Airport Self-Inspection Practices (2011)

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One of the first major considerations of any airport self- inspection program is the degree and type of training that will be required of all personnel responsible for conducting self-inspections. Only personnel who have met the training requirements of Part 139 can perform the FAA-required daily self-inspection (Lammerding 2010b). This requires, therefore, developing an effective training program backed up with adequate documentation. For certificated airports, this is required; for others, it is recommended. As stated in AC 150/5200-18C: While Part 139 requirements are mandatory for a holder of a Part 139 Airport Operating Certificate, the regulation contains many safety practices that the Federal Aviation Administration recom- mends for use at all airports (FAA 2004, p. 1). PART 139.303 Section 303 of Part 139 addresses the training of personnel. This section requires every certificated airport to: a. Provide sufficient and qualified personnel to comply with the requirements of its ACM and Part 139. b. Equip personnel with sufficient resources needed to comply with the requirements of Part 139. c. Train all personnel who access movement areas and safety areas and perform duties in compliance with the requirements of its ACM and Part 139. d. Record all training completed by each individual after June 9, 2004 in compliance with this section, includ- ing, at a minimum, a description and date of training received. Such record must be maintained for 24 con- secutive calendar months after completion of training. e. As appropriate, comply with the following training requirements of Part 139: i. 139.319, Aircraft rescue and firefighting: Opera- tional requirements; ii. 139.321, Handling and storing of hazardous sub- stances and materials; iii. 139.327, Self-inspection programs; iv. 139.329, Pedestrians and ground vehicles; v. 139.337, Wildlife hazard management; and vi. 139.339, Airport condition reporting. f. Use an independent organization or designee to comply with the requirements of its ACM and Part 139 only if: i. Such an arrangement is authorized by the Admin- istrator; 12 ii. A description of the responsibilities and duties that will be assumed by an independent organization or designee is specified in the ACM; and iii. The independent organization or designee prepares records required under Part 139 in sufficient detail to assure the certificate holder and the Administrator of adequate compliance with the ACM and Part 139 (Certification of Airports 2004). In providing “sufficient and qualified personnel” as re- quired by Part 139.303(a), certificated airports are tasked with (a) employing an adequate number of personnel to carry out the duties of the ACM, and (b) ensuring that these per- sonnel are qualified with the requisite skills, knowledge, and abilities to carry out the duties specified in the ACM. In addressing the first part of this task, airports focus not only on recruiting top-notch personnel but also on retaining these personnel. By recruiting through nationwide venues and offering competitive salaries, significant benefits, and a safe and productive work environment, airports can make significant strides in these two areas (Certification of Air- ports 2004). As required by Part 139.303(b), equipping personnel suf- ficiently to carry out the duties specified in the ACM and the requirements of Part 139 is a significant expense for certifi- cated airports. At a minimum, as noted in chapter three, per- sonnel conducting self-inspections need a properly marked and lighted vehicle equipped with a two-way aeronautical radio, as well as a flashlight and a camera (Lammerding 2010a). However, Part 139 has requirements beyond the self-inspection. For instance, aircraft rescue and firefighting (ARFF) personnel require substantial financial resources in the form of equipment, agents, tools, clothing, training, and facilities in which to house personnel and equipment, with the degree of investment dictated to some extent by the air- port’s ARFF Index. Many airports have entered into mutual aid agreements with local municipalities to meet the ARFF Index requirements, but with minimal investment in person- nel, equipment, and facilities. At the same time, many airports, especially larger airports, have found it more efficient to employ ARFF personnel and invest in equipment, training, and facilities. With regard to an airport’s self-inspection program, sub- part (c) is the most important section within Part 139.303. As CHAPTER TWO TRAINING

13 mentioned, this subpart requires certificated airports to “train all personnel who access movement areas and safety areas and perform duties in compliance with the requirements of the ACM and the requirements of this part” (Certification of Air- ports 2004). Additionally, the subpart requires that this train- ing be completed before the initial performance of such duties and at least once every 12 consecutive calendar months there- after. According to Part 139.303(c) the curriculum for initial and recurrent training must include at least the following areas (Certification of Airports 2004): • Airport familiarization, including airport marking, light- ing, and signs system; • Procedures for access to, and operation in, movement areas and safety areas, as specified under 139.329; • Airport communications, including radio communication between the air traffic control tower and personnel, use of the common traffic advisory frequency if there is no air traffic control tower or