1. A. Program Policies and Objectives

   1. 1. The policy statement of the Louisiana SSO program. The Louisiana Department of Transportation and Development’s State Safety Oversight Program is responsible for the development and implementation of an effective and comprehensive state safety oversight program. The purpose of this program is to ensure that all rail fixed guideway public transportation systems in its jurisdiction fully define and implement a safety program that is compliant with all applicable state and federal rules and regulations.

   2. 2. The objectives for the SSO program include the following:

      1. a. developing and maintaining an SSO program meeting the federal and state requirements, including but not limited to 49 CFR Parts 674.11(f), 674.13(a)(1-3) and 674.41(c);
      2. b. assuring that SSO program staff and contractors meet training and qualification requirements outlined in the Public Transportation Safety Certification Training Program final rule per 49 CFR Part 672;
      3. c. providing oversight and technical assistance to the RTA in developing, maintaining, evaluating, and implementing a safety program wholly owned by the RTA, not the state of Louisiana;
      4. d. working cooperatively with the RTA and FTA SSO program to improve system safety performance and reduce system safety risk to as low as reasonably practical;
      5. e. ensuring RTA conducts investigations and internal audits as required, and participating as appropriate (SSOA may choose to lead, participate in, or conduct independent investigations, audits, or inspections);
      6. f. ensuring RTA executive staff fully support the safety principles and methods of safety management systems (SMS) as the basis for enhancing the safety of public transportation;
      7. g. ensuring RTA safety staff and contractors meet training and qualifications requirements outlined in the Public Transportation Safety Certification Training Program;
      8. h. participating in safety meetings;
      9. i. ensuring that investigations are conducted to determine causality, and reviewing investigations of safety events as appropriate;
      10. j. providing guidance and input to the RTA safety implementation program;
      11. k. investigating any allegations of an RTA’s non-compliance with their safety plan.

2. B. Minimum Safety Standards. The SSOA reviews RTA documents to ensure minimum safety standards are met. These include but are not limited to the types of documents shown in the table below, in effect as of January 2024. Each control document, including plans, policies, and procedures, is listed in the Procedures Manual with the date of its most recent update.

   1. 1. Types and Examples of RTA Minimum System Safety and Security Related Documents:

      Document Type	Examples
      Overarching Safety Plan	Agency Safety Plan (ASP)
      Emergency Preparedness	All Hazards Plan (including Annex B: Infectious Disease); Continuity of Operations Plan (COOP)
      Operations	Streetcar Operator Manual
      Maintenance	Transit Asset Management (TAM) Plan, Rail Maintenance Plan
      Administration	Employee Onboarding Handbook, Employee Code of Conduct, Procurement Manual, RTA Employee Safety and Health Handbook
      Safety Policies	RTA Distracted Driving Policy (SAF2), RTA Safety Management Policy (SAF3)
      Safety-Related SOPs	Safety Assurance of Safety Critical Areas (004-006), Working in Hot Weather (004-009), Safety event Investigation Procedures

3. C. State Safety Oversight Program Standard.

   1. 1. Annual Review. The Procedures Manual includes provisions for the annual review and update of the SSOPS and all its supporting documents. An annual review schedule outlines the recurring tasks the SSOA will undertake to prepare for and execute this process, including reviewing changes to federal policy and industry safety standards, reviewing the agency’s updates to safety standards, incorporating revisions, verifying updates comply with federal rules, and submitting SSOPS revisions for adoption to the Louisiana Administrative Code.
   2. 2. Adoption and Distribution of Program Standard. The SSOA follows the Louisiana Administrative Code Rule Making SOP to formalize the updates to the SSOPS, which is included in the Appendix of the Procedures Manual. This process includes the review of any changes by DOTD’s Legal Department. The updated Program Standard is then submitted to FTA with the SSO’s Annual Report on or before March 15 of each year. The SSOA’s completed Program Standard review checklist is included in the Appendix of the Procedures Manual.
4. D. Safety Plan Review. RTA system safety program plan must be compliant with 49 CFR Part 673 and 49 USC §5329(d). The SSOA reviews the safety plan for compliance with federal regulations within 30 calendar days of receipt. The SSOA’s completed ASP review checklist is included in the Appendix of the Procedures Manual.
5. E. Security and Emergency Preparedness Plan. 49 CFR Part 674 does not require the SSOA to oversee the development, revision or implementation of a Security and Emergency Preparedness Plan for the RTA. However, 49 CFR Part 673.11(a)(6) requires an agency to have an emergency preparedness plan. The SSOA supports the RTA in all aspects of its Security and Emergency Preparedness planning as it relates to the safety of the system, its employees, and passengers.
6. F. RTA Internal Audits. The Procedures Manual describes the timeline, materials, and communication to be used by the SSOA when conducting its review of the RTA’s internal audits. The SSOA reviews and approves the internal audit report submitted by the RTA each year on or before March 15.

