# Safety and Security Management Plan (SSMP)

## What is an SSMP?

## 

An SSMP is a required document that must be prepared by applicants and
recipients of Federal Transit Administration (FTA) funds for major
capital projects. The SSMP is part of the Project Management Plan (PMP)
and is written to describe how the recipient will address safety and
security in the major capital project from initial project planning
through initiation of revenue service.

## Is an SSMP required for all major capital projects funded by FTA?

Yes. The Safe, Accountable, Flexible, Efficient Transportation Equity
Act: A Legacy for Users (SAFETEA-LU), signed into law on August 10,
2005, identifies "safety and security management" as a required
component of the PMP. FTA requires recipients of FTA funds for major
capital projects, as defined in 49 CFR Part 633.5, to develop a PMP for
the project. As part of the PMP, FTA also requires that an SSMP be
developed and implemented. The SSMP may be a separate chapter or plan
contained within the PMP.

## Why is the SSMP needed?

Historically, grantees of FTA-funded major capital projects have
described project safety and security management strategies and controls
as sub-elements of other required PMP sections. Some projects elected to
perform specific safety and security activities, such as safety and
security certification or pre-revenue operational readiness assessments,
while other projects did not. There was no consistent approach to safety
and security in major capital projects. As a component of the PMP, the
SSMP now establishes a consistent baseline for the management of safety
and security activities in all federally funded major capital projects,
specifying minimum activities which must be performed. Through the SSMP,
FTA can now ensure that safety and security are adequately addressed in
all project development phases.

**Is there information available to help recipients develop and
implement SSMPs?**

Yes. Since 2002, FTA has required SSMPs for all New Starts projects
entering into Full Funding Grant Agreements (FFGAs) with FTA. These
requirements were contained in FTA's Full Funding Grant Agreement
Circular 5200.1A, Chapter II, Section 6, issued on December 5, 2002.[^1]
They were also discussed in FTA's 2003 update to the Project and
Construction Management Guidelines.[^2] In 2006, in response to new
SAFETEA-LU provisions, FTA began developing new guidance for SSMPs for
all major capital projects. FTA published its notice of availability
regarding this new guidance in the *Federal Register* on June 21, 2007.
This new guidance, now found in Circular 5800.1, Safety and Security
Management Guidance for Major Capital Projects, went into effect August
1, 2007.[^3] In Appendix A of Circular 5800.1, FTA includes a checklist
designed to support the development and implementation of SSMPs for
major capital projects.

## Which projects are applicable to the requirements of FTA's Safety and Security Management Guidance for Major Capital Projects Circular 5800.1?

Circular 5800.1 [applies to]{.underline}:

1.  Recipients with major capital projects, as defined in 49 CFR 633.5,
    **initiated after August 1, 2007**.

2.  Recipients with major capital projects, as defined in 49 CFR 633.5,
    involving the construction of a new fixed guideway or extension of
    an existing fixed guideway, that are **in preliminary engineering or
    earlier phases as of August 1, 2007**.

Circular 5800.1 [does not apply to]{.underline}:

(1) Recipients receiving capital investment grants under 49 U.S.C.
    5309(e), more commonly referred to as "Small Starts" and "Very Small
    Starts" projects, unless FTA's Administrator determines that a PMP
    is necessary.

(2) Recipients with major capital projects, as defined in 49 CFR 633.5,
    involving the rehabilitation or modernization of an existing fixed
    guideway with a total project cost in excess of \$100 million, and
    **initiated before August 1, 2007**. These recipients must continue
    to follow existing safety and security certification requirements
    established by their State Safety Oversight Agencies and/or the
    Federal Railroad Administration (FRA).

(3) Recipients with major capital projects, as defined in 49 CFR 633.5,
    involving the construction of a new fixed guideway or extension of
    an existing fixed guideway, that are **in final design or later
    phases as of August 1, 2007**. These recipients must continue to
    follow the guidance in Chapter II, Section 6, Safety and Security
    Management Plan of FTA's FFGA Circular 5200.1A.

(4) Recipients with major capital projects, as defined in 49 CFR 633.5,
    designated by the Administrator, and **initiated before August 1,
    2007**. As applicable, these recipients must continue to follow the
    guidance in Chapter II, Section 6, Safety and Security Management
    Plan of FTA's FFGA Circular 5200.1A.

## Are existing major capital projects with pending/signed FFGAs in the final design or later phases of project development required to develop a new SSMP in accordance with FTA Circular 5800.1?

No. Recipients with projects covered under Chapter II, Section 6 of FFGA
Circular 5200.1A that are in final design or later phases of project
development, as of August 1, 2007, may continue to follow the guidance
of Chapter II, Section 6 of FFGA Circular 5200.1A until their projects
are completed.