the tower is not in operation, and procedures for reporting unsafe airport conditions; • Duties required under the ACM and Part 139; and • Any additional subject areas required under 139.319, 139.321, 139.327, 139.329, 139.337, and 139.339, as appropriate. Next, Part 139.303(d) requires certificated airports to document and maintain records of all training. This was not required before the June 2004 revision of Part 139. Since the revision, certificated airports have been required not only to develop training programs but to maintain a record-keeping system as well. Although the manner in which certificated airports conduct initial and recurrent training varies, the doc- umentation need not be complex. Table 2 presents a sample individual training record that may be used in compliance with Part 139.303. Airports may find it useful to develop a spreadsheet or database to maintain training records elec- tronically, but in reality, compliance with the record-keeping aspect of 139.303(d) could be handled as easily using alpha- betical folders in a file cabinet. Part 139.303(e) makes it clear to the certificate holder that training is required in areas beyond conducting self- inspections. For instance, Part 139.319, Aircraft rescue and firefighting: Operational requirements, requires all rescue and firefighting personnel to be trained in the following areas: • Airport familiarization, including airport signs, mark- ing, and lighting; • Aircraft familiarization; • Rescue and firefighting personnel safety; • Emergency communications systems in the airport, including fire alarms; • Use of the fire hoses, nozzles, turrets, and other appli- ances required for compliance with Part 139; • Application of the types of extinguishing agents required for compliance with Part 139; • Emergency aircraft evacuation assistance; • Firefighting operations; • Adapting and using structural rescue and firefighting equipment for aircraft rescue and firefighting; • Aircraft cargo hazards, including hazardous materials or dangerous goods incidents; and • Familiarization with firefighters’ duties under the airport emergency plan (Certification of Airports 2004). Additionally, aircraft rescue and firefighting personnel must participate in at least one live fire drill before the initial per- formance of duties and every 12 consecutive calendar months thereafter. Further, at least one of these personnel must be trained and be current in basic emergency medical services and must be available during air carrier operations (Certifica- tion of Airports 2004). Part 139.321, Handling and storing of hazardous substances and materials, requires training of fueling personnel in fire safety and training of personnel who receive and handle haz- ardous substances and materials. Part 139.329, Pedestrians and ground vehicles, requires that certificated airports ensure that personnel (including employees, tenants, and contractors) are trained in procedures required under Part 139.329(b), Department: Name: latoT)0.0sruoH(tnepSemiT:raeY Month: J F M A M J J A S O N D Airport Familiarization Movement and Safety Areas Airport Communications Duties Under the ACM Source: Adapted from Lammerding 2010a. TABLE 2 SAMPLE INDIVIDUAL TRAINING RECORD (139.303)

and informed of the consequences of noncompliance, before moving on foot or operating a ground vehicle in movement areas or safety areas. Part 139.337, Wildlife hazard manage- ment, requires certificated airports with a wildlife hazard man- agement plan to develop a training program conducted by a qualified wildlife damage management biologist. According to AC 150/5200-36, Qualifications for Wildlife Biologist Con- ducting Wildlife Hazard Assessments and Training Curricu- lums for Airport Personnel Involved in Controlling Wildlife Hazards on Airports, the initial and recurrent training for airport personnel actively involved in implementing FAA- approved Wildlife Hazard Management Plans must be at least 8 hours in length (FAA 2010). Further, Part 139.339, Airport condition reporting, requires that personnel be trained ade- quately to issue Notices to Airmen (NOTAMs). 14 of unsafe conditions, and documentation of conditions found and corrective action taken, Part 139.327 also addresses training of personnel. Specifically, it requires certificate holders to: 1. Provide both initial and recurrent training at least every 12 consecutive calendar months in at least the following areas: a. Airport familiarization, including airport signs, marking and lighting; b. Airport emergency plan; c. NOTAM procedures; d. Procedures for pedestrians and ground vehicles in movement areas and safety areas; and e. Discrepancy reporting procedures. 2. Prepare records of all training given after June 9, 2004 to each individual in compliance with this section that includes, at a minimum, a description and date of train- ing received. Such records must be maintained for 24 consecutive calendar months after completion of training (Certification of Airports 2004). As with Part 139.303, documentation of training need not be complex (as seen in Table 3). However, certificated airports must provide training in the areas shown in Table 3, as well as in Table 2, for all self-inspection personnel. In that regard, Table 3 can be considered additional subject areas. In addition to the training areas spelled out in Part 139, AC 150/5200-18C provides areas or items that airports may wish to consider. First, it is important that inspection person- nel know the FAA AC standards applicable to the airport. Inspection personnel must also be taught correct