Airport Self-Inspection Practices (2011)

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5BACKGROUND In considering the features of a sound aviation system, issues such as regulatory compliance, effective management, and safety are integral. However, safety is the most integral aspect of the aviation system: without it, the system fails; with it, the system prospers. Airports, hosting every aircraft departure and arrival, provide a critical safety link in this aviation system. It is critical, therefore, for airports to place a high emphasis on safety and ensure a safe operating environment for air- craft, vehicles, and personnel. According to the FAA, a self- inspection program is the cornerstone of an airport operator’s overall safety program (B. Landry, personal communication, Jan. 12, 2010). SELF-INSPECTION PROGRAM OVERVIEW Self-inspection programs are integral for airports in (1) main- taining regulatory compliance, (2) ensuring various standards are met, and (3) contributing to aviation safety. Specifically, self-inspection programs are designed as a means by airports to identify unsatisfactory conditions and take the necessary action to correct these conditions. As explained by the FAA: While some hazardous airport conditions develop virtually instan- taneously, others are gradual. It is important that the airport oper- ator have an airport safety self-inspection program that monitors specific airport conditions in order to identify unsatisfactory conditions for prompt corrective actions (FAA 2004, p. 2). Although self-inspection programs vary among airports in scope and effectiveness, comprehensive self-inspection programs contain the following elements: • Training of personnel; • Inspection component – Inspection – Reporting discrepancies and findings – Follow-up – Resolution – Close-out; and • Quality control. Discussed in detail within this report, each of these com- ponents is essential for an effective airport self-inspection program. However, as will be discussed, airports have wide discretion in the methods they adopt for their self-inspection program: whether one individual or a team of individuals conducts an inspection, whether a runway inspection is con- ducted once each day or six times each day, whether the self- inspection checklist is in paper form or on a vehicle-mounted tablet PC, or whether training is conducted in-house or out- sourced. One purpose of this report is to highlight these dif- ferences as well as the similarities among airports in carrying out their self-inspection programs. FAA REGULATORY REQUIREMENTS To ensure airport safety, the FAA provides oversight of air- ports served by air carriers through Title 14, Code of Federal Regulations (CFR) Part 139 (Part 139). Compliance with Part 139 is mandatory for an operator of a U.S. airport that chooses to serve air carrier operations covered by the regula- tion. Specifically, Part 139 applies to airports in any state of the United States, the District of Columbia, or any territory or possession of the United States serving passenger-carrying operations of an air carrier certificated under 14 CFR Part 121 and 14 CFR Part 380 if: • Scheduled passenger-carrying operations are conducted with aircraft designed for more than nine passenger seats; and • Unscheduled passenger-carrying operations are con- ducted with aircraft designed for at least 31 passenger seats (Certification of Airports 2004). Part 139 is applicable in the state of Alaska only to airport operators serving scheduled or unscheduled passenger oper- ations of an air carrier with aircraft with a seating capacity of more than 30 passengers (FAA 2004). Airport operators can choose not to be certificated under Part 139. However, compli- ance with Part 139 is mandatory if the airport operator chooses to serve the air carrier operations previously noted. Alaskan airports that serve air carrier aircraft with 30 seats or less are exempt from federal airport certification requirements. Compliance with this regulation is ensured through the granting of an Airport Operating Certificate (AOC). To obtain a certificate, an airport must agree to certain operational and safety standards and provide for certain equipment and facil- ities. An AOC issued under Part 139 is effective until the cer- tificate holder surrenders it or the certificate is suspended or revoked by the Administrator of the FAA. CHAPTER ONE INTRODUCTION

