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Safety Reporting Systems at Airports (2014)

Chapter: Chapter Two - Existing Part 139 Data Requirements

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Suggested Citation:"Chapter Two - Existing Part 139 Data Requirements ." National Academies of Sciences, Engineering, and Medicine. 2014. Safety Reporting Systems at Airports. Washington, DC: The National Academies Press. doi: 10.17226/22353.
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Suggested Citation:"Chapter Two - Existing Part 139 Data Requirements ." National Academies of Sciences, Engineering, and Medicine. 2014. Safety Reporting Systems at Airports. Washington, DC: The National Academies Press. doi: 10.17226/22353.
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Suggested Citation:"Chapter Two - Existing Part 139 Data Requirements ." National Academies of Sciences, Engineering, and Medicine. 2014. Safety Reporting Systems at Airports. Washington, DC: The National Academies Press. doi: 10.17226/22353.
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Suggested Citation:"Chapter Two - Existing Part 139 Data Requirements ." National Academies of Sciences, Engineering, and Medicine. 2014. Safety Reporting Systems at Airports. Washington, DC: The National Academies Press. doi: 10.17226/22353.
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Suggested Citation:"Chapter Two - Existing Part 139 Data Requirements ." National Academies of Sciences, Engineering, and Medicine. 2014. Safety Reporting Systems at Airports. Washington, DC: The National Academies Press. doi: 10.17226/22353.
×
Page 14
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Suggested Citation:"Chapter Two - Existing Part 139 Data Requirements ." National Academies of Sciences, Engineering, and Medicine. 2014. Safety Reporting Systems at Airports. Washington, DC: The National Academies Press. doi: 10.17226/22353.
×
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Suggested Citation:"Chapter Two - Existing Part 139 Data Requirements ." National Academies of Sciences, Engineering, and Medicine. 2014. Safety Reporting Systems at Airports. Washington, DC: The National Academies Press. doi: 10.17226/22353.
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10 Certificated airports within any state, territory, or possession of the United States and the District of Columbia are regulated by the FAA under Title 14 CFR Part 139. FAA issues AOCs to airport opera­ tors to “ensure safety in air transportation. To obtain a certificate, an airport must agree to certain operational and safety standards” (FAA 2014). PART 139 COMPLIANCE Airport certification standards are maintained through requirements set forth in Part 139, and com­ pliance is demonstrated through written documentation in an ACM. Annually, or more frequently if necessary, FAA Airport Certification Safety Inspectors (ACSIs) conduct on­site visits and review ACM and other files and paperwork as part of an airport certification inspection. The ACSI assesses compliance with safety and regulatory requirements through documentation review, data analy­ sis, and observance of airport operational procedures. To retain an AOC, airports are required to collect and compile a variety of information, including airfield self­ inspection reports; Notices to Airmen (NOTAM); Aircraft Rescue and Fire Fighting (ARFF) training and accidents/incidents; fueling facility inspections; and train­ ing documentation. This information is reviewed by the FAA during the periodic inspection. PART 139 DATA COLLECTION A variety of safety­related data are compiled by specific Part 139 sections, primarily under Subpart D—Operations. The primary means to collect airport safety data is through the airport safety self­inspection program. An effective self­inspection program enables an airport operator to operate in compliance with Part 139 standards on a “day­to­day basis” (FAA 2004). The primary areas of airport self­inspection programs include pavement areas, safety areas, mark­ ings, signs, lighting, ARFF, fueling operations, navigational aids, ground vehicles, obstructions, pub­ lic protection, wildlife hazard management, construction, FOD, and snow and ice control. Airport operators are required to document, collect, and provide records to the FAA ACSI upon request. FAA states, “For even the smallest airport, it is desirable to use a safety self­inspection checklist that constitutes a written record of conditions noted, and acts as a check on follow­up actions taken. The scheduled use of a dated checklist will assure the regularity and thoroughness of safety inspections and follow­up. The checklist can be an important administrative tool for airport management. It can provide a snapshot of the condition of the airport, indicating trends, defining problem areas, indicat­ ing systems that are beginning to deteriorate and helping to define budgetary requirements. It is most desirable to use a format . . . in which each inspected area of the airport complex is positively noted” (FAA 2004). Table 5 presents sections, descriptions, and relevant data types, such as records, reports, inspec­ tions, and plans, typically collected for compliance and management oversight by Part 139 airport operators. As described previously, certain records must be made available to the FAA ACSI and must be retained for a designated length of time. Table 5 demonstrates that airport operators col­ lect a wide assortment of information to support safe airport operations and compliance; however, in most cases the information compiled is not centralized and is not maintained in an electronic chapter two EXISTING PART 139 DATA REQUIREMENTS Part 139 Subpart D—Operations outlines safety-related information collected at airports.

