# Federal Aviation Administration

Airport Safety Management Systems (SMS)

Pilot Studies

May 2011

Prepared for:

Office of Airports

Federal Aviation Administration 800 Independence Ave SW Washington, DC 20591

Prepared by:

Innovative Solutions International 1201 Maryland Ave SW Suite 510 Washington, DC 20024FAA SMS Pilot Studies Technical Report May 2011 Page 2



## Table of Contents

Executive Summary..................................

................................................... ....................... 3

1. Why SMS ............................................

................................................... ..................... 4

2. Notice of Proposed SMS Rulemaking and Pilot Studies ............................................. 5

3. FAA SMS Airport Pilot Studies ......................

................................................... ......... 5

4. Technical Report on the Pilot Studies ..............

................................................... ........ 6

5. Summary Observations...............................

................................................... .............. 7 Appendix A: Airports Participating in the SMS Pilot Studies........................................... . 9 Appendix B: Interview Results/Workload Assessment b y Pilot Study Airports.............. 11 Appendix C: SMS Pilot Study Interview Comments ..... .................................................. 1 2



## List of Tables

Table 1 – Boeing Field, WA.........................

................................................... ................. 36 Table 2 – Concord Regional Airport, NC.............

................................................... ......... 38
Table 3 – Toledo, OH ...............................

................................................... ..................... 40 Table 4 – Cheyenne Regional Airport, WY............

................................................... ....... 42 Table 5 – Ohio State University, OH................

................................................... ............. 44 Table 6 – Austin-Bergstrom International, TX.......

................................................... ....... 46 Table 7 – San Antonio International Airport, TX....

................................................... ...... 47 Table 8 – Baltimore Washington International, MD ...

................................................... .. 49 Table 9 – Daytona Beach International, FL..........

................................................... ......... 51 Table 10 – Dubuque, IA.............................

................................................... .................... 52 Table 16 – Tallahassee Regional, FL................

................................................... ............. 64
Table 17 – Alliance Fort Worth, TX.................

................................................... ............. 67
Table 18 – Jackson, MS.............................

................................................... .................... 68
Table 19 – Teterboro, NJ ...........................

................................................... .................... 70
Table 20 – Atlanta, GA.............................

................................................... ..................... 72 Table 21 – North Las Vegas, NV.....................

................................................... .............. 76 Table 22 – Pittsburgh, PA..........................

................................................... .................... 78
Table 23 – South Bend, IN ..........................

................................................... .................. 81 Table 24 – Southern Illinois University, IL........

................................................... ........... 83 Table 25 – Talladega, AL ...........................

................................................... ................... 86FAA SMS Pilot Studies Technical Report May 2011 Page 3



## EXECUTIVE SUMMARY

The United States is a member state of the Internat ional Civil Aviation Organization (ICAO) and supported ICAO’s adoption of Safety Mana gement Systems (SMS) as a means of moving aviation to the next level of safet y. To promote SMS, ICAO amended Annex 14, Aerodromes, to require states to implemen t SMS at international airports.

SMS is a formalized process for collecting safety d ata, identifying hazards and trends, determining safety risk severity, and mitigating ri sk to an acceptable level. The FAA Office of Airports is implementing SMS within its i nternal organization. In addition, we initiated a rulemaking action to require commercial service airports certificated under 14 CFR Part 139 to implement SMS.

Starting in 2008, over 25 airport operators volunte ered to participate in SMS Pilot Studies. The majority of those participating recei ved federal-financial assistance through the Airport Improvement Program (AIP). These airpo rt operators experienced the challenges and benefits of developing and implement ing SMS at 14 CFR 139 airports. In spring 2011, as part of the rulemaking effort, the FAA formed a team to gather information from the ongoing Pilot Studies and prep are a Technical Report documenting the participating airports’ experiences and lessons learned. The team interviewed airport operators and analyzed the responses to make a numb er of observations.

Observations

Workload Impact: Pilot Study airports found the workload impact of SMS-related elements manageable. Although unable to make staff ing changes, many airports were still able to reasonably accommodate development of SMS guidance and implementation.

Gap Analysis: The airport operators found the Gap Analysis usefu l. It enabled the airport operators to identify those requirements of SMS tha t are not part of 14 CFR 139 compliance activities and showed them that many 14 CFR 139 activities (such as daily self-inspection, airport emergency plans, and notif ications) can serve as a foundation for the components and elements of SMS.

Benefits: Overall, airport operators benefitted from improve d communication and increased safety awareness.

SMS Guidance : In general, airport operators found the guidance was sufficient. They suggested we further clarify areas such as SMS deve lopment, support tools, and templates.FAA SMS Pilot Studies Technical Report May 2011 Page 4



## 1. Why SMS

In the early days of aviation safety, efforts were focused on the prevention of accidents. The principal means of prevention were increased re gulation and investigation of accidents to correct identified problems. Technolo gical advances in aircraft design and construction, improvements in engine reliability, a nd the development of airport infrastructure led to a decreasing accident rate. By the 1950s, commercial aviation (in terms of accidents) was one of the safest industrie s.

Accident investigation generated a number of safety recommendations. However, the recommendations placed little emphasis on the hazar dous conditions that, although present, were not identified as causal in the accid ent investigation. Accident investigation was quite good at identifying “what” happened and “who” did it, but it became clear that it was also important to identify “why” and “how” the accident

occurred.

The early 1970s saw the introduction of commercial jet aircraft, airborne and ground radar, autopilots, flight directors, and improved n avigation and communications. The safety focus started to shift to human factors and human performance. The development of crew resource management and training further im proved safety, but human performance remained a recurring factor in safety b reakdowns. By the mid-1990s,

human factors tended to focus on the individual and not on the operational context in

which individuals did their work.

Industry started to accept that human failures at t he operational level (active failures) can trigger conditions that help breach the system’s in herent safety defenses (latent failures). From the perspective of these organizational accide nts, safety is improved through organizational structure and processes that identif y latent failure conditions. Corrections or mitigations are implemented to reduce active fai lures and avoid accidents.

This understanding led to the development of Safety Management Systems. SMS is a integrated collection of processes and procedures t hat ensures a formalized and proactive approach to system safety through risk management. The table below identifies noteworthy comparisons between 14 CFR 139 and SMS:

14 CFR 139 SMS Formalized, rigid structure Formalized, dynamic str ucture Does not analyze new risk Analyzes new and existing risk Regulatory structure is a static-state

condition Management process is a dynamic, evolving condition Regulatory requirements are applicable to certain airports in certain conditions Scalable, flexible process is applicable to all airports in all conditionsFAA SMS Pilot Studies Technical Report May 2011 Page 5



## 2. Notice of Proposed SMS Rulemaking and Pilot Studies

The FAA initiated a rulemaking process to require c ertificated airports to implement SMS. In October 2010, FAA issued a Notice of Propo sed Rulemaking (NPRM) in the Federal Register. The NPRM proposed amending 14 CF R 139 to include a requirement for certificate holders to develop, implement, and maintain an SMS. The comment period for the NPRM has been extended twice and is now scheduled to end July 5, 2011. The FAA piloted SMS development at a number of cert ificated airports. The majority of participating airports received federal-financial a ssistance through the Airport Improvement Program. The Pilot Studies were intend ed to allow the FAA and individual airports to gather data and gain experience through onsite development and implementation of SMS.

The FAA intends to use the information from the Pil ot Studies to help with the review of comments to the SMS NPRM and to improve the guidanc e included in the SMS Advisory Circular. The information in this Technical Report may also assist individuals or groups submitting comments about the NPRM.



## 3. FAA SMS Airport Pilot Studies

Background

The FAA conducted two types of Pilot Studies to eva luate the development and implementation of SMS at airports of varying size a nd complexity. 1 

### FAA conducted two rounds of the initial study where airports develope d their SMS policies, procedures, and

processes. 2 

### Participants conducted a gap analysis and SMS Man ual and Implementation Plan. A second study, using three of the original participants, conducted a proof-ofconcept.

The scope of the pilot studies may significantly di ffer from the scope of proposed requirements in the NPRM because the FAA was invest igating SMS through the pilot studies. We selected the participating airports in part because they represented a crosssection of all 14 CFR 139 airports. The Pilot Stud ies allowed these airports and the FAA to gain experience establishing airport-specific SM S that were tailored for the individual airport. The results of the Pilot Studies provide information about SMS best practices

and benefits.

Benefits Anticipated

SMS is a systematic and proactive method that airpo rt operators can use to improve safety in the face of significant forecasted air tr affic growth. Airport operators using SMS are more likely to detect and correct safety pr oblems before they result in an aircraft

1 

### Currently, a third pilot study is underway to gath er best practices and information on implementation of certain components and elements of SMS.

2 

### FAA opened a second round to gain participation fr om smaller Class II, III, and IV certificated airpo rts.FAA SMS Pilot Studies Technical Report May 2011 Page 6



### accident or incident. Through these Pilot Studies, the FAA learned from the experiences of airport operators developing SMS at airports of widely varying activity levels and operational complexity.



## 4. Technical Report on the Pilot Studies

Background

The FAA has received questions and comments from in dustry in response to the SMS NPRM. One comment provided before we extended the comment period indicated that it would be difficult for industry to provide comments on the SMS NPRM without knowing the results of the SMS Pilot Studies. In response, we extended the comment period and agreed to provide this Technical Report summarizing the findings of the Pilot Studies.

Objective

This Technical Report gathers preliminary informati on from Pilot Study airports that will be useful to those commenting on the NPRM. It also allows us to share the information we have gathered so far with airports and the aviat ion industry. The report will help industry familiarize itself with SMS and the FAA’s intent with the SMS NPRM. This document does not represent a final agency decision on any aspect of the NPRM. The FAA expects the final rule may vary significantly f rom the proposal, and the FAA remains open to all comments by interested parties.

Methodology

The FAA formed a team to collect information inform ally about each Pilot Study airport’s experiences. The team gathered informati on from the Pilot Study airports through a series of face-to-face and telephone inte rviews using scripted questions (Appendix B). These questions addressed the follow ing topics:

• Personnel dedicated to SMS-related tasks during the Pilot Study and planned SMS staffing after conclusion of the Pilot Study;

• Resources employed during the Pilot Study for SMS d evelopment and implementation;

• Interpretation of the SMS;

• Results of the Gap Analysis conducted as part of th e Pilot Study;

• Benefits observed from employing SMS;

• Key findings made by the airport as a result of SMS during the Pilot Study;

• Difficulties, challenges, and lessons learned durin g the Pilot Study; and

• Adequacy of the FAA guidance and recommendations fo r improvement.

We reviewed and normalized the collected informatio n to create the Interview Results/Workload Assessment included as Appendix B. Interview responses thatFAA SMS Pilot Studies Technical Report May 2011 Page 7



### consisted of comments to the NPRM rather than obser vations from the pilot studies have been edited as irrelevant to the scope of this repo rt. Additionally, some interview responses may vary slightly from data the FAA relie d on for the NPRM because the intervening airport experience between drafting and the interviews. Based on the
interview results, the team made observations about the Pilot Study airports’ experiences. The Summary Observations section below contains the team’s observations. Appendix C includes the team’s notes from the airport intervie ws.



## 5. Summary Observations

Information summarized in Appendix B of this report allowed the team to make the following observations:

a. Results indicate the proposed SMS framework can be implemented in a scalable and flexible fashion. Pilot Study airports have us ed varying levels of personnel, consultant support, and technological tools to achi eve the intended safety goal.

b. Results show that most of the Pilot Study airports find value in SMS as it improves:

(1) Overall communication, training, and safety awarene ss;

(2) Safety consideration throughout the organization as it encourages a systemic process; and

(3) Evaluation of hazards (through Safety Risk Manageme nt 3 

### processes).

c. Results suggest that SMS will provide benefits to a irport safety beyond those operations regulated by 14 CFR 139, such as interde partmental communications, general aviation customs issues, and vehicle operat ions near hazardous features.

d. Results found that many of the Pilot Study airports acknowledge their existing 14 CFR 139 compliance programs contain elements simila r to those of SMS.

e. Results found that most Pilot Study airports though t a confidential reporting system is preferable to a non-punitive reporting sy stem.

f. Results emphasize concerns about the implementation cost of SMS among the Pilot Study airports.

g. Results included the following recommendations for improving SMS guidance:

(1) Clarify confidential / non-punitive reporting;

(2) Outline process steps to define SMS to the airport organization (what does SMS mean to their department and to the airport as a whole);

3 

### Many pilot study airports refer to their SRM proce sses as the Safety Risk Assessment (SRA). The term s will be used interchangeably throughout the documen t.FAA SMS Pilot Studies Technical Report May 2011 Page 8



### (3) Clarify the apparent incompatibilities between the different FAA SMS efforts (Airports, Aviation Safety, Air Traffic);

(4) Provide tools for developing and implementing SMS—t emplates, checklists, examples of SRM, assurance/training requirements, a nd data collection and analysis;

(5) Provide knowledge sharing relative to workload asse ssment and distribution;

(6) Suggest/support/provide outreach to promote partici pation by executive management and end users, such as tenants; and

h. Results found many of the airports were willing to share lessons learned and the documentation they developed during the Pilot Studi es. We have posted this documentation— including SMS Gap Analyses, SMS Manu als, and SMS Implementation Plans—to the SMS docket (see http://www.regulations.gov

– Docket number FAA-2010-0997).FAA SMS Pilot Studies Technical Report May 2011 Page 9



## APPENDIX A: Airports Participating in the SMS Pilot Studies

First Pilot Study

1. Atlanta Hartsfield International, GA

2. Austin-Bergstrom International, TX

3. Baltimore-Washington International Airport, MD

4. Concord Regional Airport, NC

5. Dallas-Ft. Worth International Airport, TX

6. Daytona Beach, FL

7. Detroit Metro - Wayne County, MI

8. Dubuque Regional Airport, IA

9. Indianapolis International, IN

10. Jacksonville, FL

11. Jackson Municipal Airport, MS

12. Kona International at Keahole, HI

13. Lexington - Blue Grass Airport, KY

14. Pittsburgh - Allegheny County, PA

15. Sacramento International Airport, CA

16. San Antonio International, TX

17. Santa Maria Public Airport, CA

18. Seattle - Tacoma International, WA

19. South Bend Regional, IN

20. Southern Illinois, IL

21. Tallahassee Regional Airport, FL

22. Toledo Express Airport, OH

Second Pilot Study

1. Boeing Field, WA

2. Cheyenne Regional, WY

3. Fort Worth Alliance, TX

4. North Las Vegas, NV

5. Ohio State University, OH

6. Show Low Regional, AZ

7. Sloulin Field, ND

8. Talladega Municipal, AL

9. Teterboro, NJ

Proof-of-Concept Study

1. Concord Regional Airport, NC

2. Seattle - Tacoma International Airport, WA

3. South Bend Regional, INFAA SMS Pilot Studies Technical Report May 2011 Page 10



### This page intentionally left blank.FAA SMS Pilot Studies Technical Report May 2011 Page 11



## APPENDIX B: Interview Results/Workload Assessment b y Pilot Study AirportsFAA SMS Pilot Studies Technical Report May 2011 Page 12

LOCID / SMS- Adding What were your challenges in interpreting SMS?

#of tasked SMS Operations Employees FTEs?

FTE / PT

SBN 0 2 No No significant challenges encountered. Consultant is experienced in 139

24000 and ICAO. One future challenge is to correlate SMS with 139 - are they integrated, separate, redundant? Airport needed to figure out the "what" of SMS, then the "how". Next step was to sell it to t he users. An overall challenge is to get buy-in from people who feel thi s is redundant to 139 and "get them to the table".

ASN 0 0 Unsure The match between part 139 and the SMS was difficul t to digest as well as

41000 trying to determine if part 139 was a subset of SMS , or vice versa. No guidance as to the applicability or relationship wa s or is provided. In addition, the ICAO and FAA SMS ACs regarding SMS ar e not always consistent with industry SMS standards. In particu lar, as defined by the AC 150/5200-37, SMS expectations are at times clearly communicated (e.g., Responsibility for assigning a safety manager) and at other times vague (such as establishing Objectives to achieve SMS or in the performance of Investigations). As a result, our Gap Analysis add ed Elements to the SMS outline to reflect some of the industry standards. In particular, we added an element on Incident Investigations under Risk Manag ement and Recognition under Safety Promotion, Encouragement. We also def ined Business Integration under Safety Assurance to include Preve ntative Maintenance and Emergency Preparedness. Associated criteria we re added to these elements, again, based on industry standards.

TOL 1 0 Unsure Guidelines seemed directed for airlines - the airpo rt environment is different.

47000 Problem interpreting and applying the Gap Analysis , not sure how to use SMS for different parts of the airport

DBQ 0 4 No DBQ has been involved in SMS since the beginning. T hey had the benefit of

50000 having an airport manager that was prior military a nd had extensive SMS experience.

SMX 1 0 No There was not a lot of direction from the FAA. Was not sure what the FAA

51217 was looking for

CYS 1 1 No Definitions- What is significant, catastrophic. A uditor Inspection

58000 requirements that could be foreseen. Technology In tegration. Cultural buy in.

JQF 1 0 No (1) Trying to determine where SMS applied. The scop e and the extent, beyond

60000 139.(2) Non-punitive reporting was (and still is) an issue. It contradicts the City's regulations. Airport employees are city empl oyees. (3) Trying to keep attendance at "SMS's safety committees was an issue , especially for nonairport participants

JAN 0 1 Unsure 1. Educating Staff, 2. Non-Punitive system, 3. Scop e, 4. Not much

65000 background provided by FAA

OSU 1 4 Yes Not all that much literature out there. Had to exp lore around. It was a

73000 challenge to be one of the first to do it.FAA SMS Pilot Studies Technical Report May 2011 Page 13

LOCID / SMS- Adding What were your challenges in interpreting SMS?

#of tasked SMS Operations Employees FTEs?

FTE / PT

SIU 1 0 Yes Concept was difficult to grasp at first. Guidance was vague, nebulous.

80000 Airport felt like it was stumbling through the proc ess, with little idea of where the FAA wanted the study to go other than the 21 deliverable items to use as guidance. When constructing a foundation, a irport had difficulty defining the difference between SMS and safety prog ram. Airport sought background information by attending AAAE meetings a nd reviewing ACRP and ICAO material. The airport had a theory that t he FAA was intentionally vague on its instructions in order to spark creativ ity among airports. The Airport felt the Gap Analysis was challenging becau se of a lack of guidance. The airport used ICAO as a reference to perform t he Gap Analysis.

JAX 1 0 No Safety Risk analysis, to what depth, how complicate d, What is the

94614 threshold? Participation of tenants is a challenge . Not all airlines participate because they have their own SMS programs. If not a ll tenants participate, the airport's SMS program will suffer.

AFW 2 0 Yes The process was challenging due to the fact that SM S overall is more of a

105000 mindset than actual regulation. During and after th e SMS study we found that getting our FTEs to understand the process was cha llenging. We were asking them to take a process that would improve sa fety and apply it to operational situations without providing particular areas of focus. In the end we found that our team was ultimately using SMS, su ch as SRM when evaluating air show planning and AOA construction. In my opinion the SMS process talks too broadly and asks the users to apply the tools where necessary without giving particular guidance, which is different than what most ACs and FARs provide. As an example: One FTE might think that an SRM process is needed for a particular project, but another may see it differently and feel that the process is not necess ary. So how do you determine what’s worthy of an SRM analysis and what ’s not?

