Seven Steps to Safety

Seven Steps to Safety


By Paul Comfort

© 2017 Paul Comfort, All Rights Reserved


Great safety is no accident.  It takes seven steps to really improve safety performance in your operation.  I know, I’ve taken transit properties to industry leading accident frequency rates (AFR) and been on leadership teams that have literally turned around plummeting safety performance and made it a national model. Let’s discuss.

Step 1 – Define Safety Performance

Before you embark on your journey to improve your agency system’s safety be sure you know and what to measure.  Like a wise man once said, “Be careful not to climb the ladder of success only to find out at the end of your life that it was leaning against the wrong wall”.

While working at major city transit system I noticed that the AFR for our paratransit service was too high and our benchmark was 2.0 preventable accidents per 100,000 miles (a good industry P-AFR average) but we were sometimes over 4 P-AFR.  When I looked into comparing our rates with other cities I noticed that theirs were often a lot lower but when I looked at how they defined an accident versus how we did, I quickly realized why they were “outperforming” us.  Their definition of an accident was much different than ours.  I kid you not, our agency was counting curb strikes/bumps and the like as reportable “accidents” instead of incidents like most of the rest of our peers.

As I surveyed the industry I noticed that many used a version of the National Safety Council definition of an accident and it seemed to include all that was needed – “An accident is an undesired event that results in personal injury or property damage”.  An “incident is an unplanned, undesired event that adversely affects completion of a task”.  By adopting this nationally accepted definition of accident and driving performance by it our accident rate dropped to below 2.0 P-AFR and stayed there for the next two years. Curb strikes and other minor incidents that caused no property damage or injury were still tracked and addressed but damage/injury causing incidents became the focus of our efforts to improve safety and it worked.



Step 2 – Track all Safety Data

In order to address behavior causing accidents you need to track safety related incidents relentlessly.  This means mandatory reporting of all incidents by drivers or employees that meet certain criteria.   You must require this clearly in writing and have every employee sign a document stating they understand these must be reported that failure to report an accident or incident is just cause for job discipline up to and including termination of employment.  If we really are going to make Safety #1 – we have to treat it as the top priority for all employees.

Accidents should be reported immediately and investigated.  The data from the accident should be entered into tracking software and accident cause and effect categorized.



Step 3 – Trend Safety Data

To really drive down accidents you need to understand the trends of your employees.  Take the data you gathered in Step 2 and aggregate it into spreadsheet form tracking accident categories over the past year, quarter and month and look for trends.  Are they hitting low overhangs, is backing a problem, do mirrors often get struck by opposing traffic?

This type of trend analysis can assist you as you work to improve your AFR.  You need to understand what are the top categories of accidents and focus your efforts on reducing them.

Do not make mountains out of molehills.  If you have one or two high profile accidents it can often disorient you and cause you to spend most of your time on “one – offs” instead of real change for your whole driver force that can improve your overall safety record.



  1. Perform a Root Cause Analysis

Now that you know the trends and where most of your accidents are occurring, do a deep dive and figure out what’s causing them.  It’s not hard.  In DC the trends showed our paratransit vehicles getting a lot of mirror strikes, often when the driver was at the door of the passenger.  The root cause analysis showed that because our vans often had to park on the street in front of a passenger’s house, sometimes drivers behind them would just swerve around the van and hit their side mirrors or tight traffic and street parking caused opposing vehicles to hit our side view mirrors.

We also noticed operators were too often driving under overhangs at fast food restaurants, medical centers etc… and hitting the top of their van roofs.  A root cause analysis showed that drivers often wanted to get their lunch fast at a drive through but didn’t always remember that their van had a high clearance of 11 feet.  So they would hit the overhang at the drive through of the restaurant.  Or when they were pulling up to a hospital or medical center they would drive under the overhang not noticing the clearance to pick up a passenger and hit their roof.

In Baltimore I noticed that too many operators of our fixed route buses were being assaulted by passengers – either physically or by having stuff thrown at them.  A root cause analysis showed many different reasons why passengers would assault drivers including fare disputes and simple unruly behavior and the drivers would often not have their “driver shield” in place. This is a “Dutch door” with a heavy plexiglass top that protects the driver.  We noted that during driver assaults most often the operator would only have the bottom part closed with the top part left open so that passengers could reach to the operator.

None of these root cause analyses were “rocket science”.  They were easy to figure out what was really causing these accident/incident trends.  Now to figure out how to stop them.



  1. Develop a Strategy

After analyzing and determining the root cause of your highest trending accidents you need to develop a strategy to attack their root causes. This often involves a discussion with drivers, road supervisors, safety leaders and senior management.  These discussions can take place at your monthly safety meetings where you review your safety trends or in regular management meetings.  Again, the strategy isn’t that complicated usually but it should involve all parties mentioned above to ensure you haven’t overlooked a unintended consequence of your proposed strategy.