7. G. Triennial Audits of RTA. The SSOA will conduct an onsite audit of the RTA’s implementation of its safety program at least once during each three-year cycle. The SSOA and RTA may agree that the SSOA will conduct its audit on an ongoing basis over the three-year cycle. If an SSOA audits an RTA's compliance on an ongoing basis, the SSOA shall issue interim audit reports at least annually. The Procedures Manual includes details on the following:

   1. 1. the timeline for scheduling and conducting a triennial audit;
   2. 2. the development and use of audit checklists;
   3. 3. the tracking of findings; and
   4. 4. the writing and distribution of the audit report.

8. H. Notification of Safety Events

   1. 1. Requirements. The RTA is required to report any safety event meeting the criteria or guidance under the National Public Transportation Safety Plan or other reporting guidelines. These guidelines for reportable safety events are communicated to the RTA through the Procedures Manual.
   2. 2. Two-hour Notification. In addition to the content described in SSOPS §1513, the Procedures Manual includes details about the notification form to be used by the RTA. The Manual’s Appendix includes the most recent version of the form, which will be updated as needed and when requirements for safety event reporting change as directed by FTA.

9. I. Investigations

   1. 1. Safety event Investigations. The SSOA must investigate or require an investigation of any reportable safety event and is ultimately responsible for the sufficiency and thoroughness of all investigation reports. Investigations can:

      1. a. be conducted by the SSOA;
      2. b. be delegated to the RTA by the SSOA;
      3. c. be conducted jointly by the SSOA and RTA; or
      4. d. be conducted by a third party.
   2. 2. The RTA’s Safety Event Investigation procedures are developed by the RTA, approved by the SSOA, and reviewed annually against industry standard.
   3. 3. Reviewing Findings of Causation. For each RTA investigation, the SSOA will conduct an independent review of the RTA’s findings of causation. This review is primarily based on the RTA’s Safety Event Investigation SOP and communication between the SSOA and the RTA’s Chief Safety, Security & Emergency Management Officer (CSSEM). In cases where the SSOA does not believe that adequate investigation into the cause of a safety event has been performed, it may conduct its own investigation.
   4. 4. Reporting. The Procedures Manual details the required contents of all final safety event reports produced by the RTA for the SSOA. The Procedures Manual’s Appendix includes the RTA’s current Investigation Report template, which includes all required components.
   5. 5. Other Incidents that Warrant Investigation. In certain cases, the SSOA or the RTA may determine that a formal investigation is necessary for events occurring at the RTA, even though such events may not meet safety event reporting regulation criteria. These events may include hazards, significant operational incidents, significant failures of SMS, and other events that might, under other circumstances, lead to significant adverse events. RTA will use its established investigation procedures and comply with all SSO requirements and requests for participation in such an investigation.
10. J. Confidentiality of Information. The SSOA will handle all reportable information in accordance with all federal and state laws.

11. K. Corrective Action Plans. The Procedures Manual details the process by which CAPs are

    1. 1. identified;
    2. 2. developed;
    3. 3. approved by the SSOA;
    4. 4. implemented;
    5. 5. tracked; and
    6. 6. closed.
12. L. The Procedures Manual also describes CAP log procedures the RTA must follow. This includes the requirement for an updated log to be shared with the SSOA every thirty days. A CAP log example is included in the Appendix of the Procedures Manual.