TLH 0 3 No Conflicting information. When is SMS really require d? Begin with trigger

118000 events? What does FAA expect? It would help if the final rule includes specific staff positions and qualifying attributes ( similar to TSA)

KOA 1 0 Yes There were no known problems; the challenge came wi th interviews and

123772 long distance communication

PIT 2 0 1 One difficulty in preparing our SMS plan was the fa ct that we developed the

144563 plan in advance of the NPRM. As such, this necessi tated our revising the plan in order to meet the new pending requirements of the NPRM.

TEB 0 0 No 1. Non-Punitive system - how would that work, 2. Wh o is the accountable

150000 Executive, 3. What type of reporting system, 4. Cos ts and who pay for them

SMF No Will need to review the report and reach out to oth er staff involved to

150000

AUS 0 1 Yes SMS process has not yet been fully developed.

176914FAA SMS Pilot Studies Technical Report May 2011 Page 14

LOCID / SMS- Adding What were your challenges in interpreting SMS?

#of tasked SMS Operations Employees FTEs?

FTE / PT

SAT 2 2 Unsure Changing the culture, stakeholder acceptance of som e safety initiatives,

178484 participation of stakeholders in the SRA process an d getting usable information from the previous pilot programs.

BWI 2 0 Defining SMS to the organization / management (what does SMS mean)?

268005

BFI 0 1 No Applying to scope of operations.

280000

VGT 0 0 Yes Determining the responsibilities of the airport ope rator and third parties

313143 regarding the development and maintenance of SMS. Ascertaining if the airport sponsor can delegate SMS responsibilities t o tenants within exclusive leaseholds. Determining legal liabilitie s of the accountable executive and acceptance of known risks identified on the risk assessment

SEA 1 0 4 No SMS alignment within FAA: ATO and Airports- Who' s on first to initiate and

318000 perform SRAs and SRMs?, No common Language/referen ce; No provisions or process to share data across hazard databases; No protection from

"Public Information" statutes.

DAB 1 0 No Many. Was pilot for consultant too. Who does what? Tower, ERAU, air

350000 carriers, each have their own separate SMS, this is the biggest challenge.

DFW 1 0 No o Interpretation of possible legal/liability issues with no guidance.

652261 Accountability of tenants not defined/regulated. Me thodology for “inspection”/FAA oversight of SMS within ACM/139 fr amework not defined

ATL 1 3 Yes Some of the instructions were not as clear in the p ilot study documents,

950119 especially with providing resource information to c onduct research.

DTW 1 0 1 Airports in the continental US have not worked on S MS before; therefore, it

4622520 was difficult to have a point of reference for deve lopment of a SMS implementation document. Our SMS document was done by a consultant familiar with how SMS was implemented in the Europe an countries. The Airport Authority had to ensure that the consultant understood what the US airports have to comply with, pertaining to the FAA regulations. Despite the challenges, the airport was able to create a good w orking document for

SMS.FAA SMS Pilot Studies Technical Report May 2011 Page 15

SMSLOCID / tasked Adding What did the Gap Analysis reveal?

#of Employees SMS Operations FTE / PT FTEs?

SBN 0 2 No Self Inspection: Upward reporting of inspection and correction process -

24000 making senior management aware of activity; Airfie ld Inspections: Capture current self-inspection practices (1 inspec tion per shift vs. 1 per day in the ACM) in writing; Commercial aircraft operations ramp: Documenting specific inspection items on self-inspe ction documentation; Safety Manager: Designate a safety m anager to oversee SMS and ensure communication with senior management ; Non-Punitive Reporting System: Establish a system; Training Rec ords: Document procedures for conducting the established practice of auditing FBO fueling personnel training records; Recurring Train ing: Establish consistent recurrent training timelines and conside r establishing 12 month cycle for all training; Condition Reports: Es tablish and document timelines for filing condition reports; Communicati on: Evaluate and capture current practices in writing (ACM); Pedestr ian and Ground

Vehicle Procedures: Evaluate content and effectiven ess of training program; Obstructions: Identify ownership of obstru ctions and develop a notification / tracking system for ensuring obstru ctions are monitored and addressed; Wildlife: Include training requireme nts in the WHMP

ASN 0 0 Unsure As part of the Gap Analysis, a Perception Survey wa s also performed, to

41000 gauge the perception of management commitment and safety program performance on the part of the workforce. The resu lts of the gap analysis represent an overall strong perception tha t safety is important; its importance is communicated and considered of va lue in terms of Talladega airport operations. There was only one qu estion that did not rank as a strength and that was “Safety Suggestions ” (vulnerability). There were no “gaps” identified by the Perception S urvey. Therefore, based on the Gap Analysis, the findings and scores indicate that there is about a 20-25% overall agreement between what is r equired by part 139, and future SMS expectations (75-80% gap). How ever, one element in particular registered a score of 60% (Inspection s and Self-Auditing) and along with Requirements, was the highest of any of the Elements.

The remainder of the Elements and Sections all show ed “Gaps” as defined by this pilot assessment process. As a resu lt of this comparison, part 139 and ACM requirements provide s ome of the documentation expected of an SMS; however, the majo rity of the implementation strategy and responsibilities are un defined, except for Inspections, Integration of Maintenance and Emergen cy Preparedness. Some other element of SMS, (i.e., Tracking Systems, Roles and Responsibilities) would only provide a few of the e xpected documents. Overall, the documentation expectations of SMS woul d require the ACM to be enhanced quite a bit. Upon comparing ICAO an d AC SMS expectations to other industry SMS standards (ANSI Z10, OSHA’s VPP, OHSAS 18000, etc.), there are a number of gaps to t he proposed FAA SMS. ESIS recommends that, at a minimum, FAA consi der either adding or better integrating or expanding the concepts of : • Safety Policy and Objectives: Objective setting based on Leading Tren d Data and Performance Indicators. • Safety Policy and Objecti ves: Safety Committee Expectations• Safety Risk Management: Req uirements• Safety Risk Management: Ongoing Risk Reductions (th is is the biggest gap between industry standards and the FAA / ICAO S MS) the FAA/ ICAO seems to stop at a one-time treat and mitigate, ra ther than ongoing risk reductions.• Safety Risk Management: Incident Inve stigations and Root Cause Analysis.• Safety Risk Management: Emphasize the RiskFAA SMS Pilot Studies Technical Report May 2011 Page 16

SMSLOCID / tasked Adding What did the Gap Analysis reveal?

#of Employees SMS Operations FTE / PT FTEs?

Management Portion, Especially in Terms of Continuo us Improvement and Risk Reduction.• Safety Promotion: Recognition and Encouragement

ESIS recommends that FAA refer to OSHA’s VPP 9Volun tary Protection Program) and ANSZI Z 10 Health and Safety Managemen t Systems) for better clarification of the above integration and e xpansion suggestions,

TOL 1 0 Unsure Not sure how to interpret part 139 and the Gap anal ysis

47000

DBQ 0 4 No Couldn’t recall

50000

SMX 1 0 No We were not conducting regular meetings with tenant s. There were

51217 informal safety resolution procedures. The airport would take care of issues as notified. The SMS processes allowed airpo rt personnel to actively communicate with the airport users.

CYS 1 1 No They had gaps in all areas. Some minor and some si gnificant. There

58000 was no area where they were fully compliant with SM S.

JQF 1 0 No Management and front line personnel had different i nterpretation and

60000 opinion of safety. This revealed gaps in communicat ion, and the "buyingin" of safety.

JAN 0 1 Unsure Some gaps with respect to SMS

65000

OSU 1 4 Yes Part 139 does not go into non-movement area. Form ality of safety

73000 program required for SMS. More paperwork and proc ess. Proactive Safety policy and promotion.

SIU 1 0 Yes Safety must be formalized through: 1) Adjusting do cumentation where it

80000 is lacking; 2) developing committees; 3) setting up data collection (e.g., providing a website to collect confidential safety reports); 4) ensuring visibility of/attention to safety is maximized.

JAX 1 0 No Risk analysis process needs to be put in place. Hav e a lot of issues

94614 inside the gate & baggage areas.

AFW 2 0 Yes The Gap Analysis revealed that we meet all componen ts of FAR139 and

105000 currently unintentionally meet some parts of the SM S guidelines. The Gap Analysis identified weaknesses in resolving mai ntenance items, record keeping and training. As a result these area s were reviewed and strengthened. It helped identify programs such as safety committees and showed the value of the program.

TLH 0 3 No Reporting mechanism for unsafe conditions. Airport developed branded

118000 safety [products to advertise the program, voice ma il 891SAFE, drop boxes]. Still struggling with Staffing issues, how are Ops supposed to interact with capital programs.FAA SMS Pilot Studies Technical Report May 2011 Page 17

SMSLOCID / tasked Adding What did the Gap Analysis reveal?

#of Employees SMS Operations FTE / PT FTEs?

KOA 1 0 Yes Gap Analysis for ICAO vs. FAR part 139 did not reve al anything too

123772 earthshaking , but there were issues with Emergency Equipment traversing level surfaces.

PIT 2 0 1 To implement SMS, the airport was required to revie w our 144563 organizational structure and assign specific duties related to SMS. Additionally, we found that we could improve upon s afety promotion efforts. Finally, we found that we were in need of an incident reporting database that would allow for the easy review of in cidents and hazards in order to conduct trend analysis.

TEB 0 0 No TEB has a solid safety foundation, SMS will require centralized reporting

150000 system, Management guidelines need to be developed

SMF No Have no answer at this time, will comment at a late r date.

150000

AUS 0 1 Yes Gaps existed in the following areas: SMS Policy St atement, Training,

176914 Non-punitive reporting systems, Implementation Plan , detailed SRA documentation, approval and follow-up of mitigation s by senior management, description of airport risk management program, selfauditing process, plan to integrate SMS program int o overall airport operations, promotion of safety awareness, document ation of lessons

learned

SAT 2 2 Unsure That 139 is a good base for SMS.

178484

BWI 2 0 Shortcomings in communication / training (not willi ng to speak in any

268005 specifics).

BFI 0 1 No Non-movement area safety. Hot spots in movement a rea. Signing

280000 marking and lighting. Safety area focus at BI inte rsection.

VGT 0 0 Yes The results of comparisons between existing condit ions, including the

313143 documentation of practices at the airport, and SMS standards revealed that in some instances certain practices or procedu res are in place, but may not be collectively gathered or documented to m eet the intent of a formal SMS. In other instances, data collection or record-keeping is being completed as part of a database managed by CC DOA, but has not been formally included as part of the SMS program.

SEA 1 0 4 Reflection of philosophy. Part 139 relies on chec klists, SMS is bigger

318000 picture and requires more judgment.

DAB 1 0 No FBO, NASCAR, ERAU, Flight schools...how do we get the m under one

350000 umbrella? Need a formal system under SMS program. Larger airports will have more challenges.FAA SMS Pilot Studies Technical Report May 2011 Page 18

SMSLOCID / tasked Adding What did the Gap Analysis reveal?

#of Employees SMS Operations FTE / PT FTEs?

DFW 1 0 No Gap Analysis results determined and reported by con sultant as part of

652261 first pilot study. Several SMS elements are present , though not yet all formalized, and, therefore, not consistently or sys tematically applied. Need to establish/refine formal “safety policy.” Re sponsibilities – need to clarify with respect to SMS at all level so Coor dination – many SMS processes require cross-functional working coordina tion and cooperation, this occurs on a case-by-case basis cu rrently but organizational processes will need to be improved. Documentation – with the exception of all those required by regulat ion, all other actions and activities related to safety issues or hazards will need to be formalized. Risk management – hazard identification , risk assessment and mitigation will need to become a systematic par t of all processes, in particular with regard to current airside hazards facing the organization and change management. Communication – there is a n eed for a formalized and systematic process and mechanism to promote and ensure the free exchange of safety information betw een staff at all levels of the organization, between sections and de partments, between divisions and with external service providers. Acco untability – current FAA framework does not extend airport authority to the non-movement area. The efforts made by the Airport to improve s afety performance by fostering cooperation amongst all is sometimes met with diverging and competing interests. To resolve this and ensure SM S is successful, the accountability and responsibility can only be acce pted by the Airport if supported by the authority under an unambiguous reg ulatory framework.

o Performance Indicators – there will need to be a process for establishing and measuring comprehensive safety goa ls, objectives and key performance indicators – collection of safe ty data will need to be linked to such safety objectives

ATL 1 3 Yes Did not have a comprehensive Safety Policy Statemen t, although the

950119 City of Atlanta and DOA have internal safety polici es in safety manuals. Did not have Safety Risk Assessment Process

DTW 1 0 1 No response received.

4622520FAA SMS Pilot Studies Technical Report May 2011 Page 19

LOCID / SMS- Adding What benefits have you seen to your airport from SM S

#of tasked SMS development and implementation?
Operations Employees FTEs?

FTE / PT

SBN 0 2 No Unknown Hazards: One SRA did identify previously un known hazards

24000 relating to the issue with tug operations on the ai r carrier ramp. Other SRAs were conducted for system changes; Active Safe ty Committee: Good participation in SRAs, considering safety-rela ted work is a collateral duty for most of the SRMP members; Track ing System: System is in development; One party identified as responsi ble/in charge of safety concerns: No real change - there's awareness of the process, reliance on

the chain of command. Familiarization will occur through recurrent badge training; Lower long term costs: No change, t oo early to tell. There is an anticipated cost reduction similar to the wor kers' comp multiplier. Cost savings under 139 may not be significant becau se it is already saving costs by preventing accidents; Others: Relat ionship with tenants improved. The process inherently and actively invo lves impacted parties/users to provide data, resulting in better communication /

awareness of hazards and risk. It also forces the airport into a leadership role, bringing everyone into a collabora tive effort. The approach an airport takes to SMS speaks to the way the airport is managed.

ASN 0 0 Unsure None... The airport staff is simply doing what it de ems is necessary to

41000 exist for 50 out of 52 weeks each year. The two ot her weeks it is a well run, well-staffed, well-protected facility with num erous safety programs in place. Once the NASCAR races are over, the airpor t reverts back to a sleepy, GA-style airport with minimal operations. A n SMS can provide an airport with the capacity to anticipate and addr ess safety issues before they lead to a catastrophic incident or acci dent. SMS provides management with the ability to deal effectively wit h accidents and near misses so that valuable lessons are applied to impr ove safety and efficiency. Research has shown that safety and eff iciency are positively

linked.

TOL 1 0 Unsure 1. SMS does raise the level of safety awareness, 2. discovered

47000 interesting chemistry between different people and airport departments

DBQ 0 4 No They already had a safety culture, but this experie nce really enforced the

50000 big picture mentality and made them look outside th e box at safety in general, as well as safety areas. Approaches to bes t possible solutions. DQB has also created an anonymous safety reporting hotline on their website starting soon. The reports will go directly to the airport manager and safety chief.

SMX 1 0 No We have taken a more proactive approach with holdin g tenant safety

51217 meetings using the local FAA Safety Team comprised of tenants.

CYS 1 1 No 1. Improve communication among all stakeholders. 2. Increased

58000 awareness of airport environment itself. 3. Crea tion of process does not allow items to fall through cracks.

JQF 1 0 No (1) our Safety Programs were not as effective as we initially thought, (2)

60000 there were some disconnects between programs, (3) c ommunication across the organizations needs to be improved (4) l ower costs by preventing litigation, (5) effective documentation system is keyFAA SMS Pilot Studies Technical Report May 2011 Page 20

LOCID / SMS- Adding What benefits have you seen to your airport from SM S

#of tasked SMS development and implementation?
Operations Employees FTEs?

FTE / PT

JAN 0 1 Unsure More safety awareness for the staff - cultural chan ges
65000

OSU 1 4 Yes 1.Revealed potential hazards on non-movement area- blind spots. 2.

73000 Formalizing movement of vehicles. 3. Wildlife mi tigation - Finding birds on runway in morning when tower has been closed. 4. Formal lines of communication on safety have been facilitated, they now meet quarterly. 4. Brings in a culture of safety. 5. Have not ex perienced cost savings yet, it will cost to hire new staff person.

SIU 1 0 Yes Unknown Hazards: Some issues may be more efficientl y dealt with using

80000 longer term, continuing SRAs as opposed to multiple SRAs on individual issues that are all related. SMS is building a cul ture that, combined with improved data collection, will bring out hazards mo re efficiently. A more active safety committee: Results in more activity - information sharing. People respond to the tone set by the airport manag er through the Safety Committee, which leads to improved identification o f hazards. Formalization of the safety culture through element s like the safety committee establishes the SMS's credibility among u sers. A tracking system that leads to a more proactive approach: Inc ident Reporter by OMNI Air Group (data collection software) was cumbe rsome. SIU developed a web-based data collection site that col lects, organizes and tracks data, reducing workload on the person respon sible for monitoring the system (currently airport manager). Email func tionality allows immediate receipt, evaluation and action on safety reports submitted through the website. One party identified as being responsible /in charge of safety concerns: Greater impact using the web b ased data collection system. The system allows one person to address is sues more efficiently. With efficient data collection and no tification, one person can address issues efficiently and consistently. Lower long-term costs: Too early to determine - no cost savings noted yet, but enough data to evaluate. Others: SIU's SMS project has been a boo n to SIU for professional development, aviation industry and air ports. The system increases communication, which has led to increased safety-related activity and awareness.

JAX 1 0 No Heightened level of awareness of hazards and docume nting the process.

94614 Proactive about documenting hazards and then invest igating and correcting, things get acted upon. The safety comm ittee was very active at first but now participation is lower, as the nov elty has worn off.FAA SMS Pilot Studies Technical Report May 2011 Page 21

LOCID / SMS- Adding What benefits have you seen to your airport from SM S

#of tasked SMS development and implementation?
Operations Employees FTEs?

FTE / PT

AFW 2 0 Yes a. Unknown hazards. Nothing identified during or af ter the pilot study. b.

105000 A more active safety committee- As a result of the SMS pilot study we established and maintained an Airport Safety Commit tee comprised of all major stakeholders on the airport. Next meeting is planned for June of 2011. c. A tracking system that leads to a more p roactive approach - As a result of the SMS study we implemented a be tter tracking system for open items such as damaged airport signs and m issing lights. Our challenge with this has been consistent application . In addition to this we still use the standard airport inspection to list any non-complying items found during the required airport inspections. Bet ter application and consistency would allow for more detailed trend ana lysis, better long term planning, and could show unknown problems with the airport environment. d. One party identified as being respo nsible/in charge of safety concerns. Senior Leaders do play an active r ole in safety and have implemented several components from the SMS pi lot study. e. Lower long-term cost- None at this time. Although w e do anticipate lower cost in the future as it relates to tracking repair and maintenance issues.

f. Others- None

TLH 0 3 No 1- Greater focus on safety 2- More people invol ved- they check the

118000 reporting hotline daily, 3- Hard to quantify cost s avings, yes if you save one life., 4- Better responsibility, accountability , reporting, 5- Got safety vests for increased visibility for ramp workers

KOA 1 0 Yes A more robust driver's training program should be p art of SMS. The safety

123772 committee should have been better developed. It to ok a year after the consultant/Engineers and FAA program Manager went o ut to the site to improve the process. Tracking system consists of em ail for linkage on new positions. The airport system's fire chief is designated as the decision maker. There is no significant change in airport operating cost for SMS. The Self Inspection program ties into SMS

.