11 Subpart D— Operations Part 139 Section Subpart D— Operations Part 139 Description Information and Types Data Collected §139.301 Records Airport personnel, emergency personnel, fueling personnel training records, airport fueling agent inspection records, self-inspection records, accident and incident records, airport condition records and dissemination §139.303 Personnel See §139.301—Records §139.305 Paved areas Self-inspection and maintenance records §139.307 Unpaved areas Self-inspection and maintenance records §139.309 Safety areas Planning and design documentation, self-inspection, and maintenance records §139.311 Marking, signs, and lighting Marking, sign, and lighting system designs, Airport Sign and Marking Plan, self-inspection and maintenance records, including preventive maintenance programs §139.313 Snow and ice control Snow and ice control plan, including instructions and procedures, NOTAMS, snow event practice sessions and debriefs, accident or incident reports (if any), and deicing permits §139.319 Aircraft rescue and firefighting: Operational requirements ARFF staff training records, fuel inspection records, live fire-drill records, and Airport Emergency Plan (AEP) §139.321 Handling and storing of hazardous substances and materials Training records, inspection records, corrective action records, AEP §139.325 Airport emergency plan AEP, contact lists, inventories, procedures, emergency plan exercises and debriefs §139.327 Self inspection program, FOD Inspection reports collected during regular operations, unusual conditions, such as construction activities or meteorological conditions, or after an accident or incident. Staff training, NOTAMs, discrepancy reports, wildlife reports, corrective actions, FOD collection reports, self- inspection records, tenant reports, other FOD program documentation §139.329 Pedestrians and ground vehicles Staff training and noncompliance procedures, vehicle or escort procedures, accidents or incidents in the movement areas and safety areas involving air carrier aircraft, ground vehicle, or pedestrian, Vehicle/Pedestrian Deviation (VPD) reports §139.331 Obstructions Form 7460 Notice of Proposed Construction or Alteration §139.333 Protection of NAVAIDS Form 7460 Notice of Proposed Construction or Alteration §139.337 Wildlife hazard management Wildlife Hazard Management Plan; wildlife strike reports (during self- inspections and from tenants or airlines); wildlife observations, hazard assessments, and monitoring reports; snarge collection kits and content identification; depredation permits and reports; wildlife reduction recommendations and actions; wildlife hazard control measures; procedures to review and evaluate the wildlife hazard management plan; and training program and records §139.339 Airport condition reporting Airport condition information to air carriers through use the NOTAM system §139.341 Identifying, marking, and lighting construction and other unserviceable areas; construction safety Construction Safety Phasing Plan (CSPP), construction management and oversight, self-inspection reports, FOD reports §139.343 Noncomplying conditions Reports and records of noncomplying conditions TABLE 5 PART 139 SECTIONS AND SAFETY DATA REPORTING TYPES

