Gap Analysis 

Fort Worth Alliance Airport (AFW) 

Safety Management System 

Submitted to: 

Alliance Air Services (AAS) 

Submitted by: 

Jacobs Engineering Group Inc. 

March 24, 2009

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Gap Analysis 

 Fort Worth Alliance Airport (AFW) 

Table of Contents 

Section Page 

EXECUTIVE SUMMARY ........................................................................................................... 1 

I. Introduction .................................................................................................................... 3 

Background .................................................................................................................... 3 

Objectives ...................................................................................................................... 3 

Methodology................................................................................................................... 3 

Operations at AFW......................................................................................................... 4 

Structure of The Gap Analysis ....................................................................................... 4 

II. SAFETY POLICIES AND OBJECTIVES........................................................................ 7 

Key Features.................................................................................................................. 7 

Existing Policies and Objectives .................................................................................... 7 

Gaps and Development Required.................................................................................. 8 

III. SAFETY ORGANIZATION............................................................................................. 10 

Key Features.................................................................................................................. 10 

Existing Policies, Practices and Systems....................................................................... 11 

Gaps and Development Required.................................................................................. 15 

IV. SAFETY RISK MANAGEMENT ..................................................................................... 18 

Key Features.................................................................................................................. 18 

Existing Practices and Systems ..................................................................................... 18 

Gaps and Development Required.................................................................................. 19 

V. SAFETY ASSURANCE.................................................................................................. 20 

Key Features.................................................................................................................. 20 

Existing Practices and Systems ..................................................................................... 21 

Gaps and Development Required.................................................................................. 23 

VI. SAFETY PROMOTION - TRAINING.............................................................................. 24 

Key Features.................................................................................................................. 24 

Existing Policies, Practices and Systems....................................................................... 24 

Gaps and Development Required.................................................................................. 26 

VII. SAFETY PROMOTION - COMMUNICATIONS ............................................................. 27 

Key Features.................................................................................................................. 27 

Existing Policies, Practices and Systems....................................................................... 27 

Gaps and Development Required.................................................................................. 27 
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List of Appendices 

Appendix A Draft Statement Of Work - FAA SMS Airport Pilot Study 

Appendix B Inspection Forms Used by AFW Operations Specialists 

Appendix C Inspection Forms Used by ARFF 
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EXECUTIVE SUMMARY 

In February 2007 the FAA issued Advisory Circular, AC 150/5200-37, Introduction to Safety 

Management Systems (SMS) for Airport Operators, to introduce the concepts of SMS. The FAA 

also initiated a pilot program to assist airports in the development of an SMS specific to their 

situation and operations, and to share their acquired experience on SMS development and 

implementation with other airports and the FAA. 

Alliance Air Services (AAS), under contract with the City of Fort Worth to manage the Fort Worth 

Alliance Airport (AFW), has decided to take a leadership role in the development and 

implementation of SMS Fort Worth Alliance Airport by participating in the FAA pilot program. 

The purpose of this document is to compare existing safety policies and practices at AFW with SMS 

program requirements and identify elements that require development for SMS. 

 As detailed in this report, the gaps between existing safety policies and practices and the FAA’s 

anticipated SMS regulations and guidance material are as follows: 

Safety Policies and Objective 

4 There are no specific aviation safety policies and objectives. These need to be developed for 

inclusion in the SMS. 

Safety Organization 

4 AAS does not have roles and responsibilities defined specifically for safety. The Gap Analysis 

details the potential safety organization for consideration for the SMS Manual. 

Safety Risk Management 

4 Because Safety Risk Management (SRM) is an entirely new requirement under SMS, AAS 

currently does not have a formal SRM process for aviation safety. The SRM process will be 

developed and documented during subsequent tasks in the project. 

Safety Assurance 

4 AAS has a number of safety assurance mechanisms including self-inspection and wildlife 

controls. 

4 Based on new SMS requirements, subsequent tasks of the SMS project will need to develop: 

o Non-punitive reporting. 

o Tracking safety performance indicators. 

o Systematic reviews and audits. 

o Safety oversight. 
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Safety Training and Communication 

4 AAS currently provides mandated training programs required by CFR Part 139, as well as 

training in ramp safety, aircraft fueling, aircraft marshalling and the use of aircraft ground 

support equipment. 

4 Gaps include: 

o SMS training. 

o Formal training program manuals. 

o Aviation safety promotional programs. 

Subsequent project tasks will develop the SMS based on the gaps identified. 
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I. INTRODUCTION 

Background 

In February 2007 the FAA issued Advisory Circular, AC 150/5200-37, Introduction to Safety 

Management Systems (SMS) for Airport Operators, to introduce the concepts of SMS. The FAA has 

also opened a rulemaking project to consider formal requirements for SMS at certified airports. In 

support of this rulemaking effort, the FAA has initiated a pilot program to assist airports in the 

development of an SMS specific to their situation and operations, and to share their acquired 

experience on SMS development and implementation with other airports and the FAA. 

Alliance Air Services (AAS) has decided to take a leadership role in the development and 

implementation of SMS at the Fort Worth Alliance Airport (AFW) by participating in the FAA pilot 

program. 

As part of the pilot program, AAS has retained the services of Jacobs Engineering Group Inc.

(Jacobs), to provide consulting services for the development of a Safety Management System 

(SMS) Program. 

Objectives 

The specific objectives and deliverables of the SMS development project include: 

1. A Gap Analysis: The gap analysis will identify procedures, policies, documentation, and actions 

that need to be developed as part of an SMS. 

2. A Draft Plan: A draft of the complete SMS Manual and Program Plan. 

3. The Final Plan: The final copy of SMS Manual and Program Plan ready for implementation by 

AAS. 

4. Training of AAS employees in SMS and Safety Risk management (SRM). 

This report addresses the Gap Analysis. Subsequent project tasks will develop the SMS for AFW 

and document it in an SMS Manual and Program Plan. 

The Gap Analysis addresses what needs to be developed and implemented beyond the 

requirements of current Part 139. Our analysis was not an audit of existing AFW policies and 

procedures as to their adequacy, completeness or compliance with Part 139 requirements. This is 

the subject of detailed FAA certification audits which is well beyond the scope of this project. 

