Current Airport Inspection Practices Regarding FOD (Foreign Object Debris/Damage) (2011)

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3BACKGROUND Foreign Object Debris Defined Foreign Object Debris (FOD) has been defined by National Aerospace FOD Prevention, Inc. (NAFPI) as “a substance, debris, or article alien to a vehicle or system which would potentially cause damage” (NAFPI n.d., p. 4). By defining FOD so broadly, any material that could possibly be found on the air operations area (AOA) could be defined as FOD. Out- side the airport environment, small items such as nails, screws, and aluminum cans would only be considered a minor nui- sance; however, if any of these items are ingested by an air- craft engine, they can lead to catastrophic results. Currently the FAA defines FOD as “Any object, live or not, located in an inappropriate location in the airport environment that has the capacity to injure airport or airline personnel and damage aircraft” (FAA 2010a, p. 1). The Australasian Aviation Ground Safety Council (AAGSC) defines FOD as “any object that is left in an area where it could possibly cause damage. Such debris includes, but is not restricted to, metal (e.g., tools, nuts, bolts, and lock wire), wood, stones, pavement fragments, sand, plastic wrapping, and paper” (AAGSC 2003, p. 21). Despite these definitions, at present no standard international definition of FOD exists. The FAA is currently working with the International Civil Aviation Organization (ICAO) to develop a standard definition of FOD for the international aviation community. Introduction to Foreign Object Debris FOD may be present on runways, taxiways, aprons, or ramps, and can affect an aircraft in a variety of ways. Because of where FOD is typically located, aircraft can be directly affected during critical phases of flight, such as take-off. Esti- mates place the worldwide direct costs of FOD, including damages caused by bird strikes, at $1.26 billion annually. Direct plus indirect costs of FOD and bird strikes, such as those costs created by flight delays, cost the global aviation industry $13.9 billion annually. In the United States alone, direct and indirect costs of FOD and bird strikes total $5.2 bil- lion. When considering the direct and indirect costs of FOD not including damages caused by bird strikes, the United States experiences losses of $2.1 billion annually. At the top ten U.S. airports, FOD and bird strikes on runways alone cre- ate costs of $28.3 million annually (McCreary 2010). Accord- ing to McCreary (2010, p. 247), Airlines at a ‘typical’ airport of 300,000 movements per year can expect to spend $12 million per year on the direct and indirect cost of FOD and bird strikes on the runway. For an airport of 400,000 movements the total climbs to just under $16 million per year. Regardless of how FOD damages are quantified, they repre- sent a significant expense for the aviation industry, both in the United States and globally. In addition to the economic costs of FOD, in extreme cases it can cause aircraft accidents result- ing in loss. As Reid (2004, p. 28), explains, “EVERYTHING not nailed down can create big trouble.” CHAPTER ONE INTRODUCTION FOD Strikes Bird Strikes Total strikes per 4.0 2.1 10,000 movements Runway strikes per 2.1 0.7 10,000 movements Damage on the 1.6 0.1 runway per 10,000 movements FOD Strike Bird Strike Direct Costs Direct Costs Average cost per strike $10,000 $23,000 Average cost per $32,000 $47,000 10,000 movements Average cost per $2,000 N/A tire strike Average cost per $33,000 N/A engine strike Direct + Direct + Indirect Cost Indirect Cost of FOD + of FOD + Bird strikes Bird strikes (in all areas) (runway only) Economic value $5.216 billion $2.675 billion lost to U.S. Economic value $4.347 billion $2.229 billion lost to EU Economic value $13.910 billion $7.133 billion lost worldwide EU = European Union. Note: Larger airports may experience 300,000 to 500,000 or more movements annually. Large airlines may conduct 600,000 move- ments annually. Source: McCreary 2010, pp. 20, 158

Sources of Foreign Object Debris FOD can be difficult to mitigate because of its unique charac- teristics. First, it can be generated from a number of sources. According to Advisory Circular (AC) 150/5210-24, Airport Foreign Object Debris (FOD) Management, FOD can be produced by: • Personnel • Airport infrastructure (pavements, lights, and signs) • Environment (wildlife, snow, and ice) • Equipment operating on the airfield (aircraft, airport oper- ations vehicles, maintenance equipment, fueling trucks, other aircraft servicing equipment, and construction equipment) (FAA 2010a, p. 7). Construction activities on an airport can be prolific genera- tors of FOD if proper precautions are not implemented. Con- struction at an airport routinely causes debris, as construction items (e.g., as nails, screws, wood, or stone) can be blown onto the AOA. For this reason, among others, the FAA issued AC 150/5370-2E, Operational Safety on Airports During Con- struction. The AC provides guidance on how to minimize haz- ards (including FOD) generated by construction activity (FAA 2003). Specifically, the AC recommends adopting a safety plan with FOD control provisions spelled out. Section 