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 20024
FAA 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 by Pilot Study Airports.............. 11

Appendix C: SMS Pilot Study Interview Comments ....................................................... 12

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

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EXECUTIVE SUMMARY 

The United States is a member state of the International Civil Aviation Organization 

(ICAO) and supported ICAO’s adoption of Safety Management Systems (SMS) as a 

means of moving aviation to the next level of safety. To promote SMS, ICAO amended 

Annex 14, Aerodromes, to require states to implement SMS at international airports. 

SMS is a formalized process for collecting safety data, identifying hazards and trends, 

determining safety risk severity, and mitigating risk to an acceptable level. The FAA 

Office of Airports is implementing SMS within its internal 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 volunteered to participate in SMS Pilot 

Studies. The majority of those participating received federal-financial assistance through 

the Airport Improvement Program (AIP). These airport operators experienced the 

challenges and benefits of developing and implementing 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 prepare a Technical Report documenting 

the participating airports’ experiences and lessons learned. The team interviewed airport 

operators and analyzed the responses to make a number of observations. 

Observations

Workload Impact: Pilot Study airports found the workload impact of SMS-related 

elements manageable. Although unable to make staffing changes, many airports were 

still able to reasonably accommodate development of SMS guidance and implementation. 

Gap Analysis: The airport operators found the Gap Analysis useful. It enabled the airport 

operators to identify those requirements of SMS that 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 notifications) can serve as a foundation for 

the components and elements of SMS. 

Benefits: Overall, airport operators benefitted from improved 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 development, support tools, and 

templates. 
FAA SMS Pilot Studies Technical Report May 2011 

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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 regulation and investigation of 

accidents to correct identified problems. Technological advances in aircraft design and 

construction, improvements in engine reliability, and 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 industries. 

Accident investigation generated a number of safety recommendations. However, the 

recommendations placed little emphasis on the hazardous conditions that, although 

present, were not identified as causal in the accident 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 navigation and communications. The 

safety focus started to shift to human factors and human performance. The development 

of crew resource management and training further improved safety, but human 

performance remained a recurring factor in safety breakdowns. 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 the operational level (active failures) can 

trigger conditions that help breach the system’s inherent safety defenses (latent failures). 

From the perspective of these organizational accidents, safety is improved through 

organizational structure and processes that identify latent failure conditions. Corrections 

or mitigations are implemented to reduce active failures and avoid accidents. 

This understanding led to the development of Safety Management Systems. SMS is a 

integrated collection of processes and procedures that 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 structure 

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 conditions 
FAA 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 certificated airports to implement 

SMS. In October 2010, FAA issued a Notice of Proposed Rulemaking (NPRM) in the 

Federal Register. The NPRM proposed amending 14 CFR 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 certificated airports. The majority of 

participating airports received federal-financial assistance through the Airport 

Improvement Program. The Pilot Studies were intended 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 Pilot Studies to help with the review of 

comments to the SMS NPRM and to improve the guidance 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 evaluate the development and 

implementation of SMS at airports of varying size and complexity.1 FAA conducted two 

rounds of the initial study where airports developed their SMS policies, procedures, and 

processes.

2

 Participants conducted a gap analysis and SMS Manual and Implementation 

Plan. A second study, using three of the original participants, conducted a proof-ofconcept. 

The scope of the pilot studies may significantly differ from the scope of proposed 

requirements in the NPRM because the FAA was investigating 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 Studies allowed these airports and the FAA 

to gain experience establishing airport-specific SMS 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 airport operators can use to improve 

safety in the face of significant forecasted air traffic growth. Airport operators using 

SMS are more likely to detect and correct safety problems before they result in an aircraft 

 

1

 Currently, a third pilot study is underway to gather best practices and information on implementation of 

certain components and elements of SMS. 

2

 FAA opened a second round to gain participation from smaller Class II, III, and IV certificated airports. 
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 industry 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 information 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 aviation 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 from the proposal, and the FAA 

remains open to all comments by interested parties.

Methodology

The FAA formed a team to collect information informally about each Pilot Study 

airport’s experiences. The team gathered information from the Pilot Study airports 

through a series of face-to-face and telephone interviews using scripted questions 

(Appendix B). These questions addressed the following 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 development and 

implementation; 

• Interpretation of the SMS; 

• Results of the Gap Analysis conducted as part of the 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 during the Pilot Study; and 

• Adequacy of the FAA guidance and recommendations for improvement. 

We reviewed and normalized the collected information to create the Interview 

Results/Workload Assessment included as Appendix B. Interview responses that 
FAA SMS Pilot Studies Technical Report May 2011 

Page 7 

consisted of comments to the NPRM rather than observations from the pilot studies have 

been edited as irrelevant to the scope of this report. Additionally, some interview 

responses may vary slightly from data the FAA relied 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 interviews. 

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 used varying levels of personnel, 

consultant support, and technological tools to achieve 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 awareness; 

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

process; and 

(3) Evaluation of hazards (through Safety Risk Management3 processes). 

c. Results suggest that SMS will provide benefits to airport safety beyond those 

operations regulated by 14 CFR 139, such as interdepartmental communications, 

general aviation customs issues, and vehicle operations near hazardous features. 

d. Results found that many of the Pilot Study airports acknowledge their existing 14 

CFR 139 compliance programs contain elements similar to those of SMS. 

e. Results found that most Pilot Study airports thought a confidential reporting 

system is preferable to a non-punitive reporting system. 