radio com- munication phraseology, procedures, and techniques, as spec- ified in the Aeronautical Information Manual. Additionally, inspection personnel must be aware of construction safety plans and know how to become familiar with safety plans for new and future construction projects. For certificated air- ports, it is important that inspection personnel be familiar Department: Name: latoT)0.0sruoH(tnepSemiT:raeY DNOSAJJMAMFJ:htnoM Airport Familiarization Airport Emergency Plan NOTAM Procedures Pedestrians and Ground Vehicles Discrepancy Reporting Procedures Source: Adapted from Lammerding 2010a. TABLE 3 SAMPLE INDIVIDUAL TRAINING RECORD (139.327) According to the FAA, airports may not allow a person to, for example, perform ARFF duties or sign a daily self- inspection report if they have not received all of the train- ing in the required subject areas. This training must be accomplished before personnel perform their duties and every 12 consecutive calendar months thereafter. If an air- port allows improperly or insufficiently trained personnel to carry out tasks required by Part 139, the function that per- son was performing would be considered invalid. In other words, it would be the same as not doing it at all. Source: Lammerding 2010b. PART 139.327 Of the areas of training required under Part 139.303(e), the training requirements of Part 139.327 are the most important to an airport’s self-inspection program. Part 139.327 sets forth regulatory requirements for certificated airports in carrying out a self-inspection program. Aside from addressing such items as the frequency of inspections, the dissemination of infor- mation to air carriers, a reporting system to ensure correction

15 with the requirements of the ACM concerning training and self-inspection. Lastly, it is important that personnel become familiar with any Standard Operating Procedures, Operating Directives, Letters of Agreement, Memorandums of Under- standing, and any other policies related to the certification of the airport, the operation of the airport, the ACM, and the self-inspection program (FAA 2004). INITIAL TRAINING Initial training of new personnel is common for most posi- tions within the aviation industry. During initial training, personnel are indoctrinated into company policies and taught how to perform their essential duties safely. Specifically, for personnel conducting airport self-inspections, initial training provides a critical link for teaching new inspection personnel not only the duties of their position (typically operations- related) but also the proper manner in which to perform a self-inspection in support of the overall safety of the airport and Part 139 regulatory requirements. As previously presented, although the curriculum for initial training of personnel at certificated airports responsible for carrying out the requirements of the ACM is spelled out in Part 139, specific training methods are at the discretion of each airport. Many options currently exist for airports in this regard. One common method of training self-inspection personnel is by means of on-the-job training. This method of training requires a great deal of commitment by airport personnel. Often, airports require new personnel to ride along with more senior personnel on daily self-inspections to gain firsthand knowledge of how to conduct an inspection properly and of the items specific to that airport that are to be inspected. Some airports, such as Tampa International Airport, require new operations personnel to undergo up to 6 months of on-the-job training and to complete a checkride and a written and oral knowledge test successfully before allowing them to conduct an inspection solo. Training methods used often to supplement on-the-job training include videos, textbooks, oral and written tests, self-study, group study, simulation, and interactive training. The use of simulation in personnel training, although a rela- tively new concept, can add a sense of realism never before possible away from on-the-job training. Specifically for self- inspection personnel, driver simulation programs have been developed to allow the trainee to simulate driving on the air- field in both daytime and nighttime conditions while commu- nicating with Air Traffic Control and responding to instruc- tions. For newly hired self-inspection personnel who may be unfamiliar with operating a vehicle on the aircraft operating area (AOA) while conducting a self-inspection, gaining expe- rience while safely inside a training room can have a positive impact. Similar to simulation programs to some degree, elec- tronic interactive training programs are used by some air- ports and, although typically supplied by an off-site provider, can be integrated into an in-house training program. Although interactive training can be web-based, many of these pro- grams are housed on an airport’s server and have touch-screen monitors that show airport-specific video clips before quizzing the trainee on the information viewed. Questions can even be selected by the computer in real-time, as the trainee answers questions correctly or incorrectly. One provider currently offers a system that can be designed to offer training in areas such as security identification display area procedures, movement area driver training procedures, and self-inspection and Part 139 procedures. Typically, airport-specific video is recorded and incorporated into the interactive training platform to provide as much realism for the trainee as possible. RECURRENT TRAINING Even though personnel are trained before they