PIT 2 0 1 As a result of our implementing SMS there is a grea ter safety awareness

144563 among employees. Once role out is complete, we ant icipate improved means of monitoring and trending safety incidents/h azards. Finally, we have received positive input from our liability ins urance carrier resulting from our use of SMS, though no reduction in rates h ave been realized.

TEB 0 0 No More safety awareness for the staff - cultural chan ges
150000

SMF No Because we have not implemented, minimal benefit ha s been gained. We

150000 did discover some potential hazards that we resolv ed, so did result in improved safety.

AUS 0 1 Yes Not yet implemented.

176914FAA SMS Pilot Studies Technical Report May 2011 Page 22

LOCID / SMS- Adding What benefits have you seen to your airport from SM S

#of tasked SMS development and implementation?
Operations Employees FTEs?

FTE / PT

SAT 2 2 Unsure There are many, and this section should be formally developed in a

178484 working group of Pilot Study Airports prior to fina l rule making. Here are a few we see: trend tracking of unsafe issues, a for mal safety process and structure, SRA and the associated benefits, overal l awareness of safety

culture.

BWI 2 0 BWI has not implemented SMS fully. Have noticed an increase in safety

268005 awareness

BFI 0 1 No 1. More proactive on safety. 2. Overall Awar eness.
280000

VGT 0 0 Yes The SMS process has not been implemented at the air port. During the

313143 pilot study only a few specific test items were sub jected to the process. Benefits cannot be determined until a large samplin g of items can be

achieved.

SEA 1 0 4 Track and trend hazards to ID and mitigate safety r isks, Evaluate

318000 previous studies proposed policies and practices, d evelop a quality management program, align airport, airline, ground handler safety programs, incorporate non-movement areas into inspe ctions/audits, reinforce safety culture, improve safety awareness

DAB 1 0 No More active safety committee meetings every week, s afety is now a

350000 major component of monthly tenant meetings. Intern s from Embry Riddle are tracking projects such as wildlife, alert calls , medical calls, sign changes. John Murray is the point person.

DFW 1 0 No o Unknown hazards proactively identified (in theory )o A more active

652261 safety committee. A tracking system that leads to a more proactive Approach. One party identified as being responsible /in charge of safety concerns - not just the “accountable executive” bu t accountability at all levels within the organization (in theory)o Lower l ong-term costs – quite possibly difficult to measure/quantify or categoriz e. Enhanced collaboration between departments regarding hazards /SRA process. Review and adjustment of current policies and proce dures with regards to not only SMS, but other business processes - SM S merely provides the reason/”excuse” for review and adjustment

ATL 1 3 Yes SRA process is helping to effectively evaluate haza rds with construction

950119 projects and changes on the airfield; Establishing a SMS Work Group with tenant involvement in the development and refi nement of our SMS Program. The SMS Work Group will become the Safety Committees defined in the SMS Program; The ASOCS database sys tem is very beneficial for Part 139 reporting and being able to fulfill our SMS reporting requirements. The SMS Dashboard will supplement the ASOCS data with trend analysis and tracking capability.

DTW 1 0 1 No response received.

4622520FAA SMS Pilot Studies Technical Report May 2011 Page 23

LOCID / SMS- Adding What was/were the key finding(s) at your airport as part of the

#of tasked SMS pilot studies?
Operations Employees FTEs?

FTE / PT

SBN 0 2 No The pilot study work validated the airport's curren t activity relative to safety

24000 and provided ideas for formalizing and tweaking th e process to improve it.

ASN 0 0 Unsure This was basically a GA airport with 139 credential s. It is not funded by the

41000 City, and the Airport Board uses its funds to matc h FAA/AIP projects. The FBO runs the airport on a day-to-day basis, and the ir financial situation at the airport is poor, due to low revenues, etc. All of this contributed to the airport's relinquishing its 139 certification.

TOL 1 0 Unsure Made us aware that processes and procedures need to be revisited and

47000 improved all the time. Cultural changes. Talking ab out Safety and SMS

DBQ 0 4 No Found a high rate of damage with pushing and pullin g aircraft into and out

50000 of hangars and gate areas. Training and fatigue iss ues, general awareness

SMX 1 0 No Tenants want to help out as long as it doesn’t cost them anything. Since our

51217 size allows us easy access and a familiarity with our tenants, a formal SMS seemed to add another layer of bureaucracy into a community that already has skepticism over additional controls.

CYS 1 1 No Sensitivity to perceived criticisms, Verbiage issue s amongst airports

58000 Governance and legal, ATC and airports have differe nt focus. ATC hazard life risk only, SRM is a PROCESS that must fit the airport, not the other way around, Risk Matrix Chart color variations, Identif ication verbiage for severity and probability variances, Definitions dev eloped over time, Tolerance levels vary, Assessments became more calc ulated

JQF 1 0 No Gaps in communication between management and front line

60000

JAN 0 1 Unsure Able to identify that a legacy safety culture does already exist at the airport

65000

OSU 1 4 Yes Self identifying hot spots, mitigate before it happ ens for safety in non73000 movement areas.

SIU 1 0 Yes Performing the SRAs at the airport demonstrated val ue early on. It helped

80000 direct specific attention to safety issues and miti gation. SRAs were valuable in bringing together different perspective s and allowing participants to understand the perspectives of the other parties involved.

JAX 1 0 No Need to start somewhere. Develop a foundation for S MS to get a grasp,

94614 then once foundation is set, easy to modify. Can ma ke adjustments easily in the future once you have developed a reporting s ystem. A consultant may be helpful to make sure things stay on track wi th the ImplementationFAA SMS Pilot Studies Technical Report May 2011 Page 24

LOCID / SMS- Adding What was/were the key finding(s) at your airport as part of the

#of tasked SMS pilot studies?
Operations Employees FTEs?

FTE / PT

AFW 2 0 Yes a. Some aspects of the SMS system are already being used. b. Safety

105000 Culture exists but needs improving. Since SMS study this has improved. c. Training in all areas needed to be strengthened.

TLH 0 3 No Need to do a better job with the business process. If issues are

118000 identified, follow it through until the issue is cl osed out with documentation. Work toward better airport visibility for SMS, nee d a platform for organizing safety & outstanding work orders in the same manne r that you have a platform for security.

KOA 1 0 Yes Require additional: Driver's training, SMS qualifi ed training, Self inspection

123772 training.

PIT 2 0 1 In many respects we are operating under SMS in much the same way as

144563 we have always operated, reviewing hazards and iden tifying ways in

which to minimize risk. We tend to have a more met hodical approach to safety reviews. It has been our experience that SM S has brought a significant increase in required documentation.

TEB 0 0 No Nothing yet

150000

SMF No Again, the details will be in the report.

150000

AUS 0 1 Yes The Gap Analysis indicates that in order to impleme nt SMS a formal

176914 process must be developed by management to lead the way in the promotion of a safety culture.

SAT 2 2 Unsure No response received.

178484

BWI 2 0 Noticed an improvement in communication throughout the organization,

268005 quality of training and safety awareness

BFI 0 1 No BFI focused on unique elements on the airport from a safety prospective.

280000

VGT 0 0 Yes The SMS process has not been implemented. No preva lent findings were

313143 ascertained. We are only in the process of definin g the SMS.

SEA 1 0 4 Culture change in risk from legal and operations wa nting just the facts (no

318000 interpretation) to SMS looking at root cause and th is incurs more potential liability.FAA SMS Pilot Studies Technical Report May 2011 Page 25

LOCID / SMS- Adding What was/were the key finding(s) at your airport as part of the

#of tasked SMS pilot studies?
Operations Employees FTEs?

FTE / PT

DAB 1 0 No Development is needed- need higher management invol vement and

350000

DFW 1 0 No o Gap analysis findings. Many processes already don e today are key

652261 components of SMS – just need to refine and “formal ize” through policy/procedure, documentation, and accountability

.

ATL 1 3 Yes We realized a lot of what we were doing is part of Safety Management

950119 System with Part 139 responsibilities, Risk Managem ent Office, DOA and City of Atlanta Safety Policy Manuals

DTW 1 0 1 No response received.

4622520FAA SMS Pilot Studies Technical Report May 2011 Page 26

LOCID / SMS- Adding What difficulties / challenges have you experienced during the

#of tasked SMS pilot studies? Do you have any Lessons Learned?
Operations Employees FTEs?

FTE / PT

SBN 0 2 No Challenges: Legality/confidentiality of the non-pun itive reporting system;

24000 Presenting SMS to an industry structure and culture that has changed greatly (employee/employer loyalty, subcontracting, dedication to aviation; Encouraging communication of safety related activit ies (e.g., getting air carriers to report incidents/damage to their equipm ent on the ramp); Encouraging documentation of conversational informa tion (water cooler talk) to collect relevant data; Determining who cal ls a SRMP and when, how; Concern about multiple SMSs for ATO, ARP, AVS, Air Carriers - how will multiple SMSs be integrated / correlated to pr event duplication of effort?; Addressing the issue of LOBs convening com peting SRMPs to produce a desired outcome; Non-Punitive Reporting - A subcontractor was hired to research confidentiality and data suscepti bility to FOIA. Data storage alternatives were proposed to isolate the d ata from the airport or entities where it would be subject to FOIA. Append ix A of the Follow-On report SBM submitted details these alternatives.

ASN 0 0 Unsure Multiple entities controlling life-safety issues du ring the race weekends at

41000 the nearby speedway. Also, staff during these peri ods is subject to change, and specific training for the NASCAR events is on- going... race to race...
year to year.

TOL 1 0 Unsure As a smaller organization, hard to implement SMS. P roblems with FAA

47000 LOB's to attend meetings, etc. Also not always the right people, upper mgt delegated some lower level people. How many people to participate in these SMS meetings (too many at times, too few at o ther times)

DBQ 0 4 No How does the airport implement, maintain and fund w ith current staffing and

50000 resources in a challenging budget environment?

SMX 1 0 No Development of a true safety policy and objective w as hard since you really

51217 wouldn’t promote unsafe activities. We didn’t real ly know where this document and the mandatory records fall within SSI and FOIA standards and how that could affect future responses. We are not sure if documenting a mitigation would come back to haunt us. We learne d that we are already communicating hazards fairly well since we are a sm aller airport. Daily interaction with our tenants has provided a good fl ow of communication.

CYS 1 1 No Public Disclosure protection, SMS in Non Movement T enant Areas; SMS

58000 technology development, "Non-Punitive" Policy, Defi nitions for SRM, Budget: Implementation, Corrective Actions, Staffi ng SMS when employees already wear several hats. Airport pilot simila rities: all had 139 Safety Self-Inspections, Gap Analyses varied in size/compl exity, Full time SMS employee is challenging, Budgeting will be difficul t, All had some technology for support, Training tracking could be tied to existing SIDA/driver’s training, Culture CHANGE is a challen ge Airport pilot differences: the larger the airport the more compl icated the safety issues, Governance varies (“Policy”), Safety threats vary. Larger airports have more resources including technology, Smaller airpor ts can implement more easily, Employee turnover at small airports is lowe rFAA SMS Pilot Studies Technical Report May 2011 Page 27

LOCID / SMS- Adding What difficulties / challenges have you experienced during the

#of tasked SMS pilot studies? Do you have any Lessons Learned?
Operations Employees FTEs?

FTE / PT

JQF 1 0 No Difficulties in introducing technology to all. Fina ncial incentives to help with

60000 the safety efforts did not work. Use of field-toug h tablets makes sense though.

JAN 0 1 Unsure Issue with the word "Policy", non-punitive approach , cultural change

65000

OSU 1 4 Yes Easier than expected to get buy in from users. Cha llenge was to get buy in

73000 from wider airport community to collect hazards. Experimenting with different hazard reporting models. Education of I T staff takes time. Overall, not as challenging as we had thought. It will tak e a long time to change the

culture.

SIU 1 0 Yes 1) How do airports get funding for staffing, traini ng delivery, developing

80000 tools? This will test Airport Managers' creativity . 2) How do airports get funding for mitigation that requires construction? 3) Question: Is liability assumed when mitigations are made known but not act ed on? This may create a risk of airport sponsors minimizing hazard s to avoid spending money. Lessons Learned: 1) Ensuring management inv olvement / buy-in. Leadership is critical. 2) Communication should co me early and often to front-end load information from the FAA through the airport to the tenants (end users).

JAX 1 0 No The consultant recommended a drop box for hazard re ports- too archaic.

94614 Instead went 'high tech' with a web based report d esigned by a local contractor. Promotion is a major challenge, have t o be a cheerleader to promote the program.

AFW 2 0 Yes We struggled, and currently struggle with the overa ll implementation of

105000 SMS. We often find that making the time to manage t he SMS process is our main obstacle. Some areas within SMS require addit ional manpower to perform analysis, reports or training. Ultimately, this process will add layers to already existing FARs.

TLH 0 3 No Lessons learned from study: the need to foster inte rest, "Bleed Safety".

118000 Developed posters, banners, safety candy jars, lany ards, badge reels etc. Make a BIG DEAL about safety. Patterned his progra m off of military aviation Risk management program called "ANY MOUSE"

.

KOA 1 0 Yes Selection of a well-qualified consultant is paramou nt. In order for ANY safety

123772 plan, program or management system to be effective it MUST have dedicated staff to administer it. Time and time ag ain my experience is that

this task is an add on to someone or some unit that already has a full plate. The consultants recognized this and recommended the creation of an SMS safety officer position. Such a position remains t o be established at Kona.

PIT 2 0 1 We underestimated the amount of staff time required in order to implement

144563 SMS. Training time for staff is significant, as is the time and effort related to the documentation of the SRM process. Our desire to integrate incident reporting software with a legacy work order managem ent software has also been a challenge.FAA SMS Pilot Studies Technical Report May 2011 Page 28

LOCID / SMS- Adding What difficulties / challenges have you experienced during the

#of tasked SMS pilot studies? Do you have any Lessons Learned?
Operations Employees FTEs?

FTE / PT

TEB 0 0 No Very time-consuming, 18 months to complete the draf t, but overall a

150000 positive experience, was handled by manager groups only

SMF No The challenges were primarily addressed by the cons ultant

150000

AUS 0 1 Yes Approval of SMS Policy with inclusion of non-puniti ve policy

176914

SAT 2 2 Unsure Need to communicate with stakeholders, understand t he time it will take to

178484 implement SMS at the Airport (5-7 years)

BWI 2 0 Non-punitive reporting is a big problem with organi zation and Legal Dept.

268005 Highly suggest hiring a consultant to develop the m anual and implementation plan. Said they brought an outside p erspective and viewpoint that is really important.

BFI 0 1 No Potential liability exposure, Program scalability, Third party roles and

280000 responsibilities, electronic vs. paper format, data base.FAA SMS Pilot Studies Technical Report May 2011 Page 29

LOCID / SMS- Adding What difficulties / challenges have you experienced during the

#of tasked SMS pilot studies? Do you have any Lessons Learned?
Operations Employees FTEs?

FTE / PT

VGT 0 0 Yes SMS introduces new requirements for record keeping , ensuring that all

313143 SMS documentation is current and accurate. This in cludes the introduction and maintenance of SMS training records for all air port employees, documentation of hazard identification and analysis , documentation of the effectiveness of corrective and preventative measur es taken, and the

documentation and dissemination of the results from accident and incident investigations. There is not presently sufficient administrative staff to accomplish these tasks. SMS annual record keeping and the training requirements outlined below would necessitate the h ire of a full time Management Analyst I at $84,460 annually including benefits. The SMS process includes new requirements for initial a nd annual recurrent training of airport employees in overall airport sa fety objectives, safety risk management principles, safety assurance topics, air port rules and regulations, and overall department organization an d functions. A plan to validate training effectiveness and a process to ob tain feedback, including useable metrics, is also required. Providing eight hours of annual training for 450 employees would require 30 classes with 15 employees per class. Ten weeks would be required to complete training at 3 classes per week. The training would consume 3,600 man hours. Assumi ng an average hourly wage of $28 for each CCDOA employee, CCDOA trainin g costs for 30 employees would total $6,720. Assuming an average hourly wage of $15 for each commercial airport tenant employee, tenant training costs for 420 employees would total $50,400. Annual training cos ts total $57,120. SMS requires change management, a formal process to ide ntify, anticipate, and prepare for potential hazards introduced into the a irport environment. Trigger events include such common occurrences as t he introduction of a new commercial aircraft type, the commissioning of new equipment or the adoption of new procedures or regulations. The airp ort embraces a nonpunitive safety reporting policy as outlined in the Clark County Workplace Safety and Health Policy. However, certain violati ons of applicable laws, policies, or procedures may require additional disc iplinary action. This issue is not addressed by SMS. Safety communicati on to promote a safety culture through all levels of the airport or ganization is a requirement of SMS. Although some communication processes are currently in place, such as newsletters and tenant meetings, other syst ems for disseminating information regarding airport operations, facility maintenance, airfield construction, employee safety awareness, tenant saf ety awareness, airside safety, and wildlife safety would be required. The additional cost cannot be calculated until the specific media are selected, b ut the expense would be significant. Implementation and maintenance of SMS would be challenging and labor intensive, particularly at North Las Vega s Airport. A new management analyst position would be required at $8 4,460. Annual training costs are estimated at $57,120. These staffing an d training costs together total $141,580. These costs do not take into accou nt the time necessary for the duties of the Deputy Director of Aviation as th e SMS Accountable Executive, the Assistant Director of Aviation, Gene ral Aviation as SMS Responsible Executive, or the duties of the Airport Manager under the draft

SMS manual submitted to the FAA. The annual cost o f communication and file storage would also be a significant factor. T his represents a financial and administrative burden during a time of economic difficulty and budgetary constraints.FAA SMS Pilot Studies Technical Report May 2011 Page 30

LOCID / SMS- Adding What difficulties / challenges have you experienced during the

#of tasked SMS pilot studies? Do you have any Lessons Learned?
Operations Employees FTEs?

FTE / PT

SEA 1 0 4 ATO and Airport SRAs/SRMs- Conflicting and overlapp ing assignments,

318000 roles, responsibilities; Will FAA defer safety to S RA process in lieu of their "intuition" or expert opinion; FAA ARP does not ha ve staff or resources to support participation or facilitation of SRAs, thei r review, and approval; No way to ensure continuity of findings amount airport SRAs or their associated mitigations.

DAB 1 0 No Understand what it is you're being asked to do. Try to get as much info as

350000 you can. Try to get buy-in from tenants- they have weekly meetings to talk about safety issues. Communication is critical.

DFW 1 0 No o Coordination of key stakeholders for SRA panel me etings challenging –

652261 possibly establish a “core” identified group commit ted to the effort that can easily convene at short notice. Inherent bias/natur al human instinct with internal and external stakeholders – people have th e tendency to “defend” their businesses in the name of safety, also they r ealize that identification of hazards may “create work” for their organization, these may skew their hazard risk ratings (lower risk)o Non-movement area inclusion will be a challenge without more explicit regulatory oversigh t. Internal FAA Order 5200.11 is now required prior to airports SMS being required. This, in essence, requires SMS be in place (at least for AIP funded projects) prior to a published rule for airports.