In our example of mirror strikes by surrounding traffic a simple fix was found.  If we fold in the mirrors when leaving the vehicle in an on street parking situation it should reduce mirror strikes. And these type of accidents are often considered “non-preventable” because the driver isn’t in the vehicle but as you can see – they really are preventable with the right approach.  Even if considered non- preventable they still put a vehicle out of service and require costly repairs.

For reducing hitting overhangs our strategy was two pronged – remind drivers of their 11′ roof clearance and do not allow them to use fast food drive thru’s.  Often drivers must go under overhangs at hospitals etc… to provide true curb to curb service as required under ADA.  So we couldn’t simply prohibit them all together but we needed to have them be more mindful of their van roof clearance.

As for lunch – they can park and eat in.  No more using drive thru’s for food in the agency van as this is not required under ADA and they had enough time to park and eat in the restaurant.  This had the added benefit of reducing trash and food smells in the vehicle for the passengers.

Finally what to do about reducing driver assaults in Baltimore.  Well the funny thing is they had the tool in place already but just weren’t using it.  The agency had installed driver shields that protected the driver from someone taking a swing at them or throwing coffee in their face (both of which had happened repeatedly) but the previous administration had left its usage optional.  We spoke with operators and reviewed what was happening nationally and determined that this was a safety protocol that needed to be implemented – mandatory bus shield usage.  While some drivers complained this would make them claustrophobic, we noted that our metro subway and light rail operators were in closed off compartments and generally did not have this issue (and also did not normally have assaults on them)  and we would make any ADA required reasonable accommodations.



  1. Implement a Campaign

Here I’ve got some stories.  Have you ever heard that “Safety Never Sleeps”?  That was our campaign name in DC implementing numerous safety strategies including the van clearance/ overhang issue.  It was a team effort that involved every one in management personally involved in speaking to all of our thousand plus drivers during each shift pull out and pull in for several months.  Early, dark, cold mornings and late nights too were required.  Every driver, every shift, every day.  It wasn’t always fun but it got the job done.

Our maintenance teams put together PVC pipe structures for the vans to drive through each morning on the way out of the yard that had a tennis ball attached to a string that would hit their windshield to remind them they might hit something driving through an overhang. On the PVC structure and at the gates we had signs that said “Your van has an 11′ Clearance”.  Inside each van we put a sticker overhead that said “This van has 11’ Clearance”.  We stood outside at pullouts dressed as “Superheroes of Safety” reminding drivers of their clearance.  We took pictures of all the buildings with overhang structures that drivers had hit in the past year and put that collage of photos on posters in each drivers lounge called “The Overhangs of Washington” to remind them not to drive under them. We issued mandatory safety guidance that drivers were not allowed to use drive thru’s at restaurants etc… And we did it repeatedly.

The results? – no more overhang hits.  We nearly eliminated this major safety issue and dramatically reduced accident related cost and lost time.  It was a win!

The mirror strikes were handled similarly and drivers were reminded repeatedly to pull in their mirror when parked on street by their dispatchers verbally when given their equipment and manifests as they began their shift, it was written on their manifests and gate keepers reminded them when they pulled out.  Road Supervisors handed out written campaign reminders in their regular safety/credentials checks on the road.

Results? – drivers pulled in their mirrors and we basically eliminated this costly “non-preventable” accident type.  It was a no cost fix that saved thousands.

What about the driver shields?  After several months of a long education campaign where I discussed the benefits directly with hundreds of operators at my regular “Lunch with the Administrator” Town Halls and we encouraged drivers to use the shields through numerous methods I believe we convinced the great majority that this really was about their safety and nearly all drivers now use the shield. We also made it mandatory.

Results? – zero driver assaults (for over 6 months) where operators were using the shield.

Campaigns are needed to really implement lasting change.  You cannot just issue a memo to effect behavior change in drivers or employees in general.  I believe you need to make your case just like in a political campaign where you win the hearts and minds of your employees to your cause.  Be creative like we did with our “Superstars of Safety” and “Safety Never Sleeps” campaigns.  Have fun with it when you can and reward outstanding performance.


  1. Make it Policy

In each of these cases after we defined the safety goal, tracked and trended the safety data, performed a root cause analysis, developed a strategy and implemented a campaign – we then made it policy with consequences.  Most changes were added to our safety policies that resulted in safety points if there was non-compliance.  Many of these policies were not always welcomed by the unions but all stuck and are now enforced.  Safety really is #1 in transit and in most industries.  If we aren’t safe we can’t do our job. Senior management must lead the way in implementing a safety culture.  The way to keep the good safety results is to institutionalize the strategy that caused it.  That’s the main role of policy – to implement good procedures so we can reproduce great results.

Remember the 7 Steps to Safety and enjoy improved safety at your system.

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