3-14 of the AC, Foreign Object Debris Management, explains that: Waste and loose materials, commonly referred to as FOD, are capable of causing damage to aircraft landing gears, propellers, and jet engines. Construction contractors must not leave or place FOD on or near active aircraft movement areas. Materials tracked onto these areas must be continuously removed during the construction project. We also recommend that airport opera- tors and construction contractors carefully control and continu- ously remove waste or loose materials that might attract wildlife (FAA 2003, p. 12). FOD also has the ability to self-relocate, as debris collects on or near ground support equipment and in and around gate areas it can be picked up and propelled by jet blast or prop wash. FOD can also be relocated from runway and taxiway shoulders or grassy safety areas and propelled onto pavement surfaces by larger aircraft with outboard engines. Further- more, FOD can be relocated by helicopters as they maneuver over freshly mowed grassy areas or areas with loose dirt. Helicopter rotor wash can also produce FOD, as lightweight equipment may become airborne when subjected to rotor wash (FAA 2010a; McCreary 2010). 4 Types of Foreign Object Debris Although the FAA definition of FOD includes any item that could be found in the airport environment, some items are more common than others. Indeed, a one year airport study on FOD (FAA 2010a) discovered that nearly two-thirds of foreign objects removed from airfield pavement are com- posed of metal. Rubber was the next most common category at 18%. Additionally, data released by Delta Airlines in 2005 showed that 45% of the FOD damage sustained by its aircraft engines was caused by aircraft parts, including fasteners (McCreary 2010). Furthermore, according to AC 150/5210- 24, typical FOD includes the following (FAA 2010a): • Aircraft and engine fasteners (nuts, bolts, washers, safety wire, etc.); • Aircraft parts (fuel caps, landing gear fragments, oil sticks, metal sheets, trapdoors, and tire fragments); • Mechanics tools; • Catering supplies; • Flight line items (nails, personnel badges, pens, pencils, luggage tags, soda cans, etc.); • Apron items (paper and plastic debris from catering and freight pallets, luggage parts, and debris from ramp equipment); • Runway and taxiway materials (concrete and asphalt chunks, rubber joint materials, and paint chips); • Construction debris (pieces of wood, stones, fasteners, and miscellaneous metal objects); • Plastic and/or polyethylene materials; • Natural materials (plant fragments, wildlife, and vol- canic ash); and • Contaminants from winter conditions (snow and ice). Many foreign nations and agencies, such as ICAO, Euro- pean nations, and Australia are also conducting research and leading the way in FOD prevention. A ten-year study con- ducted from 1998–2008 by the Australia Transport Safety Bureau found that of the 398 ground-related aviation acci- dents/incidents during the study 116 (30%) were FOD related. Of the FOD-related accidents, 25% were caused by aircraft FOD and 19% were caused by misplaced tools and equipment. Highlighting how the long-term effects of FOD can be more detrimental to safety than short-term cata- strophic accidents, of the 116 FOD occurrences only one resulted in engine ingestion and failure, and three resulted in a tire blowout. According to the findings, 80% of the FOD occurrences did not adversely affect the safety of the flight in any manner (Australia Transport Safety Bureau 2010). Hartsfield–Jackson Atlanta International Airport is consid- ered to have one of the most effective FOD management programs relying on visual inspections. During 2008–2009, the airport documented the removal of 886 pieces of FOD over the course of 487 days. This equates to 10.6 pieces of FOD for every 10,000 commercial aircraft movements, equivalent to one piece of FOD for every 1,000 commercial aircraft movements. During this period, luggage and pas- senger equipment represented 46% of the FOD collected, concrete and bitumen 21%, ground vehicles and tools 18%,

5In addition to the many types of FOD possible at airports, debris varies greatly in size. As McCreary (2010) explains, large FOD is mostly an issue of safety, whereas small FOD is mostly an issue of cost. Larger FOD includes “metal strips, hinges, thrust reverser parts, flap hardware, hose nozzles, fuel caps, large pieces of pavement, and tire chunks” (McCreary 2010, p. 109). If an aircraft strikes an item of this size, it may result in engine destruction or failure, landing gear collapse, tire failure, damage to aircraft control surfaces, and punctures to the airframe. Smaller FOD includes “pieces of gravel, air- craft fasteners, ice, rivet heads, [and] . . . small nuts and bolts” (McCreary 2010, p. 109). When ingested into an aircraft engine, small FOD can cause nicked, cracked, or broken tur- bine blades. Small FOD can also create gouges in tires and damage to the airframe. In a 2004 study conducted by the United Kingdom Civil Aviation Authority (as cited in McCreary 2010), considered the most comprehensive record of runway FOD made pub- licly available, debris were categorized into 15 clusters by weight. The most common category of FOD (at 10%) was small debris weighing 0.07 to 0.14 ounces and ranging in size from 0.8 to 7.9 in. Examples of such FOD include small bolts, nuts, and aircraft fasteners. The next most common category (at 9%) was heavier objects weighing 5.29 to 7.05 ounces and ranging in size from 2.4 to 15 in. Examples of debris in this category include aircraft pins and nose gear door hinges. The third most common category (also at 9%) included objects weighing 14.10 ounces to 1.1 pounds and ranging in size from 5.5 to 23.6 in. Examples of debris in this category include thrust reverse parts, fuel caps, and small panel covers. Regardless of the size of debris discov- ered at airports, FOD management programs, according to McCreary (2010), must focus on both small and large cate- gories of FOD. NATURAL MATERIALS Of the types of FOD previously mentioned, the category of “natural materials” deserves special attention. Natural materials are typically plant fragments or wildlife. Plant frag- ments may be in the form of grass clippings as a result of mowing or brush that has found its way onto the pavement. Minimizing FOD in the form of plant fragments can be reme- died by choosing to perform activities such as mowing dur- ing down times of airport activity and thoroughly performing any necessary clean up after the activity has been completed. However, minimizing FOD in the form of wildlife is not a simple matter. Of the many types of FOD, wildlife is unique. As stated by MacKinnon (2004, p. 49), “In our enthusiasm to minimize the Foreign Object Damage created by errant aviation hardware, we often forget that FOD also comes in a soft package.” This “soft package” in the form of wildlife, represents “between 15% and 33% of the total FOD costs to the aviation industry” (MacKinnon 2004, p. 49). It is estimated that the annual total direct, indirect, and ancillary costs of wildlife-related FOD equal $1.2 billion worldwide (McCreary 2010). Clearly, wildlife FOD makes up a large part of the debris problem at airports and as this threat increases this type of FOD deserves special emphasis. Interestingly, evidence from airports with automated FOD detection technology has shown that there are many more birds on the runway than were previously sus- pected (McCreary 2010, p. 93). As explained by MacKinnon (2004, p. 51): The curtailing of DDT chemical use, successful wildlife conser- vation policies and laws, the reduction in pressure from hunting and natural predators, the availability of highly processed food in waste disposal facilities, global warming, and increased breeding success have all contributed to the remarkable population increases seen in some North American wildlife populations. whereas aircraft parts represented 1%. FOD that could not be categorized in these categories was categorized as “other” and made up 14% of the FOD collected. A full 83% of FOD during this period was collected on the ramp or on ramp/taxiway connectors. Source: McCreary 2010, p. 122 “Wildlife control officers and biologists suggest it is not sur- prising to find birds sitting on the runway surface. Ground feeding birds such as finches, sparrows, and thrushes often land in non-threatening open areas to eat. Game birds, rails, and crakes are all ground dwelling, and at some airports can be found loitering in grass on the runway edges—presum- ably because those edge sites offer a combination of suffi- cient views of the paved surface with some measure of con- cealment in the grass. For birds such as geese, flocking behavior means they tend to congregate on the ground in open areas. Eating behavior in seagulls and terns means they like hard flat surfaces to break open clams, crabs, and other crustaceans by dropping the shells from height. Crows have been known to drop items on runway and road surfaces as well. Additionally, birds, snakes, mice, and other ground creatures can be attracted to warm paved surfaces, especially at night. Such creatures often attract birds of prey such as owls and raptors, as well as an assortment of foxes, coyotes, and dogs” (McCreary 2010, p. 93). Living animals are typically targeted by airports as part of their wildlife hazard management program. Using either pas- sive or active techniques, or preferably both, airports can take action to minimize wildlife on an airport. Techniques such as habitat modifications, scare techniques, and fencing may prove quite effective. Although dead animals are quickly cat- egorized as FOD, living animals can represent or even gen- erate FOD at an airport, such as shore birds dropping mussels onto a runway to crack the shells. Whether living or dead,