13. M. Annual Reporting to FTA

    1. 1. SSOA Reporting Requirements. The Procedures Manual details each of the documents that must be submitted by the SSOA to the following entities:

       1. a. Louisiana Governor’s Office;
       2. b. the RTA Board of Commissioners; and
       3. c the FTA (through its State Safety Oversight Reporting Tool). The documents must all be submitted on or before March 15 of each year.
    2. 2. RTA Reporting Requirements. The Procedures Manual describes the contents of the Annual Report the RTA will submit to the SSOA on or before February 15 of each year.

14. N. Risk-Based Inspection

    1. 1. Category 1: Authority to Perform Risk-Based Inspections. Category 1 includes the following:

       1. a. the SSO’s authority to access the RTA;
       2. b capability to access the RTA;
       3. c inspection frequencies; and
       4. d. SSO enforcement actions.
    2. 2. Category 2: Risk-Based Inspection Policies and Procedures. Category 2 of the Procedures Manual includes procedures for SSO staff and contractors to notify the RTA for inspections, conduct inspections with notice, and conduct inspections without notice. It also details inspection practices of publicly accessible areas, inspection practices for access and RTA escorts for non-publicly accessible areas, inspection safety certification and training, scheduling inspections, the contents of inspection reports, and procedures for immediate safety concerns. In addition, it includes procedures for event verification, ongoing monitoring, defects and corrective or remedial actions, and CAP and safety risk mitigation verification. All inspection policies and procedures pertain to the inspections of equipment, infrastructure, and practices specific to each RTA.
    3. 3. Category 3: Data Sources and Collection. Procedures in Category 3 include those for the RTA’s data sharing of safety program data, maintenance data, inspection data, and additional safety data with the SSOA as required. It also includes data management policies for how data sets will be stored and used for analysis, where data sets will be stored, how the data will be organized, how long records must be retained, how and when records are disposed, how the SSOA will ensure the system accurately stores records, and how the SSOA will protect security sensitive information.

    4. 4. Category 4: Inspection Prioritization. Procedures included are those that describe:

       1. a. the prioritization of safety concerns to inform inspections,
       2. b. metrics used for inspection prioritization,
       3. c. safety concern prioritization rating procedures,
       4. d. inspection prioritization processes, and
       5. e. the continuous process for RBI prioritization.

    5. 5. Category 5: Risk-Based Inspection Commensurate with Number, Size, and Complexity of the RFGPTS. The SSOA conducts RBI tailored to the RTA’s risk profile based on its size and complexity. The SSOA oversees only one rail transit agency at this time. This category includes procedures for:

       1. a. evaluating the rail system’s size and complexity,
       2. b. performing consistent and ongoing risk-based inspections, and
       3. c. inspecting the full spectrum of activities at the RTA.

    6. 6. Category 6: SSO Staffing, Qualifications, and Training. To ensure adequate staffing and resources for the effective implementation and management of the RBI program, three elements will be reviewed and updated annually: the SSO Workload Assessment, Inspection Personnel Qualification Verification, and the SSOA’s Technical Training Plan. Procedures for the use and update of these elements are included in Category 6 of the Procedures Manual.

       1525. 49 CFR 674.41 Conflicts of Interest

15. A. An SSOA must be financially and legally independent from any rail fixed guideway public transportation system under the oversight of the SSOA. The Administrator may waive this requirement in accordance with 49 C.F.R. § 674.13(b).
16. B. An SSOA may not employ any individual who provides services to a rail fixed guideway public transportation system under the oversight of the SSOA., The Administrator may waive this requirement in accordance with 49 C.F.R. § 674.13(b).
17. C. A contractor may not provide services to both an SSOA and a rail fixed guideway public transportation system under the oversight of that SSOA. The Administrator may waive this prohibition.

Authority Note

AUTHORITY NOTE: Promulgated in accordance with R.S. 48:214; 49 C.F.R. Part 674; 49 U.S.C. § 5329.

Historical Note

HISTORICAL NOTE: Promulgated by the Department of Transportation and Development, Office of Multimodal Commerce, LR 44:922 (May 2018), amended LR 48:2188 (August 2022), LR 52:368 (March 2026).

Authority Note

AUTHORITY NOTE: Promulgated in accordance with R.S. 48:214; 49 C.F.R. Part 674; 49 U.S.C. § 5329.

Historical Note

HISTORICAL NOTE: Promulgated by the Department of Transportation and Development, Office of Multimodal Commerce, LR 52:370 (March 2026).