Recipients with projects covered under Chapter II, Section 6 of FFGA
Circular 5200.1A that are in the preliminary engineering or earlier
phases as of project development, as of August 1, 2007 will follow the
guidance specified in FTA Circular 5800.1, Safety and Security
Management Guidance for Major Capital Projects.

## What topics must be addressed and included in the SSMP?

## 

## SSMPs must be developed in accordance with Chapter IV of FTA Circular 5800.1, Safety and Security Management Guidance for Major Capital Projects. As specified by this section, the recipient must describe its approach to safety and security activities to be carried out during each phase of the major capital project, including:

1.  Project Management commitment and philosophy towards safety and
    security.

2.  Integration of safety and security into the project development
    process.

3.  Assignment of organizational safety and security responsibilities
    for the project.

4.  Safety and Security Analysis and hazard and vulnerability management
    processes.

5.  Development of safety and security design criteria.

6.  Process for ensuring qualified operations and maintenance personnel.

7.  Safety and security verification processes (including final safety
    and security certification) to verify conformance with specified
    safety and security requirements during design, in equipment and
    materials procurements, and during testing/inspection and start-up
    phases.

8.  Construction safety and security management activities.

9.  Requirements for 49 CFR Part 659, Rail Fixed Guideway Systems; State
    Safety Oversight.

10. FRA coordination.

11. Department of Homeland Security (DHS) coordination.

## 

## What should a grant recipient do if specific SSMP requirements may not be applicable to the major capital project?

In Chapter III, Paragraph 2 of FTA's SSMP Circular 5800.1, FTA provides
a process where recipients can petition FTA to exclude their projects
from specific SSMP requirements.

Recipients must simply arrange a meeting with their FTA Regional Offices
and the PMOCs assigned to their projects, either in person or via
teleconference. During this meeting, the recipient must explain why the
SSMP section or sections, as identified in Chapter IV of the Circular
5800.1, are not applicable to the project. It is also acceptable for the
recipient to prepare a letter or memo explaining its situation, and its
request that the project be exempt from specific SSMP requirements.

FTA and the PMOC assigned to the project will review the request, and
FTA will get back to the recipient as quickly as possible with its
determination. If FTA agrees with the recipient, then FTA will not
require the recipient to address the specific requirements in the SSMP.
FTA will designate these specific sections as "not applicable."

For recipients with SSMP sections or sub-sections designated as "not
applicable" by FTA, the recipient is still required to include the
section or sub-section in the SSMP. However, immediately following the
section or sub-section, the recipient must include the phrase "not
applicable."

**Are sample SSMPs available to recipients to facilitate SSMP
development?**

No. However, FTA Safety and Security Management Guidance Circular 5800.1
has been prepared with ample information pertaining to the required
contents of SSMPs. Recipients are also encouraged to work with the PMOC
and FTA to obtain any additional guidance or clarity that may be needed
to complete the SSMP. Appendix A of FTA Safety and Security Management
Guidance Circular 5800.1 also provides guidance regarding FTA's
expectations for the type of information to be included by recipients in
their SSMPs during each phase of the development process.

## What safety and security management activities are required of recipients receiving federal financial assistance?

In order to receive federal financial assistance, and as part of the
SSMP development and implementation process, recipient's must complete
the activities specified in FTA Safety and Security Management
Guidelines Circular 5800.1, Chapter II, Section 2. These activities
include:

-   Preparing a policy statement.

-   Identifying safety and security interfaces for the project.

-   Establishing a safety and security organization that will manage
    safety and security activities for the project. The recipient must
    provide a visual illustration of its safety and security management
    organization in the form of an organizational chart.

-   Identifying and carrying out specific safety and security activities
    by project phase. At a minimum, the recipient must:

    -   Establish a program for identifying, assessing, controlling,
        documenting, and tracking safety hazards and security
        vulnerabilities using formal safety and security analysis
        techniques.

    -   Establish specific safety and security requirements for the
        project based on applicable safety and security regulations,
        codes, standards, guidelines, recognized best practices, etc.,
        and verify that all final drawings, specifications and contracts
        issued for the project conform to these requirements.

    -   Establish a means for verifying contractor and recipient staff
        and committees have designed, built, procured, installed,
        inspected, and tested all facilities, systems, and equipment
        comprising the project in accordance with the recipient's
        adopted safety and security requirements.

    -   Develop documentation through which it conveys the safety,
        security, and emergency rules and procedures it has established
        for project employees, staff, contractors, and oversight
        agencies.