wildlife is not compatible with operations being conducted on the AOA, and the detection and management of living and dead animals on the AOA is one aspect of FOD man- agement that rests with the airport operator. Although wildlife is typically the focal point of a wildlife manage- ment plan, it is possible to integrate a FOD management plan with a wildlife management plan. Rather than exist- ing in isolation, these two plans can be complimentary. In essence, the wildlife management plan exists to miti- gate aircraft–wildlife incursions and FOD in the form of wildlife. Although this synthesis does consider wildlife as FOD, the report only addresses FOD (including wildlife) and does not refer to wildlife hazard management pro- grams, which is the subject of ACRP Report 32: Guide- book for Addressing Aircraft/Wildlife Hazards at General Aviation Airports (2010). Airports may also wish to refer to Wildlife Hazard Management at Airports: A Manual for Airport Personnel, published by the FAA in cooperation with the U.S. Department of Agriculture (USDA). Thus, the definition of wildlife for this study is limited to wild- life, whether living or dead, that would be characterized as FOD. Because pilots are often the first to detect debris in the form of wildlife, it is important for pilots to always report any wildlife FOD accidents/incidents or near misses to the appro- priate authorities, whether that is the airport operator, Air Traffic Control (ATC), operations personnel, or a fixed-base operator (FBO) operator/employee. More information on mit- igating the presence of wildlife on or near airports may be found in AC 150/5200-33B, Hazardous Wildlife Attractants on or Near Airports (FAA 2007a). Although the FAA offers no guidance in this area and these systems are not specifically designed for this purpose, FOD detection technology can also aid the airport operator in preventing cases of wildlife FOD. Some fixed radar-based detection systems have the capability to detect birds and other animals that are present at the airport. When these detections are made, operations personal can remove the wildlife and ATC or the airport operator can inform pilots of any hazards that may exist. In most instances, wildlife as debris can be handled the same as other forms of FOD, in that it is continuously monitored and inspected for, as well as removed and documented according to the airport’s FOD management program. Airports are strongly encouraged by the FAA to voluntar- ily report wildlife strikes with civil aircraft by means of the FAA Wildlife Strike Reporting Form, which is available online. The FAA estimates that it takes 5 min to complete the 24 items on the form. Reporting strikes ensures that these events will be included in the National Wildlife Strike data- base, which is currently searchable online. The database includes more than 108,000 records of wildlife strikes occur- ring between 1990 and 2009 (FAA n.d.). There is room for progress with such reporting, as only 39% of the wildlife strikes at all Part 139 airports were reported between 2004 and 2008 (Dolbeer 2009). 6 Damage Caused by Foreign Object Debris In the industry, FOD also refers to Foreign Object Damage. As defined by the NAFPI in this regard, FOD is “any damage attributed to a foreign object that can be expressed in phys- ical or economic terms which may or may not degrade the product’s required safety and/or performance characteristics” (NAFPI n.d., p. 4). Damage caused by FOD can result in inci- dents that range from a nick on an engine fan blade, a cracked windscreen, or, rarely, an aircraft accident. FOD creates the potential for significant losses, whether financially or in human terms. According to E. Gervais of Boeing Aircraft, “jet engines are basically just big vacuum cleaners” (as cited in McCreary 2010, p. 49). Further, McCreary (2010, p. 49) explains that engines are at greatest risk of FOD damage when at “high suck” and “low speed conditions.” Thus, the danger of FOD is most pronounced during critical stages of flight, such as takeoff and landing. A 2008 study found that the world’s 300 busiest airports deal with more than 60,000 inci- dents of FOD each year (McCreary 2008). The study esti- mated that $20 million worth of FOD damage is incurred at each airport annually, as the airports work to prevent, detect, and remove FOD from airport surfaces. Additionally, the average U.S. airline incurs $250,000 worth of maintenance costs from damage caused by FOD for every 10,000 move- ments performed by the airline. If an aircraft engine is dam- aged it may require blade burnishing, blade replacement, fan changes, or a complete engine overhaul (Figure 1). If the fuse- Select Wildlife–FOD Accidents Watertown, USA, 1975 On June 14, 1975, a NA265 Sabreliner crashed following takeoff after ingesting gulls in both engines. Both wings were torn off, resulting in a significant fire. Three of six people on board were injured and the aircraft was destroyed as a result of the crash and post-crash fire. The city of Watertown, which was sued by the Safeco Insurance Company, was found guilty of failing to warn the pilot of the presence of birds. Judgment for the full value of the destroyed aircraft was entered against the city. New York, USA, 1995 On June 3, 1995, an Air France Concorde struck Canada geese during its approach and landing at John F. Kennedy International Airport. Two of the four aircraft engines sub- sequently caught fire and were destroyed. Air France sued the airport operator, the Port Authority of New York and New Jersey, for the $6 million cost of the two engines. After extensive legal costs for both sides, the parties reportedly set- tled for $5.3 million on the day before the trial. The airport, in this case, was faulted for not warning the flight crew of known Canada geese activity. Source: MacKinnon 2004, p. 52.