With the revision of Part 139 in 2004, four classes of airports were developed. Class I airports are those airports serving all types of scheduled operations of air carrier air- craft designed for at least 31 passenger seats and any other type of air carrier operations. Class II airports are those air- ports that serve scheduled operations of small air carrier aircraft and unscheduled operations of large air carrier air- craft. Class II airports are not permitted to serve scheduled large air carrier operations. Class III airports are those air- ports that serve only scheduled operations of small air car- rier aircraft. Class IV airports are those airports that serve only unscheduled operations of large air carrier aircraft. Class I, II, and IV airports are those that held a Part 139 AOC before the 2004 revision. Class III airports are those that were newly certificated (FAA 2010). As of 2010, there were 553 airports certificated under Part 139. Table 1 shows the number of airports in each class. To comply with Part 139, certificated airports are required to develop an Airport Certification Manual (ACM). Designed as an airport-specific extension of Part 139, the ACM is writ- ten by an airport to define specifically how it will comply with Part 139. The ACM must be submitted to the FAA for approval. Once the ACM is approved, the airport can and must do what is spelled out in its ACM (Lammerding 2009). Although each airport requires an approved ACM, the requirements differ slightly among airport classes. However, each airport is re- quired to address Part 139.327 procedures for conducting the self-inspection program within its ACM. As specified in Part 139.105, the FAA holds inspection authority over certificated airports. According to Part 139.105, “Each applicant for, or holder of, an Airport Operating Certifi- cate must allow the Administrator to make any inspections, including unannounced inspections, or tests to determine com- pliance with 49 U.S.C. 44706 and the requirements of this part” (Certification of Airports 2004). Although the FAA is responsible for ensuring that these certificated airports comply with Part 139, it is not possible for the FAA to monitor the operations of each certificated airport daily; thus, the need for airport self-inspections. As spelled out in AC 150/5200-18C, Airport Safety Self-Inspection, “One of the requirements of Part 139 is that the operator of each certificated airport regu- larly conduct a daily safety self-inspection to ensure that prompt corrective action is taken to eliminate unsafe condi- tions on the airport” (FAA 2004, p. 2). Self-inspections serve two purposes. First, they allow an airport to ensure compli- ance with Part 139 on a daily basis. Second, they allow an air- port to discover existing or potential discrepancies and initiate action to resolve these discrepancies before airport safety is adversely affected. 6 However, with 4,150 publicly owned, public-use airports in the United States and only 553 certificated airports, it is clear that the majority of U.S. airports need not comply with the requirements of Part 139 or with AC 150/5200-18C. Although the requirements of Part 139 are mandatory for a holder of a Part 139 Airport Operating Certificate and AC 150/5200-18C represents an acceptable means of compliance with the self- inspection requirements of Part 139, the FAA notes that the reg- ulation and AC contain many safety practices and recommends these practices for use at all airports, including those airports not holding an AOC under Part 139. It can be noted, however, that if any airport accepts Airport Improvement Program funding, the airport operator is held to grant assurances. Even so, there is no federal oversight of self-inspection pro- grams at non-certificated airports. However, in many states, the state aviation agency (i.e., department of transportation) may assume this inspection authority. Some states even license airports, so that their oversight has some consequence. Regard- less, whether certificated or not, airport self-inspection pro- grams have many similarities among airports and serve the same purpose of ensuring that the airport is operating safely and is complying with regulatory requirements. The regulatory requirements for an airport self-inspection program are spelled out in Part 139.327, entitled Self- Inspection Program. This section of the regulation addresses both the inspection and training processes. Regarding inspec- tions, each certificate holder must: 1. Inspect the airport according to the following schedule: a. Daily, unless specified otherwise in the ACM; b. When required by any unusual condition, such as construction activities or meteorological conditions that may affect safe air carrier operations; and c. Immediately after an accident or incident. 2. Provide the following: a. Equipment for use in conducting safety inspections; b. Procedures, facilities, and equipment for rapid and reliable dissemination of information between the certificate holder’s personnel and air carriers; c. Procedures to ensure that qualified personnel per- form the inspections; and d. A reporting system to ensure prompt correction of unsafe airport conditions noted during the inspection, including wildlife strikes (FAA 2004). Additionally, the section mentions that FAA advisory cir- culars contain methods and procedures for conducting airport self-inspections that are acceptable to the Administrator. VIssalCIIIssalCIIssalCIssalC Number of Airports 381 50 35 87 TABLE 1 AIRPORT CERTIFICATION STATUS