ATL 1 3 Yes The SRA process requires a lot of preparation, time allocation, especially to

950119 conduct the SRM Panel that could take a full day or more to complete the process. Develop a documented process/protocol for the airport and its business partners ensuring acceptance and harmoniza tion of the decision making process and defining responsibilities to eva luate, accept, and mitigate risks. These items will need to be address ed in each operator’s particular SMS (ie MOUs MOAs, Lease Agreements); Wi th the stakeholder data, we only received a few reports from companies which were deidentified. The challenge was most of the companies were concerned about the data protection and FOIA laws. Airline concerns are on the (a) incompatibles between an airport SMS and air carrie r SMS, (b) lack of ownership of data in control of an external sources , and (c) company data subject to sunshine laws at a public airport. Most of the companies believe it could result in an unintended lack of protection by the company for its employees and potential non-compliance of regulator y issue that affect their reputation. Most companies would require clarity in (a) the protection for ensuring their documents and data are maintained as confidential documents not subject to release to the public unde r government disclosures laws, (b) possession and control of the data acquired, (c) use of

accident and incident data in tenant risk assessme nt exercises, and (d) use of stakeholder data for creating and or modifyi ng processes for all tenant at an airport.FAA SMS Pilot Studies Technical Report May 2011 Page 31

LOCID / SMS- Adding What difficulties / challenges have you experienced during the

#of tasked SMS pilot studies? Do you have any Lessons Learned?
Operations Employees FTEs?

FTE / PT

DTW 1 0 1 Airports should start the process by building the f oundation of their

4622520 respective SMS structure. It’s essential to begin by evolving/improving your airport’s current data retention systems into a comprehensive information system that bridges and communicates wi th all divisions that are accountable for the airfield, while you learn t o understand and develop the four main components of SMS. Develop, improve, and/or recreate all reports and information structured, or organized, r eflective of the functions (Safety Critical Systems-SCS) of the airfield and o utlined in FAR 139. Engage your airport’s cross functional SME’s to champion each SCS throughout the development. Utilize computer and mobile technolog y to streamline reporting, foster decision making, improve asset m anagement, track and trend risks, reduce frustration, and build relation ships. Many airports are already performing much of the activities that make up the components required for a SMS. These activities may just need to be formalized, organized, documented and improved.FAA SMS Pilot Studies Technical Report May 2011 Page 32

LOCID / SMS- Adding Do you feel the FAA guidance was sufficient? What would

#of tasked SMS you want to see included in Advisory Circular guida nce
Operations Employees FTEs? material?

FTE / PT

SBN 0 2 No Yes. Further guidance came from teleconferences, c onsultants,

24000 networking with other airports. With basics laid o ut by the FAA, the study became a "community thing." The guidance got parties started down the road and left enough leeway for interpreta tion. AC: Include written clarification describing how FAA approaches SMS. Does it intend for SMS to be a standalone document or part of the ACM? If SMS is part of the ACM, and an airport includes inform ation about operations outside of 139, can the ACSI inspect and cite the a irport for violations in those areas? Will the airport need to maintain 2 S MSs - 1 within the ACM and another for everything outside of 139? Thi s will be counterproductive. Make sure the AC does not move airports too far toward procedure-based documents (overreliance on c hecklists). Too

much documentation will be a distraction to the SRM process.

ASN 0 0 Unsure FAA had very little input during the preparation of the report, and

41000 provided no feedback on GAP analysis submittal.

TOL 1 0 Unsure Guidance was not sufficient: some was misleading (i n terms of what is

47000 applicable - and scalability). Need clear definitio n of responsible parties: e.g. for runways - AT vs. the airport.

DBQ 0 4 No Thought the guidance was sufficient (had prior SMS experience on their

50000 side). They highlighted that scope and complexity w ill affect the overall program. They felt they had a good grasp on what th ey needed. They said they relied heavily on the consultants to create t he documents for them.

SMX 1 0 No An option for smaller airports like SMX is to have an informal Safety

51217 Management System that will allow us flexibility wi th recording and tracking hazards, and Safety Policy language and so me sort of clearinghouse where safety information can be distr ibuted to all participants. An example would be a place that will provide safety videos and hazard mitigation courses without too mu ch cost.

CYS 1 1 No It was sufficient for pilot studies. Needs to be more clearly defined in

58000 AC relative to the Part 139 requirement.

JQF 1 0 No Outside guidance was required. For the AC, the foll owing is desirable:

60000 Flexibility, Scalability, and Encouragement to use technology, i.e. use of simple-to-use reporting and training systems

JAN 0 1 Unsure No. Lack of details for airport environments. Would like more guidance,

65000 more cost-benefit analysis, and measurable data and rationale from the pilot studies

OSU 1 4 Yes Still trying to figure out.

73000

SIU 1 0 Yes No. Include examples or samples of SMS Manual or A CM with SMS.

80000 The CSPP example in the current AC 150-5200-37 was helpful. Develop the guidance to be helpful to the end user. Cater the guidance to those airports that do not have many resources (like cons ultants) available.FAA SMS Pilot Studies Technical Report May 2011 Page 33

LOCID / SMS- Adding Do you feel the FAA guidance was sufficient? What would

#of tasked SMS you want to see included in Advisory Circular guida nce
Operations Employees FTEs? material?

FTE / PT

JAX 1 0 No Guidance was adequate. It was easy to tap in to SMS from other

94614 industries. In the AC, would like to see documentat ion of safety risk analysis, a standardized method across the aviation industry. Risk matrix needs to be the same, with the same training for everyone. The consultant was using their own format for the risk matrix.

AFW 2 0 Yes We do feel the FAA guidance was sufficient, but cou ld be strengthened

105000 and more clearly defined. The FAA issued the AC in early 2007 that addressed the “concepts”. In our opinion airports w ould benefit by knowing the particulars of the SMS regulation. The SMS AC was written in a broad sense and ultimately offered a basic und erstanding and not clear guidance as you would expect from an AC. In a ddition, it would

be nice to have a chart that shows how SMS will be implemented at the different classes of airports (Ex: Will Class IV ai rports be held to the same standards as Class I airports?) Having a break down of the requirements would be helpful and eliminate questio ns. We would suggest that those airports that participated in th e first and second pilot studies be allowed to participate or offer informat ion to the airports division before and during the rewrite of the AC. Overall better alignment with ACs and current 139 regulations woul d be helpful.

TLH 0 3 No Guidance was okay. Need to focus on what are FAA's expectations for

118000 key positions for SMS implementation. Describe mini mum qualifications, reporting relationships etc. Describe specificall y in the manner that, for example, TSA has specific requirements for airport security

KOA 1 0 Yes Many airports, not just in Hawaii, do not have staf f enough to produce

123772 the kinds of documents and training to promote and implement the program effectively. SMS is a cultural change and therefore should receive any and all coverage to accomplish this; ev en in the circulars. The topics covered in the present circular AC150-52 00-37, are sufficient. I would just add forms and templates.

PIT 2 0 1 It is important that the SMS AC is updated to refle ct provisions specified

144563 in the final SMS rule making. This document was d eveloped as a general guidance document and in order to provide a n orientation to SMS. It would also be beneficial to clarify how va rious SMS initiatives (airport, airline, FAA ATO, FAA ADO) will coincide and become a comprehensive as opposed to a segmented approach to safety.

TEB 0 0 No First AC only provided start-up guidance. Did every thing per the AC.

150000 Need better risk matrix definitions, training requi rements, how is SMS going to be implemented?, specify a baseline vs. ga p analysis

SMF No Many areas need clarification.

150000

AUS 0 1 Yes The FAA guidance is sufficient in most areas. Stat e and local

176914 laws/ordinances relating to open records make it ne arly impossible to protect identities of individuals who identify haza rds.FAA SMS Pilot Studies Technical Report May 2011 Page 34

LOCID / SMS- Adding Do you feel the FAA guidance was sufficient? What would

#of tasked SMS you want to see included in Advisory Circular guida nce
Operations Employees FTEs? material?

FTE / PT

SAT 2 2 Unsure Yes, but with some limitations. We appreciate the c ooperation and

178484 dialogue with the pilot airports. SAT would suggest that a working group of the Pilot Airport be developed to discuss their experiences, lessons learned and input to the AC and Final Rule.

BWI 2 0 1. Forms 2. Examples of SRM 3. Example of complete SMS manual 4.

268005 Define what the FAA Certification Inspector will co ver/look for 5. Define step by step process for implementing SMS 6. Clear and specific auditing requirements 7. SRM documentation 8. Polic y statement requirement 9. What are the requirements for traini ng / education? 10. Define non-punitive reporting 11. How is data prote cted (FOIA) 12. Clear and specific definition of all terms

BFI 0 1 No Guidance was sufficient. Tie in of regulator as a third party. For

280000 example, BFI held an RSA meeting after an aircraft hit a fuel truck and FS, ARP were involved and they agreed on new signag e and marking. Six months later ANM held an RSAT and they tried to change what had just been done.

VGT 0 0 Yes The practical and legal problems inherent in imposi ng SMS

313143 responsibilities on airports for non-movement areas under the control of tenants. The operational costs (including especial ly personnel, recordkeeping, training and liability) for airports and the mechanisms by which airports will fund compliance with their ongo ing SMS obligations. The manner by which airports should resolve conflic ts or competing obligations imposed by the proposed part 139 SMS ma nual, by other SMS requirements (including, but not limited to, Or der 5200.11), SMS requirements imposed on other airfield users (inclu ding part 121 operators and ATO), existing contractual obligation s, and other grant assurance obligations. The liability and public inf ormation issues raised by the obligation to prepare safety risk ass essments and to keep records on safety evaluations of all sorts that may necessarily be available to the public under federal or state law. The responsibilities

of the accountable executive in the context of the practical realities of staff organization and responsibilities at large co mplex airports. The agency needs to provide a clear and unequivocal hie rarchy of authority among the various proposed and forthcoming SMS requ irements so that airports do not have to guess who has authority an d which SMS program governs a particular activity.

SEA 1 0 4 Guidance is sufficient for now as we are trying to learn as we go. The

318000 AC should stress consistent continuity of data and information. There should only be one SRA, not one the airport, one f or FAA Airports Division, and one for ATO. There should be some l anguage that gives relief with regard to data sharing, i.e. exempt fro m FOIA requests and some anonymousness. Much more to learn as we conti nue to

DAB 1 0 No Guidance was sufficient, you have to read it and un derstand it. Would

350000 like to see language to make it clear enough for th e airport operator to be able to get buy-in from the tenants and encourag e the carriers and flight schools that we're all in this together. Tem plates would be a good idea, similar to the template for the AEP. Need a g uideline to walk someone through the process (especially the airport s without aFAA SMS Pilot Studies Technical Report May 2011 Page 35

LOCID / SMS- Adding Do you feel the FAA guidance was sufficient? What would

#of tasked SMS you want to see included in Advisory Circular guida nce
Operations Employees FTEs? material?

FTE / PT

DFW 1 0 No o Personally, I feel the FAA guidance is sufficient , however I am quite

652261 familiar with safety risk management and associated processes. The AC, and all associated SMS documents published by t he FAA should be better aligned with one another and include consist ent verbiage/definitions (i.e. SRA vs. Safety Assessmen t Screening)o The current AC provides an appendix and uses an example of SRM during a construction plan, this may be more appropriate to include in FAA Order 5200.11, possibly include a different example (mayb e 2 or 3)?

ATL 1 3 Yes I felt there was a lack of guidance material made a vailable for the pilot

950119 studies; However the airport collaboration has help ed in the area. We would like to see more guidance documents on Safety Risk Management Resources, and SMS Training Material.

DTW 1 0 1 AC: Description what an airport will be responsible to prove or provide

4622520 for SMS certification and also during a certificate inspection.FAA SMS Pilot Studies Technical Report May 2011 Page 36



## APPENDIX C: SMS Pilot Study Interview Comments

Airport: King County International Airport/Boeing Field, Seattle WA

Team Member: Bill Watson

Airport contact: Mike Colmant # of Operations:
280,000 # of Employees:

64 Documents

delivered for Pilot Study: Gap Analysis, SMS

Manual How many FTEs currently work on

SMS? One-half FTE Do you anticipate adding FTEs when implementation is complete? No Do you envision FTEs or consultants managing your SMS after implementation? No Did you use a consultant in your SMS process? If so, which one? In

what areas? Yes, Jacobs Consultancy What were your challenges in interpreting the SMS process? Applying to scope of operations What types of risks/hazards did you put through the SRM process during the Pilot Study? 1. Stop bar on taxiway leading to non standard use pavement, 2. Hazard investigation after wind tip went

thru fuel truck cab

What did the Gap Analysis Reveal? Non-movement area safety. Hot spots in movement a rea. Signing marking and lighting. Safety area focus at BI

intersection. What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? Potential liability exposure, Program scalability, Third party roles and responsibilities, electronic vs. paper fo rmat,

database. What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety

concerns

• Lower long-term costs

• Others 1. More proactive on safety. 2. Over all Awareness. What were the key findings at your airport, as part of the Pilot Study? This caused BFI to focus on unique elements on airp ort from a safety prospective.

Did you feel the FAA guidance was sufficient? What would you want to

see included in the SMS AC? Guidance was sufficient. Tie in of regulator as a third party. For example, BFI held a RSA meeting after an aircraft hit a fuel truck and FS, ARP were involved and they agreed on new signage and marking. Six months later ANM held and RSAT and they tried to change wh at had just been done. May we put your information on the public docket? Please send electronic copies along with your ok

to use the information. Yes, Will send copies



### Table 1 – Boeing Field, WAFAA SMS Pilot Studies Technical Report May 2011 Page 37



### Airport: Concord Regional Airport,

NC

Team Member: Michel Hovan

Airport contact: Richard Lewis # of Operations:
60,000 # of Employees:

34 FTE 10 PTE Documents

delivered for Pilot Study: Gap Analysis, SMS Manual, Training Manual, SOP, Implementation

Manual How many FTEs currently work on

SMS? One FTE Do you anticipate adding FTEs when implementation is complete? No Do you envision FTEs or consultants managing your SMS after implementation? Yes, partially, but the airpo rt takes the lead also Did you use a consultant in your SMS process? If so, which one? In what areas? Yes, Aviation Safety Consultants. Used in all areas

What were your challenges in interpreting the SMS process? (1) Trying to determine where SMS applied. The scop e and the extent, beyond 139.(2) Non-punitive report ing was (and still is) an issue. It contradicts the Cit y's regulations. Airport employees are city employees. (3) Trying to keep attendance at "SMS' safety committee s was an issue, especially for non-airport participan ts

What types of risks/hazards did you put through the SRM process during the Pilot Study? (1) Fueling mats - procedures, (2) Refueling trucks - getting on top of the trucks - limit this, (3) mana ging people traffic on ramps during race days (solution was to paint walkways)

What did the Gap Analysis Reveal? Management and front line personnel had different interpretation and opinion of safety. This revealed gaps in communication, and the "buying-in" of safety. What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? Difficulties in introducing technology to all. Fina ncial incentives to help with the safety efforts did not work. Use of field-tough tablets makes sense though What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety

concerns

• Lower long-term costs

• Others (1) our Safety Programs were not as effective as we initially thought, (2) There were some disconnects between programs, (3) communication across the organizations needs to be improved (4) lower costs by preventing litigation, (5) effective documentation system is key What were the key findings at your airport, as part of the Pilot Study? Gaps in communication between management and front

line

Did you feel the FAA guidance was sufficient? What would you want to

see included in the SMS AC? Outside guidance was required. For the AC, the foll owing is desirable: Flexibility, Scalability, and Encoura gement to use technology, i.e. use of simple to use reporting and training systems May we put your information on the Yes, did send co pies alreadyFAA SMS Pilot Studies Technical Report May 2011 Page 38



### Airport: Concord Regional Airport,

NC

Team Member: Michel Hovan

Airport contact: Richard Lewis # of Operations:
60,000 # of Employees:

34 FTE 10 PTE Documents

delivered for Pilot Study: Gap Analysis, SMS Manual, Training Manual, SOP, Implementation

Manual public docket? Please send electronic copies along with your ok

to use the information.



### Table 2 – Concord Regional Airport, NCFAA SMS Pilot Studies Technical Report May 2011 Page 39



### Airport: Toledo, Ohio

Team Member: Michel Hovan

Airport contact: Steve Arnold # of Operations:
47,000 # of Employees:

28 Documents

delivered for Pilot Study: Gap Analysis, SMS
Manual, Implementation Manual (part of the Study Plan),

three SRA's How many FTEs currently work

on SMS? One FTE Do you anticipate adding FTEs when implementation is complete? Depends on the NPRM final rule Do you envision FTEs or consultants managing your SMS after implementation? Depends on the NPRM final rule, at first yes to get up to speed Did you use a consultant in your SMS process? If so, which one?

In what areas? Yes, SMQ Airport Services, in all areas

What were your challenges in interpreting the SMS process? Guidelines were for airlines, was different for air ports. Problem interpreting and applying the Gap Analysis, not sure how to use SMS for different parts of the airp ort What types of risks/hazards did you put through the SRM process during the Pilot Study? 1. Annual Sports Car Event, 2. Snow removal equipme nt, 3. runway markings, all issues were mitigated What did the Gap Analysis Reveal? Not sure how to interpret part 139 and the Gap analysis

What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? As a smaller organization, hard to implement SMS. Problems with FAA LOBs to attend meetings, etc. Als o not always the right people, upper mgt delegated some l ower level people. How many people to participate in the se SMS meetings (too many at times, too few at other times ) What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety concerns

• Lower long-term costs

• Others 1. SMS does raise the level of safety awareness, 2. discovered interesting chemistry between different people and airport departments What were the key findings at your airport, as part of the Pilot Study? Made us aware that processes and procedures need to be revisited and improved all the time. Cultural chang es. Talk about Safety and SMS helped Did you feel the FAA guidance was sufficient? What would you

want to see included in the SMS

AC? Guidance was not sufficient: some was misleading (i n terms of what is applicable - and scalability). Need clea r definition of responsible parties: e.g. for runways - AT vs. t he airport May we put your information on No, not at this timeFAA SMS Pilot Studies Technical Report May 2011 Page 40



### Airport: Toledo, Ohio

Team Member: Michel Hovan

Airport contact: Steve Arnold # of Operations:
47,000 # of Employees:

28 Documents

delivered for Pilot Study: Gap Analysis, SMS
Manual, Implementation Manual (part of the Study Plan),

three SRA's the public docket? Please send electronic copies along with your

ok to use the information.



### Table 3 – Toledo, OHFAA SMS Pilot Studies Technical Report May 2011 Page 41



### Airport: Cheyenne Regional Airport

Team Member: Bill Watson

Airport contact: Dave Haring # of Operations:
58,000 # of Employees:

10 Documents

delivered for Pilot Study: SMS Manual, SMS Implementation Plan, Gap Analysis, SMS Report How many FTEs currently work

on SMS? One FTE Do you anticipate adding FTEs when implementation is complete? No Do you envision FTEs or consultants managing your SMS after implementation? One FTE

Did you use a consultant in your SMS process? If so, which one?

In what areas? Heidi Beneman, Faith Group Wrote SMS Manual and Implementation Plan. Wrote and vetted forms. Did Technology evaluation. Ran first two assessments a nd

assisted in third.

What were your challenges in interpreting the SMS process? Definitions- What is significant, catastrophic. A uditor Inspection requirements that could be foreseen. Te chnology Integration. Cultural buy in. What types of risks/hazards did you put through the SRM process during the Pilot Study? 1. Rwy 27 Retaining Wall, 2. Movement Area Signs, 3

. Safety Area Demarcation, 4. Take trees down for a pproach

zone clearances. What did the Gap Analysis

Reveal? They had gaps in all areas. Some minor and some significant. No area where they were fully complia nt.