12 format. The norm, according to the study findings, is a tendency toward paper­based checklists, reports, and binders or stand­alone software programs that are rarely inte­ grated. Multiple questions were asked of interviewees regarding Part 139 informa­ tion collecting and reporting tools; the findings are presented and discussed later in this chapter. PART 139 DATA COLLECTION TOOLS Airports collect data through a variety of mechanisms to track and demonstrate compliance with FAA’s reporting requirement. These means include purchased or custom­developed software programs; elec­ tronic documents organized within file servers; mobile devices (e.g., tablets, rugged laptops, and hand­ held devices); and hard copy forms compiled in three­ring binders. At many airports, self­inspections are conducted using paper forms and the results subsequently entered into a software program or con­ verted to electronic format for storage and future reporting. Many of the required documents are main­ tained in separate offices, file servers, or software programs. For example, ARFF inspections often are housed within the Fire Department, and NOTAM are filed and managed as part of the airport operations division safety oversight. PART 139 AND VOLUNTARY DATA COLLECTION PROGRAMS Airport representatives were asked what types of systems were used to collect all manner of safety data, including Part 139 and voluntary safety data programs such as SMS. Regarding voluntary data collection, airport respondents described various programs, including implementation of formal SMS programs and reporting tools and voluntary safety reporting through meetings, phone lines, staff repre­ sentatives, comment boxes, and websites. When airport staff interviewed did not have voluntary report­ ing tools or programs, the discussion focused on mandatory reporting; when airport representatives had both systems, key differences or similarities were documented. Various choices were presented for selection, including paper, software, website, drop box, phone, verbal reports, e­mail, meetings, and “other,” as summarized in Table 6. The most frequently cited means for recording self­inspection data, regardless of airport size, was paper. Of the 35 airport staff interviewed, 28 use paper as a means to conduct Part 139 self­ inspections. However, multiple airport representatives indicated that the paper­based checklists were subsequently entered into a software system or the checklist was scanned as a Portable Document Format file and stored electronically on a file server for easier review, retrieval, and distribution to other departments, such as maintenance. It was noted that the Portable Document Format files are not searchable, so there is no means for using the electronic copy for trending or conducting specific que­ ries (e.g., activities, data types) or for automated reporting purposes. The use of tools and reporting formats varies; one interviewee stated that the FAA ACSI preferred paper as part of the certification inspection review process. To effectively manage the process, the airport operations staff maintains Safety Reports Received by Method Software Website Hard Copy Phone E- mail Meetings Verbal Other Respondent count of reports received by method 16 21 17 32 29 30 32 2 Respondent percent of reports received by method 46 60 49 91 83 86 91 6 3 shaded cells = top 3 highest percentages. TABLE 6 SAFETY REPORTS BY COLLECTION METHOD Record retention and management is a requirement of Part 139 and is periodically reviewed by the FAA during certification inspections.

13 a three­ring notebook with all relevant documentation in a hardcopy format. Another means of collecting self­inspection data included the airport operations staff report­ ing discrepancies by phone or radio; these were immediately entered into a software program shared by maintenance for work order initiation, tracking, and management. SOFTWARE SYSTEMS Airport representatives using software programs or systems for recording self­inspections stated they typically used a tablet or a vehicle­mounted rugged laptop to collect information in the field. If no in­field wireless network (WiFi) existed, the data were synchronized through the WiFi network once the representative was back in the office or manually uploaded through a software program interface. A representative of a large hub airport commented that the inspection software system was custom developed by the airport’s in­house information technology (IT) department staff. The software program was designed for multiple inspections to be conducted, approved, aggregated, and published on a daily basis. In addition, the soft­ ware program publishes inspection reports, allows for key word searches and comments, and presents a list of open discrepancies for management oversight and reporting. Numerous com­ mercially available self­inspection software programs offer various technologies and platforms, such as hosted or nonhosted options, price points, technical support, and integrative solutions (see Appendix B for an overview of IT concepts and systems). Airports reported information regarding purchased or in­house electronic solutions used to col­ lect self­inspection, maintenance, and voluntary safety data records. Table 7 presents a summary of electronic programs by functional type and includes whether the representative airport has an SMS program in place for determining if airports had implemented SMS software programs in conjunc­ tion with their formal SMS programs. Thirteen of the 20 airports (65%) reported they had purchased or developed software programs to support the SMS. The most frequently reported (65%) type of software for all hub­size airports related to maintenance tracking and work order management, with all large hubs reporting the use of maintenance software. Only 48% of the airports surveyed used electronic means to manage Part 139 35 Airports in Survey Group Formal SMS Program? SMS Software Count Part 139 Software Count Maintenance Software Count Average No. of Systems 10 Large hub airports Yes, 7 3 2 5 2 No, 3 1 4 5 9 Medium hub airports Yes, 6 3 3 5 1.77 No, 3 0 3 2 5 Small hub airports Yes, 0 0 0 0 .06 No, 5 0 1 2 9 Nonhub airports Yes, 5 3 2 2 1.33 No, 4 1 2 2 2 airports 1 NA–GA 1 NA–Reliever Yes, 2 2 0 0 1 No, 0 0 0 0 Total count by program type 20 13 17 23 TABLE 7 SOFTWARE SYSTEM TYPES BY AIRPORT NPIAS CATEGORY 20 of the 35 airports surveyed have an SMS program in place; 13 of the 20 have implemented software. Regardless of airport size, paper is the most frequently used means for recording self-inspections.

