Scale Down for Compliance

Scale Down for Compliance

By Catalina9

Scale Down for Compliance

An airport operator has several responsibilities when it comes to the activation of an airport emergency plan, activities during the emergency and post emergency activities. Airport Emergency Plan compliance is a comprehensive task which at first glance seems impossible to comprehend and achieve.

Airport emergency planning is the process of preparing an airport to cope with an emergency occurring at the airport or in its vicinity. The object of the airport emergency planning is to minimize the effects of an emergency, particularly in respect of saving lives and maintaining aircraft operations. The airport emergency plan sets forth the procedures for coordinating the response of different airport agencies and other community agencies in the surrounding community that could be of assistance in responding to the emergency. The basic needs and concepts of emergency planning and exercises are command, communicate and coordinate.

An airport operator has a responsibility to identify organizations at the airport and community organizations that are capable of aiding during an emergency at the airport or in its vicinity. Telephone numbers and other contact information for each organization are listed in the airport emergency plan and the type of assistance each organization can provide is also listed.

An airport operator has a responsibility to identify any other resources available at the airport and in the surrounding communities for use during an emergency, or in recovery operations and provide their telephone numbers and other contact information.

An airport operator has a responsibility to describe lines of authority for each emergency and the relationships between the organizations and how interactions between these organizations are coordinated, and coordination within each of these organizations.

An airport operator has a responsibility to identify supervisors and describe the responsibilities for each emergency.

An airport operator has a responsibility to specify the positions occupied by airport personnel who will respond to an emergency and describe their specific emergency response duties.

An airport operator has a responsibility to identify the on-scene controller and describe the person’s emergency response duties.

An airport operator has a responsibility to provide authorization for a person to act as an on-scene controller or a supervisor if they are not airport personnel.

An airport operator has a responsibility to set out the criteria to be used for positioning the on-scene controller within visual range of an emergency scene.

An airport operator has a responsibility to set out the measures to be taken to make the on-scene controller easily identifiable at all times by all persons responding to an emergency.

An airport operator has a responsibility to describe the procedure for transferring control to the on-scene controller if initial on-scene control was assumed by a person from a responding organization, e.g. fire, ambulance or police.

An airport operator has a responsibility to describe any training and qualifications required for the on-scene controller and other airport personnel identified in the emergency plan.

An airport operator has a responsibility to describe the method for recording any training provided to the on-scene controller and airport personnel.

An airport operator has a responsibility to describe the communication procedures and specify the radio frequencies to be used to link the airport operator with the on- scene controller, and to link the airport operator with the providers of ground traffic control services and air traffic control services.

An airport operator has a responsibility to describe the communication procedures allowing the on-scene controller to communicate with the organizations identified in the emergency plan.

An airport operator has a responsibility to identify the alerting procedures that activate the emergency plan, establish the necessary level of response, allow immediate communication with the organizations identified in the emergency plan in accordance with the required level of response, confirm the dispatch of each responding organization, establish the use of standard terminology in communications, and establish the use of the appropriate radio frequencies as set out in the emergency plan.

An airport operator has a responsibility to specify the airport communication equipment testing procedures, a schedule for the testing, and the method of keeping records of the tests.

An airport operator has a responsibility to specify the location of the emergency coordination center used to provide support to the on-scene controller when ARFF is on the field.

An airport operator has a responsibility to describe the measures for dealing with adverse climatic conditions and darkness for each potential emergency.

An airport operator has a responsibility to describe the procedures to assist persons who have been evacuated if their safety is threatened or airside operations are affected.

An airport operator has a responsibility to describe the procedures respecting the review and confirmation of emergency status reports, coordination with the coroner and the investigator designated by the Transportation Safety Board of Canada regarding the accident site conditions, disabled aircraft removal, airside inspection results, accident or incident site conditions, and air traffic services and NOTAM coordination to permit the return of the airport to operational status after an emergency situation.

An airport operator has a responsibility to describe the procedures for controlling vehicular flow during an emergency to ensure the safety of vehicles, aircraft and persons.

An airport operator has a responsibility to specify the procedures for issuing a NOTAM in the event of an emergency affecting the critical category for fire fighting if ARFF are available on the field, or changes or restrictions in facilities or services at the airport during and after an emergency.

An airport operator has a responsibility to describe the procedures for preserving evidence as it relates to aircraft or aircraft part removal, and the site of the accident or incident in accordance with the Canadian Transportation Accident Investigation and Safety Board Act.

An airport operator has a responsibility to describe the procedures to be followed, after any exercise, or the activation of the plan, a post-emergency debriefing session with all participating organizations, the recording of the minutes of the debriefing session, an evaluation of the effectiveness of the emergency plan to identify deficiencies, changes, if any, to be made in the emergency plan, and partial testing subsequent to the modification of an airport emergency plan.

An airport operator has a responsibility to describe the process for an annual review and update of the emergency plan, describe the administrative procedure for the distribution of copies of an updated version of the emergency plan to the airport personnel who require them and to the community organizations identified in the plan, and describe the procedures to assist in locating an aircraft when the airport receives notification that an ELT has been activated.

An airport operator includes in the airport emergency plan a copy of signed agreements between the airport operator and community organizations that provide emergency response services to the airport and an airport grid map.

A Safety Management System (SMS) is a process oversight system of all areas of airport operations. The challenge with an Airport Emergency Plan (AEP) is not all required responsibilities, and a conglomerate of interactions, but that the AEP must be scaled down to size and complexity of the airport. Unless the AEP is scaled, the airport operator is in non- compliance with a regulatory requirement that a safety management system is adapted to the size, nature and complexity of the operations, activities, hazards and risks associated with the operations. The key to success is to scale down to a common denominator with combined tasks.