What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? Public Disclosure Protection, SMS in Non Movement T enant Areas, SMS Technology Development, "Non Punitive" Policy, Definitions for SRM, Budget: Implementatio n, Corrective Actions, Staffing SMS when employees alr eady

wear several hats.

Airport Pilot Similarities: All had 139 Safety Self Inspections, Gap Analysis varied in size/complexity, Full time S MS employee is challenging, Budgeting will be difficul t, All had some technology for support, Training tracking coul d be tied to existing SIDA/Driver’s Training, Culture CHANGE is a challenge

Airport Pilot Differences: The larger the airport the more complicated the safety issues, Governance varies (“ Policy”), Safety threats vary, Larger airports have more reso urces including technology, Smaller airports can implemen t more easily, Employee turnover at small airports is lowe r What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach 1. Improve communication among all stakeholders. 2. Increased awareness of airport environment itself. 3. Creation of process does not allow items to fall th rough

cracksFAA SMS Pilot Studies Technical Report May 2011 Page 42



### Airport: Cheyenne Regional Airport

Team Member: Bill Watson

Airport contact: Dave Haring # of Operations:
58,000 # of Employees:

10 Documents

delivered for Pilot Study: SMS Manual, SMS Implementation Plan, Gap Analysis, SMS Report

• One party identified as being responsible/in charge of safety concerns

• Lower long-term costs

• Others

What were the key findings at your airport, as part of the Pilot Study? • Sensitivity to perceived criticisms, Verbiage issu es amongst airports

• Governance and Legal, ATC and airports have differ ent

focus

• ATC hazard life risk only

• SMS is a PROCESS that must fit the airport, not th e other way around

• Risk Matrix Chart color variations

• Identification verbiage for Severity and Probabili ty

Variances

• Definitions developed over time

• Tolerance levels vary

• Assessments became more calculated Did you feel the FAA guidance was sufficient? What would you

want to see included in the SMS

AC? It was sufficient for Pilot Study. Needs to be mo re clearly defined in AC for a regulatory environment. See o ther

comments May we put your information on the public docket? Please send electronic copies along with your

ok to use the information. Yes, will send a copy



### Table 4 – Cheyenne Regional Airport, WYFAA SMS Pilot Studies Technical Report May 2011 Page 43



### Airport: Ohio State University

Team Member: Bill Watson

Airport contact: Seth Young # of Operations:
73,000 # of Employees:

70 Documents

delivered for Pilot Study: SMS Manual, SMS Implementation Plan, SMS Gap Analysis How many FTEs currently work on SMS? 3 FTE's One full time and 3-4 part time Do you anticipate adding FTEs when implementation is complete? Add one full time. Use existing employees as par t time Do you envision FTEs or consultants managing your SMS after implementation? Probably not- Maybe use a v ender for software Did you use a consultant in your SMS process? If so, which one? In what areas? No, Used internal resources from the university What were your challenges in interpreting the SMS process? Not all that much literature out there. Had to exp lore around. It was a challenge to be one of the first to do it What types of risks/hazards did you put through the SRM process during the Pilot Study? 1. Risk assessment of airfield incursion hot spots . 2. Wildlife Hazards, birds, unreported bird strikes. 3. Non Movement Area Operations

What did the Gap Analysis

Reveal? Part 139 does not go into non movement area. Form ality of safety program required for SMS. More paperwork a nd process. Proactive Safety policy and promotion

What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? Easier than expected to get buy in from users. Cha llenge was to get buy in from wider airport community to c ollect hazards. Experimenting with different hazard repo rting

models. Education of IT staff takes time. Overal l, not as challenging as he had thought. It will take a long time to change the culture What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety concerns

• Lower long-term costs

• Others 1. Revealed potential hazards on non movement area- blind spots. 2. Formalizing movement of vehicles. 3 . Wildlife mitigation - Finding birds on runway in morning whe n tower
has been closed. 4. Formal lines of communicatio n on safety has been facilitated, they now meet quarterl y. 4. Brings in a culture of safety. 5. Have not experi enced cost savings yet, it will cost to hire new staff person What were the key findings at your airport, as part of the Pilot program? Self identifying hot spots, mitigate before it happ ens for safety in non movement areas Did you feel the FAA guidance was sufficient? What would you

want to see included in the SMS AC? Still trying to figure out. May we put your information on the public docket? Please send Will send to me with caveats by 10-15 AprilFAA SMS Pilot Studies Technical Report May 2011 Page 44



### Airport: Ohio State University

Team Member: Bill Watson

Airport contact: Seth Young # of Operations:
73,000 # of Employees:

70 Documents

delivered for Pilot Study: SMS Manual, SMS Implementation Plan, SMS Gap Analysis electronic copies along with your

ok to use the information.



### Table 5 – Ohio State University, OHFAA SMS Pilot Studies Technical Report May 2011 Page 45



### Airport: Austin-Bergstrom Intl Airport Team Member: Joe Washington

Airport contact: Scott Madole # of Operations:
176,914 # of Employees:

340 (Department of Aviation) Documents

delivered for Pilot Study: Gap Analysis Safety Management

Manual How many FTEs currently work on SMS? One (part-time) Do you anticipate adding FTEs when implementation is complete? Yes Do you envision FTEs or consultants managing your SMS after implementation? FTEs Did you use a consultant in your SMS process? If so, which one? In what areas? Yes - Jacobs Carter Burgess What were your challenges in interpreting the SMS process? SMS process has not y et been fully developed. What types of risks/hazards did you put through the SRM process during the Pilot Study? None

What did the Gap Analysis

Reveal? Gaps existed in the following areas: SMS Policy St atement, Training, Non-punitive reporting systems, Implement ation Plan, detailed SRA documentation, approval and foll ow-up of mitigations by senior management, description of airport risk management program, self-auditing process, pla n to integrate SMS program into overall airport operatio ns, promotion of safety awareness, documentation of les sons learned What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? Approval of SMS Policy with inclusion of non-punitive policy What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety concerns

• Lower long-term costs

• Others Not yet implemented

What were the key findings at your airport, as part of the Pilot Study? The FAA guidance is sufficient in most areas. Howe ver, the timeline for incorporating airport tenants is unrea sonable (we need to put the SMS in-place for airport owner empl oyees first). State and local laws/ordinances relating t o open records make it nearly impossible to protect identi ties of individuals who identify hazards. Did you feel the FAA guidance The FAA guidance is s ufficient in most areas. State andFAA SMS Pilot Studies Technical Report May 2011 Page 46



### Airport: Austin-Bergstrom Intl Airport Team Member: Joe Washington

Airport contact: Scott Madole # of Operations:
176,914 # of Employees:

340 (Department of Aviation) Documents

delivered for Pilot Study: Gap Analysis Safety Management

Manual was sufficient? What would you

want to see included in the SMS

AC? local laws/ordinances relating to open records make it nearly impossible to protect identities of individuals who identify

hazards. May we put your information on the public docket? Please send electronic copies along with your

ok to use the information. Yes



### Table 6 – Austin-Bergstrom International, TXFAA SMS Pilot Studies Technical Report May 2011 Page 47



### Airport: San Antonio International Airport Team Member: Joe Washington Airport contact: Tim O'Krongley or

John Chase # of Operations: # of Employees: Documents

delivered for Pilot Study: Gap Analysis, SMS

Manual

How many FTEs currently work on

SMS? One (1) SMS Manager, One (1) Safety Specialist. Two other who have some responsibilities on a limited b asis

with SMS Do you anticipate adding FTEs when implementation is complete? Will depend upon requir ements of Final Rule Do you envision FTEs or consultants managing your SMS after implementation? City Staff

Did you use a consultant in your SMS process? If so, which one? In

what areas? Yes. First Pilot Study - Critical Path, Inc. for in itial program documents. Third Pilot Study we are using Landry Consultants and their sub-consultant team members for SRAs and some training materials

What were your challenges in interpreting the SMS process? Changing the culture, stakeholder acceptance of som e safety initiatives, participation of stakeholders i n the SRA process and getting usable information from the pre vious

Pilot Studies. What types of risks/hazards did you put through the SRM process during the Pilot Study? RSAT issue, GA/Customs issue, Wildlife issue and a Terminal fire evacuation plan What did the Gap Analysis Reveal? That 139 is a go od base for SMS What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? Need to communicate with stakeholders, understand t he time it will take to implement SMS at the Airport ( 5-7 years) What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety

concerns

• Lower long-term costs

• Others There are many, and this section should be formally developed in a working group of Pilot Study Airport s prior to final rule making. Here are a few we see: trend tracking of unsafe issues, a formal safety process and structure, SRA and the associated benefits, overall awareness of safety culture What were the key findings at your airport, as part of the Pilot Study?

Did you feel the FAA guidance was sufficient? What would you want to

see included in the SMS AC? Yes, but with some limitations. We appreciate the cooperation and dialogue with the Pilot Study airpo rts. SAT would suggest that a working group of the Pilot Study airports be developed to discuss their experi ences, lessons learned and input to the A/C and Final Rule May we put your information on the public docket? Please send electronic copies along with your ok

to use the information. Yes



### Table 7 – San Antonio International Airport, TXFAA SMS Pilot Studies Technical Report May 2011 Page 48



### Airport: Baltimore Washington

International

Team Member: Travis Fiebelkorn

Airport contact: George Haehl # of Operations: 346 Daily Departures # of Employees:

Approx 550 Documents

delivered for Pilot Study: Manual, Gap Analysis, Implementation

Plan How many FTEs currently work on

SMS? 2 Do you anticipate adding FTEs when implementation is complete? Unknown at this time. C urrent budget issues Do you envision FTEs or consultants managing your SMS after implementation? Unknown at this time. Current budget issues Did you use a consultant in your SMS process? If so, which one? In

what areas? Hired a consultant for the entire process. ADCI (Ai rport Design Consultants INC) What were your challenges in interpreting the SMS process? Defining SMS to the organization / management (what does SMS mean)? What types of risks/hazards did you put through the SRM process during the Pilot Study? None

What did the Gap Analysis Reveal? Shortcomings in communication / training (not willi ng to speak in any specifics).

What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? Non-punitive reporting is a big problem with organi zation and Legal Dept. Highly suggest hiring a consultant to develop the manual and implementation plan. Said th ey brought an outside perspective and viewpoint that i s really important What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety

concerns

• Lower long-term costs

• Others BWI has not implemented SMS fully. However, they ha ve noticed an increase in safety awareness. What were the key findings at your airport, as part of the Pilot Study? He noticed an improvement in communication througho ut the organization, quality of training and safety aw areness

Did you feel the FAA guidance was sufficient? What would you want to

see included in the SMS AC? 1. Forms 2. Examples of SRM 3. Example of complete

SMS manual 4. Define what the FAA Certification Inspector will cover/look for 5. Define step by ste p process for implementing SMS 6. Clear and specific auditing requirements 7. SRM documentation 8. Polic y statement requirement 9. What are the requirements for training / education 10. Define non-punitive report ing 11. How is data protected (FOIA) 12. Clear and specific

definition of all terms May we put your information on the public docket? Please send electronic copies along with your ok

to use the information. Yes, SMS Manual (sending disk in the mail)FAA SMS Pilot Studies Technical Report May 2011 Page 49



### Table 8 – Baltimore Washington International, MDFAA SMS Pilot Studies Technical Report May 2011 Page 50



### Airport: Daytona Beach International Airport, Daytona Beach, FL

Team Member: Laurie Jane DragonasAirport contact: John MurrayOperations Manager # of Operations:
350,000 # of Employees:

38 Documents

delivered for Pilot Study: Gap Analysis, SMS Manual, SMS Implementation

Plan How many FTEs currently work on

SMS? One Do you anticipate adding FTEs when implementation is complete? No. Will not add anymore unless there is federal $

assistance Do you envision FTEs or consultants managing your SMS after implementation? No Did you use a consultant in your SMS process? If so, which one? In

what areas? Yes, Wilbur Smith

What were your challenges in interpreting the SMS process? Many. Was Pilot Study for consultant too. Who does what? Tower, ERAU, air carriers, each have their ow n separate SMS this is biggest challenge

What types of risks/hazards did you put through the SRM process during the Pilot Study? 1. Alert calls - have a lot of them and ARFF staffi ng is

issue. 2. Vehicle Pedestrian deviations. 3. Pilot training, have a lot of flight schools on airport, ERAU has 2 50 ops / day at peak

What did the Gap Analysis Reveal? FBO, Nasser, ERAU, Flight schools...how do we get the m under ONE umbrella? Need a formal system under SMS program. Larger airports will have more challenges

What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? Understand what it is you're being asked to do. Try to get as much info as you can. Try to get buy-in from ten antsthey have weekly meetings to talk about safety issu es. Communication is critical What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety

concerns

• Lower long-term costs

• Others More active safety committee meets every week, safe ty is now a major component of monthly tenant meetings. Interns from Embry Riddle are tracking projects suc h as wildlife, alert calls, medical calls, sign changes. John Murray is the point person What were the key findings at your airport, as part of the Pilot Study? Development is needed- need higher management involvement and support

Did you feel the FAA guidance was sufficient? What would you want to

see included in the SMS AC? Guidance was sufficient, have to read it and unders t and it. Would like to see language to make it clear enough for the airport operator to be able to get buy-in from the tenants and encourage the carriers, & flight schools that w e're all in this together. Templates would be a good idea, s imilar to the template for the AEP. need a guideline to wa lk someone through the process ( specially the airport s without a consultant)FAA SMS Pilot Studies Technical Report May 2011 Page 51



### Airport: Daytona Beach International Airport, Daytona Beach, FL

Team Member: Laurie Jane DragonasAirport contact: John MurrayOperations Manager # of Operations:
350,000 # of Employees:

38 Documents

delivered for Pilot Study: Gap Analysis, SMS Manual, SMS Implementation

Plan May we put your information on the public docket? Please send electronic copies along with your ok

to use the information. Yes, willing to share documents on the docket. Will send a PowerPoint about the race, use of graphic style NOT AM, gap analysis, manual and SMS implementation plan



### Table 9 – Daytona Beach International, FLFAA SMS Pilot Studies Technical Report May 2011 Page 52



### Airport: Dubuque, Iowa

Team Member: Travis Fiebelkorn

Airport contact: Todd Dalsing # of Operations: 50,000/year # of Employees:

23 Documents

delivered for Pilot Study: SMS Manual, Gap Analysis, Implementation

Manual How many FTEs currently work on

SMS? 4 (limited Basis...not full time on SMS...absorbed into other duties) Do you anticipate adding FTEs when implementation is complete? No.....possibility of add ing consultant support Do you envision FTEs or consultants managing your SMS after implementation? Depends on future budget. At this point, they would need to absorb into existing numbers Did you use a consultant in your SMS process? If so, which one? In what

areas? ARA - Applied Research Associates (Prime) Also used a sub

What were your challenges in interpreting the SMS process? DBQ has been involved in SMS since the beginning. They had the benefit of having an airport manager t hat was prior military and had extensive SMS experience What types of risks/hazards did you put through the SRM process during the Pilot Study? Construction safety issues, ground handling and air craft receipt and dispatch (pushing and pulling aircraft) , hot spots (runway movement areas) What did the Gap Analysis Reveal? Couldn’t recall What difficulties/ challenges have you experienced during the Pilot Study?

Lessons learned? How do they implement, maintain and fund with curre nt staffing and resources? In a challenging budget

environment What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety

concerns

• Lower long-term costs

• Others DBQ said they already had a safety culture, but thi s experience really enforced the big picture mentalit y and made them look outside the box at safety in general , as well as safety areas. Approaches to best possible solutions. DQB has also created an anonymous safet y reporting hotline on their website starting soon. T he reports will go directly to the airport manager and safety

chief

What were the key findings at your airport, as part of the Pilot Study? Found a high rate of damage with pushing and pullin g aircraft into and out of hangars and gate areas. Tr aining and fatigue issues, general awareness

Did you feel the FAA guidance was sufficient? What would you want to

see included in the SMS AC? Thought the guidance was sufficient. (had prior SMS experience on their side) They highlighted that sco pe and complexity will affect the overall program. The y felt they had a good grasp on what they needed. They sai d they relied heavily on the consultants to create th e documents for them May we put your information on the public docket? Please send electronic copies along with your ok to use the

information. Yes



### Table 10 – Dubuque, IAFAA SMS Pilot Studies Technical Report May 2011 Page 53



### Airport: Jacksonville International Airport/ Jacksonville, FL

Team Member: Laurie Jane Dragonas

Airport contact: Roger Studenski # of Operations:

? # of Employees:

3500 Documents

delivered for Pilot Study: Gap Analysis, SMS Manual, SMS Implementation Study, SMS Implementation

Plan How many FTEs currently work

on SMS? One Do you anticipate adding FTEs when implementation is complete? No. Will be rolling out SMS at GA airports, maybe 1 more

FTE for the GA Do you envision FTEs or consultants managing your SMS after implementation? No Did you use a consultant in your SMS process? If so, which one?

In what areas? Yes, ARA did 1st Pilot Study and developed manual. ESIS consultants did third Pilot Study

What were your challenges in interpreting the SMS process? Safety Risk analysis, to what depth, how complicate d, What is the threshold? Participation of tenants is a ch allenge. Not all airlines participate because they have their ow n SMS programs. If not all tenants participate, the airpo rt's SMS program will suffer What types of risks/hazards did you put through the SRM process during the Pilot Study? 1. Wildlife. 2. FOD. 3. aircraft/ vehicle movement s What did the Gap Analysis

Reveal? Risk analysis process needs to be put in place. Hav e a lot of issues inside the gate & baggage areas

What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? The consultant recommended a drop box for hazard re portstoo archaic. Instead went 'high tech' with a web-ba sed report designed by a local contractor. Promotion is a maj or challenge, have to be a cheerleader to promote the program What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety concerns

• Lower long-term costs

• Others Heightened level of awareness of hazards and docume nting the process. Proactive about documenting hazards an d then investigating and correcting, things get acted upon . The safety committee was very active at first but now participation is lower, as the novelty has worn off

What were the key findings at your airport, as part of the Pilot Study? Need to start somewhere. Develop a foundation for S MS to get a grasp, then once foundation is set, easy to m odify. Can make adjustments easily in the future once you have developed a reporting system. A consultant may be helpful to make sure things stay on track with the implemen tation plan Did you feel the FAA guidance Guidance was adequate . It was easy to tap in to SMS fromFAA SMS Pilot Studies Technical Report May 2011 Page 54



### Airport: Jacksonville International Airport/ Jacksonville, FL

Team Member: Laurie Jane Dragonas

Airport contact: Roger Studenski # of Operations:

? # of Employees:

3500 Documents

delivered for Pilot Study: Gap Analysis, SMS Manual, SMS Implementation Study, SMS Implementation

Plan was sufficient? What would you

want to see included in the SMS

AC? other industries. In the AC, would like to see docu mentation of safety risk analysis, a standardized method acro ss the aviation industry. Risk matrix needs to be the same , with the same training for everyone. The consultant was usi ng their

own format of risk matrix May we put your information on the public docket? Please send electronic copies along with your

ok to use the information. Yes, Keri already has copies of everything from JAX



### Table 11 – Jacksonville International, FLFAA SMS Pilot Studies Technical Report May 2011 Page 55



### Airport: Kona International Team Member: Abel Tapia

Airport contact: Martinez Jacobs # of Operations:

XXX # of Employees:

XXX Documents

delivered for Pilot Study: SMS manual, gap analysis and implementation plan How many FTEs currently work on SMS? Five for the airport system Do you anticipate adding FTEs when implementation is complete? Yes, 1 per airport in our system of 15 airports

Do you envision FTEs or consultants managing your SMS after implementation? I would very much like to add at least one staff pe rson to manage and/or support the program. We were unable to do this previously, however, there may be opportunity in the new administration to bring staff aboard Did you use a consultant in your SMS process? If so, which one?