    -   Establish qualifications and training programs that address the
        safety and security elements of operating and maintenance rules,
        plans, procedures, manuals and emergency procedures for all
        personnel who will operate and maintain the project in revenue
        service.

    -   Ensure that it is capable of providing documentation that
        verifies how the recipient trained and qualified its personnel
        and/or contractors to operate and maintain the system, and to
        respond to emergencies. This includes ensuring outside emergency
        response personnel receive training regarding the project's
        operations, equipment and emergency procedures.

    -   Maintain a process to manage open safety and security items
        resulting from design deviations, change orders, and non
        conformances. The recipient must take action to address and
        mitigate these issues (through temporary measures if necessary)
        and to track all open items through closure and acceptance.

    -   If applicable, conduct emergency exercises and drills prior to
        placing the project into revenue service. Drill results must be
        documented in after action reports.

    -   Make final Safety and Security Certification prior to placing
        the project into revenue service. Certification may be
        documented in a Final Verification Report.

-   Ensuring construction safety and security.

-   Ensuring coordination with external agencies.

-   Identifying safety and security interfaces for the project.

**Is it acceptable to use contractor or consultant staff to prepare the
SSMP?**

Yes. FTA recognizes that some recipients, especially those pursuing New
Starts projects, may not have the in-house staff or expertise to prepare
the SSMP. In these cases, it is acceptable for recipients to use
contracted expertise to complete the SSMP. However, recipients retain
the ultimate responsibility for meeting FTA's requirements, including
the development and implementation of an SSMP.

**Is it acceptable to use contractor or consultant staff to complete the
safety and security management activities required to receive federal
funding assistance?**

Yes. Recipients may delegate the completion of safety and security
activities to contractor and/or consultant staff. However, for all
contractor and consultant staff used by the recipient to complete the
project, the recipient must identify a recipient staff member or
committee responsible for overseeing the contractor. Again, the
recipient retains the ultimate responsibility for meeting FTA's
requirements including the development and implementation of an SSMP.

## What are the consequences of not completing the SSMP or the safety and security management activities required by FTA?

## 

## Failure to complete the SSMP or the safety and security management activities required by FTA may delay or prevent federal financial assistance and project progress.

## How often must the SSMP be reviewed and revised by the recipient and submitted to the FTA?

## 

Because the SSMP is part of the PMP, the SSMP must be developed,
reviewed, revised, and submitted each time the PMP is required. At a
minimum, FTA typically requires the PMP prior to entering into each
phase of project development (e.g., preliminary engineering, final
design, construction, testing, and pre-revenue operations).

For new fixed guideways and extensions, FTA requires recipients to
submit their initial SSMPs with the initial PMPs they prepare for
request to enter preliminary engineering. For rehabilitation and
modernization projects in excess of \$100 million, FTA requires that
recipients submit their SSMP whenever a PMP is required. For major
capital projects designated by the Administrator, FTA also requires
recipients to submit their SSMP whenever a PMP is required.

FTA must review and conditionally approve the SSMP, as part of the PMP,
prior to the recipient receiving approval to enter the next project
phase.

## 

## How will FTA protect Sensitive Security Information (SSI)?

U.S. Department of Transportation (DOT) regulation 49 CFR Part 15,
Protection of Sensitive Security Information, specifies that each grant
recipient must control the release of "sensitive security information"
(SSI).

DOT published "Interim Policies and Procedures for 49 CFR Part 15,
Protection of Sensitive Security Information" on June 7, 2005. These DOT
policies and procedures apply to all DOT employees and to all DOT
contractors, recipients, consultants, licensees, and regulated entities
that have access to or receive SSI.

Following this DOT guidance, FTA requires recipients with major capital
projects covered by 49 CFR Part 633 to document or reference their
procedures for managing SSI materials in the SSMP. These procedures must
extend to any contractors involved with the project to ensure that all
project documents are maintained in a secure manner while in the
possession or control of contractors.

FTA and its PMOCs will follow the recipient's established procedures
when reviewing SSI materials. Further, FTA has the authority to exempt
any SSI information that is submitted to FTA or its PMOCs by grant
recipients from being available to the public under the Freedom of
Information Act (FOIA).

## 

## For rail transit projects, does the State Oversight Agency have to review and approve the SSMP?

No. The SSMP is used by FTA's PMO contractors and FTA's Office of Safety
and Security to monitor performance of required safety and security
activities. However, for informational purposes, FTA recommends that the
New Starts project share a copy of its SSMP with the State Oversight
Agency and other interested parties, as appropriate, such as the Federal
Railroad Administration (FRA), the Department of Homeland Security
(DHS)/Transportation Security Administration (TSA), and the DHS/Federal
Emergency Management Agency (FEMA)/ National Preparedness Directorate
(NPD).