7FAA GUIDANCE The FAA has issued numerous Advisory Circulars (ACs) designed to guide airports in complying with various federal regulations. Some ACs are mandatory. ACs that contain man- datory guidance are relatively defined and present the only way in which an airport may comply. Most ACs present infor- mation that is advisory in nature, leaving specific techniques up to the airport operator. In other words, there are often many ways an airport operator may comply with a regula- tion. These are to be spelled out within the “applicability” section of an AC. In any event, the regulatory requirement for complying with an AC stems not from the AC itself, but from the airport’s ACM, as approved under Part 139. Series 150 ACs (for airport projects) aid airport operators in devel- oping methods to comply with Part 139 by providing airports with guidance as well as specific standards. As of this writ- ing, there are 127 ACs in the 150 series. ACs are frequently updated; therefore, airports are encouraged to access the most current version of an AC at the FAA website, http:// www.faa.gov. The most beneficial AC regarding the topic of this synthe- sis is AC 150/5200-18C, Airport Safety Self-Inspection. This AC is the most important document, second only to Part 139, for airports conducting self-inspections. This AC pro- vides guidance for airport operators in developing airport self-inspection programs that facilitate regulatory compliance with Part 139 on a day-to-day basis. Even so, the programs currently in use by airports “. . . vary in scope and effectiveness from verbal instructions and unscheduled and unrecorded inspections to very comprehensive inspection programs with multiple daily schedules and widely distributed responsibili- ties” (FAA 2004, p. 2). In providing guidance in developing a self-inspection pro- gram, AC 150/5200-18C addresses inspection frequencies, inspection records, inspection techniques, knowledge and equipment, and the airport physical facilities and areas that should be inspected during each type of inspection. Although an excerpt from this AC is included in Appendix N, specific requirements are detailed in each chapter as appropriate. In addition to ACs, CertAlerts are designed to give the FAA Airports Safety and Operations Division an efficient method of providing information on issues related to Part 139. By def- inition, CertAlerts are advisory, cautionary, and nondirective in nature, and may be accessed on the FAA website at http:// www.faa.gov/airports/airport_safety/certalerts/. CertAlerts may simply be reminders about the need for foreign object debris (FOD) detection and removal (as in CertAlert No. 09-06), or may follow an aircraft accident involving an aircraft colliding with construction equipment while attempt- ing to depart on a closed runway (as in CertAlert No. 02-01). Of the 77 CertAlerts that have been issued during the 8.5-year period between 2002 and June 30, 2010, 22 address some aspect of self-inspections or training programs. Specifically, the majority of these 22 address fuel safety training, and one (09-06) addresses FOD. CertAlert No. 09-06, Closing active runway for FOD checks increases safe operations To prevent future occurrences of airports not removing FOD from runways in a timely manner or allowing aircraft operations on a runway contaminated with FOD, the FAA Office of Safety and Standards issued an advisory CertAlert in March 2009. Airports are not required to abide by this CertAlert, but they are cautioned not to continue aircraft operations on contaminated surfaces. Although specifically addressing FOD, the CertAlert does challenge airport oper- ators with regard to self-inspections: In an effort to avoid damage to aircraft, airports are reminded of their obligation to maintain safe movement areas through- out their facilities. This should include procedures for [e]ffect- ing immediate runway closures in the presence of certain types of FOD, such as large pieces of metal, large aggre- gate, large concrete spalling pieces, or any other materials likely to pose a high risk for operator. Source: FAA 2009. ADDITIONAL GUIDANCE In addition to FAA guidance on self-inspections, various industry publications and conferences, courses, and work- shops are available to help airports develop self-inspection programs and carry out self-inspection duties. One such publi- cation is ACRP S04-06, Current Airport Inspection Practices Regarding FOD. Although S04-06 addresses managing FOD at airports, it contains information on technology and equip- ment for conducting self-inspections and for documenting findings. TRAINING OF INSPECTION PERSONNEL Based on the requirements of Part 139, the training of per- sonnel is integral to an effective self-inspection program. Indeed, only those personnel who have met the training require- ments can perform the daily self-inspection (Lammerding 2010a). According to Part 139.303(c), this training must be completed before the initial performance of duties and at least once every 12 consecutive calendar months. Initial training is typically arranged for new personnel to enable them to learn the airport’s unique characteristics and the requirements of Part 139 (specifically, the airport’s self- inspection program as spelled out in the ACM) before being allowed to perform self-inspection duties. Initial training can be accomplished in a number of ways, some of which include on-the-job training, videos, tests, self-study, electronic or web-based interactive training, conferences, and workshops.