perform their duties, recurrent training is important to maintain proficiency. Without recurrent training, the effects of initial training grad- ually decline, thus negatively impacting the airport self- inspection program. Many airports have adopted a program of recurrent training for personnel in various departmental areas, and the 2004 revision of Part 139 requires recurrent training of personnel in certain areas at least once every 12 consecutive calendar months. However, an airport may find it beneficial to offer more frequent recurrent training to personnel. For instance, if a new piece of equipment, such as a friction tester, is acquired, an airport will likely need to train personnel in the proper use of that equipment. Similar to initial training, recurrent training may be con- ducted through a variety of methods. Airports may use work- shops, conferences, hands-on training, job shadowing, tests, videos, self-study, interactive training, and other methods. However, airports often rely more on workshops, confer- ences, and various off-site schools for their recurrent training needs. By providing opportunities for personnel to “dig deeper” into Part 139, personnel will advance beyond rote memo- rization and further develop the ability to meet the regulatory requirements in all situations. TRAINING DESIGN Although the design of an airport’s training program will vary and is best if specific to that airport, there are certain cri- teria to consider in designing training. Most important, effec- tive training is student-centered. It focuses on what students should know, be able to do, or appreciate upon conclusion of the training. In the past, the focus was on what would be taught, rather than on what students would learn. To some degree in airport training, that is still the case. For instance, air- ports want employees to know Part 139, specific ACs, the air- port layout, security identification display area requirements, and other areas. But instead of asking what will be taught, it is effective to ask what students need to know. This focus on outcomes, rather than on content, is now the new norm. Fur- ther, as part of a student-centered approach, training will be

designed with the student in mind, considering prior knowl- edge and experiences, and developed to ensure a good learn- ing experience. Rather than having airports show an old video in a darkened room, they are encouraged to develop an inter- active training program with airport-specific photos, case sto- ries, and discussions. This may involve visiting peer airports, attending industry events, and learning from FAA personnel. If airports first consider the learner, training can be designed with effective results. 16 ings can be realized. Further, by being afforded the opportu- nity to train personnel, the trainers will likely learn their own strengths and weaknesses, and enhance their knowledge as a result. In-house training also has drawbacks. For example, trainees who undergo only in-house training miss the opportunity to examine how airports in other regions of the country train and perform self-inspections. Trainees may also miss out on the expertise of professional trainers. Lastly, an in-house train- ing program requires coordination by the airport not only to train the trainer and provide training facilities, but also to schedule training and to maintain records. In sum, depending on the airport, in-house training may be more expensive and of lesser quality than outsourced training. OUTSOURCED TRAINING A valid alternative to in-house training is outsourced training. Both initial and recurrent training may be offered using this option. Outsourced training involves the airport contracting with an external provider to provide training, whether this training takes place at the airport or off site. This training may be specific only for that airport’s personnel, or it may be offered to a group of individuals from any interested airport. Several organizations, aviation-specific or non-aviation– specific, offer training for airport personnel. Indeed, airports may contract customer service training, training in wildlife hazard management, self-inspections, and other areas of training. Several industry associations, numerous state insti- tutions, and a number of private providers offer workshops, meetings, schools, and conferences each year. The training opportunities provided may be conducted by industry experts. Training may last from several hours, to 1 week, to an entire semester. In addition, the industry offers various certifications for airport personnel to gain credentials. For instance, airport personnel may become an Accredited Airport Executive or an International Airport Professional. Utilizing outsourced training has many benefits. This method may allow airport personnel to come into contact with and learn from inspectors and other airport personnel from airports across the nation. This process generates ideas and methods that may prove useful to an airport. Additionally, outsourcing minimizes the burden of coordinating in-house training to ensure that an in-house trainer is available. Thus, outsourced training may be more cost-effective for an airport. However, airport operators are responsible for maintaining oversight of external providers, and are cautioned against delegating the responsibility for initial and recurrent training of personnel solely to external training providers. Similar to in-house training, outsourced training has drawbacks. It may be more expensive to rely on outsourced training, especially if conducted