Methodology 

Jacobs prepared the Gap Analysis based on: 

4 Relevant FAA documentation including: 

• Advisory Circular, AC 150/5200-37, February 2007 
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• The Draft Statement of Work (SOW) for the SMS Airport Pilot Study (Appendix A) 

4 Relevant AFW and City of Fort Worth documentation; 

4 Selected interviews with AAS managers and supervisors; 

4 Selected interviews with the City of Fort Worth ARFF stationed at AFW; 

4 Guidelines regarding SMS from the International Civil Aviation Organization (ICAO) and other 

international organizations; and 

4 The consulting team’s experience with the preparation of SMS for other airports. 

Operations at AFW 

The Fort Worth Alliance Airport (AFW) is owned by the City of Fort Worth and is operated by 

Alliance Air Services. The President of AAS provides the role of an Airport Manager/Director. AFW 

holds a FAR Part 139, class IV Airport Operating Certificate along with an Airport Rescue and Fire 

Fighting (ARFF), Index rating of “E”. The FAA Airport Traffic Control Tower (ATCT) that provides 

air traffic control services 24 hours per day, 7 days per week, and 365 days per year. AAS in 

addition to operating the airport also provides Fixed Base Operations (FBO) serving corporate 

aviation, the military and general aviation. Major tenants at the airport include: FedEx Southwest 

Regional Sort Hub, Bell Helicopter/Textron and an American Airlines maintenance facility. 

AFW is located approximately 18 miles north of the central business district of Fort Worth. The 

airport has two parallel runways: 

1. Runway 16L/34R 9600 x 150 feet 

2. Runway 16R/34L 8220 x 150 feet 

In 2007, there were a total of 82,251 operations at the Alliance Airport, which is an average of 

about 264 operations per day. 

Structure of the Gap Analysis 

The Gap Analysis is structured to address the four core elements (pillars) of an SMS, as outlined in 

the FAA’s Advisory Circular. Additionally, Jacobs has added a separate element for Safety 

Organization which the Advisory Circular described under Safety Policy and Objectives. Jacobs 

believes that this structure is important to emphasize the equal importance of a proper organization 

structure as well as the policy & objectives, rather than a sub-set of the policies and objectives. In 

previous FAA pilot projects that we conducted, the FAA SMS Program Office agreed to this 

structure. 

1. Safety Policies and Objectives 

2. Safety Organization 

3. Safety Risk Management 
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4. Safety Assurance 

5. Safety Promotion 

Under each of these five core elements, the Gap Analysis addresses the FAA’s detailed SMS 

Program content outlined in the FAA Advisory Circular, AC 150/5200-37, and the FAA Draft 

Statement of Work (Appendix A). 

More specifically for each element, the Gap Analysis: 

1. Summarizes the FAA’s SMS guidance documentation, international guidance material where 

appropriate and Jacobs Engineering Team’s SMS experience; 

2. Describes what systems, policies and practices exist at AFW; and then 

3. Identifies procedures, policies, objectives, organizational issues and documentation (i.e., Gaps) 

that need to be developed for SMS and how they will be addressed in the subsequent tasks to 

develop the SMS Manual and Safety Program Plan. 

Intent of SMS 

The intent of SMS is to improve aviation safety. The elimination of aviation accidents is a desirable 

goal. However, no human activity or human-made system can be guaranteed to be absolutely safe. 

Failures and errors will occur, in spite of best efforts to avoid them. Although major air disasters are 

rare events, less catastrophic accidents and a whole range of incidents occur more frequently. 

Ignoring these underlying safety hazards could potentially pave the way for an increase in the 

number of more serious accidents. 

The air transportation industry’s future viability may well be predicated on its ability to sustain the 

public’s perceived safety while traveling. The management of safety is therefore a prerequisite for a 

sustainable aviation business. 

The accident rate in the air transport industry has decreased dramatically between the early 60’s 

and the mid 80’s from 30 to near 2 per million departures. It could be easily argued that this rate 

was achieved from continuing efforts by the industry to make air travel a safe mode of 

transportation. Figure 1 – Traffic Growth/Accident Rate1

, illustrates, between the mid eighties and 

now, we find an 80% increase in air traffic and a 73% increase in the number of accidents. Although 

the accident rate per million departures remains steady at 2, air travel safety as perceived by the 

public is likely to decline if traffic growth and accident rate per million departures remain the same. 

Air travel related accidents make instant worldwide news and there will be more and more reports 

even while maintaining a relatively low accident rate. Safety management, when well in place within 

the industry will be a key factor in further reducing the accident rate and achieving actual and 

perceived improvement in aviation safety. 

 

1 Source: Jacobs Consultancy for illustrative purposes
Figure 1 - Traffic Growth/Accident Rate 

Some recent statistics from the International Air Transport Association (IATA) for 2008 provide 

further rationale for the implementation of a SMS program: 

4 More than 500 people died in air crashes on Western-built jets in 2008 and safety lapses at 

airlines contributed to nearly a third of accidents, according to International Air Transport 

Association (IATA) 

4 The industry-wide accident rate, measured in hull losses per million flights, was 0.81, or one 

accident every 1.2 million flights. This compared with 0.75 in 2007. 

4 "Runway excursions", when an aircraft left the runway on take-off or landing, accounted for onequarter of accidents, and ground damage was reported in another 17 percent. 

4 There was an estimated $4 billion worth of damage to aircraft and equipment on the ground. 

4 Thirty percent of the accidents had "deficient safety management at the airline level as a 

contributing factor", according to IATA which represents 230 carriers including British Airways, 

Cathay Pacific and United Airlines. 

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II. SAFETY POLICIES AND OBJECTIVES 

Key Features 

The FAA SOW for SMS states that Safety Policies and Objectives should include: 

4 A written safety policy statement(s) and a description of how it is communicated to airport 

employees; and 

4 Identification and description of the airport safety goals. 

The FAA Advisory Circular under Safety Policy indicates that management’s commitment to safety 

should be formally expressed in a statement of safety policy that reflects the airport’s safety 

philosophy and that is signed by Top Management. 

Key attributes of the policy could also include the following: 

4 The commitment of senior management to implement SMS; 

4 The airport’s intentions, management principles and commitment to continuous improvement to 

safety at the airport; 

4 Communication of the policy to all employees; 

4 Implementation of the policy at all levels of the airport; 

4 Confirms that safety is everyone’s responsibility; and 

4 Recognizes that there will always be threats to safety and that the airport will provide the 

highest reasonable standard of safety. The Advisory Circular refers to a commitment to make 

safety the highest priority which may have a different meaning. 