## How should the SSMP be organized?

As specified in FTA's FFGA Circular 5800.1, Chapter IV, SSMPs prepared
for major capital projects must contain the 11 sections listed in
Exhibit 1 below.

+----------------------------------+-----------------------------------+
| **Exhibit 1, Required SSMP       |                                   |
| Sections**                       |                                   |
+==================================+===================================+
| **Section 1: Management          | **Section 7: Safety and Security  |
| Commitment and Philosophy**      | Verification Process (Including   |
|                                  | Final Safety and Security         |
| 1.1 Safety and Security Policy   | Certification)**                  |
| Statement                        |                                   |
|                                  | 7.1 Design Criteria Verification  |
| 1.2 Purpose of SSMP              | Process                           |
|                                  |                                   |
| 1.3 Applicability and Scope of   | 7.2 Construction Specification    |
| SSMP                             | Conformance Process               |
|                                  |                                   |
| 1.4 SSMP Goal                    | 7.3 Testing/Inspection            |
|                                  | Verification                      |
| **Section 2: Integration of      |                                   |
| Safety and Security into Project | 7.4 Hazard and Vulnerability      |
| Development Process**            | Resolution Verification           |
|                                  |                                   |
| 2.1 Safety and Security          | 7.5 Operational Readiness         |
| Activities                       | Verification                      |
|                                  |                                   |
| 2.2 Procedures and Resources     | 7.6 Safety and Security           |
|                                  | Certification Requirements        |
| 2.3 Interface with Management    |                                   |
|                                  | **Section 8: Construction Safety  |
| **Section 3: Assignment of       | and Security**                    |
| Safety and Security              |                                   |
| Responsibilities**               | 8.1 Construction Safety and       |
|                                  | Security Program Elements         |
| 3.1 Responsibility and Authority |                                   |
|                                  | 8.2 Construction Phase Hazard and |
| 3.2 Committee Structure          | Vulnerability Analysis            |
|                                  |                                   |
| 3.3 Safety and Security          | 8.3 Safety and Security           |
| Responsibilities Matrix          | Incentives                        |
|                                  |                                   |
| **Section 4: Safety and Security | **Section 9: Requirements for 49  |
| Analysis**                       | CFR Part 659, Rail Fixed Guideway |
|                                  | Systems, State Safety Oversight   |
| 4.1 Approach to Safety and       | (if applicable)**                 |
| Security Analysis                |                                   |
|                                  | 9.1 Activities                    |
| 4.2 Requirements for Safety and  |                                   |
| Security Analysis                | 9.2 Implementation Schedule       |
|                                  |                                   |
| **Section 5: Development of      | 9.3 Coordination Process          |
| Safety and Security Design       |                                   |
| Criteria**                       | **Section 10: FRA Coordination    |
|                                  | (if applicable)**                 |
| 5.1 Approach to Development of   |                                   |
| Safety and Security Requirements | 10.1 Activities                   |
| and Design Criteria              |                                   |
|                                  | 10.2 Implementation Schedule      |
| 5.2 Design Reviews               |                                   |
|                                  | 10.3 Coordination Process         |
| 5.3 Deviations and Changes       |                                   |
|                                  | **Section 11: DHS Coordination    |
| **Section 6: Process for         | (if applicable)**                 |
| Ensuring Qualified Operations    |                                   |
| and Maintenance Personnel**      | 11.1 Activities                   |
|                                  |                                   |
| 6.1 Operations and Maintenance   | 11.2 Implementation Schedule      |
| Personnel Requirements           |                                   |
|                                  | 11.3 Coordination Process         |
| 6.2 Plans, Rules and Procedures  |                                   |
|                                  |                                   |
| 6.3 Training Program             |                                   |
|                                  |                                   |
| 6.4 Emergency Preparedness       |                                   |
|                                  |                                   |
| 6.5 Public Awareness             |                                   |
+----------------------------------+-----------------------------------+

## 

## Can grant recipients reference other documents in their SSMPs?

## 

Yes. FTA appreciates that some recipients are established agencies with
existing safety and security programs and plans. FTA encourages these
recipients to reference their existing programs and plans in the SSMPs
they develop for their projects. Mature transit agencies are encouraged
to use the 11 sections specified in Chapter IV of Circular 5800.1, as a
checklist for identifying the minimum safety and security management
activities FTA requires.