Likewise, airports have an equal number of options for recurrent training. Regardless of which training methods are employed, training is an integral component of all self- inspection programs. Quality is an important component of a training program. Maintaining quality control requires that airports address com- placency, as well as stress the importance of self-inspections, to ensure a successful self-inspection program. Otherwise, poor employee habits may develop and airfield safety may suffer as a result. SCOPE OF STUDY The scope of this synthesis is current airport self-inspection procedures and training practices. Specifically, this project focused on the following components of a complete airport self-inspection program: • Training (initial and recurrent); • Inspecting; • Reporting discrepancies and findings; • Follow-up, resolution, and close-out; and • Quality control. This synthesis focuses broadly on the manner in which (1) self-inspections are conducted and (2) responsible per- sonnel are trained. Each chapter presents guidance in these areas (based on the literature) as well as in current airport practices (based on survey data). Additionally, chapter seven presents insights into the oversight of certificated airports by the FAA and non-certificated airports by state aviation agencies. STUDY METHODOLOGY Information used in this study was acquired through an extensive literature and data review, three surveys, follow- up interviews with survey respondents, contributions from panel members, and the author’s professional knowledge of the subject area. A literature and data search was conducted to document reg- ulations and guidance for conducting airport self-inspections at certificated airports. This search focused on (1) Part 139, (2) relevant state and federal regulations on the subject matter, (3) other federal guidance such as CertAlerts and Advisory Circulars, and (4) relevant literature in the form of books, magazines, reports, and surveys conducted on the various aspects of self-inspection programs and training. Three unique questionnaires were developed to survey air- port operators, lead FAA airport certification safety inspectors, and state aviation agencies. The first questionnaire, entitled “Airport Self-Inspection Survey,” can be found in Appendix D. This questionnaire was designed to solicit responses from air- port managers or operations personnel regarding their current 8 self-inspection practices and training techniques. Specifi- cally, the questionnaire was designed to determine the meth- ods and tools used to perform self-inspections, methods used by airports in initial and recurrent training of inspection per- sonnel, the manner in which discrepancies are addressed, and the degree to which human factors are an issue in airport self- inspection programs. The second questionnaire, entitled “FAA Inspection Sur- vey,” can be found in Appendix E. The questionnaire was sent to the lead airport certification safety inspector in each of the nine FAA geographical regions. The purpose of this ques- tionnaire was to supplement airport-specific information with FAA regional insight. Specifically, inspectors were asked to provide examples of successful airport inspection and train- ing practices from their respective regions. This survey also sought to understand what differences exist, if any, among the FAA geographical regions in regard to self-inspection requirements. The third questionnaire, entitled “Airport Oversight by State Aviation Agencies,” is in Appendix F. This questionnaire was designed to supplement perspectives on FAA oversight (typi- cally appropriate to certificated airports) with perspectives on state oversight (typically appropriate for non-certificated airports). Because practices vary substantially by state, this survey was designed to make sense of the practices in place in each state. In summary, information for this synthesis was gathered from a literature review and three survey questionnaires. Owing to this, considerable effort was exerted to ensure that the methodology for the survey implementation was both sound and strategically orchestrated. First, to facilitate the distribution of the questionnaires and simplify the responses, the question- naires were developed and distributed using a web-based sur- vey tool. Potential participants were invited to join the study by means of an e-mail invitation. Second, to obtain a nationwide representation of airports, the population was stratified into the nine FAA regions. Within each region, airports were selected from the following categories, as possible: large hub, medium hub, small hub, non-hub, and general aviation (GA). This selec- tion process yielded a total sample size of 40. Likewise, the lead certification inspector from each of the nine FAA regions was invited to participate. In gathering information from state avia- tion agencies, each of the 50 states was invited to participate in the survey, rather than only a selection of states. PARTICIPANTS Airports Data were collected from 33 airports of the 40 that chose to respond, which resulted in a survey response rate of 83%. Appendix A lists the airports participating in the study. As seen in Figure 1, the study garnered responses from each of the nine FAA regions.