Catalina9

Your Safety Data System

Your Safety Data System

By Catalina 9

The regulations require that an airport or airline operator implement a safety data system, by either electronic or other means, to monitor and analyze trends in hazards, incidents and accidents. Regulations are scalable and paper format as other means is included to monitor and analyze trends. At some of the smaller airports with only one or two persons managing and maintaining the airport the paper format may work for that size and complexity. For airports with three or more workers or larger airports and airlines, it becomes a humongous and labor-intensive task to conform to regulatory compliance by monitoring and analyzing trends using paper documents.

Unless there is tangible action the SMS is only empty words

The Safety Management System (SMS) is more than data point entries and designing graphs. SMS needs to be built up by a safety data system with tangible actions and results. A safety data system must be autonomous, preserve its integrity, it must be flexible and scalable to size and complexity, or tailored to operational needs. In an autonomous safety data system there is task completion, performance reliability and performance analytics. Performance analytics is the engine, or system, that uncovers insights and reveals hidden value to define new, targeted learning interventions. The result is learning spend that helps aviation safety achieve key objectives.

A requirement for a safety data system is that it acts as an inhibitor against corruption, subjectivity or bias. Corruption is when a system may, intentionally or unintentionally, being altered causing a different outcome. Subjectivity is when someone has a personal interest, or an agenda to manipulate the outcome of data collected, or of facts discovered. Bias is prejudice of outcome based on an assumption or an opinion about someone, or something, simply based on past history. The differences between corruption, subjectivity and bias, is that corruption could be an error, mistake or intentional action, subjectivity is personal to the outcome where facts are ignored, and bias is a decision made prior to an investigation or fact finding mission. A safety data system must prevent these opportunities to occur within its system.

A paper format safety data system is inherent corrupted by self-degradation over time. A document may be legible one year but totally unreadable the next year. Paper documents can also be altered or lost. In an operation with two workers only, such as the Accountable Executive and Airport Manager/ SMS Manager, a paper format may work since any changes are traced to one or the other. If there are three workers, a conflict of interest may arise. Paper documents is an available option under the regulation to accommodate for the simplest common denominator which is one aircraft and one person, or one airport and one person.

Electronic spreadsheets is an option often used by airlines and airport operator as their safety data system. Just as a paper system, an electronic spreadsheet system may also be corrupted, subjective or biased to the facts. A safety data system that in not corrupted, subjective or bias starts with the SMS safety policy. An effective Safety Policy is a tool to manage corruption, subjectivity or bias and must be tailored to the organization so all personnel can recognize accountability, accept accountability for the policy and take ownership of it. Without ownership of the Safety Policy, the policy is an ineffective tool and in itself a hazard to safety.

When there is no accountability to the Safety Policy it becomes more important to adhere to the text in the policy rather than the intent of safety in operations. When the text itself is paramount in the decision-making process, a grammatical error has in the past become the determining factor for a regulatory SMS finding. When selecting a safety data system, the two most important functions to consider are the probability of file deletion, or alternation and the simplicity of reporting. In its simplest form an SMS report should accept a submission with one or two pictures only. A system where files can be deleted by an operator does not preserve the integrity of the system. Files must remain in the safety data system for as long as they are applicable to operations, or personnel, at which time they may be archived, but still available for retrieval. An example would be the Canadian CADORS files for an airport. The airport may analyze CADORS for the past five years, but after 5 years and 1 month, the 1 month may be archived.

If advertising does not work, social media does not affect safety in aviation

CADORS are as much a part of the data collection system as any other report. If CADORS are excluded from the hazard register, an airline or airport operator is operating with a corrupt safety data system and a skewed analysis. Public complaints are also a part of the hazard register, since public opinions affects how the regulator views an airline or airport. As an example, it was not long ago that the regulator revoked a certificate with unsubstantiated findings, or findings added after the inspection, due to public opinion of the operator. Another example is how the public opinion affected a CADORS to be biased against a smaller operator and gave an excuse for the airline’s on-time departure record. The excuse why the airliner entered the runway for backtracking when the smaller aircraft was on base leg was that they needed a VFR departure since the IFR clearance was going to take a while. When the smaller aircraft turned onto final, the taxiing aircraft was ¾ of the way down the runway for takeoff and declared that they had vacated the active runway when they were parked in the turnaround bay. An unbiased CADORS would have stated the facts, which was that a small aircraft had to make an avoidance maneuver due to an airliner backtracking on an active runway. There are several examples of how public opinions or social media affects the CADORS. For an airport or airline to preserve their integrity and fight for their regulatory conformance, CADORS must be investigated and filed in their hazard register. Another short CADORS example shows how social media or public opinions make it into the CADORS [redacted]: An aircraft flew directly overhead an airport [small private airport] northbound, at an altitude of approximately 1000 feet above ground level and a rate of 151 knots ground speed without making any radio calls. Video evidence is available.  

Your Safety Data System must be integrated as a winning combination of your quality control and quality assurance system for incremental safety improvements. SiteDocs is a winning safety data collection tool. Data collected must be preserved and include reports that are both favorable, and unfavorable for your operations. A Safety Data System is more than just collecting and filing reports, it is a tool for the Accountable Executive to learn and comprehend safety in operations and review how lessons learned are derived from the Safety Policy. 

 

Catalina9