Luas is seeing an increase in the number of people walking out in front of an oncoming tram.
It says pedestrian behaviour, as observed by drivers, is seeing "earphones in, head down, and thumb firmly fixed on screen".
It says: "More and more people don't even look up, yet alone look left and right. Commuters are distracted.
"Walking out in front of an oncoming tram is a common experience."
When this happens, the company says the driver applies the emergency brake.
Figures show this has happened 223 times so far this year.
Overall, the tram system had an emergency brake applied 550 times.
Operator Transdev says this breaks down as 266 times for a car, 223 due to a pedestrian and 61 times because of a cyclist.
Last year, the emergency brake was applied 570 times for the same reasons.
The company says motorists are also at risk.
Road Safety Authority (RSA) research shows motorists are four times more likely to be in a collision when using a mobile phone while driving.
While texting or messaging behind the wheel is on the decline, it is still happening.