In what areas? Jacobs Consultant What were your challenges in interpreting the SMS process? There were no known problems; the challenge came wi th interviews and long distance communication What types of risks/hazards did you put through the SRM process during the Pilot Study? Obstacle Free Zone, however the consultant did a po or job assessing the hazard

What did the Gap Analysis

Reveal? Gap Analysis for ICAO vs FAR part 139 did not revea l anything too earthshaking , but there was issues wi th Emergency Equipment traversing level surfaces What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned?

What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety concerns

• Lower long-term costs

• Others Selection of a well qualified consultant is paramou nt. In order for ANY safety plan, program or management sy stem
to be effective it MUST have dedicated staff to adm inister it. Time and time again my experience is that this task is an

add- on to someone or some unit that already has a full plate. The consultants recognized this and recommended the creation of an SMS safety officer position. Such p osition

remains to be established at Kona.

A more robust driver's training program should be p art of SMS. The safety committee should have been better developed. It took a year after the consultant/Engi neers and FAA program Manager went out to the site to improve the process. Tracking system consists of email for link age on new positions. The Airport system's fire chief is designated as the decision maker. There is no significant cha nge in airport operating cost for SMS. the Self Inspectio n program ties into SMS What were the key findings at your airport, as part of the Pilot Study? Require additional: Driver's training, SMS qualifi ed training, Self inspection training Did you feel the FAA guidance was sufficient? What would you Many airports, not just in Hawaii, do not have staf f enough to produce the kinds of documents and training to prom ote andFAA SMS Pilot Studies Technical Report May 2011 Page 56



### Airport: Kona International Team Member: Abel Tapia

Airport contact: Martinez Jacobs # of Operations:

XXX # of Employees:

XXX Documents

delivered for Pilot Study: SMS manual, gap analysis and implementation plan

want to see included in the SMS

AC? implement the program effectively. SMS is a cultur al change and therefore should receive any and all coverage t o accomplish this; even in the circulars. The topics covered in the present circular AC 150/5200-37, are sufficient . I would just add forms and templates May we put your information on the public docket? Please send electronic copies along with your ok to use the information. Yes, will email allowabl e documents



### Table 12 – Kona International, HIFAA SMS Pilot Studies Technical Report May 2011 Page 57



### Airport: Sacramento International Team Member: Abel Tapia

Airport contact: Bonnie Hankins # of Operations:
150,000 # of Employees:

425 Documents

delivered for Pilot Study: Draft SMS

manual and
report How many FTEs currently work on SMS? Zero - we have not implemented Do you anticipate adding FTEs when implementation is complete? No - it will be incorporated into existing position s in Airport Operations Do you envision FTEs or consultants managing your SMS after implementation? No Did you use a consultant in your SMS process? If so, which one? In

what areas? Yes, the Faith Group, first Pilot Study What were your challenges in interpreting the SMS process? Will need to review the report and reach out to oth er staff

involved to answer What types of risks/hazards did you put through the SRM process during the Pilot Study? Airfield facilities and operational practices (ramp s, perimeter, etc) What did the Gap Analysis

Reveal? Have no answer at this time, will comment at a late r date What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? The challenges were primari ly addressed by the consultant What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety

concerns

• Lower long-term costs

• Others Because we have not implemented, minimal benefit ha s been gained. We did discover some potential hazards that we resolved, so did result in improved safety What were the key findings at your airport, as part of the Pilot Study? Again, the det ails will be in the report Did you feel the FAA guidance was sufficient? What would you want to

see included in the SMS AC? Many areas need clarification. May we put your information on the public docket? Please send electronic copies along with your

ok to use the information. Will need to obtain clea rance from upper management



### Table 13 – Sacramento International, CAFAA SMS Pilot Studies Technical Report May 2011 Page 58



### Airport: Santa Maria Municipal Team Member: Abel Tapia

Airport contact: Chris Hastert / Rick Tokoph # of Operations:
51,217 # of Employees:

10 Documents

delivered for Pilot Study: Gap Analysis, and

SMS Manual How many FTEs currently work

on SMS? One Do you anticipate adding FTEs when implementation is complete? No Do you envision FTEs or consultants managing your SMS after implementation? Due to the additional cost, most likely it would be done in

house

Did you use a consultant in your SMS process? If so, which one?

In what areas? Jacobs consulting produced the gap analysis and SMS document. Side note they provided a document that had a different airports name throughout. They also prov ided an abbreviated training session What were your challenges in interpreting the SMS process? There was not a lot of direction from the FAA. Was not sure what the FAA was looking for What types of risks/hazards did you put through the SRM process during the Pilot Study? We used a simulated FOD hazard. At the time the doc ument was produced there were not a lot of safety issues that have been unmitigated

What did the Gap Analysis

Reveal? We were not conducting regular meetings with tenant s. There were informal safety resolution procedures. T he airport would take care of issues as notified. The SMS process allowed airport personnel to actively commu nicate with the airport users

What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? Development of a true safety policy and objective w as hard since you really wouldn’t promote unsafe activities . We didn’t really know where this document and the mandatory r ecords

fall within SSI and FOIA standards and how that cou ld affect future responses. We are not sure if documenting a mitigation would come back to haunt us. We learned that we are already communicating hazard s fairly well since we are a smaller airport. Daily i nteraction with our tenants has provided a good flow of commun ication What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety concerns

• Lower long-term costs

• Others We have taken a more proactive approach with holdin g tenant safety meetings using the local FAA Safety T eam comprised of tenants

What were the key findings at your airport, as part of the Pilot Study? Tenants want to help out as long as it doesn’t cost them anything. Since our size allows us easy access and a familiarity with our tenants, a formal SMS seemed t o add another layer of bureaucracy into a community that alreadyFAA SMS Pilot Studies Technical Report May 2011 Page 59



### Airport: Santa Maria Municipal Team Member: Abel Tapia

Airport contact: Chris Hastert / Rick Tokoph # of Operations:
51,217 # of Employees:

10 Documents

delivered for Pilot Study: Gap Analysis, and

SMS Manual has skepticism over additional controls

Did you feel the FAA guidance was sufficient? What would you

want to see included in the SMS

AC? An option for smaller airports like SMX to have an informal safety Management System that will allow us flexibi lity with recording and tracking hazards. Safety Policy langu age and some sort of clearinghouse where safety information can be distributed to all participants. Such as, a place t hat will provide safety videos and hazard mitigation courses without

too much cost May we put your information on the public docket? Please send electronic copies along with your ok to use the information. Yes, will email document s



### Table 14 – Santa Maria Municipal, CAFAA SMS Pilot Studies Technical Report May 2011 Page 60



### Airport: Dallas Fort Worth, TX Team Member: Joe Washington

Airport contact: Julie Schreacke # of Operations:
652,261 # of Employees:

1,775 Documents

delivered for Pilot Study: Gap analysis, SMS Implementation Plan ,SMS

Manual and

Selected Tools How many FTEs currently work

on SMS? 1 FTE Operations Safety Administrator dedicated to SMS (manager level) Do you anticipate adding FTEs when implementation is complete? Additional employees dedicated to the SMS effort ar e not currently planned for the DFW FY12 budget, however that need will be revisited in upcoming months Do you envision FTEs or consultants managing your SMS after implementation? The current Operations Safety Administrator positio n is planned to be maintained after implementation and o ther positions will be considered based on need

Did you use a consultant in your SMS process? If so, which one?

In what areas? Yes, a consultant was used for the first Pilot Stud y and is currently being used for the implementation study Applied Research Associates (ARA) has been the prin ciple

consultant for all deliverables/activities in both Pilot Studies (they have enlisted the assistance of sub-consultan ts in their

efforts

What were your challenges in interpreting the SMS process? Interpretation of possible legal/liability issues w ith no guidance Accountability of tenants not defined/regulated Methodology for “inspection”/FAA oversight of SMS w ithin

ACM/139 framework not defined

What types of risks/hazards did you put through the SRM process during the Pilot Study? Winter weather operations Surface incidents on the aircraft movement areas (A MA) Construction ramp safety (DFW Terminal Redevelopmen t and Improvement Plan) Results/findings are still pending with consultant

What did the Gap Analysis

Reveal? • Gap Analysis results determined and reported by consultant as part of first Pilot study

• Several SMS elements are present, though not yet a ll formalized, and, therefore, not consistently or systematically applied. Need to establish/refine f ormal “safety policy.”

• Responsibilities – need to clarify with respect to SMS at

all levels

• Coordination – many SMS processes require crossfunctional working coordination and cooperation, th is occurs on a case-by-case basis currently but organizational processes will need to be improved

• Documentation – with the exception of all those re quired by regulation, all other actions and activities rel ated to safety issues or hazards will need to be formalized

• Risk management – hazard identification, risk assessment and mitigation will need to become a systematic part of all processes, in particular wit h regard to current airside hazards facing the organization and change managementFAA SMS Pilot Studies Technical Report May 2011 Page 61



### Airport: Dallas Fort Worth, TX Team Member: Joe Washington

Airport contact: Julie Schreacke # of Operations:
652,261 # of Employees:

1,775 Documents

delivered for Pilot Study: Gap analysis, SMS Implementation Plan ,SMS

Manual and

Selected Tools

• Communication – there is a need for a formalized a nd systematic process and mechanism to promote and ensure the free exchange of safety information betw een staff at all levels of the organization, between se ctions and departments, between divisions and with externa l service providers

• Accountability – current FAA framework does not ex tend airport authority to the non-movement area. The ef forts made by the Airport to improve safety performance b y fostering cooperation amongst all is sometimes met with diverging and competing interests. To resolve this and ensure SMS is successful, the accountability and responsibility can only be accepted by the Airport if supported by the authority under an unambiguous regulatory framework.

• Performance Indicators – there will need to be a p rocess for establishing and measuring comprehensive safety goals, objectives and key performance indicators – collection of safety data will need to be linked to such safety objectives

What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? • Coordination of key stakeholders for SRA panel meetings challenging – possibly establish a “core” identified group committed to the effort that can e asily

convene at short notice

• Inherent bias/natural human instinct with internal and external stakeholders – people have the tendency to “defend” their businesses in the name of safety, al so they realize that identification of hazards may “cr eate work” for their organization, these may skew their hazard risk ratings (lower risk)

• Non-movement area inclusion will be a challenge wi thout more explicit regulatory oversight

• Internal FAA Order 5200.11 is now required prior t o Airports SMS being required. This, in essence, re quires SMS be in place (at least for AIP funded projects) prior to a published rule for Airports.
What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety concerns • Unknown hazards proactively identified (in theory)

• A more active safety committee

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charg e of safety concerns - not just the “accountable execut ive” but accountability at all levels within the organiz ation (in theory)

• Lower long-term costs – quite possibly difficult t o measure/quantify or categorize

• Enhanced collaboration between departments regardi ngFAA SMS Pilot Studies Technical Report May 2011 Page 62



### Airport: Dallas Fort Worth, TX Team Member: Joe Washington

Airport contact: Julie Schreacke # of Operations:
652,261 # of Employees:

1,775 Documents

delivered for Pilot Study: Gap analysis, SMS Implementation Plan ,SMS

Manual and

Selected Tools

• Lower long-term costs

• Others hazards/SRA process

• Review and adjustment of current policies and procedures with regards to not only SMS, but other business processes - SMS merely provides the reason/”excuse” for review and adjustment

What were the key findings at your airport, as part of the Pilot Study? • Gap analysis findings

• Many processes already done today are key components of SMS – just need to refine and “formal ize” through policy/procedure, documentation, and accountability

Did you feel the FAA guidance was sufficient? What would you

want to see included in the SMS

AC? • Personally, I feel the FAA guidance is sufficient, however I am quite familiar with safety risk management and associated processes

• The AC, and all associated SMS documents published by the FAA should be better aligned with one anothe r and include consistent verbiage/definitions (i.e. S RA vs Safety Assessment Screening)

• The current AC provides an appendix and uses an example of SRM during a construction plan, this may be more appropriate to include in FAA Order 5200.11, possibly include a different example (maybe 2 or 3) ?

May we put your information on the public docket? Please send electronic copies along with your

ok to use the information. • Assuming “information” equates to Gap analysis, SM S implementation plan, and SMS manual (?)

• Our manual is still a “living” document in its ear liest stages of development and many components are undergoing revision/editing based on results from t he current Pilot Study and review with our consultant. That said, we recognize the importance of “sharing” with our industry partners and are still reviewing the possi bility of publishing to the public docked internally



### Table 15 – Dallas Fort Worth, TXFAA SMS Pilot Studies Technical Report May 2011 Page 63



### Airport: Tallahassee Regional Airport, Tallahassee, FL

Team Member: Laurie Jane Dragonas

Airport contact: David Pollard # of Operations:
118,000 annual Ops # of Employees:

51 Documents

delivered for Pilot Study: Gap Analysis, SMS Manual, SMS Implementation Study, about to

submit third SRA How many FTEs currently work on SMS? Three, but none are full time Do you anticipate adding FTEs when implementation is complete? No. Will be putting in budget recommendation for m ore staffing. NPRM should address the amount and type o f staffing that FAA wants airport operator to have Do you envision FTEs or consultants managing your SMS after implementation? Yes, one of the employees Did you use a consultant in your SMS process? If so, which one?

In what areas? Yes, worked with two different consultants Wilbur Smith Associates and also with Reynolds, Smith & Hills Kimberly Horne is working current grant

What were your challenges in interpreting the SMS process? Conflicting information. When is SMS really require d? Begin with trigger events? What does AA expect? Fuel nee ds to more specific about expectations, organizational st ructures, reporting relationships. It would help when final rule goes out with the rule requires specific positions and q ualifying attributes ( similar to TSA)

What types of risks/hazards did you put through the SRM process during the Pilot Study? 1- Studied ramp safety. 2-Studied irregular operat ions, such as during severe weather, or when airport is suppor ting a multitude of diversions from airports around the st ate. 3- Also studied water intrusion ( terminal roof projec t)

What did the Gap Analysis

Reveal? Reporting mechanism for unsafe conditions. Airport developed branded safety [products to advertise the program, voice mail 891SAFE, drop boxes], still str uggling with staffing issues, how are ops supposed to inter act with capital programs

What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? Need to foster interest "Bleed Safety". Developed posts, banners, safety candy jars, lanyards, badge reels e tc. Make a BIG DEAL about safety. Patterned his program off of military aviation Risk management program called "A NY

MOUSE" What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety concerns

• Lower long-term costs

• Others 1- Greater focus on safety 2- More people invol ved- they check the reporting hotline daily, 3- Hard to quant ify cost savings, yes if you save one life, 4- Better respon sibility, accountability, reporting, 5- Got safety vests for increased visibility for ramp workers What were the key findings at your airport, as part of the Pilot Study? Need to do a better job with the business process. Issues

are identified... follow it thru to until the issue i s closed out w documentation. Work toward better airport visibilit y for SMS,FAA SMS Pilot Studies Technical Report May 2011 Page 64



### Airport: Tallahassee Regional Airport, Tallahassee, FL

Team Member: Laurie Jane Dragonas

Airport contact: David Pollard # of Operations:
118,000 annual Ops # of Employees:

51 Documents

delivered for Pilot Study: Gap Analysis, SMS Manual, SMS Implementation Study, about to

submit third SRA need a platform for organizing safety & outstanding work orders in the same manner that you have a platform for security

Did you feel the FAA guidance was sufficient? What would you

want to see included in the SMS

AC? Guidance was okay. Need to focus on what are FAA's expectations for key positions for SMS implementati on. Describe minimum qualifications, reporting relation ships Etc. Describe specifically what you for example such as the way TSA has specific requirements for Airport Security

Coordinator May we put your information on the public docket? Please send electronic copies along with your

ok to use the information. Okay to put on docket, Keri already has copies of e verything

from TLH



### Table 16 – Tallahassee Regional, FLFAA SMS Pilot Studies Technical Report May 2011 Page 65



### Airport: Alliance Fort Worth Team Member: Joe Washington Airport contact: C. Ash # of Operations:
105,000 # of Employees: 21 Documents

delivered for Pilot Study:
How many FTEs currently work

on SMS? Two FTEs currently. It’s a slow process that has ad ded value to our overall safety and awareness

Do you anticipate adding FTEs when implementation is complete? We hope to add one or two FTEs before implementatio n. Our staff handles both the FBO and airport operatio n component and must multitask and balance time betwe en airport operations and service delivery. Adding a S MS to FAR139 would require additional manpower to ensure appropriate application and compliance of SMS.

Implementation of SMS will increase our operating a nd administrative budget, primarily for additional FTE s needed to support the program but also includes miscellane ous equipment, hardware and software Do you envision FTEs or consultants managing your SMS after implementation? FTEs Did you use a consultant in your SMS process? If so, which one?

In what areas?

What were your challenges in interpreting the SMS process? The process was challenging due to the fact that SM S overall is more of a mindset than actual regulation . During and after the SMS study we found that getting our F TEs to understand the process was challenging. We were ask ing them to take a process that would improve safety an d apply it operational situations without providing particu lar areas of

focus. In the end we found that our team was ultima tely using SMS, such as SRM when evaluating air show pla nning

and AOA construction.

In my opinion the SMS process talks too broadly and ask the users to apply the tools where necessary without gi ving particular guidance, which is different than what m ost AC’s and FARs provide. As an example: One FTE might th ink that a SRM process is needed for a particular proje ct, but another may see it differently; therefore they may feel that the process is not necessary. So how do you determi ne what’s worthy of a SRM analysis and what’s not?

What types of risks/hazards did you put through the SRM process during the Pilot Study? We used a taxiway intersection located at midfield. Several aircraft departing the FBO ramp have mistaken Taxiw ay A as the part of the apron. The challenge at the time was some pilots mistakenly thought the taxiway intersection was the entrance to the TAXIWAY when it was actually the ru nway. What makes this intersection challenging is the fac t that the main ramp and taxiway A are only separated by a non

movement boundary marker. So if a pilot is task sat urated during taxi or has failed to properly identify the intersection

he/she could mistake the intersection as the entran ce to the taxiway system from the main ramp and ultimately en ter theFAA SMS Pilot Studies Technical Report May 2011 Page 66



### Airport: Alliance Fort Worth Team Member: Joe Washington Airport contact: C. Ash # of Operations:
105,000 # of Employees: 21 Documents

delivered for Pilot Study: runway 16L/34R environment.