The Advisory Circular under Safety Objectives (Section 2.2.2) does not address objectives but 

deals with the organization for safety. The Advisory Circular does refer to safety performance 

indicators and targets under Safety Assurance (Section 2.4). 

SMS guidelines, including the FAA Advisory Circular, give very little practical advice on safety goals 

or objectives. The terms “goals” and “objectives”, as well as “targets” are frequently used 

interchangeably. The intent in the guidelines; nonetheless, is to have measurable indicators of 

safety. 

Existing Policies and Objectives 

AAS does not currently have a written safety policy endorsed by the AAS President (Top 

Management) to indicate their commitment to aviation safety which is a key element of an SMS 

program. 
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Gaps and Development Required 

Safety Policies 

The SMS project will develop and document an aviation safety statement and set of safety policies 

that should be adopted by AAS, the contract operator of AFW for the City of Fort Worth. 

The adoption of a safety policy statement is the fundamental approach to managing safety that is to 

be adopted within the organization. Furthermore, the AFW Safety Policy would define the 

organization’s commitment to safety and overall safety vision, and empower the organization to 

fulfill the values and commitments of top management. 

Safety Objectives 

Safety objectives are required to allow for assessment of safety performance and developments at 

the airport. Safety objectives should be linked to factors such as: 

4 Safety hazards identified during inspections; e.g., type and quantity of FOD (Note: the airport’s 

self-inspection program captures this information but does not systematically monitor trends in 

this information); 

4 Airside safety violations; 

4 Aircraft bird strikes; 

4 Incursions of vehicles, aircraft, or pedestrians on movement areas; 

4 Accidents and incidents on the AOA and/or the controlled movement area involving air carrier 

aircraft and/or ground vehicles; 

4 Operable time of lighting systems; 

4 Number of AAS employees who have received safety and SMS related training; 

4 Non-punitive safety reports; and 

4 Implementation of the SMS. 

The safety objectives will need to be included in the AAS President’s statement of policy and 

objectives and then communicated to all of the organization. They should be no different from other 

organizational objectives in that they should be: 

4 Specific and measurable; 

4 Achievable and challenging; and 

4 Realized within a specific time frame. 
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More specific safety objectives applicable to AFW will be developed during subsequent tasks of the 

SMS pilot project. Emphasis will be placed on developing meaningful objectives that can 

realistically be measured by AAS. 
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III. SAFETY ORGANIZATION 

Key Features 

The FAA SOW for SMS describes the following requirement related to the safety organization. 

4 An organizational chart identifying the names and safety responsibilities of all key personnel, 

such as the following: 

o Top Management 

o Safety Manager 

o Department Heads/Managers 

o Established Safety Committees and Chairpersons 

The Advisory Circular provides considerable guidance on how an airport should be organized for 

safety. The key features described in the Advisory Circular are as follows: 

4 SMS requires that Top Management in the organization (also referred to in the Advisory Circular 

as Senior Management), one with the authority to adequately control resources, be assigned 

SMS responsibilities. 

4 Defined safety authorities and responsibilities for all key personnel that are assigned to the 

airport. 

4 Identification within the airport of someone responsible for administration of the overall SMS. 

This person reports to the highest level of management to assure appropriate consideration of 

all reports, recommendations, and issues. 

4 At many airports, operations may support the Safety Manager being a full-time permanent 

employee and in some cases having a support staff. At smaller airports, the size of the airport 

may not support a full time Safety Manager. 

4 The responsibilities of the Safety Manager are clearly defined along with identified lines of 

communication within the organization. 

4 Depending on the size and complexity of the airport’s operation, it may be useful to establish an 

Airport Safety Committee (ASC). 

The SMS should also address how, and to what extent, tenants at the airport such as air carriers 

are integrated into the airport SMS. At AFW, AAS acts as an FBO providing fueling and ground 

support services. ICAO has made very strong reference to the inclusion of tenants at an airport. 

ICAO’s Safety Management Manual, Doc 9859 A/460, First Edition – 2006, chapter 18, – 

AERODROME OPERATIONS, states that: 

Subsection 18.3.1 

Within the framework of an aerodrome SMS, the aerodrome management must oversee the 

activities of all the service providers, tenants, contractors and others to ensure the safest 

and most efficient performance of the aerodrome. 
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Subsection 18.3.8 

Given the complexity of the factors creating risk potential at aerodromes, the aerodrome 

management must coordinate the activities of the diverse stakeholders at an aerodrome – 

often with conflicting expectations and priorities. The sharing of a common focus among the 

stakeholders, most of whom are employees of agencies other than the aerodrome authority, 

needs to be fostered. In addition, resource commitments from the airlines and other service 

providers must be obtained. 

The FAA Circular does not address this organizational requirement to any extent. Tenants and Air 

Traffic Control may be major contributors to accidents at an airport and if they are not integrated 

into the airport’s SMS, then the SMS may not be very effective. Yet at the same time, the airport 

does not have direct accountability for tenant or Air Traffic Control operations. There are number of 

means that these stakeholders could be included or participate in the airport SMS including: 

4 The City of Fort Worth’s Rules and Regulation dealing with activities at the airport; 

4 The airport’s self inspection program; 

4 Participation in Safety Committees; 

4 Safety audits; and 

4 New and revised airport tenant use and lease agreements. 

Existing Policies, Practices and Systems 

The organizational structure for AFW is depicted in Figure 2 - AFW Organization Structure. The key 

positions that have a direct impact on aviation safety at AFW include: 

4 Airport President 

4 Operations & Safety Manager 

4 Service Coordinator 

4 Lead Operations Specialists (2) 

4 Operations Specialists (4) 

4 Airfield Maintenance Technician 

4 Airfield Electrical Technician 

4 Airport Firefighting and Rescue (ARFF) 
There are job descriptions in place for these positions which have been summarized below to 

highlight where responsibilities and duties have a direct impact on aviation safety. These 

descriptions given below also include the results of interviews with AAS managers and supervisors. 

Figure 2 - AFW Organization Structure 

Airport President:

The Airport President has overall safety responsibility for operations at AFW. The Airport President 

also has an overall safety consultation, facilitation and monitoring role for Alliance Airport’s business 

partners, suppliers and service providers. 

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The Airport President’s key areas of responsibility include the following: 

4 Establish, approve, and implement the AFW Safety Policy and Safety Management System 

(SMS) manual. 

