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48 Managers often use incident data to illustrate a level of safety that may exist at the airport, to evaluate risk, and/or to assess whether certain organizational goals are being met. The risk and insurance industries use the data as barometers of exposure and probability. Corroborating Incident Data Discussions with survey respondents identified a primary reason for their collecting incident data is to be able to benchmark those data with other airports [Question 3.b.]. As noted in Chapter 6, with few airports exactly alike in their structure, organization, operation, or goals and objectives, it is difficult to make comparisons about incident rates or other indicators. ACRP Report 62: Airport Apron Management and Control Programs (Ricondo & Associates, Inc. 2012) indicates that airports have a vested interest in corroborating incident data from their tenants, as safety practices on the ramp can impact the airport enterprise, operation, and risk profile in several ways, including the following: ⢠Injuries to airline and airport personnel. ⢠Injuries to airline passengers and crew. ⢠Cost of damage to equipment, such as aircraft and ground support equipment. ⢠Operational impacts due to accidents and incidents, ranging from operational delays to the costs of removing equipment from service for repair. ⢠Insurance considerations. ⢠Operational efficiency in and around the apron environment (i.e., improving aircraft turn- around time at the gate). The air carrier and charter industries have been collecting and refining incident data for a number of years. In addition, they were the first to have FAA requirements to adopt SMS (1584 Federal Register/Vol. 80, No. 8/Tuesday, January 13, 2015/Rules and Regulations). For these reasons, they require reporting of incidents and accidents by employees and contractors throughout their respective organizations in an effort to mitigate future consequences. OSHA reporting requirements also apply to air, cargo, and charter operators, as well as other private airport businesses. Sharing those data with others, including airports, is not a norm. Obtaining incident data from private third-party entities can be difficult, as they have expressed concerns about privacy and legal exposure for their business, their employees, and any other parties involved, and about negative public relations. As private entities, the air carriers are concerned with the adverse financial and operational impacts that can result from injuries, equipment outages, and facility damage. C H A P T E R 8 Practices in Incident Reporting
Practices in Incident Reporting 49 Overcome Barriers to Nondisclosure To overcome barriers of nondisclosure, several of the airports in this synthesis identified clauses in lease agreements, ordinances, and SMS involvement as means to be considered. Recognizing the mutual importance of sharing data, two airport operators in this study specifi- cally address this issue by cultivating a relationship of trust with their airline and air cargo tenants. They use meetings and personal relationships as a means to exchange risk data and âsellâ the need to the air carriers, pointing to operating and financial efficiencies to be gained. The survey asked what airport stakeholders or tenants collect incident-hazard-SPI-KPI data on their airport [Question 3.g.]. The airlines, cargo operators, and fixed-base operators (FBOs)/ ground handlers were the prominent collectors of data. When asked if other organizations, tenants, or business entities share incident-hazard-SPI-KPI data with the airport, the majority said no [Question 6.c.]. Eight airports in the survey indicated they share data with other orga- nizations, with federal regulatory agencies such as the FAA, OSHA, and EPA being the most prominent [Questions 6.a. and 6.b.]. Insurers, risk managers, internal organizational depart- ments, and employees were the next most common. Tracking Incident Data To make decisions affecting safety and risk in an organization, data are required. Data collected need to be supplied to management or other responsible parties in a timely manner for effective decisions or actions to occur. Decisions about how to collect, track, and report the data involve discussion about what kind of an information management system will be used to manage the data, who will collect what kind of data, how the data will be investigated and verified, and how data will be made available to others. The synthesis survey found that the collection of incident data occurs within any number of departments [Question 3.a.]. Much of the collection depends on the type of data being collected. Risk management, airfield operations, aircraft rescue and firefighting, and police and security departments were the more prevalent departments noted to collect data. To a lesser extent, engineering and construction, ground transportation, terminal operations, parking operations, and finance were the next common. These data are supported by where the responsibility for the oversight of the incident reporting processes resided. Operations, risk management, and safety departments had prime responsibility [Question 3.d.]. ACRP Report 62 (Ricondo & Associates, Inc. 2012) found that at U.S. airports, there is no comprehensive system-wide database to track accident and incident statistics to quantitatively assess the safety of operations on the aprons or airports. This is because apron areas are typically managed by the air, cargo, or charter carriers that use them. This is in contrast to European airports where the airport often controls and has responsibility for apron areas. In the United States, unless an accident or incident on the aprons and ramps involves airport operations, pub- lic safety, or emergency response, the air operator does not normally report such information to the airport. ACRP Report 62 further found that while 45% of survey respondents would notify the airport by telephone of an incident, only 11% had a standard practice of submitting the reports to it. No distinction was made as to whether the reports involved an incident or an accident. Discussion with airport operators for this synthesis supports the findings in ACRP Report 62 and found that even OSHA reportable accidents and incidents are not normally conveyed to the airport by tenants or third-party operators [Question 6.c.].