7lage is damaged, it may require the repair of dents and holes (Figure 2). Tire damage results in the replacement of tires with cuts, loss of pressure, or complete failures (Figure 3). It can be noted, however, that damage from FOD more likely results from debris being thrown by prop wash or jet blast, not necessarily from sucking debris into an engine. As summa- rized by McCreary (2010, p. 28), “FOD strikes are unlikely to cause a major catastrophe, yet are the most expensive of the four identified runway risks” (the others being incursions, excursions, and birds). Interestingly, FOD strikes that cause actual damage are 5,500 times more likely to occur than even minor damage from an incursion (McCreary 2010). In addition to damages to fixed-wing aircraft, helicopters may also be damaged by FOD. Unlike fixed-wing aircraft, helicopters are less susceptible to catastrophic FOD damage such as engine failures through ingestion, because the engine intake is on top of the helicopter. Even so, FOD-related dam- age to helicopters can occur over time through the accumu- lation of dust, sand, and other fine particles passing through the engine. Seventy-five percent of U.S. helicopter accidents in wars in Afghanistan and Iraq this past decade were directly caused by FOD. Historically, helicopters have had signifi- cant trouble with regard to FOD when landing in sandy and rocky areas (Fails 1978). Technologies have been developed to prevent sand, dirt, rocks, and other items from being blown into helicopter engines, such as portable helipad mattings that may be placed on landing areas. The U.S. Army is cur- rently testing how successful these items are at minimizing FOD. In addition, helicopters can also cause debris to be dis- persed to other areas of the AOA, which requires vigilance by airport operators of helipads and helicopter operating areas (Brower 2004). Clearly, FOD is a true risk with significant consequences to the aviation industry. Whether a large or small airport, mil- itary or civilian, FOD not only impacts safety of operations, but also the bottom line. FOD also inconveniences airline passengers and results in thousands of hours of delayed flights each year. It is therefore extremely important for any airport to be aware of FOD and to have plans in place to detect and remove debris, as well as minimize the frequency of FOD on the AOA. FIGURE 1 Results of engine ingestion of FOD. Source: Jim Stephan, Delta Air Lines Corporate Safety, Oct. 25, 2005, FOD/ Wildlife, An Airline’s Perspective presentation. [Online]. Avail- able: http://www.fodnews.com/FOD_For_FAA-gif/slide001.htm. Although rare, engine ingestion of FOD has also caused fatal aircraft accidents. A well-publicized accident with FOD as one of the casual factors occurred on July 25, 2000. On this day, Air France Flight 4590 was scheduled to depart from Charles de Gaulle International Airport in Paris, France, bound for New York. During the takeoff roll, the Concorde blew a tire after running over a piece of metal on the runway. Debris from the Concorde’s blown tire imme- diately punctured the underside of the Concorde, which subsequently ruptured a fuel tank. Two of the aircraft’s engines lost power as the result of an electrical short caused by fuel rushing out of the ruptured tank. These occurrences FIGURE 2 Result of fuselage damage from FOD. Source: Jim Stephan, Delta Air Lines Corporate Safety, Oct. 25, 2005, FOD/ Wildlife, An Airline’s Perspective presentation. Available: http:// www.fodnews.com/FOD_For_FAA-gif/slide001.htm. FIGURE 3 Result of tire damage from FOD. Source: Jim Stephan, Delta Air Lines Corporate Safety, Oct. 25, 2005, FOD/ Wildlife, An Airline’s Perspective presentation. Available: http:// www.fodnews.com/FOD_For_FAA-gif/slide001.htm.

Addressing Foreign Object Debris To effectively mitigate FOD, airports develop comprehen- sive management programs. Although the airport operator maintains the responsibility for a FOD management program, airlines, construction companies, and other agencies that have access to the AOA may have their own programs. Regardless of whether a tenant or contractor has a unique FOD management program of their own, their support of the airport’s overall FOD management program is encouraged to minimize the risk of FOD in the airport operating environ- ment. Indeed, Chaplain and Reid (2004) promote the concept of an Integrated FOD Team, which includes everyone con- cerned for the safety of the airport, such as flight crews, office staff, tenants, and visiting contractors and vendors. 8 In advising airports on this issue, the FAA issued Cert Alert No. 09-06, Closing Active Runway for FOD Checks Increases Safe Operation (2009b). It states, in part: The FAA’s Office of Safety and Standards has been made aware of instances where some airports have failed to take immediate and positive action following a report of FOD (on or near the runway) from flight crews. In one instance, operations on an active runway continued for several minutes following a report of loose aggregate material (of a size that posed a threat to air- craft operations) on the runway. Stressful situations have added fuel to this debate by fostering opportunities where a controller or pilot reports FOD but operations are continued until someone arrives to clear the debris from the runway. While the temptation to continue operations on a contaminated surface may be strong, particularly during periods of increased traffic movement, air- ports must never lose sight of the primary goal, which first and foremost is safety of flight. The manner in which airports accomplish this primary goal of safety of flight may vary, but an effective FOD man- agement program is integral to achieving that goal. The FAA, in AC 150/5210-24, has identified the four main components of a FOD management program (FAA 2010a) as follows: 1. FOD Prevention a. Awareness i. Program existence and status ii. FOD policy and management support iii. Safety culture. b. Training and education i. Audience ii. Features iii. Training objectives iv. Training documentation. c. Maintenance programs. 2. FOD Detection a. General b. FOD risk assessment c. FOD detection operations i. Inspection areas ii. Methods and techniques. d. FOD detection equipment. 3. FOD Removal a. Background b. Equipment characteristics i. Mechanical systems ii. Non-mechanical systems iii. Storage systems. c. Performance i. Operational standards ii. Testing/validation. d. Removal operations. 