data to forecast their operating future in order to move their vehicle safely through traffic.
Carrying passengers in a large profile transit vehicle makes it even more important that distractions are kept to a minimum – especially those that can be completely eliminated from the process – like cell phones and other electronic devices.
Getting a Perspective on The Magnitude of The Problem
Rail Transit: Here are some statistics of three recent high-profile commuter rail, railroad, and rail transit accidents in varying stages of National Transportation Safety Board (NTSB) investigation:
● In September 2008, a commuter rail train crashed with a freight train in Los Angeles and 25 people died. The crash was
blamed on an engineer on the commuter rail train texting on a cell phone. The announcement prompted Federal Railroad
Administration (FRA) officials to issue an emergency order prohibiting the use of personal electronic devices by all
railroad employees while operating trains. Damages have been estimated at over $7 million while legal claims against
that public transit agency could exceed $200 million.
● The NTSB also recommended a U.S. ban on cell-phone use by train crews, after a separate investigation of a May 28,
2002, head-on collision of two Burlington Northern Santa Fe Corp. trains that killed one worker. The engineer of a coal
train operating near Clarendon, Texas, was talking on a cell phone and didn't act on orders to stop on a railroad siding so
that another train could pass.
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Hazard Analysis: The Practice of Using Cell Phones While Operating a Transit Vehicle
● In May 2009, about 50 people were injured in Boston when a trolley rear-ended another trolley. The conductor admitted to texting when the crash took place. The cost of the damaged equipment alone was approximately $9.5 million. The
operator was charged with gross negligence for using his cell phone.
Bus Transit: Since bus operators operate with mixed traffic on the general roadway system, it is appropriate to consider the risk that overall cell phone use while driving brings to the safety of our transit operation. According to a Harvard Center
for Risk Analysis study conducted in 2003, it was estimated that there were 330,000 total injuries, 12,000 serious to critical injuries, and 2,600 fatalities attributed to cell phone distraction while driving that year. The cost of this damage and injury has been estimated at $43 billion. According to the National Highway Traffic Safety Administration (NHTSA), drivers are four times more likely to get in
an accident when using a cell phone. Hands free devices don’t minimize the hazard, as it is the conversation that creates the distraction, not the equipment. For example, when a conversation is conducted between two individuals in the same
vehicle, the conversation automatically attenuates in response to traffic conditions. This auto-attenuation does not occur when the driver is conducting a cell phone conversation with someone who is not part of those specific driving
circumstances. Actually, the driver must work even harder, layering a difficult and unrelenting conversation on top of the complex task of operating a vehicle.
Researchers at the University of Utah have concluded that using a cell phone while driving results in the driver missing important driving cues, including regulatory signs and needs for braking, etc. Ultimately, they suggest that cellular phone use disrupts driving performance by drawing certain amounts of brain processes (up to 37 percent) away from the complex task of driving. Further, a 2005 University of Minnesota study concluded that drivers using cell phones demonstrate a higher level of impairment than an intoxicated driver.
Unfortunately, tragic examples exist that support the seriousness of cell-phone-induced distraction while driving:
● In Philadelphia, Pa., a school bus driver has been charged with vehicular homicide after an accident where it was determined that the bus driver had been listening to his Ipod, and using a cellular phone in the process of ignoring ten stop signs and finally colliding with an oncoming car, killing one of its occupants. The same person was previously cited in a November 1999 crash that claimed the life of a two-year-old girl. He told police investigating the earlier crash that he was dialing his cell phone when he ran a stop sign and struck the other vehicle.
● In Cleveland a transit bus driver has been convicted of vehicular homicide in connection with the death of a pedestrian who was struck by the bus while the driver was using a cell phone. Apparently the bus driver was talking on a cell phone
when she struck and killed the pedestrian in a crosswalk in downtown Cleveland.
● The NTSB concluded that a tour bus driver's "cognitive distraction" was to blame for a Nov. 14, 2004, accident after he failed to notice road signs warning of a low-clearance bridge because he was talking on a hands-free cell phone. The top of the bus was ripped off resulting in 11 injuries, one of them critical.
Government Agencies Are Responding To The Hazard
The effects of cell-phone-induced distracted driving in tragic accidents are catastrophic, costly, and far too frequent. The situation is so serious that governments are prohibiting their use by drivers. Government agencies worldwide are active in this effort:
● Worldwide, 45 countries have already banned handheld cell phone use while driving. Japan has had very promising results from its prohibition on cell phone use while driving. In the six months prior to instituting the ban there were 1,473
accidents, 12 deaths, and 2,174 injuries caused by cell phone use. In contrast, there were only 580 accidents, 7 deaths, and 846 injuries within the six months after the ban went into effect.
● In the wake of the 2008 Chatsworth Metrolink accident, the NTSB issued a recommendation to restrict use of cell phones
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Hazard Analysis: The Practice of Using Cell Phones While Operating a Transit Vehicle by train crews on the general railroad system. The FRA responded by issuing an emergency order to that effect.