off site. With lodging, transportation, and registration fees, outsourced training may be cost-prohibitive. Personnel will also require more time “Stories from the Field” Salt Lake City International Airport has a well-developed and comprehensive training program for self-inspection personnel. Each Operations Manager and Operations Spe- cialist undergoes several weeks of training before assuming self-inspection duties. In training personnel on all aspects of airfield self-inspection and condition reporting, the airport training program covers all movement and non-movement areas (including taxiways, runways, and ramps), as well as perimeter security, fuel farms and equipment, ARFF, and buildings. Each Operations Manager and Operations Special- ist undertakes three additional training sessions each year, covering airfield condition reporting and inspections. These sessions are in the form of either computer-based training or PowerPoint presentation. Source: A. Stuart, Salt Lake City International Airport. IN-HOUSE TRAINING Whether conducting initial or recurrent training, airports may choose from one of two main options: in-house and out- sourced. Depending on the airport, in-house training can be more or less expensive than outsourced training. Although developing quality in-house training requires the commit- ment of personnel, it may be particularly suited for airports with personnel skilled in training. In-house training may also benefit smaller airports without the resources required for outsourced training, or with such a small number of person- nel that in-house training simply makes more sense finan- cially. Two substantial benefits of in-house training are the avoidance of travel costs and minimal time away from work for the personnel being trained. For example, with no costs for airfare, lodging, or per diem, in-house training provides substantial financial savings for the airport. Additionally, the individual being trained can complete training while at work, minimizing time away from the job. In-house training also provides an opportunity to tailor training to the specific airport environment and to incorporate any special airport circum- stances into the training. In-house training familiarizes the air- port inspector with the “home” airport, which should translate to smoother and more thorough inspections. By conducting in-house training with airport personnel, additional cost sav-

17 85% 30% 18% 15% 6% Operations personnel Airport manager Training manager Interactive Employee Training System Varies FIGURE 6 Responsibility for self-inspection training. Note: Participants were asked to select all that apply; thus, percentages do not total 100%. 61% 36% 13% 3% Combined with other training More than five hours One to five hours Less than one hour FIGURE 7 Duration of initial training. Note: Participants were asked to select all that apply; thus, percentages do not total 100%. away from work while attending off-site training. Addition- ally, depending on the training program, outsourced training may not be as airport-specific as desired. CURRENT AIRPORT TRAINING PRACTICES Frequency of Self-Inspection Training Before discussing current types of airport training methods, it is helpful to understand the frequency of self-inspection training at airports. The majority of participating airports (91%) conduct initial training as needed, when new personnel are hired. Most participating airports (72%) conduct recurrent training annually. A few of the participating airports (10%) conduct recurrent training monthly, with the remainder con- ducting either weekly or bimonthly recurrent training. Responsibility for Conducting Training When asked who conducts self-inspection training at their air- port, 85% of the participants indicated their respective airport operations personnel; none of the participating GA airports utilize operations personnel for this purpose. Other partici- pants identified the airport manager or training manager as responsible for self-inspection training (Figure 6). The air- port manager conducts training at 100% of non-hub airports and 50% of GA airports. Training is conducted by a training manager at 25% of small-hub airports and 25% of non-hub airports, but only at 18% of large-hub airports. Interactive training is relied on by 27% of large-hub airports and 25% of non-hub airports, but much less at airports of other sizes. Duration of Training As previously discussed, training is composed of both initial training (typically for new hires) and recurrent training (typi- cally on an annual basis for all personnel). To determine current practices regarding training of personnel for self-inspections, participating airports were first asked about the duration of ini- tial training for inspection personnel before these individuals are granted self-inspection authority. As seen in Figure 7, self- inspection training is most often combined with other training offered to new hires. However, open-ended responses also revealed a pattern of on-the-job training lasting from 1 to

