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Checklist states "that Hazard Identification is an ongoing process, viable throughout the system life cycle."

However, in spite of these recommendations, RFGS practices, as observed by FTA's Audit Program, do not always specify either the terms of unacceptable hazardous condition (UHC) notification to the Oversight Agency or the specific events during transit operations for which a hazard analysis must be performed.

Notification. FTA has interpreted the definition of UHC, and the subsequent notification requirements, to cover the occurrence of all hazardous conditions that fall into the "unacceptable" category in the Hazard Resolution Matrix specified in the APTA Manual. In other words, if hazard analysis reveals an "unacceptable hazardous condition," the Oversight Agency should be notified, even if this condition is quickly corrected by the rail transit agency.

FTA's Audit Program has discovered that UHCs, as determined by the RFGS, are not always communicated to the Oversight Agency, as is required by Part 659.  One of the reasons that RFGS struggle with implementing this requirement is that, in a majority of the incidents, the occurrence of an UHC is readily apparent, obvious, and requires immediate resolution during operations (i.e., suspension of service, removal of vehicle from service, etc.). Rarely is formal analysis performed in these instances. Therefore, documenting the occurrence of the UHC is viewed by the transit agency as an additional and unnecessary reporting burden.  These agencies believe that, if they have addressed the UHC, then the condition no longer exists, and therefore does not have to be reported to the Oversight Agency. This practice is in direct opposition to the intent of FTA's Rule, which requires Oversight Agency notification of the occurrence of

these conditions, whatever their corrected status. Further, the Rule requires the RFGS to submit to the Oversight Agency, for review and approval, both an investigation report (if the Oversight Agency has designated this responsibility to the RFGS) and a Corrective Action Plan (CAP) describing how the identified UHC will be resolved.  These activities are central to the effective implementation of FTA's Rule and must be performed for each identified UHC.  Oversight agency use of the sample UHC Notification Form, located on page 13, should effectively address this problem.

Performing Hazard Analysis. To support the use of the hazard analysis process specified in Checklist Number 7, FTA recommends that the Oversight Agency's Program Standard require the RFGS SSPP to provide a clear description of the hazard classification system, including explicit definitions for each category of hazard severity and probability. Quantitative criteria, such as those recommended in the draft Military Standard 882-D (see box below), can be particularly helpful in clarifying distinctions among categories. Further, the Oversight Agency and transit agency should work together to develop the framework--reflected in

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