5310 System Safety & Funding Study

1. 5310 System Safety & Funding Study Objectives Identify agencies receiving only 5310 program funding Identify the current contracts or agreements used to pass along safety requirements Recommend a set of baseline safety requirements

2. Methodology CTC Survey

3. Methodology Identifying 5310 sub-recipients that only receive 5310 program funding and do not receive additional federal or FDOT state program funding • Contacted District Representatives with 5310 agency list and requested they identify the agencies only receiving 5310 program funds from FDOT • Contacted CTCs with 5310 list and requested they identify 5310 agencies receiving trip reimbursements (CTD funding) to eliminate those agencies from the master list

4. Results of Survey Research study identified 112 agencies that were 5310-only sub recipients

5. CTC Agreements & Coordination Contracts Identified regulations stated in 5310 grant application manual Requested CTCs (with identified 5310-only agencies) provide the contract or agreement they use to pass requirements along to the 5310 agencies • CTD Standard Coordination Contracts • Customized Coordination Agreements

6. Results of Contracts & Agreements

7. Assessing Regulations and Requirements Primary regulations identified to pass requirements on to 5310 sub recipients: • Chapter 41-2, FAC “Commission for the Transportation Disadvantaged” • Chapter 14-90, FAC “Equipment and Operational Safety Standards for Bus Transit Systems” • Section 341.061, F.S. “Transit Safety Standards; Inspections and System Safety Reviews” • Chapter 234.051, F.S. “Transportation of School Children on School Buses” Additional regulations examined: • Americans With Disabilities Act of 1990 • Medicaid Agreements • SSPP regulations • Various local regulations provided

8. Rule 41-2, FAC “Transit operator” is defined as “transportation service that is purchased or funded by local government, state or federal transportation disadvantaged funds” 5310-only agencies do not provide services that are funded by transportation disadvantaged funds

9. Rule 14-90, FAC “Bus system” as defined in 14-90.002 excludes agencies that use non-public sector vehicles This excludes 5310-only agencies as they only provide service to their private clients and are considered non-public sector vehicles

10. Conclusion of Assessment The laws and rules identified in this study were not intended to regulate the types of agencies that do not provide transportation services to the general public; Currently there are no current laws, administrative rules or other regulations that provide safety standards for the 5310-only agencies

11. Establishing Baseline Safety Requirements • Agencies should develop SSPP’s and SPP’s that include minimum safety standards • Agencies should be required to establish and maintain a drug-free workplace policy according to Section 112.0455, F.S. • Agencies should be required to perform and document a pre-operational bus inspection report according to Rule 14-90.006 • Agencies should develop a maintenance plan that outlines the agency’s basic maintenance policies and procedures for maintaining the vehicles

12. Establishing Baseline Safety Requirements • Agencies should be required to investigate events involving the vehicles and resulting in fatality, injury or property damage and the development of necessary reports, corrective action plans and other documentation • Agencies should be required to ensure drivers licenses are active at all times while operating vehicles • Agencies should require that drivers not be permitted to drive more than 12 hours in a 24 hour period; and drivers are not permitted to be on duty more than 72 hours in any period of 7 consecutive days

13. Establishing Baseline Safety Requirements • Agencies should be required to ensure that all buses operated undergo a safety inspection at least annually in accordance with bus inspection procedures set forth in Rule 14-90.009 • Agencies should be required to undergo a safety review and inspection by FDOT to ascertain compliance with the baseline requirements set forth

14. Recommendations • A standardized template be developed and utilized between FDOT District Representatives and the 5310-only recipients; Current CTD Standard Coordination Agreement to only be used between CTCs and their trip subcontractors. This contract template will include the baseline safety requirements recommended in the study • FDOT District representatives be responsible for conducting the safety review and inspections for the 5310-only agencies. Currently CTCs and Districts are providing this service. • Standard combined SSPP & SPP template be created to include minimum safety requirements

15. Minimum Safety Requirements for SSPP & SPP • Vehicle safety policies and responsibilities established by the agency • Vehicle equipment information and standards, including procurement criteria • Operational standards and procedures • Basic maintenance plan that includes agency’s vehicle maintenance policies and procedures • Investigations of events as described under Rule 14-90.004(5) • Equipment and standards for transporting wheelchairs • Security policies and objectives, including agency roles and responsibilities in emergency management processes

16. Contact Information Laurie Revell The Marketing Institute Florida State University College of Business lrevell@cob.fsu.edu (850) 644-2509 Julie Eck The Marketing Institute Florida State University College of Business jeck@cob.fsu.edu (850) 644-2509