This exercise is where it all started to come toget her for our FTEs. Once they had a way to tie the SMS process to a particular process they began to understand the pro cess

What did the Gap Analysis

Reveal? The Gap Analysis revealed that we meet all componen ts of FAR139 and currently unintentionally meet some part s of the SMS guidelines. It identified weaknesses in resolving maintenance i tems, record keeping and training. As a result these area s were reviewed and strengthened. It helped identify progr ams such as, safety committees and showed the value of the p rogram

What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? We struggled, and currently struggle with the overa ll implementation of SMS. We often find that making th e time to manage the SMS process is our main obstacle. So me areas within SMS require additional manpower to per form analysis, reports or training. Ultimately, this pr ocess will add layers to already existing FARs

What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety concerns

• Lower long-term costs

• Others a. Unknown hazards Nothing identified during or after the Pilot Study

b. A more active safety committee- As a result of the SMS Pilot Study we established and maintained an Airport Safety Committee comprised of all major stakeholders on the airport. Next meeting is planned

for June of 2011.

c. A tracking system that leads to a more proactive approach

As a result of the SMS study we implemented a bette r tracking system for open items such as damaged airp ort signs and missing lights. Our challenge with this h as been consistent application. In addition to this we stil l use the standard airport inspection to list and non-complyi ng items found during the required airport inspections. Bet ter application and consistency would allow for more de tailed trend analysis, better long term planning and could show unknown problems with the airport environment.

d. One party identified as being responsible/in cha rge of safety concerns

Senior Leaders do play an active role in safety and have implemented several components from the SMS Pilot S tudy.

e. Lower long-term cost- None at this time. Althoug h we do anticipate lower cost in the future as it relates t o tracking repair and maintenance issues.

f. Others- None What were the key findings at a. Some aspects of th e SMS system already being used.FAA SMS Pilot Studies Technical Report May 2011 Page 67



### Airport: Alliance Fort Worth Team Member: Joe Washington Airport contact: C. Ash # of Operations:
105,000 # of Employees: 21 Documents

delivered for Pilot Study: your airport, as part of the Pilot Study? b. Safety Culture exists but needs improving. Since SMS study this has improved. c. Training in all areas needed to be strengthened

Did you feel the FAA guidance was sufficient? What would you

want to see included in the SMS

AC? We do feel the FAA guidance was sufficient, but cou ld be strengthened and more clearly defined. The FAA issu ed the AC in early 2007 that addressed the “concepts”. In our opinion airports would benefit by knowing the parti culars of the SMS regulation. This AC was written in a broad sense and ultimately offered a basic understanding and no t clear guidance as you would expect from an AC.

In addition, it would be nice to have a chart that shows how SMS will be implemented at the different Classes of airports (Ex: Will Class IV airports be held to the same sta ndards as Class I airports?) Having a breakdown of the requir ements would be helpful and eliminate questions. We would suggest that those airports that participated in the first and second Pilot Studies be allowed to participate or offer in formation to the airports division before and during the rewrite of the AC. Overall better alignment with AC’s and current 139 regulations would be helpful May we put your information on the public docket? Please send electronic copies along with your

ok to use the information. We do not object with putting our information on th e public

docket



### Table 17 – Alliance Fort Worth, TXFAA SMS Pilot Studies Technical Report May 2011 Page 68



### Airport: Jackson, MS

Team Member: Michel Hovan

Airport contact: Denson Stachler # of Operations:

65000 # of Employees:

110 Documents

delivered for Pilot Study: Gap Analysis, Manual How many FTEs currently work

on SMS? 0.5 or less Do you anticipate adding FTEs when implementation is complete? Depends on the final rule Do you envision FTEs or consultants managing your SMS after implementation? FTE, airport authority Did you use a consultant in your SMS process? If so, which one?

In what areas? Yes, Faith Group LLC, in all areas What were your challenges in interpreting the SMS process? 1. Educating staff, 2. Non-punitive system, 3. Scop e, 4. Not much background provided by FAA What types of risks/hazards did you put through the SRM process during the Pilot Study? 1. Non-Movement Area hazards, 2. Passenger Hazards, 3.

Vehicle Hazards What did the Gap Analysis

Reveal? Some gaps with respect to SMS What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? Issue with the word "Policy", non-punitive approach , cultural change What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety concerns

• Lower long-term costs

• Others More safety awareness for the staff - cultu ral changes What were the key findings at your airport, as part of the Pilot Study? Able to identify that a legacy safety culture does already exist at the airport Did you feel the FAA guidance was sufficient? What would you

want to see included in the SMS

AC? No, Lack of details for airport environments, Would like: more guidance, more cost-benefit analysis, and meas urable

data and rationale from the Pilot Studies. May we put your information on the public docket? Please send electronic copies along with your

ok to use the information. Not yet, will get back



### Table 18 – Jackson, MSFAA SMS Pilot Studies Technical Report May 2011 Page 69



### Airport: Teterboro, NJ

Team Member: Michel Hovan

Airport contact: Richard Hesslin # of Operations:
150,000 # of Employees: 3

PNNYNJ, 35 others Documents

delivered for Pilot Study: Gap Analysis, draft SMS Manual,

draft implementation plan How many FTEs currently work on SMS? Zero right now Do you anticipate adding FTEs when implementation is complete? No Do you envision FTEs or consultants managing your SMS after implementation? Study found 1 FTE to be added Did you use a consultant in your SMS process? If so, which one?

In what areas? Yes, Louis Berger, in all areas

What were your challenges in interpreting the SMS process? 1. Non-punitive system - how would that work, 2. Wh o is the accountable executive, 3. What type of reporting sy stem, 4. Costs and who pay for them What types of risks/hazards did you put through the SRM process during the Pilot Study? None at this time. All effo rts were on the Manual

What did the Gap Analysis

Reveal? EB has a solid safety foundation, SMS will require centralized reporting system, Management guidelines need to be developed What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? Very time-consuming, 18 months to complete the draf t, but overall a positive experience, was handled by manag er groups only What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety concerns

• Lower long-term costs

• Others More safety awareness for the staff - cultu ral changes What were the key findings at your airport, as part of the Pilot Study? Nothing yet Did you feel the FAA guidance was sufficient? What would you

want to see included in the SMS

AC? First AC only provided start-up guidance. Did every thing per the AC. Need better risk matrix definitions, traini ng requirements, how is it going to be implemented?, s pecify a baseline vs. gap analysisFAA SMS Pilot Studies Technical Report May 2011 Page 70



### Airport: Teterboro, NJ

Team Member: Michel Hovan

Airport contact: Richard Hesslin # of Operations:
150,000 # of Employees: 3

PNNYNJ, 35 others Documents

delivered for Pilot Study: Gap Analysis, draft SMS Manual,

draft implementation plan May we put your information on the public docket? Please send electronic copies along with your

ok to use the information. No yet, need to confirm with legal



### Table 19 – Teterboro, NJFAA SMS Pilot Studies Technical Report May 2011 Page 71



### Airport: Atlanta, GA

Team Member: Travis Fiebelkorn Airport contact: Scott M. Ayers # of Operations:
950, 119 # of Employees: Documents

delivered for Pilot Study:

How many FTEs currently work

on SMS? One fulltime Airport Operations Supervisor with ass istance of 3 other representatives from Risk Management and Safety/Training Do you anticipate adding FTEs when implementation is complete? SMS Position Fulltime Do you envision FTEs or consultants managing your SMS after implementation? FTE Did you use a consultant in your SMS process? If so, which one?

In what areas? No

What were your challenges in interpreting the SMS process? Some of the instructions were not as clear in the P ilot Study documents, especially with providing resource infor mation to

conduct research

What types of risks/hazards did you put through the SRM process during the Pilot Study? Vehicle traffic on the ramp and FOD SRAs. We will b e conducting another SRA on a taxiway conversion to a taxilane with a vehicle crossing in May 2011. The SRA process requires a lot of preparation, time allocat ion, especially to conduct the SRM Panel that could take a full day or more to complete the process

What did the Gap Analysis

Reveal? Did not have a comprehensive Safety Policy Statemen t, although the City of Atlanta and DOA have internal safety policies in safety manuals. Did not have Safety Ri sk

Assessment Process

What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? Develop a documented process/protocol for the airpo rt and its business partners ensuring acceptance and harmonization of the decision making process and de fining responsibilities to evaluate, accept, and mitigate risks. These items will need to be addressed in each operator’s particular SMS (ie MOUs MOAs, Lease Agreements); With the stakeholder data, we only received a few reports fr om companies which were de-identified. The challenge w as most of the companies were concerned about the data protection and FOIA laws. Airline concerns are on t he (a) incompatibles between an airport SMS and air carrie r SMS, (b) lack of ownership of data in control of an exte rnal sources, and (c) company data subject to sunshine l aws at a public airport. Most of the companies believe it co uld result in an unintended lack of protection by the company for its employees and potential non-compliance of regulator y issue that affect their reputation.

Most companies would require clarity in (a) the pro tection for ensuring their documents and data are maintained as confidential documents not subject to release to th e public under government disclosures laws, (b) possession a nd control of the data acquired, (c) use of accident a nd incident data in tenant risk assessment exercises, and (d) u se of stakeholder data for creating and or modifying proc esses for all tenant at an airportFAA SMS Pilot Studies Technical Report May 2011 Page 72



### Airport: Atlanta, GA

Team Member: Travis Fiebelkorn Airport contact: Scott M. Ayers # of Operations:
950, 119 # of Employees: Documents

delivered for Pilot Study: What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety concerns

• Lower long-term costs

• Others SRA process is helping to effectively evaluate haza rds with construction projects and changes on the airfield; Establishing a SMS Work Group with tenant involveme nt in the development and refinement of our SMS Program. The SMS Work Group will become the Safety Committees defined in the SMS Program; The ASOCS database syst em is very beneficial for part 139 reporting and being able to fulfill our SMS reporting requirements. The SMS Dashboard will supplement the ASOCS data with trend analysis and tracking capability

What were the key findings at your airport, as part of the Pilot Study? We realized a lot of what we were doing is part of Safety Management System with part 139 responsibilities, R isk Management Office, DOA and City of Atlanta Safety P olicy

Manuals

Did you feel the FAA guidance was sufficient? What would you

want to see included in the SMS

AC? I felt there was a lack of guidance material made a vailable for the Pilot Studies. However the airport collabor ation has helped in the area. We would like to see more guida nce documents on Safety Risk Management Resources, and SMS Training Material May we put your information on the public docket? Please send electronic copies along with your

ok to use the information.



### Table 20 – Atlanta, GAFAA SMS Pilot Studies Technical Report May 2011 Page 73



### Airport: North Las Vegas Team Member: Abel Tapia

Airport contact: Ben Czyzewski # of Operations:
131,143 # of Employees:

27 Documents

delivered for Pilot Study: Pilot safety
management system plan How many FTEs currently work

on SMS? 0 Do you anticipate adding FTEs when implementation is complete? Yes Do you envision FTEs or consultants managing your SMS after implementation? Definitely FTEs but we are still considering employ ing consultants to augment staffing Did you use a consultant in your SMS process? If so, which one?

In what areas? Yes, Ricondo and Associates. Consultant used to as sist with gap analysis and draft the SMS Plan

What were your challenges in interpreting the SMS process? Clarifying the extent to which leaseholds within th e nonmovement area are subject to this SMS rule. Determ ining the responsibilities of the airport operator and th ird parties regarding the development and maintenance of SMS. Ascertaining if the airport sponsor can delegate SM S responsibilities to tenants within exclusive leaseh olds. Determining legal liabilities of the accountable ex ecutive and acceptance of know risks identified on the risk ass essment

matrix

What types of risks/hazards did you put through the SRM process during the Pilot Study? Runway environment during construction at night. Existing driver training program and the use of es corts for

construction vehicles.

ATCT that does not have radio communications with construction vehicles, which are not radio equipped

. Signs, markings, and lighting to the taxiways, run ways, and

construction areas

What did the Gap Analysis

Reveal? The results of comparisons between existing conditi ons, including the documentation of practices at the Air port, and

SMS standards revealed that in some instances certa in practices or procedures are in place, but may not b e collectively gathered or documented to meeting the intent of a formal SMS. In other instances, data collection of recordkeeping is being completed as part of a database ma naged by CCDOA, but has not been formally included as par t f the SMS program

What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? SMS introduces new requirements for record keeping, ensuring that all SMS documentation is current and

accurate. This includes the introduction and maint enance of SMS training records for all airport employees, documentation of hazard identification and analysis

, documentation of the effectiveness of corrective an d preventative measures taken, and the documentation and

dissemination of the results from accident and inci dent investigations. There is not presently sufficient administrative staff to accomplish these tasks. SM S annual record keeping and the training requirements outlin ed below would necessitate the hire of a full time Managemen t AnalystFAA SMS Pilot Studies Technical Report May 2011 Page 74



### Airport: North Las Vegas Team Member: Abel Tapia

Airport contact: Ben Czyzewski # of Operations:
131,143 # of Employees:

27 Documents

delivered for Pilot Study: Pilot safety
management system plan I at $84,460 annually including benefits. The SMS process includes new requirements for init ial and annual recurrent training of airport employees in o verall airport safety objectives, safety risk management p rinciples, safety assurance topics, airport rules and regulati ons, and overall department organization and functions. A plan to validate training effectiveness and a process to ob tain feedback, including useable metrics, is also requir ed. Providing 8 hours of annual training for 450 employ ees would require 30 classes with 15 employees per clas s. Ten weeks would be required to complete training at 3 c lasses per week. The training would consume 3,600 man hou rs. Assuming an average hourly wage of $28 for each CCD OA employee, CCDOA training costs for 30 employees wou ld total $6,720. Assuming an average hourly wage of $ 15 for each commercial airport tenant employee, tenant tra ining costs for 420 employees would total $50,400. Annua l training costs total $57,120. SMS requires change management, a formal process to identify, anticipate, and prepare for potential haz ards introduced into the airport environment. Trigger e vents

include such common occurrences as the introduction of a new commercial aircraft type, the commissioning of new equipment or the adoption of new procedures or regu lations. The airport embraces a non-punitive safety reportin g policy as outlined in the Clark County Workplace Safety an d Health Policy. However, certain violations of applicable laws, policies, or procedures may require additional disc iplinary action. This issue is not addressed by SMS. Safety communication to promote a safety culture t hrough all levels of the airport organization is a require ment of SMS. Although some communication processes are currently in place, such as newsletters and tenant meetings, oth er systems for disseminating information regarding air port operations, facility maintenance, airfield construc tion, employee safety awareness, tenant safety awareness, airside safety, and wildlife safety would be requir ed. The additional cost cannot be calculated until the spec ific media are selected, but the expense would be significant. Implementation and maintenance of SMS would be challenging and labor intensive, particularly at No rth Las Vegas Airport. A new management analyst position w ould be required at $84,460. Annual training costs are estimated at $57,120. These staffing and training costs toge ther total $141,580. These costs do not take into account the time necessary for the duties of the Deputy Director of Aviation as the SMS Accountable Executive, the Assistant Direct or of Aviation, General Aviation as SMS Responsible Execu tive, or the duties of the Airport Manager under the draf t SMS

manual submitted to the FAA. The annual cost ofFAA SMS Pilot Studies Technical Report May 2011 Page 75



### Airport: North Las Vegas Team Member: Abel Tapia

Airport contact: Ben Czyzewski # of Operations:
131,143 # of Employees:

27 Documents

delivered for Pilot Study: Pilot safety
management system plan communication and file storage would also be a sign ificant factor. This represents a financial and administra tive burden during a time of economic difficulty and budgetary

constraints. What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety concerns

• Lower long-term costs

• Others The SMS process has not been implemented at the air port. During the Pilot Study only a few specific test ite ms were subjected to the process. Benefits cannot be deter mined until a large sampling of items can be achieved. What were the key findings at your airport, as part of the Pilot Study? The SMS process has not been implemented. No preva lent findings were ascertained. We are only in the proc ess of defining the SMS.

Did you feel the FAA guidance was sufficient? What would you

want to see included in the SMS

AC? The practical and legal problems inherent in imposi ng SMS responsibilities on airports for non-movement areas under

the control of tenants. The operational costs (including especially personn el, recordkeeping, training and liability) for airports and the mechanisms by which airports will fund compliance w ith their ongoing SMS obligations. The manner by which airports should resolve conflic ts or competing obligations imposed by the proposed part 139 SMS manual, by other SMS requirements (including, b ut not limited to, Order 5200.11), SMS requirements impose d on other airfield users (including part 121 operators and ATO), existing contractual obligations, and other grant a ssurance obligations. The liability and public information issues raised by the obligation to prepare safety risk assessments and t o keep records on safety evaluations of all sorts that may necessarily be available to the public under federa l or state

law. The responsibilities of the accountable executive in the context of the practical realities of staff organiz ation and responsibilities at large complex airports. The agency needs to provide a clear and unequivocal hierarchy of authority among the various proposed a nd forthcoming SMS requirements so that airports do no t have to guess who has authority and which SMS program governs a particular activity. The proprietor’s safety obligations should be scale d and adapted depending upon (a) the activities that occu r withinFAA SMS Pilot Studies Technical Report May 2011 Page 76



### Airport: North Las Vegas Team Member: Abel Tapia

Airport contact: Ben Czyzewski # of Operations:
131,143 # of Employees:

27 Documents

delivered for Pilot Study: Pilot safety
management system plan each non-movement area; (b) the practical level of control that the proprietor exercises over activities withi n these areas and (c) the extent to which access is within the control

of a tenant. May we put your information on the public docket? Please send electronic copies along with your

ok to use the information. No



### Table 21 – North Las Vegas, NVFAA SMS Pilot Studies Technical Report May 2011 Page 77



### Airport: Pittsburgh, PA

Team Member: Travis Fiebelkorn

Airport contact: Kurt Sopp # of Operations:
144,563 # of Employees:

6000 Documents

delivered for Pilot Study: In Progress How many FTEs currently work on SMS? Collectively, two FTEs Do you anticipate adding FTEs when implementation is complete? Yes, one additional FTE Do you envision FTEs or consultants managing your SMS after implementation? FTEs will manage our program after full implementat ion. We may use a consultant periodically to conduct an aud it in support of safety assurance efforts. Did you use a consultant in your SMS process? If so, which one?

In what areas? We utilized Jacobs Consultancy (now Leigh Fisher) t o conduct GAP analysis and the drafting of our SMS Pr ogram and implementation plan

What were your challenges in interpreting the SMS process? One difficulty in preparing our SMS plan was the fa ct that we developed the plan in advance of the NPRM. As such , this necessitated our revising the plan in order to meet the new pending requirements of the NPRM.

What types of risks/hazards did you put through the SRM process during the Pilot Study? As part of the implementation Pilot Study we will c onduct three SRA. We have completed one dealing with Jetw ay Hazards. Other planned SRA will include runway construction, and wildlife hazards.

What did the Gap Analysis

Reveal? To implement SMS, the airport was required to revie w our organizational structure and assign specific duties related to SMS. Additionally, we found that we could improve upon safety promotion efforts. Finally, we found that w e were in need of an incident reporting database that would a llow for the easy review of incidents and hazards in order t o conduct trend analysis.

What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? We underestimated the amount of staff time required in order to implement SMS. Training time for staff is significant, as is the time and effort related to t he documentation of the SRM process. Our desire to in tegrate incident reporting software with a legacy work orde r management software has also been a challenge. What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety concerns

• Lower long-term costs

• Others As a result of our implementing SMS there is a grea ter safety awareness among employees. Once role out is complete, we anticipate improved means of monitorin g and trending safety incidents/hazards. Finally, we hav e received positive input from our liability insurance carrier resulting from our use of SMS, though no reduction in rates h ave been realized.