4 Take a leadership role in the airport’s safety management system program. 

4 Ensure the annual business plan (i.e. including the capital program) is sufficiently addresses 

compliance with AAS safety policies and management system. 

4 Appoint safety conscious direct reports, monitor their performance and ensure that safety is 

given a reasonable priority within their training and development plans. 

4 Ensure that full consideration is given to the integrity of changes in the airport’s organization 

structure and business processes as it relates to safety. 

4 Clearly define safety performance, accountability, and responsibility for all staff. 

4 Ensure policies, standards and procedures are established in a manner that contributes to the 

success of the airport’s SMS. 

Operations & Safety Manager:

The Operations & Safety Manager is accountable to the Airport President for administrating AFW 

SMS strategy and compliance processes. 

The Operations & Safety Manager key areas of responsibility include the following: 

4 Provide a leadership role in the Airport’s SMS program. 

4 Champion safety at all AFW meetings. 

4 Define meaningful, measureable, and obtainable safety performance indicators and the 

processes to track them. 

4 Ensure that operations and maintenance standards, procedures and practices contribute to the 

success of AFW’s Safety Policy and Safety Management System. 

4 Hire safety conscious employees, monitor safety performance, and ensure safety is given a 

reasonable priority within their training and development plans. 

4 Incorporate system safety during all maintenance and construction projects. 

4 Issues Notice to Airmen (NOTAM) and closes or restricts portions of the Airport as required. 

4 Ensure compliance with all safety related legislation applicable to the management of the airport 

and facilities. 

Service Coordinator

The Service Coordinator position is accountable to the Operations & Safety Manager for deploying, 

monitoring, and reporting on the organization’s overall SMS strategy and compliance process. 

The Service Coordinator key areas of responsibility include the following: 

4 Monitors the activities and performance of, and has oversight responsibility of the Operations 

Leads and Specialists 

4 Track, maintain records of and report on established safety performance indicators. 

4 Perform internal audits of safety assurance processes, records, and related programs 

4 Participate with the Airport’s Safety Management System including emergency planning and coordinate resources during emergency incidents, aircraft recovery operations, adverse weather 

conditions, equipment service issues and unscheduled movements. 

4 Apprise AAS management of all operational and programmatic matters that may influence or 

impact their areas of control. 
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4 Maintain and develop constructive relationships with all stakeholders in the safe and efficient 

operation of the airfield. 

4 Follow “best practice” operational standards and procedures. 

Lead Operations Specialist

The Lead Operations Specialist positions are accountable to the Service Coordinator for monitoring, 

inspecting, and reporting on the organization’s SMS strategy and compliance process. The Lead 

Operations Specialist is responsible for maintaining a safe and efficient operating environment at 

the Airport. 

The Lead Operations Specialist key areas of responsibility include the following: 

4 Perform inspections and monitor all airfield activities to ensure compliance with AOA safety, 

maintenance, and construction rules and regulations. 

4 Monitor the performance of the Operations Specialists on an assigned shift, and assist with 

duties and assignments as may be necessary to ensure a safe and efficient operation. 

4 Report to the Service Coordinator on documented safety performance indicators. 

4 Participate with the Airport’s Safety Management System including emergency planning; and 

co-ordinate resources during emergency incidents, aircraft recovery operations, adverse 

weather conditions, equipment service issues and unscheduled movements. 

4 Apprise management of all operational matters that may influence or impact their areas of 

control. 

4 Performs safety inspections of the airport in accordance with established policies and 

procedures. 

4 Maintain and develop constructive relationships with all stakeholders in the safe and efficient 

operation of the airfield. 

4 Follow “best practice” operational standards and procedures. 

4 Ensure the safe throughput of aircraft movements by liaising with the FAA Airport Traffic Control 

Tower, tenants, airport fire/rescue, especially when affected by adverse weather conditions, 

incidents, emergencies or other disruptions. 

Operations Specialist

The Operations Specialist positions are accountable to the Service Coordinator for monitoring, 

inspecting, and reporting on the organization’s SMS strategy and compliance process. The 

Operations Specialist is responsible for maintaining a safe and efficient operating environment at 

the Airport. 

The Operations Specialist key areas of responsibility include the following: 

4 Ensure compliance with established AOA safety, maintenance, and construction rules and 

regulations for AFW. 

4 Performs safety inspections of the airport in accordance with established policies and 

procedures. 

4 Report to the Lead Operations Specialists on documentation of safety performance indicators. 

4 Participate with the Airport’s Safety Management System including emergency planning; and 

co-ordinate resources during emergency incidents, aircraft recovery operations, adverse 

weather conditions, equipment service issues and unscheduled movements. 

4 Apprise management of all operational matters that may influence or impact their areas of 

control. 
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4 Maintain and develop constructive relationships with all stakeholders in the safe and efficient 

operation of the airfield. 

4 Follow “best practice” operational standards and procedures. 

4 Ensure the safe throughput of aircraft movements by liaising with the Airport Traffic Control 

Tower, tenants, airport rescue and fire fighting, especially when affected by adverse weather 

conditions, incidents, emergencies or other disruptions. 

Airfield Maintenance Technician

The Airfield Maintenance Technician is accountable to the Service Coordinator for the repair of 

airfield components, equipment, and assets. 

Airfield Electrical Technician

The Airfield Electrical Technician is accountable to the Service Coordinator for the repair of airfield 

electrical components, equipment, and assets. 

(NOTE: Alliance Air Services positions and safety responsibilities are subject to change without notice.) 

ARFF Services 

The City of Fort Worth Fire Department (COFWFD) is responsible for providing ARFF services at 

the airport. In addition, COFEFD provides the training and operations at the Airport, in accordance 

with CFR Part 139. The Airport has been designated as an Index “E” for ARFF services. The Fort 

Worth Fire Department Captain and two Lieutenants (who are ARFF certified) are assigned to the 

ARFF station at the airport. One Officer and at least three ARFF certified Firefighters are assigned 

to each shift. ARFF is also responsible for conducting and documenting inspections of fuel 

farm/storage and mobile fuelers every three months. 

Airport Committees 

AAS currently does not have formalized meetings with airport tenants or employees that focus on 

aviation safety other than for special events such as air shows. 

Gaps and Development Required 

AAS does not have roles and responsibilities defined or documented specifically for safety at AFW. 

As detailed above, AAS does, of course, have positions with responsibilities that have a direct 

impact on the safety of aviation operations. 

