When Systems Shape the Road: Rethinking Bus Safety Through OSH and Quality Lenses
Engr. Elaine Macatangay Morales, MPA | 12 November 2025
A few years ago, a video of an MSJ Tours bus speeding along the newly built EDSA Busway went viral. The bus hit the concrete separator, shattered barriers, and shook commuters aboard and on the ground. The Department of Transportation called it a “gross violation of road transport rules and safety.” But as an auditor of quality, environment, and occupational safety and health (QESH) management systems, I did not just see a reckless driver. I saw a possibly flawed system.
For decades, the boundary-based compensation scheme has shaped how buses move in Metro Manila. Drivers must remit a fixed “boundary” to operators and keep whatever they earn beyond that. The logic is simple: the more trips they complete and the more passengers they collect, the more they take home. Studies on bus drivers in the region have shown that they often work up to 16 hours a day, usually engaging in over speeding and road racing just to meet their quota. More than half have experienced work-related accidents, averaging 3 per driver. An earlier research even described them as “wrongly accused road monsters,” pushed into unsafe behavior by operators’ demands and weak regulatory oversight. In ISO 45001 terms, this is not merely an unfortunate practice but a designed hazard- an unsafe condition embedded in the way work is structured and carried out.
Design Helps, but Design is Not Enough
Since the pandemic, some positive changes have been implemented. The EDSA Busway or EDSA Carousel introduced a dedicated bus lane, designated stops, and physical barriers that separated buses from mixed traffic. Travel times improved and boarding became more orderly. For many commuters, the system felt more predictable and less chaotic. Yet even with these improvements, safety incidents continued. Between November 2020 and November 2022, the Move as One transport coalition recorded 9 crashes on the Busway involving buses or vehicles entering the lane, causing 6 deaths and 13 injuries. Infrastructure could reduce exposure, but it could not counteract possible deeper issues in operations, incentives, and enforcement.
The reality is that bus operations are workplaces and high-risk ones. Bus drivers are exposed to long hours, chronic fatigue, persistent pressure to “habol” boundary, and the daily stress of navigating congested roads and unpredictable conditions. A 2025 policy brief described their occupational safety and health situation as “structurally precarious,” marked by unsafe conditions that accumulate unnoticed and unaddressed. Republic Act 11058, the OSH Law, and its implementing rules under DOLE Department Order 198-18 require employers to identify hazards, assess risks, and implement OSH programs. But when operators run businesses on thin margins and informal controls, compliance becomes selective, and OSH becomes an afterthought rather than a foundation.
Hazards as System Outputs
ISO 45001 provides a structured way to confront these problems. Hazard identification in a transport company should not begin and end with a reminder that “drivers must be careful.” It should map the hazards inherent in how drivers are paid, how their shifts are scheduled, how maintenance is conducted, how stops are designed, and how incidents are reported. A boundary compensation system that indirectly rewards speed is itself a hazard. Chronic fatigue is a risk that must be controlled as part of the job. Poorly maintained fleets, weak pre-trip inspections, and inconsistent documentation are operational risks. When these conditions are normalized, they predict the very accidents we continue to see on the road.
Controls, therefore, must follow the logic of risk reduction. The most effective control is eliminating the hazard. Moving away from pure boundary systems and adopting fixed income with transparent, safety-based incentives directly reduces the pressure to race for passengers. Several operators have implemented fixed salaries or fixed salaries combined with performance bonuses that are tied to adherence to schedules, zero traffic violations, and prevention of avoidable accidents. These are not just HR innovations, they are risk controls that realign behavior with safety.
Engineering and technical controls reinforce this shift. Proper preventive maintenance programs, functional brakes and lights, operational speed limiters, and well-designed bus stops with adequate lighting all contribute to safer operations. Vehicles that meet roadworthiness standards are not extras; they are basic safeguards. Administrative controls, often taken for granted, complete the picture. Limiting driving hours, enforcing rest periods, assigning routes systematically, conducting defensive driving and OSH training, and establishing clear procedures for emergencies and near-misses are essential steps. All of these require functioning OSH committees or person(s) in-charge as mandated by DOLE, not in name but in action.
Where Process and Competence Meet
ISO standards, whether ISO 9001 (for Quality) or 45001 (for OSH), emphasize the importance of worker competence. Bus operations are service systems and they require the same process clarity expected from manufacturing lines or technical services. Recruitment must ensure that drivers meet minimum qualifications responsibly and verifiably. Training must be more than a ceremonial lecture; it should assess skills in defensive driving, emergency response, traffic regulation compliance, and OSH awareness. Dispatching, fare collection, maintenance, incident reporting, and corrective action must be designed as repeatable processes, monitored regularly, and improved continuously.
Across the government agencies, private firms, and nonprofits I have audited, I have seen that performance failures often stem not from a lack of good intentions but from unclear processes and inconsistent implementation. When accreditation, training, or maintenance becomes mere paperwork instead of central operational elements, systems deteriorate, risks multiply, and accidents become unavoidable.
Audits as the System’s Mirror
This is where ISO 19011 (Guidelines for Auditing Management Systems) becomes essential. Internal audits give organizations a mirror. A well-designed audit program in a bus company would test whether documented processes match actual practice- whether driver logs reflect real working hours, whether maintenance records correspond to the physical condition of the fleet, whether incident investigations identify systemic issues rather than scapegoating drivers, and whether corrective actions are implemented and verified. The same patterns appear in factories, laboratories, offices, and nonprofit programs. Honest audits reveal the gap between policy and practice and compel leaders to decide whether improvement or denial will guide the system moving forward.
The Leadership Decision
Ultimately, leadership commitment is what determines whether a system improves or deteriorates. ISO 45001 and ISO 9001 both put top management at the center of system effectiveness. RA 11058 reinforces this by attaching legal accountability to OSH failures, and DOLE’s updated rules, including Department Order 252-25, further strengthen obligations. For bus operations, leadership commitment means treating the safety of passengers and drivers as non-negotiable, co-equal with profitability. It means investing in decent pay, credible OSH programs, meaningful training, real maintenance, and honest audits. These are not regulatory burdens, they are responsibilities tied to public trust.
Looking Beyond the Driver
After years of auditing management systems across sectors, I have learned that crashes, whether in a factory, a laboratory, or along EDSA, are rarely surprises. They are predictable outputs of how systems are designed, controlled, and led. The EDSA Busway demonstrated that design can shape behavior, but deeper change requires redesigning invisible systems: compensation, work hours, maintenance, competence, and accountability.
Safer roads will not come from blaming drivers alone. They will come from acknowledging that bus operations are workplaces governed by OSH laws, applicable standards, and public expectations. When incentives, controls, competence, and leadership finally align, we protect not only the commuting public but also the drivers who have long carried the cost of a hazardous system on their shoulders.
Drivers carry lives, not just passengers. Systems help shape how safely they can do that.