When a recipient addresses the majority of the circular's requirements
in other existing documents, FTA intends for the SSMP to present an
integrated, coherent approach for the project's safety and security
management program that can direct all involved project participants to
the applicable supporting documents. In this situation, FTA believes the
SSMP will enhance the recipient's ability to communicate the elements of
its safety and security program with project team members, project
leadership, other employees and contractors, FTA and its PMOCs, and
other involved agencies (i.e., State Oversight Agencies, FRA, DHS/TSA
and DHS/FEMA/NPD).

Further, FTA understands that as recipients with new fixed guideway
systems and extensions move through the project development phases they
will develop additional programs, plans, and documentation. FTA also
encourages these recipients to reference to-be-developed and newly
developed documents and procedures in their SSMPs.

FTA requires references made by recipients in SSMPs to include **the
document name, chapter or title, and appropriate page numbers**. The
recipient must provide **a brief statement in the SSMP regarding how the
referenced document addresses the applicable SSMP requirement**. FTA
also requires recipients to make all referenced materials available to
FTA and the PMOC for review.

For any SSI materials that the recipient may reference, FTA and the PMOC
will follow the SSI handling procedures established by the recipient.

Examples of materials appropriate for referencing include:

-   [Other Sections of the PMP]{.underline}. The recipient may reference
    other appropriate sections of the PMP, including those sections
    relating to the project's overall organization and structure; the
    project's quality assurance and quality control (QA/QC) program for
    design and construction; the recipient's process for design reviews;
    the recipient's process for integrated testing; and the recipient's
    approach to pre-revenue operations and demonstration, including
    activation activities and coordination with external agencies, such
    as State Oversight Agencies, the FRA, and DHS/TSA and DHS/FEMA/NPD.

-   [Other Plans]{.underline}. The recipient may reference other plans,
    or sections of plans that it has developed, or will develop to
    address specific safety and security issues for the project,
    including the Safety and Security Certification Plan (SSCP), the
    Construction Safety and Security Plan, the System Safety Program
    Plan (SSPP), the System Security Plan, the Fleet Management Plan,
    the Operations and Maintenance Plan, the Integrated Testing Plan,
    the Service Activation Plan, the Emergency Response Plan, staffing
    and training plans, rulebooks and procedures, maintenance manuals,
    plans for emergency exercises and drills, and any documents
    necessary for compliance with requirements specified by State
    Oversight Agencies, FRA, and DHS/TSA and DHS/FEMA/NPD. In addition,
    the recipient may reference applicable portions of the metropolitan
    plan that relate to system-wide consideration of safety and
    security, as well as documents prepared as part of the metropolitan
    planning process (MPO) that relate to key systems communication
    provisions.

-   [Contract Specifications and Project Documents]{.underline}. The
    recipient may also reference contract and project requirements for
    hazard and vulnerability analysis; plans and procedures for the
    verification of safety and security requirements in final
    specifications and contract documents; safety and security
    construction specification conformance; testing and acceptance
    procedures and forms; submissions and waiver requests to external
    agencies; and other applicable documents.

## 

## Does the SSMP duplicate other safety and security plans developed by the project?

No. The SSMP is a distinct plan developed to ensure that project
management is adequately identifying and addressing FTA's safety and
security requirements. Sometimes there is confusion regarding the
difference between the SSMP and other safety and security plans because,
to address requirements specified in FTA's Circular 5800.1, the SSMP
should explain the project's approach to the development of other safety
and security plans, procedures, and programs. However, there is an
important difference between explaining the management approach to be
used to develop these plans and programs versus the actual plans
themselves.

For example, as specified in FFGA Circular 5800.1, FTA requires a set of
specific activities to be performed, including: designation of a
function with responsibility for safety and security throughout the
project; safety and security certification; hazard and vulnerability
analysis; and the identification and implementation of activities to
address construction safety and security, State Safety Oversight
requirements, and FRA waiver requirements. To address these
requirements, the SSMP must explain the project's organizational
structure, management controls, schedule, and dedicated resources for
ensuring that these activities actually occur. The SSMP therefore
provides a blueprint for how the grantee will ensure both the safety and
security of the project during the project development process and once
it is placed in revenue service. Using the SSMP as part of the PMO
process, FTA's PMO contractors, FTA's Regional Offices, and FTA's Office
of Safety and Security will monitor these activities and report on their
occurrence and progress.

Depending on the type of project and where it is in the development
process, grantees may have already developed Safety and Security
Certification Plans and Construction Safety and Security Plans, or may
have already prepared submittals for State Oversight Agencies and made
waiver petitions to the FRA. In these cases, grantees can simply
reference these programs and documents in the appropriate section of
their SSMPs.