3 months. If training for conducting self-inspections is com- bined with other operational training, it may last for several months. However, if the training required to conduct self- inspection is offered in a stand-alone module, it takes signif- icantly less time. Training Methods When queried about whether this initial training was con- ducted in-house or from a private provider, all respondents indicated they have an in-house training program. Moreover, 9% of large-hub and 17% of medium-hub airports also rely on private providers. Airports were also queried about the methods used for ini- tial training of inspection personnel. Although on-the-job training is the most common, airports employ a diverse set of methods for training, as seen in Figure 8. Large-hub airports tend to use on-the-job training (100%), interactive training (82%), and self-study (73%). Medium- and small-hub air- ports rely mostly on on-the-job training (100%). Self-study and on-the-job training are common at non-hub and GA air- 18 ports, although 75% of non-hub airports also employ interac- tive training. When airports were asked why they had chosen these initial training methods, several themes emerged from the responses (Appendix G). Most commonly, airports indicated their chosen methods were reliable, successful, or effective. Another common theme was that the chosen methods were low-cost. Finally, several airports indicated they prefer to vary training methods to ensure blended learning. By varying techniques and relying on a combination of training methods, personnel became more informed and more apt to learn. As one participant explained, “[Our methods] have proven reli- able over a period of time, and they are implementable at a relatively low cost.” In addition to initial training of personnel, recurrent train- ing is conducted at airports. When asked about the methods in use to train inspection personnel recurrently, the most common responses were on-the-job and interactive train- ing. As seen in Figure 9, airports again rely on a diverse set of methods to recurrently train inspection personnel. 94% 67% 61% 58% 49% 27% On-the-job training Self-study Interactive training Tests Video Conferences/workshops FIGURE 8 Initial training methods. Note: Participants were asked to select all that apply; thus, percentages do not total 100%. 63% 63% 50% 50% 50% 34% On-the-job training Interactive training Self-study Tests Video Conferences/workshops FIGURE 9 Recurrent training methods. Note: Participants were asked to select all that apply; thus, percentages do not total 100%.

19 When analyzed by airport hub size, large-hub airports most commonly use interactive training (90%) and tests (80%). Medium-hub airports mostly rely on on-the-job training (67%). Small-hub airports tend to use a combina- tion of self-study, on-the-job training, interactive training, and conferences or workshops, with 63% utilizing each of these. Among non-hub and GA airports, self-study and on- the-job training are most common. When asked why these specific methods were chosen, respondents again spoke of the benefits of multiple methods (Appendix G). The most common theme identified was that the methods were reliable, effective, or successful. Other themes include a blend of methods and costs outweighing the benefits. Although only one-third of participating airports utilize conferences or workshops for recurrent training, one respondent explained why conferences or workshops are beneficial: “We feel that once the person has proven him or herself, we are comfortable with investing a little more in the employee and will send them to training or a conference off- site.” Even so, it appears that a majority of airports (97%) provide recurrent training in-house, with only a small per- centage of large-, medium-, and small-hub airports relying on a private provider. Training by Employee Group Although Part 139 indicates that training must be carried out for all personnel who access movement and safety areas and are responsible for performing duties in compliance with the ACM, airports were queried about which employee groups received all components of required Part 139 training. As seen in Figure 10, operations personnel was the group most likely to receive the required Part 139 training. However, at some airports, other employee groups received this training as well. Interestingly, one airport stated that even though they had never provided Part 139 training to maintenance person- nel in the past, “During our yearly inspection in March, our inspector requested that we train our maintenance personnel. We are currently working towards that.” Indeed, if these main- tenance personnel, such as airfield electricians, are accessing movement and safety areas and performing duties in compli- ance with the requirements of the ACM, according to FAR Part 139.303, they must receive training in the areas outlined in FAR Part 139.303. Of note, however, 71% of participat- ing airports mention they only train personnel with regard to their specific responsibilities as identified in the airport’s ACM. In other words, personnel are not necessarily being trained in all areas outlined in the ACM if they are not respon- sible for maintaining compliance with the entire ACM. This typically means that operations personnel are trained in all aspects of the AC, whereas ARFF and maintenance may receive training in specific areas. Personnel Credentials To determine whether airports require inspection personnel to pursue added credentials or certifications, airports were queried about personnel credentials. Only 34% of partici- pating airports strongly encourage inspection personnel to obtain any of these credentials; 59% do not encourage or require personnel to obtain these credentials. Only two par- ticipating airports require any of these credentials by person- nel conducting self-inspections. 87% 39% 23% 3% Operations personnel Maintenance personnel ARFF personnel Police FIGURE 10 Part 139 training by employee group. Note: Participants were asked to select all that apply; thus, percentages do not total 100%.