4. FOD Evaluation a. Data collection and analysis i. Documentation ii. Reporting iii. Investigation iv. Database. b. Continuous program improvement. resulted in a fire that caused the wing to melt and the plane to crash. A thorough investigation revealed that the accident could be attributed to a small titanium strip that had fallen off a DC-10 that had landed on the runway before the Con- corde’s departure. This accident resulted in the loss of 113 lives in the aircraft and on the ground, financial losses for the airline, and the eventual grounding of the entire fleet of Concorde aircraft in operation. In December 2010, Conti- nental Airlines and one of its mechanics were found guilty of criminal negligence in the Concorde crash. Even so, legal proceedings were expected to continue. Source: BEA Accident Reports (2002); “Airline Guilty over Concorde Crash” (2010). Sample Airport Use License Clause The Licensee shall in exercising its privileges: a) At all times keep the airside surfaces free of all foreign objects and litter; b) When directed by the Licensor acting reasonably, remove immediately from the airside surfaces or a portion thereof, its equipment and anything related to its operations; c) At all times keep the Licensor’s facilities in a neat, clean, and orderly condition, free from litter, debris, refuse, petroleum products, or grease that may accumulate thereon as a result of the use of the Licensor’s facilities by its passengers or its employees, contractors, or others ser- vicing and operating its aircraft; d) Require its employees to abide by and comply with the Licensor’s AVOP (Airside Vehicle Operator’s Permit) Pro- gram and shall cooperate with the Licensor in airside safety matters and enforcement of the AVOP Program; and e) Not engage in or allow any activities which may result in a nuisance or that may cause annoyance to adjoining occupants or any other users of the Airport, the whole as determined by the Licensor, acting reasonably. (Larrigan 2004, p. 69).

9In addition to the areas spelled out in AC 150/5210-24 (FAA 2010a), other resources are available to airport operators for developing an effective FOD management program. For instance, Dave Larrigan (2004, pp. 70–77) in chapter five of Make it FOD Free! suggests the following ten elements of an effective FOD prevention program: • Management’s strong, visible commitment • Local FOD committees • Housekeeping performance standards • Training and awareness • Selection and maintenance of ground support equipment (GSE) and airfield maintenance equipment • Spare parts and tools • Airport construction projects • Motivating construction crews to understand FOD threats • Monitoring and inspection • Seasonal considerations. Furthermore, Simmons and Stephan (2004, pp. 95–97) sug- gest the following components of a FOD prevention program: • Organization • Policies and procedures • Vision • Measurement tools • Investigations of incidents and accidents • Feedback procedure • Establishing goals. San Antonio International Airport (SAT) has a well-devel- oped FOD prevention program that according to Ryan Rocha, Interim Assistant Aviation Director, cost approxi- mately $10,000 to establish and costs $6,000 per year to maintain. The vision of their program is to “develop and maintain a FOD Prevention Program that addresses and resolves FOD issues and establishes a culture of safety that promotes a zero-tolerance policy for airfield FOD through encouragement, training, collaboration, and commitment.” To accomplish this, they first involved stakeholders, includ- ing the aviation department, airlines, FBOs, and air cargo. They developed a FOD committee with one representative from each organization, mostly from the manager level. This committee, which meets monthly, sets policy for the FOD program and exhibits management commitment to the FOD program. The FOD Squad is comprised of the mem- bers of each organization involved in the FOD program and meets at quarterly FOD squad walks. The FOD prevention program at SAT enhances awareness and participation by developing a new FOD campaign every six months, with a new design to be placed on t-shirts, posters, and stickers. Each campaign has the following components: • FOD inspections – Inspections of each airline gate area, air cargo ramp area, and every FBO area. – Conducted by airport operations bi-weekly, with a notice sent to tenants at least 24 h in advance. – Surprise inspections conducted twice during every six month campaign. – Airlines are given a score per gate that is averaged, with FBOs and cargo airlines given a single score for their entire leasehold. Airlines compete by air- line size. – Found FOD is photographed, with a score assigned based on the number of pieces found.  0 pieces of FOD = 100%  1–2 pieces of FOD = 90%  3–4 pieces of FOD = 75%  5 or more pieces of FOD = 50%. – Scores are maintained in a database and tenants have the opportunity to raise scores by participat- ing in FOD committee meetings and FOD squad walks. • FOD squad walks – Scheduled and coordinated by airport operations – Lasts one hour – Food and beverages are provided – Incentives  Find a gold bucket, earn a gift card  Turn in a FOD bag and pick either a FOD t-shirt or cap. – Group photo after every FOD walk. • Awards ceremony – Six month and annual – Awards based on FOD inspection score, FOD squad walk participation, and FOD committee participation – First place receives trophy with second place receiv- ing a certificate. The program at SAT has been successful in preventing the accumulation of FOD, increasing FOD awareness, increas- ing participation from stakeholders, and increasing com- munication with stakeholders resulting in cleaner gates, aprons, and airfield areas; in industry recognition; and a proactive approach to a Safety Management System (SMS). Source: Ryan E. Rocha, San Antonio Airport System, Nov. 18, 2010, San Antonio International Airport FOD Prevention Program Presentation [Online]. Available: http://www.faa.gov/airports/ great_lakes/airports_news_events/2010_conference/Media/A-5_ FOD_Program.pdf. Although variation exists in how to best structure a FOD management program, to allow for the most efficient organi- zation of collected data, this report has been organized around the following five main areas: 1. Inspection 2. Detection 3. Removal 4. Documentation 5. Training and Promotion.