14 inspections. An average of systems, as measured by hub size, appears in the last column of Table 7 and shows large hubs with the most systems at 2, medium hubs at 1.77, nonhubs at 1.33, the general aviation (GA) and reliever airports at 1 (both SMS systems), and small hub airports at 0.06, the low­ est average. Of the systems reported, five respondents indicated that some portions of the software were integrated and automated (specifically airport duty logs with Part 139 self­inspections and self­ inspections with maintenance work orders). More than one­third of the airports (34%) surveyed reported that all or some aspects of the soft­ ware system were customized by the software developer/vendor or by the airport staff. More than half (54%) of the systems were hosted in house (on servers within the organization), 51% were reportedly web­based solutions, 46% were client server systems (such as MS Access), and 3% were unknown (see Figure 3). When asked about system, recurring maintenance, or other custom development costs, the major­ ity of survey respondents replied they “did not know.” Typically at airports (many managed by city, county, or authority), the purchase of software is managed through a separate department, such as procurement or IT. Thus, the lack of information available to the interviewees (primarily airport operations staff) was not unanticipated. Regarding software costs in general, multiple aspects are often considered when selecting a software program, such as number and type of licenses, hosting solutions, ongoing level and type of technical support, and customization. A brief overview of cost decision aspects can be found in Appendix B. Two nonhub and two medium hub airport interviewees reported they had built soft­ ware systems using MS Access as a means to customize the information needed for inspections and tracking maintenance work orders and to reduce costs associated with purchasing commercial software programs. The systems are accessible by staff via the airport network for data entry, tracking, trending, and reporting. Concerns with data integrity and continuity were addressed through the use of pulldown menus at one air­ port; open­ended comment fields for data entry at another airport resulted in reduced quality of data, misspellings, and inconsistencies. These issues were corrected through staff training and manage­ ment review. MS Access data at the airports were backed up through the airport’s network man­ agement and security programs ensuring no risk of data loss. One small hub airport representative reported that MS Access was being used to track maintenance records. A crucial component of the Part 139 inspection process is the ability for airport operations and management to report deficiencies to maintenance departments. FAA Advisory Circular (AC) 150/5200­18C Airport Safety Self­Inspection states, “An effective safety self­inspection program includes procedures for reporting and correcting deficiencies. This means that the airport operator 0 1 2 3 4 5 6 7 8 Large Medium Small Non Other Web based Client Server No System FIGURE 3 Software solution type by airport NPIAS category size. Four airports surveyed use Micro- soft Access as a tool to collect and manage airport data.