Considering the size of AFW, particularly in terms of staff members, the Airport President should be 

the senior manager responsible for SMS. This position has the authority to control resources within 

the mandates set out by the City of Fort Worth to manage and operate AFW. 

At this stage of developing the SMS, Jacobs recommends that the responsibilities of the Airport 

President for SMS would include: 
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4 Overall safety responsibility for operations 

4 Establish, approve, and implement SMS for AFW; 

4 Approval of safety policy, goals and objectives; 

4 Periodic reviews and updates of the SMS, safety policy and goals for AFW; and 

4 Deploying financial and human resources, within their control, for proper execution of the SMS. 

4 Co-Chair Airport Safety Committee 

SMS development will need to: 

1. Confirm that the Operations & Safety Manager will be responsible for administering the SMS. 

The responsibilities for this position would include: 

4 Serve as vice-chair to the Airport Safety Committee; 

4 Leading safety risk management analysis & assessments of hazards, incidents and 

accidents to determine the precursors (cause) and required actions; 

4 Conducting trend analysis of safety concerns, hazards, incidents and accidents and 

determining action required, in consultation with other airport staff; 

4 Ensuring appropriate action is taken in response to safety concerns, hazards, incidents and 

accidents; 

4 Keeping records of all safety related reports, incidents and accidents, and conducting trend 

analysis; 

4 Providing and coordinating safety promotion; 

4 Ensuring the provision of safety training for airport employees and tenants located or 

working in the AOA; 

4 Implementing a non-punitive reporting system; 

4 Ensuring that safety audits are conducted when required; 

4 Measuring safety performance in relation to safety objectives; and 

4 Annual review and revisions (as required) of the safety policy and safety objectives. 
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2. Describe the composition and role of the Airport Safety Committee (or Airport Safety Council) in 

addressing aviation safety issues. 

3. Define how tenants would be integrated into the SMS. For example, participation in the Airport 

Safety Committee, audits of tenant safety plans or programs. 

In consultation with AAS managers, Jacobs will develop the organization structure for safety and 

will define safety responsibilities for key organizational positions at AFW. 
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IV. SAFETY RISK MANAGEMENT 

Key Features 

The FAA Scope of Work (SOW) for SMS describes the following requirements related to Safety 

Risk Management (SRM). 

4 Description of the safety risk management process, including application of “The Five Phases of 

Safety Risk Management”, as discussed in AC 150/5200-37; 

4 Guidance on the use of SRM and trend analysis; 

4 Defined process for documenting the results of SRM, including a description of how documents 

will be stored, i.e., electronic or paper; and 

4 Descriptions of how top management will follow up on SRM to ensure safety mitigation 

strategies are appropriate. 

The FAA’s Advisory Circular indicates that safety risk management is a fundamental component of 

SMS. The principal steps in the safety risk management (SRM) process include: identification of a 

potential hazard, analysis of the risk, evaluation of the risk and development of an action plan to 

mitigate the risk if necessary. 

The Advisory Circular goes on to say that SRM hazard identification stage should consider all the 

possible sources system failures of the system (i.e. operations, equipment, people, and 

procedures). Possible sources of system failure could include: 

4 Equipment (example: construction equipment on a movement surface); 

4 Operating environment (example: cold, night, low visibility); 

4 Human element (example: shift work); 

4 Operational procedures (example: staffing levels); 

4 Maintenance procedures (example: nightly movement area inspections by airport electricians); 

and 

4 External services (example: ramp traffic by Fixed-Base Operator (FBO) or law enforcement 

vehicles). 

Existing Practices and Systems 

Although AAS informally considers many elements of SRM in management decisions, AAS 

currently does not have a formal Safety Risk Management process for aviation safety. 
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Gaps and Development Required 

The Safety Risk Management (SRM) process will need to be developed and documented during 

subsequent project tasks. 

Jacobs will develop a practical approach to SRM appropriate to the size of AFW that will be 

qualitative in nature and understandable by AAS management and employees. For example, 

Jacobs will develop simple paper-based forms for conducting a safety risk assessment and a 

simplified risk evaluation matrix for summarizing the results of an assessment. Jacobs will provide 

training in SRM to AAS managers and employees at the end of the SMS development project. 
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V. SAFETY ASSURANCE 

Key Features 

The FAA SOW for SMS describes the following requirements related to safety assurance: 

4 A plan and description of employee non-punitive reporting systems, existing and planned. 

4 A description of the airport quality management and/or risk management program (if applicable) 

and its integration into the airport SMS. 

4 Description of a plan to integrate apron safety management into the airport SMS. (The FAA’s 

review of the plan will be limited to measures for preventing accidents or incidents involving 

aircraft.) The plan could include the following: 

a. Description of current apron safety management practices, such as reporting requirements 

to the National Transportation Safety Board (NTSB), Flight Standards, or the Occupational 

Safety Health Administration (OSHA). 

b. An explanation of how current apron safety management practices meet the intent of SMS. 

This could include the safety plans and practices of tenants and operators at the airport, 

which should complement the airport SMS. 

4 A detailed method to document self-auditing processes and their findings. Self-auditing may be 

part of the airport self-inspection process. If it is, explain how the self-inspection process 

addresses systems safety, i.e. if the self-inspection program identifies a hazard on the airport 

the process should document the process utilized to determine, assess & analyze the risk, 

develop mitigation and follow-up to ensure the effectiveness of the mitigation. 

4 A detailed method to document self-inspection reviews, analysis, and findings. 

4 Process to document and review lessons learned from within the organization. 

The Advisory Circular states that safety assurance includes self-auditing, external auditing and 

safety oversight. According to the Advisory Circular safety oversight can be achieved through 

auditing and surveillance practices. 

The Advisory Circular also says that in addition to the airport operator’s existing responsibilities for 

self-inspection and correction of discrepancies in accordance with 14 CFR Part 139, an effective 

airport SMS audit program should: 

4 Develop identified safety performance indicators and targets; 

4 Monitor adherence to safety policy through self-auditing; 

4 Allocate adequate resources for safety oversight; 

4 Solicit input through a non-punitive safety reporting system; 

4 Systematically review all available feedback from daily self-inspections, assessments, reports, 
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safety risk analysis, and safety audits; 

4 Communicate findings to staff and implement agreed-upon mitigation strategies (NOTE: 14 CFR 

Part 139 already requires this for actions covered by that regulation); and 

4 Promote integration of a systems approach to safety into the overall operation of the airport. 

The Advisory Circular also provides further guidance on non-punitive safety reporting, self-auditing 

and safety performance monitoring. This guidance material is provided below and generally follows 

international SMS guidance material. 