OVERVIEW OF STUDY Scope of Study The focus of this study was on current airport inspection practices regarding FOD. Airports conduct self-inspections for a variety of purposes, but this study focused solely on those inspections for FOD. In addition, the definition of wildlife for this study is limited to wildlife, whether living or dead, that would be characterized as FOD. Although the syn- thesis focuses on inspection practices, this study approached FOD from a comprehensive perspective and, as such includes chapters on inspection, detection, removal, documenta- tion, and promotion and awareness. Each chapter not only addresses requirements, but also presents current airport practices and specific technology and equipment available for airports in carrying out each specific component of a FOD management program. Although the majority of airport oper- ators surveyed for this synthesis operate in the United States, and the bulk of pertinent information found through the liter- ature review dealt with FOD in the United States, this report included FOD programs and technologies that exist across the world, in addition to those pursued by the U.S. military. Study Methodology To best determine the current state of practice on FOD man- agement at airports, this synthesis was carried out using a comprehensive approach. Information used in this study was acquired through an extensive literature and data review, two surveys, follow-up interviews of survey respondents, contri- butions from panel members, and the author’s professional knowledge of the subject area. At the outset, a literature and data search was conducted to document regulations for conducting FOD inspections on the U.S. and international levels. Additionally, the literature was reviewed regarding all aspects of FOD management. The search focused on the following: (1) 14 CFR Part 139; (2) rel- evant state and international regulations on the subject matter; (3) other federal guidance such as CertAlerts and Advisory Circulars; (4) relevant literature in the forms of books, maga- zines, reports, and surveys conducted on the various aspects of FOD; and (5) examination of current products that exist on the market to prevent, detect, and remove FOD from an air- port’s surface. Survey instruments were developed to gather data from a sample of airport operators, as well as the population of manu- facturers of technology and equipment considered beneficial for a FOD management program. The first questionnaire, “Air- port Survey of Inspection Practices” can be found in Appen- dix B. This questionnaire, which consisted of 42 items, was designed to solicit perspectives from airport managers and/or operations personnel regarding their current airport inspection practices for FOD. Specifically, the purpose of this question- naire was to determine the tools (including equipment and tech- nology) and procedures airport personnel are using in carrying 10 out the following components of a FOD management program: inspection, detection, removal, documentation, and promotion and awareness. Also, the questionnaire sought to identify rea- sons why airports adopted various tools and procedures. The second questionnaire developed for this synthesis, “Survey of Manufacturers/Suppliers of Airport Inspection Technology and Equipment,” can be found in Appendix C. The questionnaire was sent to all manufactures and/or suppli- ers of equipment and technology considered useful to airports in conducting inspections, as well as detecting, removing, and documenting FOD. The purpose of the questionnaire was to determine the entire spectrum of equipment and technology currently available to airports for carrying out a comprehen- sive FOD management program. With this information, a con- tinuum of available technology and equipment (depending on the specific component of a FOD management program) was developed. Although the initial effort involved an attempt to determine pricing for the various technology and equipment; typically, manufacturers were reluctant to provide this infor- mation. This is the result, in large part, to the very site-specific nature of the technology currently available. Costs vary owing to civil engineering requirements, airfield complexity, and spe- cific airport needs. Thus, airports interested in acquiring equip- ment or technology for a FOD management program are encouraged to consult with specific manufacturers or suppliers to determine pricing for their intended application. Great care was taken to ensure that the methodology for the survey implementation was both sound and strategically orchestrated. For instance, to obtain a nationwide representation of airports and manufacturers/suppliers, the FAA’s nine regions were utilized. Within each region, an attempt was made to select one airport from each of the following categories: large hub, medium hub, small hub, non-hub, and general aviation (GA). In addition, where possible, two military airports were selected from each of the five U.S. branches of the military, as well as five non-U.S. airports. After revising the sample based on the recommendation of panel members, the study included a total sample size of 56 