Airport Self-Inspection Practices (2011)

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35 One of the reasons for conducting self-inspections is to find and report discrepancies. Although the term “discrepancy” typically refers to a condition that is not in compliance with Part 139, more broadly, the term “discrepancy” may refer to any unsafe airport condition that needs correction. Although some airports may adopt stricter standards than spelled out in Part 139 or AC 150/5200-18C, any airport condition that is considered unsafe must be reported and corrected promptly (FAA 2004). The manner in which discrepancies are addressed will depend on the nature of the discrepancy, the department or individual to which they are reported, the manner in which they are reported, and the urgency of the request. This report- ing process will determine how efficiently the discrepancy is corrected. As required by Part 139.327, each certificated airport must have “a reporting system to ensure prompt correction of unsafe airport conditions noted during the inspec- tion, including wildlife strikes” (Certification of Airports 2004, p. 24). NATURE OF THE DISCREPANCY The nature of a discrepancy found during a self-inspection will dictate the manner in which the discrepancy is addressed. If the conditions noted during an inspection cannot be promptly cor- rected, several options are available to the airport operator, depending on the situation. First, a NOTAM may be issued. NOTAMs are important in complying with the requirement of Part 139.327(b)(2) to “ensure rapid and reliable dissemina- tion of information between the certificate holder’s personnel and air carriers,” as well as Part 139.339 (Certification of Air- ports 2004, p. 24). Second, an area may be closed or restricted. As Part 139.343 states: Whenever the requirements of subpart D of this part cannot be met to the extent that uncorrected unsafe conditions exist on the airport, the certificate holder must limit air carrier opera- tions to those portions of the airport not rendered unsafe by those conditions. In closing a pavement, airports must ensure that closed areas are properly marked and lighted, as detailed in AC 150/5370-2E. A third option, many times used in conjunction with the two items previously mentioned, is for inspection personnel to issue a work order for resolution of the issue by appropriate personnel. Additionally, the discrepancy may be noted on a self-inspection report, with a record of the correc- tive action. It should be noted that airports may adopt stan- dards that are stricter than regulatory requirements. As a result, a condition may trigger a work order or pavement closure at one airport and not at another. REPORTING METHODS An effective safety self-inspection program includes pro- cedures for reporting and correcting deficiencies (FAA 2004, p. 3). For airports to correct deficiencies in an expeditious man- ner, it is imperative for these deficiencies to be reported to appropriate personnel to ensure prompt resolution. Although inspection personnel may be equipped and skilled to address certain issues encountered during a self-inspection (such as removing FOD, or possibly even using cold patch to repair a small spall), often maintenance personnel are relied on to address issues needing correction. Reporting methods differ among airports. These methods vary depending on staff, airport size, and technology available at each airport. Often, for urgent requests, company radio or telephone is used to contact maintenance personnel immedi- ately. Less urgent requests may be communicated by e-mail, text message, phone message, fax, radio, or paper or electronic work order. Airports that use electronic or computerized self- inspection programs may have the ability to initiate work requests from the field through an in-vehicle self-inspection platform. Regardless of the method, it is helpful to follow up with appropriate personnel to ensure the work request was received as issued. Whether faxed, e-mailed, or sent through company mail, it is incumbent upon the individual initiating the work request to make certain that the request was received. At airports with a work order system, this follow-up may be automatic, in the form of a work order number assigned to a request. Oftentimes, discrepancies are discovered by personnel conducting self-inspections during the night or weekend. As a result, reports of discrepancies may need to be made out- side normal business hours. Although many large airports have at least some degree of maintenance staffing during the weekend and night shifts, alternate reporting procedures may need to be adopted for airports without sufficient personnel during these times. These procedures may involve the use of CHAPTER FOUR REPORTING DISCREPANCIES AND FINDINGS

