WMSC reports eight corrective action plan closures covering fitness-for-duty, track inspections, operator certification and parts criticality

WMSC staff told commissioners that eight corrective action plans (CAPs) reached final closure since the commission's last public meeting, while 75 CAPs remained open and 17 were in development.

Highlights of the closed CAPs presented by Miss Rhodes and staff include:

- CAP C0129 (fitness-for-duty): Metro established a fitness-for-duty governance board, adopted procedures based on APTA and DOT guidance (regular physicals for safety-sensitive personnel, return-to-duty exams, sleep disorder screening, medication reporting, and random post-accident drug/alcohol testing) and implemented the program following resolution of labor negotiations.

- CAP C0226 (track and structures): Metro revised yard inspection procedures to require monthly general visual inspections and detailed visual checks for switches and diamonds, trained personnel, and implemented a phased rollout of a Maxtrax mobile application for defect recording.

- CAP C0242 (roadway maintenance machines): Metro updated contractor inspection processes, notification requirements, and inspection documentation review; WMSC accepted an extended submission schedule that yielded the required 18 inspection records by November 2025.

- CAP C0263 (parts criticality): Metro updated parts-action-form procedures, added a safety-critical flag in Maximo, and submitted lists showing active items under review (381 in March 2025, 54 in Sept. 2025) to document ongoing designation of safety-critical components.

- CAP C0269 (operator retraining/retesting): Metro revised its operator performance-standardization manual and demonstrated retraining/retesting practices across four quarters of records; staff reported 28 unsuccessful certifications requiring retest and one repeated failure resulting in suspension.

- CAP C0277 (shelf-life management): Metro implemented a Shelf Life Management Program, incorporated expiration dates into inventory databases, performed quarterly inspections, and passed WMSC verification including an on-site check at Brentwood Yard.

- CAPs C0283 and C0286 (RWP training materials and mobile command): Metro revised roadway worker protection (RWP) training materials to meet FTA 49 CFR part 671 requirements; because new FTA rules rescinded the prior mobile-command procedures, Metro rescinded its mobile-command procedures and WMSC approved closure of the related CAP.

Commissioner questions focused on how WMSC verifies that closed CAPs remain effective over time. Staff said they employ a multi-pronged approach: rigorous pre-closure vetting that can include inspections and requests for additional data, integration of CAP review into subsequent area audits, risk-based inspections, and WMATA's internal safety reviews (ISRs) that include sections reviewing WMSC-issued CAPs.

What this means: WMSC staff emphasized that "closed" CAPs remain under periodic verification and that closure does not mean the issue is no longer monitored; subsequent audits and inspections will revisit closed topics to ensure lasting corrective action.

Next steps: WMSC will follow up on closed CAPs through its ongoing audit and inspection programs and will validate remedies during the upcoming revenue-vehicles and roadway-maintenance-machine audit scheduled to begin field work in late January and run through February.