4 “The SMS should include a visible non-punitive safety reporting system supported by 

management. The safety reporting system should permit feedback from personnel regarding 

hazards and safety-related concerns. The SMS should use this information to identify and 

address safety deficiencies. The safety reporting system may also identify and correct nonconformance to safety policy.” 

4 “Safety auditing is a core safety management activity. Similar to financial audits, safety audits 

provide a means for systematically assessing how well the organization is meeting its safety 

objectives. Top (senior) management may choose to have an external agency audit the system 

(e.g., by a consultant or another airport operator). The safety audit, together with other safety 

oversight activities, provides feedback to managers concerning the overall safety performance 

of the organization.” 

4 “Safety performance monitoring validates the SMS, confirming the organization’s safety 

objectives. Through regular review and evaluation, management can pursue continuous 

improvements in safety management and may revise safety objectives to ensure that the SMS 

remains effective and relevant to the organization’s operation.” 

Existing Practices and Systems 

Airport Self-Inspection Program 

AAS has established a self-inspection program in accordance with the requirements of CFR Part 

139 and the Airport Certification Manual (ACM.) The reporting system requires Operations 

Specialist to complete daily Airfield Inspection Reports (Appendix B) and Airfield Lighting Inspection

Reports (Appendix B) in order to document Part 139 discrepancies that are found during the 

inspections. 

The Part 139 elements that are to be inspected daily include: paved areas, safety areas, marking 

and signs, navigational aids, fueling operations, any construction, wildlife hazards, and generator 

fuel levels. 

Inspections by AAS personnel are conducted as follows: 

4 Daily daytime and nighttime inspections (see Appendix B for forms used); 

4 During low-visibility (SMGCS) conditions; 

4 During and after construction or maintenance activity; 
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4 During and after storms, high winds freezing precipitation, and other major meteorological 

events; 

4 Immediately after an incident or accident. 

According to the ACM as part of the self-inspection program, the City of Fort Worth Airport Rescue 

and Firefighting (ARFF) Section is responsible for conducting quarterly inspections of fuel 

farm/storage and mobile fuelers using a Fuel Farm Fire Safety Inspection Report Form (see 

Appendix D). The Lead Operations Specialists and/or Operations Specialists conduct daily 

inspections of fueling facilities and equipment. 

Conditions that could affect air carrier operations are disseminated to the air carriers via NOTAMs. 

Airspace and Obstruction Management 

AFW is like many airports with frequent development and maintenance projects. AAS personnel 

appear to understand the basic concepts and requirements of FAR Part 77, Objections Affecting 

Navigable Airspace. AAS personnel are required, under Part 139, to manage & mitigate 

obstructions along with ensuring protection of their airspace. AAS personnel are not always 

actively involved in the planning or airspace process to ensure the safety of the process is met. 

FAA Airspace Determination Letters provided to AAS are not fully understood in their aeronautical 

mitigation requirements, the process to activate those requirements, stakeholder coordination and 

active management during the mitigation period. 

Apron Safety 

Aircraft movement on the apron is under the control of AAS personnel as part of the company’s 

Fixed Base Operations (FBO) services. Personnel responsible for the handling and marshalling of 

aircraft receive training through the use of on-the-job demonstrations and observed performance, 

verbal instructions, and written guidance. The appearance of ramp operations and the cleanliness 

of the facilities and ramp give the impression that aircraft handling safety and FOD management is 

a high priority for all AAS employees. 

Other leased tenant ramps and facilities do not fall within the direct purview of AAS, and as such 

are not inspected by them. 

The City of Fort Worth does have “Rules and Regulations” governing airports and aircraft. Article V 

of these Rules and Regulations address the operation of vehicles and aircraft on the Airport. 

Wildlife Management 

The ACM addresses wildlife control in Article 4, Section 4.05, Wildlife Hazardous Management. 

This section outlines guidance and reporting requirements if any event occurs on or near an airport 

where an aircraft experiences a bird strike, or where wildlife populations are noted in numbers 

capable of causing an aircraft strike. 

AAS Operations Specialists provide harassment of hazardous wildlife in accordance with CFR Part 

139.337 to discourage the presence of animals on and near runways and taxiways. Monitoring 
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hazardous wildlife by Operations staff is accomplished through the self-inspection program. 

When a wildlife strike occurs on the airport, Operations personnel are required to complete an 

online bird strike report (FAA Form 5200-7 (Electronic), Revised 7-14-2008). Where an avian 

species can not be identified, AAS will send remains to the Feather Identification Lab, c/o 

Smithsonian Institution for proper identification. 

Currently, AAS has no Wildlife Control or Management Plan or formal training program for 

personnel who are responsible for the control of wildlife on the Airport (NOTE: Class IV airports are 

not required to have such a plan in accordance with Part 139). 

Gaps and Development Required 

AAS has a self-inspection program in place. Self-inspection deals primarily with ensuring 

compliance with detailed FAA standards but can form a key component of safety assurance; for 

example, trend analysis of reported deficiencies. 

Gaps that will require development to meet the FAA’s detailed SMS guidance material referred to 

previously include: 

4 Creating safety related performance benchmarks; 

4 Non-punitive safety reporting; 

4 Systematic reviews of feedback from self-inspection, assessments, reports, safety risk analysis 

and audits which will allow the monitoring of adherence to safety policy and the monitoring of 

safety performance indicators related to safety objectives; 

4 Auditing for safety, performance, and compliance; and 

4 Safety oversight which Jacobs would define as regular Top (Senior) Management reviews and 

evaluations of the implementation of safety policies, progress to meeting safety objectives and 

lessons learned as means to continuous improvements in safety management. 

The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from 

personnel regarding hazards and safety-related concerns. However, if it is to apply only to hazards 

and safety-related concerns, then Jacobs question why does it need to be non-punitive? Jacobs’ 

understanding is that a non-punitive system is a way to safeguard employees from disciplinary 

action when reporting incidents and accidents in which they are directly or indirectly involved. 

Deliberate or unlawful actions are excluded of course. This is consistent with a systematic, explicit, 

and comprehensive approach for managing safety risk (AC, Paragraph 3). Jacobs has discussed 

this issue with FAA and have concluded that incidents and accidents should be included. 