50 Airport Incident Reporting Practices Generally, federal OSHA requirements do not apply to airports, as they are governmental entities exempt from the regulations. However, the survey and interviews found airports often do collect OSHA information due to either state or city requirements, or because they believe it is their mission to provide a safe workplace [Question 3.a.]. OSHA regulations contain standards that help airports meet the safety goal. As a national standard, OSHA data allow for comparison among airports. ACRP Report 62 provides a comprehensive literature review of accident/incident data systems related to airport terminal apron areas. The documents identified in ACRP Report 62 describe the same challenges and diversity of data collection among aviation regulatory and industry organizations as does this report. The following are several of the databases referenced in the report: ⢠FAA Aviation Safety Information Analysis and Sharing System. ⢠Integrated Management Information System, maintained by OSHA, which contains records of OSHA investigations. ⢠NASAâs ASRS. ⢠ACI Survey on Apron Incidents and Accidents (Airports Council International 2009). Tracking Methods Incident reporting systems have evolved from a paper-based format, to computer- based formats, and to web-based systems. Each can be found at todayâs airports. The more extensive the reporting of incidents, the more important it is to have a database that can manage it well. With incident reporting systems ranging from simple to complex, GA and non-hub category airports are more likely to have manual incident reporting systems in use. However, as incident reporting takes on greater importance and should SMS requirement become regulatory, airports having complex facilities and operations will be more inclined to utilize incident reporting software programs to manage their system. Reporting programs can range from a handwritten recording system, to an in-house developed spreadsheet program, to a sophisticated integrated system purchased from a vendor and based on a separate computer or cloud-based server. The programs can produce and present trending and statistical reports, performance metrics, risk mitigation solutions, and other types of data in numerous ways. They can also be integrated and shared among selected locations, departments, employees, and stakeholders. In the synthesis survey, a simple computer spreadsheet was the most prevalent means for consolidating and tracking incident data [Question 4.b.]. Five of the airports were using a custom software program, while two used a commercially available program. Three airports used a manual system in combination with other means. One airport did not use any system. Given the large amount of data to be collected in a well-developed incident reporting and safety management system, and especially at a medium or large hub airport, an integrated tech- nology solution, such as a web-based reporting system, is almost paramount. At smaller airports with less financial capabilities, a simple electronic spreadsheet would be more the norm, unless their reporting system is tied into a larger municipal reporting system. One airport in the survey identified the need to be able to customize any software to meet the needs of the organization as important. Another airport identified the importance of owning the data and not having the data be cloud-based. The reason for doing so was primarily related to issues of security and maintaining the integrity of the data.
Practices in Incident Reporting 51 Data Protection Another challenge airports must face when implementing an incident reporting program is maintaining the security and privacy of the information. Interviews with respondents to the survey conveyed the concern for incident reporting being used negatively to cause loss of reputation or to create a negative image of the airport, when the intent behind incident reporting is to increase safety and reputation. Frequently cited as an impediment to data sharing are the federal Freedom of Information Act (FOIA) and state sunshine law requirements applicable to most public governmental entities. For purposes of FOIA and state sunshine law requirements, incident reporting needs to be simple, factual, straightforward, and non-speculative. The resultant investigation or analysis of the report is what provides the level and quality of detail necessary from which an organization can learn and make improvements in its processes and procedures. For a discussion on the legal exposure to an airport subject to FOIA or sunshine laws, ACRP Legal Research Digest 19 (Bannard 2013) provides a good overview. When the survey asked what precautions are taken to protect the data collected or to pro- tect the person(s) reporting a hazard or incident, the few responses indicated redaction of permissible data and review by the legal or human resources department as the only options [Question 6.d.]. Most of the incident reporting data stored at airports were found to be on secure intranet or individual departmental computers. One survey respondent suggested the following: Because airports canât protect data, FAA, AAAE, or ACI should develop and sponsor a national safety hazard/incident database similar to the wildlife hazard database. Doing so would provide another layer of protection, allow for data sharing and enhanced identification of trends and issues nationwide instead of simply at one airport.