FTA requires references made by recipients in SSMPs to include the
document name, chapter or title, and appropriate page numbers. The
recipient must provide a brief statement in the SSMP regarding how the
referenced document addresses the applicable SSMP requirement. FTA also
requires recipients to make all referenced materials available to FTA
and the PMO contractor for review. For any SSI materials the recipient
may reference, FTA and the PMO contractor will follow the SSI handling
procedures established by the recipient.

## 

## How does the SSMP relate to the project's Safety and Security Certification Plan?

Safety and security certification is defined as the "process for
verifying conformance with specified safety and security requirements
during design, in equipment and materials procurements, and during
testing/inspection and start-up phases." The SSMP must demonstrate how
the project will meet these requirements.

The SSMP **is not** a Safety and Security Certification Plan. Instead,
it must describe the approach that will be taken by the project to
perform safety and security certification, including the project
organization, controls, schedule, and resources dedicated to perform
certification and issue final certificates and reports. The SSMP assures
FTA that the project will perform safety and security certification and
that the project has sufficient resources, personnel, and technical
capacity to carry out the certification program.

## How does the SSMP relate to the grantee's System Safety Program Plan (SSPP)?

The System Safety Program Plan (SSPP) is an agency-wide document that
describes the policies, objectives, responsibilities, and procedures in
place to address safety **during all aspects of transit operations** and
to reduce hazards to the most practical level through the most effective
use of available resources.

-   For rail transit projects, this plan is required by the State
    Oversight Agency, and must meet the 21 elements specified in 49 CFR
    Part 659.19.

-   FTA's Transit Bus Safety and Security Program provides recommended
    guidelines for developing an SSPP for bus agencies.

-   For commuter rail projects, FRA has established guidelines for
    developing SSPPs building on the handbook used for the American
    Public Transportation Association (APTA) Commuter Rail Safety
    Management Program.

For New Starts systems with no previous operating experience, the SSMP
may specify that the SSPP will be developed and establish a timeline and
resources for its creation, as well as a process for coordinating with
the State Oversight Agency (for rail transit projects), appropriate
state authorities (as may be required for bus projects), and FRA and/or
APTA (for commuter rail projects).

For existing agencies undertaking extensions or new service, previously
prepared SSPPs may guide development of the SSMP, including the
organization used to manage safety activities, the performance of safety
and security certification and construction safety and security
activities, and coordination with State Oversight Agencies, other state
agencies, and/or FRA and APTA.

## How does the SSMP relate to the grantee's System Security Plan?

Like the SSPP, the System Security Plan addresses security in all
aspects of transit operations.

-   For rail transit projects, this plan is required by the State
    Oversight Agency, and must meet the five elements specified in 49
    CFR Part 659.23.

-   FTA's Transit Bus Safety and Security Program provides recommended
    guidelines for developing a bus System Security Plan.

-   FRA addresses security requirements in its guidelines for developing
    SSPPs.

For all transit projects receiving grants from the DHS/FEMA, National
Preparedness Directorate (NPD), this plan must follow the format
established in FTA's *Public Transportation System Security and
Emergency Preparedness Guidelines*. This format is also an acceptable,
though not required, way for rail transit projects to comply with 49 CFR
Part 659.23 requirements and FRA recommended guidelines.

The Transportation Security Administration (TSA), which has overall
legislative authority for public transportation security, also requires
a System Security Plan, and may request to review this plan at any time.
In addition, TSA has developed a Surface Transportation Security
Inspector (STSI) Program, as mandated by the Fiscal Year 2005 Homeland
Security appropriations bill. The STSI program deploys TSA rail security
compliance inspectors to: conduct security system evaluations on-site at
transit properties; share security-related best practices information;
coordinate security threat advisories; and conduct inspections to ensure
compliance with TSA Security Directives.

TSA inspectors have authority to conduct on-site review of records,
technical specifications and procurement packages, and to request,
observe, and review security and terrorism preparedness activities being
conducted by the project.

## 

FTA recognizes that some of the material and information contained in
the SSMP may be considered SSI by the recipient. In such cases, FTA and
the PMOC, will follow the SSI procedures established by the recipient.

## 

**How will the SSMP be reviewed and approved by the FTA?**

FTA views SSMP development and implementation as an on-going process and
recognizes that in the early project phases, recipients may not yet have
performed many of the safety and security tasks specified in FTA's
Safety and Security Management Guidance Circular 5800.1. Consideration
will therefore be given to the current project phase and state of
project development during the SSMP review.