The development of the non-punitive reporting system should also consider whether tenant 

employees should be part of this system, or whether the system should be limited to AAS 

employees. Jacobs has discussed this issue with the FAA and they have indicated that each airport 

is unique and should set up practices particular to their airport. 
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VI. SAFETY PROMOTION - TRAINING 

Key Features 

The FAA SOW for SMS describes the following requirements related to safety promotion, and 

training specifically. 

4 A plan for employee SMS indoctrination and training. SMS indoctrination training should provide 

an outline of proposed curriculum and resources. 

4 Documented process to identify training requirements for systems safety. 

4 A plan to validate training effectiveness and the process to gain training feedback, including 

useable metrics. 

The Advisory Circular in addition to the above states that training and education should include: 

4 Initial (general safety) job-specific training; 

4 Recurrent safety training; 

4 Training that includes human factors and organizational factors ; and 

4 A training file for each employee to identify and track employee training requirements and verify 

that the personnel have received the planned training. 

Existing Policies, Practices and Systems 

Existing training programs at AFW include: 

4 Pedestrians and vehicles on the AOA; 

4 Airport familiarization and Part 139; 

4 New employee training; 

4 Ramp safety; and 

4 ARFF. 

Pedestrians and Vehicles on the AOA 

AAS’s training material consists of a document entitled, “Vehicle Operating Procedures”. This 

document, dated March, 2004, is augmented by “An FAA Guide, Airport Ground Vehicle 

Operations” which deals with airport markings and signage, and communications with the tower. 

Although these training documents meet the intent of Part 139, it could be augmented and 

improved by training material, especially audio-visual, available from the American Association of 

Airport Executives (AAAE). The training material could also be improved by using pictures of actual 

signage and markings at AFW. Jacobs also noted that the FAA Guide on Airport Ground Vehicle 
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Operations, dated 1990, is not the latest publication available. The latest guide is available 

electronically from the FAA at the following address; 

http://www.faa.gov/airports_airtraffic/airports/airport_safety/call_to_action/Airport Familiarization and Part 139

This training is accomplished annually in a classroom environment. Records are maintained in hard 

copy as part of personnel training records/files. The training is conducted by the Operations & 

Safety Manager. 

New Employee Training 

All AAS employees must successfully complete a series of classroom and on-the-job training before 

they are allowed to perform duties independent of direct supervision. The degree to which an 

employee is trained and the timeline they are given to complete the assigned training program 

depends on the individuals’ demonstrated level of experience and knowledge of the business. The 

Operations & Safety Manager has the final authority for certifying the competency of new 

employees. 

Ramp Safety Training 

AAS utilizes the National Air Transportation Association (NATA) “Safety First PLST Program” and 

Exxon Mobile Premier Care Safety online training modules. AAS alternates these training modules 

every other year. Operation’s personnel must complete all modules annually including passing 

tests for each module. There is a test and then a Practical Exercise/Applied Learning test 

administered by the Operations & Safety Manager. Training records for the course work are 

maintained online. The modules are available 24/7 for students & administrators. Modules include: 

1. Introduction and Ground Servicing 

2. Safety 

3. General Fuel Servicing 

4. General Towing Procedures 

5. Fuel Farm Management 

6. Customer Service 

7. Fire Safety 

8. Aviation Security 

Non-Operations personnel receive an abbreviated version of basic safety classes so that they are 

familiar with aviation operations topics. 
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ARFF Training 

The City of Fort Worth ARFF personnel receive instruction in accordance with AC 150/5210-17A, 

Programs for Training Aircraft and Fire Fighting Personnel, from certified ARFF Trainers. 

Gaps and Development Required 

With regard to SMS, given that there is no SMS in place, there is a gap in SMS requirements for 

SMS indoctrination and training. SMS training will be developed and provided during subsequent 

tasks of this project. More specifically the SMS will outline a plan for SMS indoctrination and annual 

refresher training to: 

4 Ensure everyone in the organization is involved in SMS and their participation in the training is 

tracked and documented. 

4 Incorporate SMS practices into everyday tasks in order to internalize SMS values and concepts. 

4 Airspace processes, management, operations and mitigation 
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VII. SAFETY PROMOTION - COMMUNICATIONS 

Key Features 

The FAA SOW for SMS describes the following requirements related to safety promotion, and 

specifically for communications: 

4 A defined process to communicate safety policies and objectives throughout the organization 

including examples of how information will be communicated and any processes for follow-up. 

4 Procedures to promote safety awareness and participation in non-punitive reporting systems. 

Documented plan for training and education, safety communication, competency, and 

continuous improvement processes. 

The Advisory Circular essentially reiterates the requirements above but also provides some 

examples including: 

4 Safety seminars; 

4 Safety letters, notices and bulletins; 

4 Safety lessons-learned; 

4 Bulletin boards, safety reporting drop boxes, and electronic reporting through web sites or email; 

4 A method to exchange safety-related information with other airport operators through regional 

offices or professional organizations; and 

4 In the future, voluntary posting of safety-related information on an existing FAA web-based 

safety reporting system currently being used by air operators. 

Existing Policies, Practices and Systems 

AAS informal safety promotion relies on required training. There is no formal policy for safety 

promotion beyond that. However, the purpose of this project is to introduce SMS concepts to the 

organization and provide a roadmap for them to incorporate SMS into their safety culture. 

Gaps and Development Required 

4 Development of the SMS will include an aviation safety promotion program. 

4 A documented process to identify training requirements 

4 A validation process that measures the effectiveness of training 
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4 Initial (general safety) job-specific training 

4 Recurrent safety training 

4 Indoctrination/initial training incorporating SMS 

4 Training that includes human factors and organizational factors 

4 Training that includes airspace analysis & management and obstruction management & 

mitigation 

4 Wildlife identification and management 
Gap Analysis 

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Appendix A 

Draft Statement of Work 

FAA SMS Airport Pilot Study 

Requirements for the Final Plan 

Gap Analysis A-1 

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DRAFT STATEMENT OF WORK 

FAA SMS AIRPORT PILOT STUDY 

1. OBJECTIVE 

The FAA is conducting a pilot program to evaluate the implementation of Safety Management 

Systems (SMS) at airports of varying size and complexity. The pilot program will allow airports 

and the FAA to gain experience establishing airport specific SMS that are tailored for the individual 

airport. This information will provide FAA information on SMS best practices and lessons learned 

that will be helpful as FAA considers development of a Notice of Proposed Rulemaking to 

incorporate SMS into 14 C.F.R. Part 139, Certification of Airports. 