airports. Because of the relatively small population of manufacturers and suppliers, the entire known population of manufacturers and suppliers was included; 20 companies. The population of manufacturers/suppliers was developed from an Internet search and review of the literature. To aid in survey distribution and simplify responses, the questionnaires were created in, and distributed by, means of a web-based survey management platform. Once contact information for the 56 participating airports was uploaded, participants were sent an e-mail explaining the purpose of the study and containing a link to the online questionnaire. Once the recipient clicked on the link to access the survey, they were presented with an introduction of the study and a consent request. By clicking “Next,” participants were then directed to the first page of the questionnaire. In an effort to reach the desired 80% response rate, multiple contacts were used. Two e-mail follow-ups were sent after the initial invitation e-mail,

11 followed by a phone call from the consultant, followed by personal contact by individual panel members as necessary. This effort was sufficient and eventually resulted in an 89% response rate (50 airports). Participating Airports Data were collected from 50 airports. Appendix A lists these participating airports and Figure 4 presents the breakdown of respondents by FAA region. In addition to the wide geographic distribution of respon- dents, the airports participating in this synthesis were of almost any size. Figure 5 presents the airport respondents by airport category or size. In addition to categorization by hub size, the questionnaire also determined the size of the responding airports by the num- ber of operations. The airports participating in this synthesis also include a wide range of airports in terms of annual opera- tions. Figure 6 shows airport respondents by annual operations. Lastly, in a final effort to fully understand the airports par- ticipating in the synthesis, participants were asked their air- port certification status. Although the majority of participants were larger, Class I airports (as specified by Part 139), other categories (including international) were represented as well. Figure 7 presents airport respondents by certification. As shown in Figures 4–7, the synthesis collected data from a diverse group of airports. Specifically, participating airports represent all FAA geographic regions and some international 1 5 2 2 4 7 5 5 5 4 5 3 Australia Canada Europe U.S. Alaska Region U.S. Central Region U.S. Eastern Region U.S. Great Lakes Region U.S. New England Region U.S. Northwest Mountain Region U.S. Southern Region U.S. Southwestern Region U.S. Western Pacific Region FIGURE 4 Airport respondent self-selected geographic location. Note: Two airports did not indicate FAA region or geographic location. 3 6 10 5 8 8 Military GA Non-hub Small hub Medium hub Large hub FIGURE 5 Airport respondent self-selected hub size. Note: Ten airports did not indicate airport size.

12 8 6 7 4 3 12 3 0 Greater than 300,000 200,001 to 300,000 150,001 to 200,000 100,001 to 150,000 70,001 to 100,000 30,001 to 70,000 10,001 to 30,000 Less than 10,000 FIGURE 6 Airport respondent self-selected number of operations. Note: Seven airports did not indicate classification status. 7 7 6 0 4 22 0 5 10 15 20 25 Not certificated ICAO Annex 14 14CFR Part 139 - Class IV 14CFR Part 139 - Class III 14CFR Part 139 - Class II 14CFR Part 139 - Class I FIGURE 7 Airport respondents by certification. Note: Four airports did not indicate certification status. countries, as well as all hub sizes. Airports vary in size by number of operations and represent all classes of 14 CFR Part 139 (with the exception of Class III), as well as ICAO Annex 14 (ICAO n.d.). Report Organization This report has been organized into seven chapters. Chapter one introduced the concept of FOD, provided examples, and detailed the scope and objectives of the project. Chapter two focuses on the methods used to inspect for FOD, as well as current airport practices and technology and equipment avail- able for inspections. Chapter three presents the methods used to detect FOD, as well as current airport practices and tech- nology and equipment available for FOD detection. Chapter four presents the methods used to remove FOD, including both mechanized and non-mechanized systems. In addition, this chapter presents current airport practices, as well as the technology and equipment available for FOD removal. Chap- ter five presents the methods used to document FOD and analyze data, as well as current airport practices and technol- ogy and equipment available for FOD documentation and analysis. Chapter six presents the concepts of training and promotion, and includes current airport practices on this topic. Chapter seven presents concluding thoughts on FOD management and summarizes the major findings of the synthesis. Each chapter generally first presents information gleaned from the literature review, before presenting equip- ment and technology currently available, followed by current airport practices. There is additional supporting information in the appendices.