What were the key findings at your airport, as part of the Pilot Study? In many respects we are operating under SMS in much the same way as we have always operated, reviewing haza rds and identifying ways in which to minimize risk. We tend to have a more methodical approach to safety reviews. It has been our experience that SMS has brought a signific antFAA SMS Pilot Studies Technical Report May 2011 Page 78



### Airport: Pittsburgh, PA

Team Member: Travis Fiebelkorn

Airport contact: Kurt Sopp # of Operations:
144,563 # of Employees:

6000 Documents

delivered for Pilot Study: In Progress increase in required documentation.

Did you feel the FAA guidance was sufficient? What would you

want to see included in the SMS

AC? It is important that the SMS AC is updated to refle ct provisions specified in the final SMS rule making. This document was developed as a general guidance docume nt and in order to provide an orientation to SMS. It would also be beneficial to clarify how various SMS initiative s (airport, airline, FAA ATO, FAA ADO) will coincide and become a comprehensive as opposed to a segmented approach to safety. May we put your information on the public docket? Please send electronic copies along with your

ok to use the information. No



### Table 22 – Pittsburgh, PAFAA SMS Pilot Studies Technical Report May 2011 Page 79



### Airport: South Bend, Indiana

Team Member: Kenneth Taira

Airport contact: Bruce MacLaclan, Operations Manager # of Operations:
24,000 # of Employees:

45 Documents

delivered for Pilot Study: Gap Analysis, Policy, Manual, Implementation Plan, Follow-On Study Report,

SRAs How many FTEs currently work

on SMS? 2 (collateral duties) Do you anticipate adding FTEs when implementation is complete? No Do you envision FTEs or consultants managing your SMS after implementation? Possibly. May enlist consult ant for training

Did you use a consultant in your SMS process? If so, which one?

In what areas? Yes. Pilot and Follow-On Studies: All phases of da ta collection, drafting documentation; used subcontrac tor help for hazard identification and legal work (non-punit ive reporting)

What were your challenges in interpreting the SMS process? No significant challenges encountered. Consultant is experienced in 139 and ICAO. One future challenge is to correlate SMS with 139 - are they integrated, separ ate, redundant? Airport needed to figure out the "what" of SMS, then the "how". Next step was to sell it to the us ers. An overall challenge is to get buy-in from people who feel this is redundant to 139 and "get them to the table".

What types of risks/hazards did you put through the SRM process during the Pilot Study? 4 subjects: 1) Parking configuration / operations during Notre Dame football games; 2) Evaluation of trend i dentified with tug operations, ramp safety near aircraft; 3) (Performed prior to Pilot Study): Terminal expansion - impact of new configuration on aircraft parking / gate usage; 4) (Performed prior to Pilot Study): Maintenance hangar access: determining if aircraft should be mechanic-taxied o r tugged across a decommissioned taxiway. A mock SRA was conducted on UPS ramp operations as a introduction to
SRM.

What did the Gap Analysis

Reveal? Self Inspection: Upward reporting of inspection and correction process - making senior management aware of activity; Airfield Inspections: Capture current sel f inspection practices (1 inspection per shift vice 1 per day in the ACM) in writing; Commercial aircraft operations ramp: Docum enting specific inspection items on self inspection docume ntation; Safety Manager: Designate a Safety Manager to overs ee SMS and ensure communication with senior management ; Non-Punitive Reporting System: Establish a system; Training Records: Document procedures for conductin g the established practice of auditing FBO fueling person nel training records; Recurring Training: Establish con sistent recurrent training timelines and consider establish ing 12 month cycle for all training; Condition Reports: Es tablish and document timelines for filing condition reports; Communication: Evaluate and capture current practic es inFAA SMS Pilot Studies Technical Report May 2011 Page 80



### Airport: South Bend, Indiana

Team Member: Kenneth Taira

Airport contact: Bruce MacLaclan, Operations Manager # of Operations:
24,000 # of Employees:

45 Documents

delivered for Pilot Study: Gap Analysis, Policy, Manual, Implementation Plan, Follow-On Study Report,

SRAs writing (ACM); Pedestrian and Ground Vehicle Proced ures: Evaluate content and effectiveness of training prog ram; Obstructions: Identify ownership of obstructions an d develop a notification / tracking system for ensuring obstr uctions are monitored and addressed; Wildlife: Include training requirements in the WHMP

What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? Challenges: Legality/confidentiality of the non-pun itive reporting system; Presenting SMS to an industry str ucture and culture that has changed greatly (employee/empl oyer loyalty, subcontracting, dedication to aviation; En couraging communication of safety related activities (e.g., g etting air carriers to report incidents/damage to their equipm ent on the ramp); Encouraging documentation of conversational information (water cooler talk) to collect relevant data; Determining who calls a SRMP and when, how; Concern about multiple SMS for ATO, ARP, AVS, Air Carriers - how will multiple SMSs be integrated / correlated to pr event duplication of effort?; Addressing the issue of LOB s convening competing SRMPs to produce a desired outc ome; Non-Punitive Reporting - A subcontractor was hired to research confidentiality and data susceptibility to FOIA. Data storage alternatives were proposed to isolate the data from the airport or entities where it would be sub ject to FOIA. The Follow-On report Appendix A details these alter natives.

What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety concerns

• Lower long-term costs

• Others Unknown Hazards: One SRA did identify previously unknown hazards relating to the issue with tug oper ations on the air carrier ramp. Other SRAs were conducted fo r system changes; Active Safety Committee: Good participatio n in SRAs, considering safety-related work is a collater al duty for most of the SRMP members; Tracking System: System i s in development; One party identified as responsible/in charge of safety concerns: No real change - there's awaren ess of the process, reliance on the chain of command. Familiarization will occur through recurrent badge training; Lower long term costs: No change, too early to tell . There's an anticipated cost reduction similar to the worker s' comp multiplier. Cost savings under 139 may not be sign ificant because it's already saving costs by preventing acc idents; Others: Relationship with tenants improved. The pr ocess inherently and actively involves impacted parties/u sers to provide data that result in better communication / awareness of hazards and risk. It also forces the airport in to a leadership role, bringing everyone into a collabora tive effort. The approach an airport takes to SMS speaks to the way the airport is managed. What were the key findings at your airport, as part of the Pilot The Pilot Study work validated the airport's curren t activity relative to safety and provided ideas for formalizi ng andFAA SMS Pilot Studies Technical Report May 2011 Page 81



### Airport: South Bend, Indiana

Team Member: Kenneth Taira

Airport contact: Bruce MacLaclan, Operations Manager # of Operations:
24,000 # of Employees:

45 Documents

delivered for Pilot Study: Gap Analysis, Policy, Manual, Implementation Plan, Follow-On Study Report,

SRAs Study? tweaking the process to improve it.

Did you feel the FAA guidance was sufficient? What would you

want to see included in the SMS

AC? Yes. Further guidance came from teleconferences, consultants, networking with other airports. With basics laid out by the FAA, the Pilot Study became a "community thing." The guidance got parties started down the road and left enough leeway for interpretation. AC: Include writt en clarification describing how FAA approaches SMS. D oes it intend for SMS to be a standalone document or part of the ACM? If SMS is part of the ACM, and an airport inc ludes information about operations outside of 139, can th e ACSI inspect and cite the airport for violations in thos e areas? Will the airport need to maintain 2 SMSs - 1 within the ACM and another for everything outside of 139? This will b e counterproductive. Make sure the AC does not move airports too far toward procedure-based documents (overreliance on checklists). Too much documentati on will be a distraction to the SRM process. May we put your information on the public docket? Please send electronic copies along with your

ok to use the information. Yes. Dave Fleet will forward information by email.



### Table 23 – South Bend, INFAA SMS Pilot Studies Technical Report May 2011 Page 82



### Airport: Southern Illinois University

Team Member: Kenneth Taira

Airport contact: Gary Shafer # of Operations:
80,000 # of Employees: 15 Documents

delivered for Pilot Study: Manual, Implementation

Plan How many FTEs currently work

on SMS? One Do you anticipate adding FTEs when implementation is complete? One Do you envision FTEs or consultants managing your SMS after implementation? No Did you use a consultant in your SMS process? If so, which one? In what areas? Yes. Gap Analysis, SMS Manual and i mplementation

What were your challenges in interpreting the SMS process? Concept was difficult to grasp at first. Guidance was vague, nebulous. Airport felt like it was stumbling throu gh the process, with little idea of where the FAA wanted t he Pilot Study to go other than the 21 deliverable items to use as guidance. When constructing a foundation, Airport had difficulty defining the difference between SMS and safety program. Airport sought background information by attending AAAE meetings and reviewing ACRP and ICAO material. The Airport had a theory that the FAA wa s intentionally vague on its instructions in order to spark creativity among airports. The Airport felt the Ga p Analysis was challenging because of a lack of guidance. The Airport used ICAO as a reference to perform the Gap Analysi s.

What types of risks/hazards did you put through the SRM process during the Pilot Study? 3 projects: 1) Impact of new buildings on pedestri an/vehicle traffic and parking at the airport campus (Landside ); 2) Assessment of blind spots on non-movement areas (Airside); WHM topic (Airside, in progress)

What did the Gap Analysis

Reveal? Safety must be formalized through: 1) Adjusting documentation where it is lacking; 2) developing committees; 3) setting up data collection (e.g., pr oviding a website to collect confidential safety reports); 4) ensuring visibility of/attention to safety is maximized.

What difficulties/ challenges have you experienced during the Pilot Study? Lessons learned? 1) How do airports get funding for staffing, traini ng delivery, developing tools? This will test Airport Managers' creativity. 2) How do airports get funding for mitigation that requires construction? 3) Question: Is liability assumed wh en mitigations are made known but not acted on? This may create a risk of Airport Sponsors minimizing hazard s to avoid spending money. Lessons Learned: 1) Ensuring management involvement / buy-in. Leadership is cri tical. 2) Communication should come early and often to front- end load information from the FAA through the Airport t o the tenants (end users). What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety Unknown Hazards: Some issues may be more efficientl y dealt with using longer term, continuing SRAs as op posed to multiple SRAs on individual issues that are all rel ated. SMS is building a culture that, combined with improved data collection, will bring out hazards more efficiently . A moreFAA SMS Pilot Studies Technical Report May 2011 Page 83



### Airport: Southern Illinois University

Team Member: Kenneth Taira

Airport contact: Gary Shafer # of Operations:
80,000 # of Employees: 15 Documents

delivered for Pilot Study: Manual, Implementation

Plan
committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety concerns

• Lower long-term costs

• Others active safety committee: Results in more activity - information sharing. People respond to the tome se t by the Airport Manager through the Safety Committee, which leads to improved identification of hazards. Formalizati on of the safety culture through elements like the safety com mittee establishes the SMS's credibility among users. A t racking system that leads to a more proactive approach: Inc ident Reporter by OMNI Air Group (data collection softwar e) was cumbersome. SIU developed a web-based data collect ion site that collects, organizes and tracks data, redu cing workload on the person responsible for monitoring t he system (currently Airport Manager). Email function ality allows immediate receipt, evaluation and action on safety reports submitted through the website. One party i dentified as being responsible /in charge of safety concerns: Greater impact using the web based data collection system. The system allows one person to address issues more eff iciently. With efficient data collection and notification, on e person can address issues efficiently and consistently. Lower long-term costs: Too early to determine - no cost savings no ted yet, but enough data to evaluate. Others: SIU's SMS pro ject has been a boon to SIU for professional development, av iation industry and airports. The system increases commun ication, which has led to increased safety-related activity and

awareness.

What were the key findings at your airport, as part of the Pilot Study? Performing the SRAs at the airport demonstrated val ue early on. It helped direct specific attention to safety issues and mitigation. SRAs were valuable in bringing togethe r different perspectives and allowing participants to understan d the perspectives of the other parties involved.

Did you feel the FAA guidance was sufficient? What would you

want to see included in the SMS

AC? No. Include examples or samples of SMS Manual or A CM with SMS. The CSPP example in the current AC 150-5 200- 37 was helpful. Develop the guidance to be helpful to the end user. Cater the guidance to those airports tha t do not have many resources (like consultants) available. May we put your information on the public docket? Please send electronic copies along with your

ok to use the information. Completed and saved to the Q: Drive



### Table 24 – Southern Illinois University, ILFAA SMS Pilot Studies Technical Report May 2011 Page 84



### Airport: Talladega, AL

Team Member: Travis Fiebelkorn

Airport contact: Ken Gilbert or Paul Esposito # of Operations: Zero **Airport

surrendered 139

certificate after completing SMS # of Employees:

FBO runs the airport, employees paid by the speedway Documents

delivered for Pilot Study: Manual, Gap Analysis
How many FTEs currently work

on SMS? None

Do you anticipate adding FTEs when implementation is complete? If Talladega decided to move forward, the estimate for SMS implementation was 953 hours for implementation and 720 hours each year for management. (refer to the repor t submitted for further detail) Do you envision FTEs or consultants managing your SMS after implementation? 

Did you use a consultant in your SMS process? If so, which one?

In what areas? Yes, ESIS, Inc. was used to perform the FAA sponsor ed Phase II Pilot Study. A gap analysis was performed, as well as a perception survey. A Sample SMS manual was al so developed.

What were your challenges in interpreting the SMS process? The match between Part 139 and the SMS was difficul t to digest as well as trying to determine if Part 139 w as a subset of SMS, or vice versa. It appears the FAA with the NPRM

has determined that SMS will be Part of Part 139. No guidance as to the applicability or relationship wa s or is provided. In addition, the ICAO and FAA SMS ACs regarding SM S are not always consistent with industry SMS standar ds. In particular, as defined by the AC 150/5200-37, SMS expectations are at time clearly communicated (e.g.

, Responsibility for assigning a Safety Manager) and at other times vague; such as establishing Objectives to ach ieve SMS or in the performance of Investigations. As a result, our Gap Analysis added Elements to the SMS outline, to reflect some of the industry standards. In particu lar, we added an element on Incident Investigations under R isk Management and Recognition under Safety Promotion, Encouragement. We also defined Business Integratio n under Safety Assurance to include Preventative Maintenance and Emergency Preparedness. Associated criteria were added to these elements, again, based on industry standards. What types of risks/hazards did you put through the SRM process during the Pilot Study? As this was a Phase II pilot, no Risk Assessment wa s performed.

What did the Gap Analysis

Reveal? As part of the Gap Analysis, a Perception Survey wa s also performed, to gauge the perception of management commitment and safety program performance on the pa rt of the workforce. The results of the gap analysis are presented below in Table 1, and represent and overall strong perception that safety is important; its importance is

communicated and considered a value in terms of Tal ladega airport operations. There was only one question that did not rank as a strength and that was “Safety Suggestions” (vulnerability). There were no “gaps” identified by the Perception Survey.FAA SMS Pilot Studies Technical Report May 2011 Page 85



### Airport: Talladega, AL

Team Member: Travis Fiebelkorn

Airport contact: Ken Gilbert or Paul Esposito # of Operations: Zero **Airport

surrendered 139

certificate after completing SMS # of Employees:

FBO runs the airport, employees paid by the speedway Documents

delivered for Pilot Study: Manual, Gap Analysis Therefore, based on the Gap Analysis, the findings and

scores indicate that there is about a 20-25% overal l agreement between what is required by Part 139, and future SMS expectations (75-80% gap). However, one elemen t in particular registered a score of 60% (Inspections a nd SelfAuditing) and along with Requirements, was the high est of any of the Elements. The remainder of the Elements and Sections all showed “Gaps” as defined by this pilot
assessment process.

As a result of this comparison, Part 139 and ACM requirements provide some of the documentation expe cted of an SMS, however, the majority of the implementat ion strategy and responsibilities are undefined, except for Inspections, Integration of Maintenance and Emergen cy Preparedness. Some other element of SMS, (i.e., Tr acking Systems, Roles and Responsibilities) would only pro vide a few of the expected documentation. Overall, the documentation expectations of SMS would require the ACM to be enhanced quite a bit.

Upon comparing ICAO and AC SMS expectations to othe r industry SMS standards (ANSI Z10, OSHA’s VPP, OHSAS 18000, etc.), there are a number of gaps to the pro posed FAA SMS. ESIS recommends that, at a minimum, FAA consider either adding or better integrating or exp anding the concepts of:

• Safety Policy and Objectives: Objective setting ba sed on Leading Trend Data and Performance Indicators.

• Safety Policy and Objectives: Safety Committee Expectations

• Safety Risk Management: Requirements

• Safety Risk Management: Ongoing Risk Reductions (t his is the biggest gap between industry standards and t he FAA / ICAO SMS) the FAA/ ICAO seem to stop at a one

time treat and mitigate, rather than ongoing risk

reductions.

• Safety Risk Management: Incident Investigations a nd Root Cause Analysis.

• Safety Risk Management: Emphasize the Risk Management Portion, Especially in Terms of Continuo us Improvement and Risk Reduction.

• Safety Promotion: Recognition and Encouragement

ESIS recommends that FAA refer to OSHA’s VPP 9Voluntary Protection Program) and ANSI Z 10 Health and Safety Management Systems) for better clarification of the above integration and expansion suggestions What difficulties/ challenges have Multiple entitie s controlling life-safety issues during the raceFAA SMS Pilot Studies Technical Report May 2011 Page 86



### Airport: Talladega, AL

Team Member: Travis Fiebelkorn

Airport contact: Ken Gilbert or Paul Esposito # of Operations: Zero **Airport

surrendered 139

certificate after completing SMS # of Employees:

FBO runs the airport, employees paid by the speedway Documents

delivered for Pilot Study: Manual, Gap Analysis you experienced during the Pilot Study? Lessons learned? weekends at the nearby speedway. Also, staff durin g these periods is subject to change, and specific training for the NASCAR events is on-going... race to race... year to ye ar.

What benefits have you seen to your airport from the SMS process?

• Unknown hazards

• A more active safety committee,

• A tracking system that leads to a more proactive approach

• One party identified as being responsible/in charge of safety concerns

• Lower long-term costs

• Others None... The airport staff is simply doing what it de ems is necessary to exist for 50 out of 52 weeks each year . The two other weeks it is a well run, well-staffed, wel l-protected facility with numerous safety programs in place. O nce the NASCAR races are over, the airport reverts back to a sleepy, GA-style airport with minimal operations.

An SMS can provide an airport with the capacity to anticipate and address safety issues before they le ad to a catastrophic incident or accident. SMS provides management with the ability to deal effectively wit h

accidents and near misses so that valuable lessons are applied to improve safety and efficiency. Research has shown that safety and efficiency are positively lin ked.

What were the key findings at your airport, as part of the Pilot Study? This was basically a GA airport with 139 credential s. It is not funded by the City, and the Airport Board uses its funds to match FAA/AIP projects. The FBO runs the airport o n a day-to-day basis, and their financial situation at the airport is poor, due to low revenues, etc. All of this contri buted to the airport's relinquishing its 139 certification.

Did you feel the FAA guidance was sufficient? What would you

want to see included in the SMS

AC? I cannot answer this. I personally think the FAA/A DO in Jackson had very little input during the preparatio n of the report, and the FAA in DC was non-responsive to on your GAP analysis submittal. The FAA/ADO is the one tha t told us to "wrap it up" so the AIP project could be clos ed out.

See comments above. May we put your information on the public docket? Please send electronic copies along with your

ok to use the information. I have no problem putting the final report on the p ublic docket. However, I need to compile the various seg ment of the final report into one large PDF file.



### Table 25 – Talladega, AL