FTA will review each SSMP through the PMO program using established PMO
SSMP review procedures. These procedures will be shared with each
recipient prior to the review. The PMO will document the results of the
review in a report which will be provided to the recipient. The PMO will
then work with the recipient to bring outstanding issues to closure.

Over the full lifecycle of the project, FTA will assess the recipient's
development and implementation of the SSMP using the criteria specified
in FTA Safety and Security Management Guidance Circular 5800.1. These
criteria include:

1.  The recipient's assignment of responsibilities for safety and
    security, including the recipient's process for maintaining
    responsibility over safety and security tasks delegated to outside
    consultants and/or contractors.

2.  The effectiveness of the recipient's process to identify and
    communicate safety hazards and security vulnerabilities during each
    project phase.

3.  The recipient's technical capacity to support and maintain the
    levels of duties and responsibilities it identified for safety and
    security activities in the SSMP.

4.  The recipient's safety and security budget and schedule, including
    the recipient's determination regarding the resources it required
    for the safety and security activities in the SSMP.

5.  The extent to which the recipient incorporates safety and security
    requirements into the project's technical specifications and
    contract documents.

6.  The extent to which the recipient incorporates the SSMP activities
    and requirements into the technical direction provided to
    contractors and recipient personnel.

7.  The effectiveness of the recipient's approach in managing the safety
    and security activities of contractors.

8.  The extent to which the recipient takes documented action to address
    safety and security concerns in a timely and appropriate manner.

9.  The effectiveness of the recipient's approach for verifying that
    contractors, recipient staff, and committees built, installed,
    inspected, and tested all facilities, systems, and equipment in
    accordance with the recipient's adopted safety and security
    requirements as reflected in the project's technical specifications,
    drawings, and contracts.

10. The effectiveness of the recipient's process for verifying that
    contractors, recipient staff, and committees ensure the readiness of
    operations and maintenance personnel for revenue service.

11. The effectiveness of the recipient's process for providing safety
    and security certification, issuing the Final Verification Report,
    and managing any identified restrictions or work-arounds to full
    safety and security certification.

12. The effectiveness of the recipient's process for ensuring compliance
    with requirements specified by State Oversight Agencies, FRA, and
    DHS including TSA and FEMA/NPD.

## How will FTA address new SAFETEA-LU requirements for the SSMP?

SAFETEA-LU requires FTA to update its Project Management Oversight Rule,
49 CFR Part 633 and to revise the definition of "major capital project.
49 CFR Part 633.5 currently defines "major capital project" as any
project that:

-   Involves the construction of a new fixed guideway or extension of an
    existing fixed guideway;

-   Involves the rehabilitation or modernization of an existing fixed
    guideway with a total project cost in excess of \$100 million; or

-   The Administrator determines is a major capital project because the
    project management oversight program will benefit specifically the
    agency or the recipient. Typically, this means a project that:
    generally is expected to have a total project cost in excess of
    \$100 million or more to construct; is not exclusively for the
    routine acquisition, maintenance, or rehabilitation of vehicles or
    other rolling stock; involves new technology; is of a unique nature
    for the recipient; or involves a recipient whose past experience
    indicates to the agency the appropriateness of the extension of this
    program.

Major capital projects can be undertaken by grantees for rail transit,
bus and bus rapid transit, commuter rail, and ferries. As specified in
SAFETEA-LU, this includes funding from Section 5305 Statewide Planning;
Section 5307 Urbanized Area Formula Program; Section 5309/5318 Bus and
Bus Facility Grants; Section 5309 Capital Investment Grants \"New
Starts;" Section 5310 Formula Program for Elderly Persons and Persons
with Disabilities; Section 5311 Other Than Urbanized Area Formula
Program; and Section 5320 Transit in the Parks. Congestion Mitigation
and Air Quality (CMAQ) Improvement Program funds and Surface
Transportation Program funds, provided through the Federal Highway
Administration, can also be used for major capital projects.

In updating 49 CFR Part 633 to address new SAFETEA-LU provisions,
including the revised definition of "major capital project," FTA has
established an internal Working Group. FTA's Office of Safety and
Security and Office of Engineering are partnering with the Working Group
to ensure that any issues related to the SSMP requirements specified in
Circular 5800.1 are addressed in the changes to FTA's existing 49 CFR
Part 633. As specified in Section 5327(e), FTA will issue a Notice of
Proposed Rulemaking (NPRM) seeking public comment on these specific
requirements, followed by a Final Rule. FTA urges all interested parties
to make comments on the NPRM when it is published.