9In addition to the wide geographic distribution of respon- dents, the airports participating in this synthesis were ade- quately representative of airports of almost any size. Figure 2 presents airport respondents by airport category or hub size. It should be noted that the majority of participants represent large-hub airports. As a result, findings are not necessarily generalizable to airports of all sizes. In addition to categorization by hub size, responding air- ports were categorized by number of operations. The airports participating in this synthesis also adequately represent a wide range of airports in terms of annual operations. Figure 3 pre- sents airport respondents by annual operations. Lastly, in an effort to understand fully the airports partic- ipating in the synthesis, participants were asked about their airport certification status. Although the majority of partic- ipating airports were larger Class I airports (according to Part 139 classification), other categories were represented as well. Figure 4 presents airport respondents by certification. FAA Inspectors Data were collected from seven of the nine FAA regions, which resulted in a response rate of 78%. Appendix B presents the list of participating FAA regions. State Aviation Agencies Data were collected from 49 state aviation agencies, result- ing in a response rate of 98%. Appendix C presents the list of states participating in the study. Additionally, to determine the degree of oversight (by number of airports), participating states were asked how many airports they were responsible for inspecting. Results are shown in Figure 5. 1 2 3 5 3 3 5 3 2 0 1 2 3 4 5 6 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 1 Airport respondents’ self-selected FAA regions. Six participants did not indicate a region. 3 4 5 4 11 GA Non-hub Small hub Medium hub Large hub FIGURE 2 Airport respondents’ self-selected hub size. Six participants did not indicate a hub size. Note: Large hub is defined as at least 1% of total U.S. passenger enplanements. Medium hub is defined as between 0.25% and 1% of total U.S. passenger enplanements. Small hub is defined as between 0.05% and 0.25% of total U.S. passenger enplanements. Non-hub is defined as less than 0.05%, but more than 10,000 annual passenger enplanements.

10 8 2 3 2 3 6 3 2 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 3 Airport respondents’ self-selected number of annual operations. Four airports did not indicate annual operation. 3 2 1 1 24 Not certificated 14CFR Part 139 - Class IV 14CFR Part 139 - Class III 14CFR Part 139 - Class II 14CFR Part 139 - Class I FIGURE 4 Airport respondents’ self-selected FAA certification. Two airports did not indicate FAA certification. 14 3 8 3 5 7 7 1 1 0 2 4 6 8 10 12 14 16 More than 130 111-130 91-110 71-90 51-70 31-50 11-30 Less than 10 Zero FIGURE 5 Number of airports inspected.

11 REPORT ORGANIZATION This report has been organized into eight chapters. This chapter introduced the concept of an airport self-inspection program, including regulatory requirements, as well as the scope and methodology of the synthesis. Chapter two focuses on training practices that exist for those individuals who per- form self-inspections, as well as specific topics such as initial training, recurrent training, outsourced training, in-house training, and typical airport training programs. Chapter three highlights the inspection process and includes types of inspec- tions, tools used during inspections, and the personnel typi- cally responsible for performing inspections. Additionally, chapter three presents photos of discrepancies discovered and areas to be inspected during regularly scheduled inspections. Chapter four includes information on the reporting of dis- crepancies, including to whom they are reported, the manner in which reports are filed, and the concept of prioritization. Chapter five addresses the follow-up, resolution, and close-out processes, including the personnel responsible for close- outs and the methods used to close out, or resolve, a dis- crepancy. Chapter six highlights the need for effective quality control of self-inspection programs and presents issues such as complacency, fatigue, and other human factor issues. In chapter seven the concept of oversight, at both the federal and state levels, is presented. Finally, chapter eight presents concluding thoughts and summarizes the major findings of the synthesis.