2. BENEFITS ANTICIPATED 

For airport operators, the application of a systematic, proactive, and well-defined safety program as 

is inherent in SMS allows an airport to continue to improve safety in the face of significant 

forecasted growth in air traffic activity. The use of SMS at airports can contribute to this effort by 

increasing the likelihood that Airport Operators will detect and correct safety problems before they 

result in an aircraft accident or incident. 

The FAA benefits from the opportunity to assimilate the experience of airport operators in 

developing an SMS for airports of widely varying activity levels and operational complexity. The 

FAA anticipates moving to a more formal requirement for the use of SMS at U.S. airports, 

consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at 

international airports. Experience gained through review of the SMS plans developed under this 

pilot program will be extremely useful in development of a general U.S. standard. 

3. APPROACH 

Because SMS is currently not a regulatory requirement in the U.S. at this time, the SMS Manual 

and program developed under the pilot program should remain separate from the Airport 

Certification Manual (ACM) required in 14 CFR Part 139. (FAA would need to approve any 

changes to the ACM itself). FAA Airport Certification Safety Inspectors may ask to review the 

airport’s SMS documents, but will not consider the SMS (or lack of an SMS) a factor in compliance 

with Part 139. 

The SMS Manual and program plan should not simply apply existing guidance that has been 

developed in other countries with their own safety oversight rules, or duplicate SMS plans of 

airports subject to those rules. Rather, the SMS Manual and plan should complement existing U.S. 

safety requirements in 14 C.F.R. Part 139, and be consistent with Part 139, FAA Advisory 

Circulars, and the Airport Certification Manual specific to the airport’s current operation. Therefore, 

the SMS Manual and program plan should address which elements of the airport operator’s existing 

practices and guidance materials currently meet SMS requirements, which elements do not, and 

how these practices and documents will be revised in the future for consistency with the SMS plan. 

4. DELIVERABLES 

The development of the SMS Manual and program should be completed 6 months after award of 

the AIP grant. To help FAA evaluate the SMS airport specific development process, copies of the 
 A-2 Gap Analysis 

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following documents must be provided to the FAA as they are completed. The FAA encourages 

sponsors and their consultants to refer other interim draft documents, questions, and comments to 

the FAA at any time in the process for consultation and information exchange. 

a. Gap Analysis 

The gap analysis should identify procedures, policies, documentation, and actions that the airport 

needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed 

by the airport’s ACM. 

Estimated completion date: 2 months from project start 

b. Draft Plan 

A draft of the complete SMS Manual and program. The draft should address the gap analysis and 

describe safety risk management, risk mitigation strategies, and documentation processes. 

Estimated completion date: 5 months from project start 

c. Final Plan 

A copy of the final SMS Manual and program to be implemented by the sponsor. 

Estimated completion date: 6 months from project start 

The contents and scope of the SMS Manual and Program plan should address the following: 

1) Written safety policy statement and description of how it is communicated to airport 

employees. 

2) Identification and description of the airport safety goals. 

3) A plan for employee SMS indoctrination and training. SMS indoctrination training should 

provide an outline of proposed curriculum and resources. 

4) Documented process to identify training requirements for systems safety. 

5) A plan to validate training effectiveness and the process to gain training feedback, including 

useable metrics. 

6) A defined process to communicate safety policies and objectives throughout the organization. 

Include examples of how information will be communicated and any processes for follow-up. 

7) A plan and description of employee non-punitive reporting systems, existing and new. 

8) An organizational chart identifying the names and safety responsibilities of all key personnel, 

such as the following: 

o Top Management 

o Safety Manager 

o Department Heads/Managers 

o Established Safety Committees and Chairpersons 

9) Description of the safety risk management process, including application of “The Five Phases 

of SRM,” as discussed in the FAA Advisory Circular 150/5200-37, Introduction to Safety 

Management Systems for Airport Operators. 

10) Guidance on the use of SRM and trend analysis. 
Gap Analysis A-3 

Alliance Fort Worth Airport 

11) Defined process for documenting the results of SRM to include a description of how 

documents will be stored, i.e., electronic or paper. 

12) Description of how top management will follow-up on SRM to ensure safety mitigation 

strategies are appropriate. 

13) A description of the airport quality management and/or risk management program (if 

applicable) and its integration into the Airport SMS. 

14) Description of a plan to integrate apron safety management into the Airport SMS. (FAA 

review of the plan will be limited to measures to prevent accidents or incidents involving 

aircraft.) The plan could include: 

a. A description of current apron safety management practices already in place such as 

reporting requirements to the NTSB, Flight Standards, or the Occupational Safety Health 

Administration (OSHA). 

b. An explanation of how current apron safety management practices meet the intent of 

SMS. This could include the safety plans and practices of tenants and operators at the 

airport, which should complement the airport SMS. 

15) A detailed method to document self-auditing processes and their findings. Self-auditing may 

be part of the airport self-inspection process. If it is, explain how the self-inspection process 

addresses systems safety, i.e. if the self-inspection program identifies a hazard on the airport 

it should determine the risk and document the process for follow-up. 

16) A detailed method to document self-inspection reviews, analysis, and findings. 

17) A description or plan to integrate the tailored SMS program plan into the overall operation of 

the airport. 

18) Documented plan for training and education, safety communication, competency, and 

continuous improvement processes. 

19) Procedures to promote safety awareness and participation in non-punitive reporting systems. 

20) Process to document and review lessons learned from within the organization. 

21) Schedule for implementation and anticipated associated costs. 

5. INFORMATION FURNISHED TO THE GOVERNMENT 

All documents submitted by a sponsor or its agent to the FAA for review under this grant remain the 

property of the sponsor. 

Final SMS documents and plans will be considered public information. Gap analyses, draft SMS 

manuals and plans, and other interim documents may be submitted with a request for 

confidentiality. The Freedom of Information Act requirements of 5 U.S.C. § 552, as amended, will 

apply to any such request. 

Gap Analysis 

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Appendix B 

Inspection Forms Used by AFW Operations Specialists

Gap Analysis B-1 

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 B-2 Gap Analysis 

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Gap Analysis 

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Appendix C 

Inspection Forms Used by ARFF 



Gap Analysis C-1 

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 C-2 Gap Analysis 

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