## Is the SSMP required by FTA similar to any other plan currently required by FTA for major capital projects? 

Yes. For a number of years, FTA has required grantees undertaking major
capital projects to prepare a *Quality Plan* as part of the PMP. The
Quality Plan guides activities to assure integration of quality
assurance and quality control activities into the overall project
management approach. The Quality Plan is an "umbrella plan" that
describes management commitment, organizational structures, project
controls, schedules, and resources available to address quality, and
specifies the development of additional plans, procedures, and processes
to assure acceptable quality while executing the project on-time and
on-budget through all project phases.

The SSMP is like the Quality Plan in that it is designed to explicitly
recognize the importance of a specific element of the project -- in this
case safety and security -- throughout the different project phases from
preliminary engineering and final design, to construction and equipment
procurement, and to testing and startup. The SSMP is also like the
Quality Plan in that it is an "umbrella plan" documenting the project's
commitment, organization, controls, schedules, and resources to be
devoted to safety and security, identifying the activities, plans,
procedures, and processes to be developed and carried out for the
project.

## For rail transit projects, how is the State Safety Oversight Agency involved?

FTA will invite State Oversight Agencies to Quarterly Review Meetings
for the project, and will copy State Oversight Agencies on minutes,
monthly reports, and spot reports and assessments which have safety and
security implications. In addition, FTA's PMO contractors and FTA's
Office of Safety and Security will be monitoring the readiness of each
State Oversight Agency to assume oversight of the project with its
initiation into revenue service.

FFGA recipients must identify the specific State Safety Oversight Agency
requirements applicable for their major capital projects and the
activities they will perform to address these requirements and
coordinate with their State Safety Oversight Agencies. These recipients
must also provide a schedule for the activities they will perform to
ensure compliance with State Safety Oversight Agency requirements. If
the State Safety Oversight Agency has authorities that exceed 49 CFR
Part 659 minimum requirements, the recipient must also explain its
approach for addressing these additional authorities.

For New Starts projects with new rail transit systems, prior to the
initiation of revenue service, State Oversight Agencies will be
responsible for reviewing and approving the project's SSPP, System
Security Plan, and supporting procedures, and for making an Initial
Submission to FTA. For existing rail transit agencies with extensions,
the State Oversight Agency will be responsible for ensuring that the
SSPP, System Security Plan and supporting procedures are revised to
address the extension. FTA recommends that State Oversight Agencies be
involved in the project from an early phase regardless of their
authority level.

## Can New Starts funding be used to support the State Oversight Agency in developing its oversight program?

Yes. Section 5309 funding may be used by the project to support the
establishment of the State Oversight Agency, including the use of state
agency personnel and/or contractors to develop the oversight agency
program standard and procedures; to review and approve safety and
security submittals from the project; and to conduct pre-revenue
operational readiness assessments. In the event New Starts funds are
used to help stand-up a State Oversight Agency, FTA will extend its
grant oversight, as appropriate, to the activities performed by the
State Oversight Agency.

## Is there a recommended schedule for submitting waiver petitions to the Federal Railroad Administration? 

Yes. FRA requests that waiver petitions be submitted to them for review
**at least 12 months prior to the project's revenue operations date**.
Additional information on the submission of these petitions is available
at: <http://www.fra.dot.gov/us/content/3>, under the "Waivers, BSAPs,
and Special Approvals" tab.

**Where can additional information pertaining to Circular 5800.1 be
obtained?**

FTA's regional and metropolitan offices are responsible for
implementation of grants and the provision of financial assistance to
recipients, other than specific programs that are the responsibility of
headquarters. Inquiries should be directed to either the regional or
metropolitan office responsible for the geographic area in which you are
located. For further information, visit the FTA website:
[http://www.fta.dot.gov](http://www.fta.dot.gov/)**[,]{.underline}**
Circular 5800.1:
<http://www.fta.dot.gov/laws/circulars/leg_reg_6930.html>, or contact
FTA headquarters at the following address and phone number:

Federal Transit Administration

Office of Communications and Congressional Affairs

1200 New Jersey Avenue SE

Washington, DC 20590

Phone: 202--366--4043

Fax: 202--366--3472

[^1]: Chapter II, Section 6 of FTA's FFGA Circular 5200.1A is available
    at:
    [[http://www.fta.dot.gov/laws/circulars/leg_reg_4119.html#chapter2]{.underline}](http://www.fta.dot.gov/laws/circulars/leg_reg_4119.html#chapter2).

[^2]: Available at:
    [[http://www.fta.dot.gov/publications/reports/other_reports/publications_3875.html]{.underline}](http://www.fta.dot.gov/publications/reports/other_reports/publications_3875.html).

[^3]: Available at:
    <http://www.fta.dot.gov/laws/circulars/leg_reg_6930.html>.