15 should have a work order system in place so that deficiencies can be corrected in an expeditious manner” (FAA 2004). Two airport representatives interviewed reported that their Part 139 inspection pro­ gram automatically interfaced with their maintenance management software system. Typically, operations and maintenance staff work in separate departments or functional groups and are obligated to manually enter and update deficiency status from one soft­ ware or paper­based system to another using work order numbers or other key infor­ mation, such as deficiency date and location. Airports that reported lack of integration also reported cumbersome, time­consuming, and manual reconciliation of disparate systems among departments to accurately report on the status of discrepancy resolution. REPORTING AND COLLECTION METHODS In addition to Part 139 self­inspection data, airport representatives were queried whether other types of data were collected, such as accident or incident reports, emergency medical responses, police dis­ patches, hazards or maintenance concerns, and wildlife strikes. Table 8 provides an overview of the types of data collected. Part 139 data are collected by all airport operations staff interviewed for air­ port certification compliance; other data collected are facility damage, slips, trips, and falls for insur­ ance claims and cost­recovery purposes. Respondents commented that claims typically are managed through the city, county, or other divisions outside the airport operations groups; however, reports often are initiated by the operations staff as part of incident and accident response. Respondents were asked what methods were used to receive or gather information or reports. All except one of the airport staff interviewed noted that one or more dedicated phone lines were the primary means of obtaining safety­related reports from staff, tenants, and in some cases the public. Phone lines were reported as often managed by the operations depart­ ment, a centralized dispatch service (911), or a combination of the two. For airports with 24/7 operations, phone lines were available at all times; for others, phone calls were forwarded to an assigned airport duty manager or a backup dispatch 911 service. In all cases, the phone line allowed for verbal reporting of safety concerns or issues; however, not all information received was documented or collected in a formal manner. When asked if paper­based systems were used to acquire safety reports, seven of the respondents reported that comment slips or drop boxes were used to collect safety suggestions; however, three Data Type Collected Pa rt 1 39 V ol un ta ry S af et y Pr og ra m ( SM S or O th er ) St af f A cc id en t o r In ci de nt ( no n ve hi cl e) T en an t A cc id en t o r In ci de nt ( no n ve hi cl e) V eh ic le A cc id en t o r In ci de nt Fa ci lit y D am ag e H ea lth a nd S af et y/ O SH A N ea r M is s/ N ea r H it Sl ip T ri p Fa ll M ed ic al R un ( A m bu la nc e) D is pa tc h M ed ic al R un ( A m bu la nc e) T ra ns po rt Fi rs t R es po nd er D is pa tc h E m er ge nc y O pe ra tio ns C en te r H az ar d or R is k D at a Respondent count by data type 35 21 33 31 34 35 33 14 34 33 31 33 28 26 Respondent percent by data type 100 60 94 89 97 100 94 40 97 94 89 94 80 74 3 shaded cells = 3 highest percentages. TABLE 8 DATA TYPES COLLECTED Few airport representatives have integrated software programs to manage safety concerns; most use manual processes to reconcile infor mation. A national FAA-hosted FOD pro- gram provides a centralized location to report and manage FOD. http:// fod.faa.gov/SubmitReport.aspx

16 of the respondents indicated they were likely to phase out the boxes and use a web­based program because of the need to manually collect and check boxes for comment slips. Most boxes (70%) were located within the terminal, with only 30% installed in break rooms adjacent to ramp area operations for tenants and ground handlers. Respondents frequently reported that public suggestions initially were collected through public affairs or public outreach functions and, if relevant to airfield or safety concerns, were routed to the appropriate department. Interviewees were asked if tenants, staff, or other stakeholders verbally commu­ nicated safety reports and concerns, and only two of the respondents reported “no.” Regardless of airport size or operation, 94% of respondents received safety­related reports verbally. The survey expectation was that small airports with fewer safety staff (airports reported as few as two and as many as 300+ airport operations, police, fire, and emergency response staff) would be more likely to receive verbal reports as a result of smaller facilities and greater familiarity with the limited airport staff; however, this was not the case. It appears that verbal reports are a key means of raising safety concerns at all airports. In addition, even within large hub airport operations, airport representatives are recognized as resources to raise safety concerns. Airport representatives indicated that the verbal reports were often subsequently called in or reported using the established phone lines to record the concern; in other cases, safety issues were not formally tracked or logged, consequently limiting the ability to track or report on the safety outcome or status. All airport representatives surveyed reported that e­mail was used either as a means to receive an initial safety concern or to collaborate and communicate with other team members to resolve safety issues. Although individuals reporting safety concerns did not necessarily have direct access to indi­ vidual staff e­mail addresses, group or shared e­mail accounts were most often used to receive and manage safety concerns or reports. Only three (9%) of the 35 airport staff surveyed reported they do not lead or participate in stand­ ing safety­related meetings with staff or tenants. All respondents participating in safety meetings reported that the meetings were used to identify and discuss safety concerns. In most cases, safety meetings included participation from airlines, ground handlers, fuelers, and fixed base operators (FBOs). In some cases, airport representatives attended airline­facilitated meetings, and in other instances airport staff managed the meetings. Frequency of safety meetings ranged widely from monthly meetings to quarterly gatherings. Simi­ lar to verbal report processes, airport respondents confirmed that safety concerns were not always formally tracked, and in some cases, issues were managed through meeting agendas and not within reporting or safety tracking software. Safety concerns from tenants are most frequently reported verbally, regardless of airport size. 32 of the 35 airport respondents participate in safety-related meet- ings with staff and/or tenants.

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TRB’s Airport Cooperative Research Program (ACRP) Synthesis 58: Safety Reporting Systems at Airports describes safety reporting methods and systems for airports certificated under Title 14 Code of Federal Regulations Part 139 by assessing current practices, processes, and systems used to collect and analyze safety data and information.

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