on-call personnel, better equipped self-inspection personnel, or the more frequent use of NOTAMs to restrict or close areas. At one airport, for instance, operations personnel are equipped with a bag of asphalt cold patch and a tamping tool to repair spalls on the runway quickly and temporarily if they are dis- covered while maintenance personnel are not present. This one procedure likely prevents unnecessary closures of run- way pavement at this airport. 36 Part 139 specifications may require an immediate runway closure and emergency response by maintenance personnel, whereas a broken taxiway edge light may only require a nota- tion on the self-inspection form with follow-up to maintenance by means of a work order. By making the order of priority for discrepancies a part of the airport’s self-inspection program and communicating this to all involved, self-inspection per- sonnel will be prepared to prioritize issues correctly as they are encountered. CURRENT AIRPORT REPORTING PRACTICES Certificated airports are required, under Part 139, to report certain types of information in two ways. First, as discrepan- cies are discovered during a self-inspection, they are reported to appropriate personnel to ensure prompt resolution of the discrepancy. Second, personnel then report certain types of information, such as pavement closures and out-of-service facilities, to air carriers utilizing the airport. Thus, the pres- ent survey was designed to gain insight into these two types of reporting requirements. Reporting Unsafe Conditions First, participating airports were queried about the manner in which they report discrepancies for resolution. Specifi- cally, Part 139.327 requires “a reporting system to ensure prompt correction of unsafe airport conditions noted dur- ing the inspection” (Certification of Airports 2004). Partic- ipating airports were asked to explain how this is accom- plished at their airport. By far, the most common theme centered on a computerized work order system (Appendix G). Several airports also utilize a written or paper-based work order system. Several airports explained that, based on the urgency of the request, maintenance personnel may be contacted immediately by means of the phone or radio. Although the manner in which unsafe airport conditions are reported varies to some degree, it appears from the responses that all airports have an effective system in place to meet this requirement. As explained by one airport: Any unsatisfactory conditions noted during an inspection will be recorded on the airport’s approved inspection checklist. A phone call is made to the on-duty Airfield Maintenance staff for unsat- isfactory conditions requiring action to be taken, and a follow-up e-mail is completed and routed to the Airfield Maintenance staff (and copied to the Airside Operations staff). Disseminating Information to Air Carriers Part 139.327 requires “procedures, facilities, and equipment for reliable and rapid dissemination of information between the certificate holder’s personnel and air carriers” (Certifica- tion of Airports 2004). Participating airports were presented with an opportunity to share how this was being accom- “Stories from the Field” Fort Lauderdale–Hollywood International Airport (FLL) is a firm believer in the ability of GIS to enhance efficiency and reduce the workload of personnel. Specifically, the GIS used at FLL provides a foundation for the airport’s work order sys- tem. For instance, if inspection personnel discover an inoper- ative taxiway light, the combination of a GIS map of airfield lights and the vehicle’s GPS location will identify the light needing repair. A web-based work order is then completed, requesting the light be repaired, and is submitted remotely to the airport’s computerized maintenance management sys- tem. A report is then generated by the computerized mainte- nance management system showing the location of the light, a part list, and the warehouse location for replacements. The report is automatically e-mailed to maintenance personnel. Once the repair is completed, the maintenance technician completing the work can e-mail a completion report back to the airfield inspector, who can then check the repair and sub- mit a final inspection report. By electronically tracking inspections and work orders, the airport is better prepared for their annual Part 139 inspection. According to Tim Neubert of Neubert Aero Corp.: The authorities will say ‘I see you have a work order that was generated three months ago; I’d like to see that work order and the corrective action.’ In the early days, you’d have to sift through mounds of paper to find that form. Now, you can pull up a list of open and closed work orders, identify the one you need, and show corrective action almost immediately, without leaving your desk. Further, he adds, “Papers are traditionally lost, and often changes to documents took place after the fact. Electronically filing this information, which is date and time stamped, reduces an airport’s risk and liability by allowing greater accountability in reporting.” Source: Garrett 2010. ORDER OF PRIORITY In AC 150/5200-18C, the FAA encourages airports to “deter- mine which problems require immediate attention and treat those with the highest priority” (FAA 2004, pp. 3–4). Clearly, upon discovery, certain issues may require more urgent attention. For instance, a runway spall exceeding

37 plished at their airport (Appendix G). First, responses show that the NOTAM system is utilized as needed. As to addi- tional means of disseminating information to air carriers, the fax is most common. Airports also utilize e-mail and the telephone, with several airports posting information on their website or delivering hard copies to airline personnel. Indeed, one airport communicates with air carrier personnel “via OpsNet software . . . which is used for issuing NOTAMs and communicating information about the Airport’s status to air carrier personnel.” Another airport explained their system as follows: Unsatisfactory conditions that cannot be promptly corrected by our maintenance department shall be identified and disseminated by NOTAM in accordance with Part 139.339, Airport Condition Reporting. NOTAMs will be filed through the FSS and faxed to all affected tenants. A Code Red paging and telephone alerting system can also be utilized if a situation or condition has an immediate negative impact to the operations of the airport.