● Following the 2004 tour bus crash noted above, the NTSB directed a recommendation to the NHTSA, public bus companies school bus associations and unions to “Develop formal policies prohibiting cellular telephone use by commercial driver’s license holders with a passenger-carrying or school bus endorsement, while driving under the
authority of that endorsement, except in emergencies.”
Transit Industry Responses
In 2005 Metro Transit developed and implemented a distracted driving program (for which it received the 2009 APTA Gold Award for bus safety programs) tailored for its operators. Important aspects of the program include training, rules and policy changes and enforcement. A DVD was produced for training bus operators, concentrating on electronic devices while also addressing the vagaries of customer interactions and ill-advised attempts at multitasking while operating (eating, reading maps, etc.).
The seriousness of the electronic device violation was accelerated twice (the most recent being late 2009) for bus and rail operators and enforcement has been stepped up – especially in view of recent accidents in the transit industry, as noted above. The policy prescribes that any electronic device must be turned off and stowed off the person. The cell phone discipline policy changes have been grieved by the Amalgamated Transit Union and an arbitrator has found that Metro Transit has acted appropriately in the establishment and clarification and enforcement of its policies as regards prohibition of the use of electronic devices. Further, those who were suspended for violating this rule were denied unemployment benefits on the grounds that the operator was not laid off but rather disciplined by suspension for misconduct.
Elevating the severity of distracted driving violations is being implemented elsewhere in the U.S. transit industry. In 2009, Boston’s MBTA has established a policy prohibiting cell phone devices while operating any transit vehicle – bus, train, or streetcar. The first instance of violating this policy carries a penalty of a 30 day suspension with recommendation for discharge. According to the policy, the operator is prohibited from having a cell phone anywhere on their person, or anywhere on the vehicle they are operating. In Atlanta, MARTA has implemented one of the U.S. transit industry’s strictest distracted driving policies. It includes all safety sensitive personnel such as operators and maintenance, but also includes anyone driving a MARTA nonrevenue vehicle. Further, it covers all forms of distracted driving including, electronic devices, reading maps, and eating. Employees who are found to have violated the policy are subject to termination.
Analyzing the Hazard Using the Probability/Severity Approach
Qualitative probability/severity hazard analysis is often used in the transit industry for categorizing and prioritizing hazards for mitigation. Applying the process to the hazard of using a cell phone while operating a transit vehicle may help illustrate the seriousness of the problem. The hazard analysis process involves assigning probability and severity categories (outlined in the attached exhibit) to the unmitigated hazard, after determining the most serious credible mishap that might occur as a result of the hazard being left to remain. The probability and severity categorizations are then combined into a risk index that is interpreted according to a widely used procedure documented in the Standard for System Safety, MIL-STD 882, adopted and documented in the Metro Transit bus and rail system safety program plans. Once the hazard is interpreted using the risk index, mitigations are developed and implemented, and the hazard is re-analyzed considering proposed mitigations.
Given the billions of dollars in damage noted above, and lives lost, and the numbers of crashes annually that are attributable to cell phone use while driving, and also considering the rail tragedies that have occurred due to electronic device
Hazard Analysis: The Practice of Using Cell Phones While Operating a Transit Vehicle
distractions, it is appropriate to assign the most serious severity category of catastrophic to the hazard. Again, considering the statistics available, the appropriate probability classification for the hazard would be reasonably probable.
Now then, combining these classifications in order to generate a risk index, the process yields a risk index of 1B, which yields an interpretation of unacceptable. Unacceptable hazards must not be allowed to remain. The traditional means of mitigation involve engineering, education and enforcement, in that order. Absent a robust engineering means of effectively preventing cell phone use while an operator is in charge of a transit vehicle, the best thinking at Metro Transit (and FRA, NTSB, and other governments, for that matter) is to prohibit the practice and enforce the policy.
Reevaluating the hazard with the mitigation in place – assuming that we could have near-total compliance, the hazard severity would remain catastrophic, but the probability would be reduced to improbable. That resulting risk index of 1E would indicate a hazard improved to acceptable with review. This is what we need and compliance with cell phone use prohibition while driving is, at this time, the only reliable way to obtain this measure of system safety. The attached exhibit summarizes the process applied to the hazard of using cell phones while driving.
Conclusions
Metro Transit is a common carrier and must not limit itself by merely complying with the law when it is about the business of providing safe operations – operations that involve our employees, patrons and the public at large. Our service reaches deep into the fabric of the Twin Cities metro area, touching even the lives of those who might never have used our service, but who nevertheless interact with us on any given day as they move about on metro area roads and highways. A great deal of information exists demonstrating that cell phone use during transit operations is an unacceptable hazard; and transit agencies have a responsibility to mitigate this hazard to the extent that political, financial and technological constraints allow.
Metro Transit has recognized the seriousness of the hazard associated with the use of cell phones while driving a transit vehicle in revenue service, and has instituted a program that, if complied with, virtually eliminates the hazard of an accident caused by a transit operator using a cell phone while operating a transit vehicle.
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