Objective

To determine whether the Metropolitan Transportation Authority – New York City Transit complied with maintenance and inspection requirements pertaining to Event Recorder Units (ERUs) and whether Transit has a corrective action plan (Plan) to fix ERU deficiencies that are identified. The audit covered the period from January 1, 2014 through to February 7, 2018.

About the Program

Transit is the largest public transportation agency in North America and one of the largest in the world, with 472 subway stations spread across four of the five boroughs of New York City. As of February 3, 2018, Transit had 6,435 subway cars and, on an average weekday, carried about 7.7 million passengers. In 2000, Transit began to deploy its New Technology Trains (i.e., Models R142, R142A, R143, R160, and R188) and train locomotives (Model R156), which included ERUs, or “black boxes.” ERUs are a valuable safety feature that allow for the monitoring of train equipment and technical analysis of incidents/accidents based on data they record, such as train speed, brake pipe pressure, and train direction. Only the cars with cabs used by train operators and conductors are equipped with ERUs.

Key Findings

We determined Transit was not in compliance with its ERU maintenance and inspection policy, as detailed below:

• Train car inspections were not always done timely. We determined that, of the 822 timed inspections during our scope period, 70 were late, exceeding the permitted time and/or mileage interval.
• For 129 inspections, maintenance personnel did not provide evidence that they downloaded information from ERUs to ensure that they were functioning correctly, as required by Transit’s work manuals.
• In 1998, the U.S. Department of Transportation released a memo about ERU requirements, based on federal regulation, which stated the industry standard for memory capacities for ERUs is 48 hours. Model R142 cars, which comprise a significant portion of Transit’s fleet, were brought into revenue service in 2000 after the federal guidance was issued. However, for this car class, the ERU’s memory capacity is not up to industry standards. This makes it challenging for Transit to retrieve a download when it is requested for a non-emergency incident/accident because the ERUs have only a 12-hour memory before their data is overwritten. Transit has been unable to fulfill some download requests as a result of this limited time frame.
• There are discrepancies between the Rolling Stock Management Information System (RSMIS) and source documents due to staff not complying with Transit guidelines regarding documentation of work. This has resulted in Transit not being able to effectively track the maintenance and inspection of the ERUs or work orders through its system.
• Transit did not have a Plan to fix deficiencies identified during the maintenance and inspection of ERUs. Instead, Transit officials stated they have processes to ensure they have a sufficient supply of working ERUs to be used as replacements as needed. However, we found Transit did not have the required number of spares for two car classes based on its own standard.

Key Recommendations

• Ensure ERUs are inspected in accordance with Transit’s maintenance and inspection policy and procedures.
• Increase the hard memory module capacity for R142s and R142As to be in compliance with the industry standard.
• Develop a more detailed work manual to include specific steps pertaining to ERUs and ensure consistency in testing across ERU models.
• Designate personnel within each maintenance shop to perform data entry so the RSMIS for the maintenance department is comprehensive.
• Develop a Plan with steps that, at a minimum, address identifying an ERU malfunction, removing and replacing an ERU, and sending and repairing the ERU at the Central Electronics Shop.