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 processes as the Safety Risk Assessment (SRA). The terms 

will be used interchangeably throughout the document. 
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—templates, checklists, 

examples of SRM, assurance/training requirements, and data collection and 

analysis; 

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

(6) Suggest/support/provide outreach to promote participation 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 Studies. We have posted this 

documentation— including SMS Gap Analyses, SMS Manuals, 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, IN 
FAA SMS Pilot Studies Technical Report May 2011 

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FAA SMS Pilot Studies Technical Report May 2011 

Page 11 

APPENDIX B: Interview Results/Workload Assessment by Pilot Study 

Airports 
FAA 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 the users. An overall 

challenge is to get buy-in from people who feel this is redundant to 139 and 

"get them to the table".

ASN 0 0 Unsure The match between part 139 and the SMS was difficult 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 was or is provided. In 

addition, the ICAO and FAA SMS ACs regarding SMS are not always 

consistent with industry SMS standards. In particular, 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 added Elements to the SMS 

outline to reflect some of the industry standards. In particular, we added an 

element on Incident Investigations under Risk Management and Recognition 

under Safety Promotion, Encouragement. We also defined Business 

Integration under Safety Assurance to include Preventative Maintenance 

and Emergency Preparedness. Associated criteria were added to these 

elements, again, based on industry standards.

TOL 1 0 Unsure Guidelines seemed directed for airlines - the airport 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. They had the benefit of 

50000 having an airport manager that was prior military and 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. Auditor Inspection 

58000 requirements that could be foreseen. Technology Integration. Cultural buy in.

JQF 1 0 No (1) Trying to determine where SMS applied. The scope 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 employees. (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. Scope, 4. Not much 

65000 background provided by FAA

OSU 1 4 Yes Not all that much literature out there. Had to explore 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 process, 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, 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 was intentionally 

vague on its instructions in order to spark creativity among airports. The 

Airport felt the Gap Analysis was challenging because of a lack of guidance.

 The airport used ICAO as a reference to perform the Gap Analysis. 

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

94614 threshold? Participation of tenants is a challenge. Not all airlines participate

 because they have their own SMS programs. If not all tenants participate, 

the airport's SMS program will suffer.

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

105000 mindset than actual regulation. During and after the SMS study we found that

 getting our FTEs to understand the process was challenging. We were 

asking them to take a process that would improve safety and apply it to 

operational situations without providing particular areas of focus. In the end 

we found that our team was ultimately using SMS, such 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 necessary. 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 required? 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 with interviews and 

123772 long distance communication

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

144563 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.

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

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

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

150000

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

176914
FAA 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 some safety initiatives, 

178484 participation of stakeholders in the SRA process and 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 operator and third parties 

313143 regarding the development and maintenance of SMS. Ascertaining if the 

airport sponsor can delegate SMS responsibilities to tenants within 

exclusive leaseholds. Determining legal liabilities 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/reference; 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. Methodology for 

“inspection”/FAA oversight of SMS within ACM/139 framework not defined

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

950119 especially with providing resource information to conduct research.

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

4622520 was difficult to have a point of reference for development of a SMS 

implementation document. Our SMS document was done by a consultant 

familiar with how SMS was implemented in the European 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 working 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; Airfield Inspections: 

Capture current self-inspection practices (1 inspection per shift vs. 1 

per day in the ACM) in writing; Commercial aircraft operations ramp: 

Documenting specific inspection items on self-inspection 

documentation; Safety Manager: Designate a safety manager to oversee 

SMS and ensure communication with senior management; Non-Punitive 

Reporting System: Establish a system; Training Records: Document 

procedures for conducting the established practice of auditing FBO 

fueling personnel training records; Recurring Training: Establish 

consistent recurrent training timelines and consider establishing 12 

month cycle for all training; Condition Reports: Establish and document 

timelines for filing condition reports; Communication: Evaluate and 

capture current practices in writing (ACM); Pedestrian and Ground 

Vehicle Procedures: Evaluate content and effectiveness of training 

program; Obstructions: Identify ownership of obstructions and develop a

 notification / tracking system for ensuring obstructions are monitored 

and addressed; Wildlife: Include training requirements in the WHMP 

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

41000 gauge the perception of management commitment and safety program 

performance on the part of the workforce. The results of the gap 

analysis represent an overall strong perception that safety is important; 

its importance is communicated and considered of value in terms of 

Talladega 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. Therefore, 

based on the Gap Analysis, the findings and scores indicate that there is

 about a 20-25% overall agreement between what is required by part 

139, and future SMS expectations (75-80% gap). However, one element 

in particular registered a score of 60% (Inspections and Self-Auditing) 

and along with Requirements, was the highest 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 expected of an SMS; however, the majority of the 

implementation strategy and responsibilities are undefined, except for 

Inspections, Integration of Maintenance and Emergency Preparedness. 

Some other element of SMS, (i.e., Tracking Systems, Roles and 

Responsibilities) would only provide a few of the expected documents. 

Overall, the documentation expectations of SMS would require the ACM 

to be enhanced quite a bit. Upon comparing ICAO and AC SMS 

expectations to other industry SMS standards (ANSI Z10, OSHA’s VPP, 

OHSAS 18000, etc.), there are a number of gaps to the proposed FAA 

SMS. ESIS recommends that, at a minimum, FAA consider either adding

 or better integrating or expanding the concepts of: • Safety Policy and 

Objectives: Objective setting based on Leading Trend Data and 

Performance Indicators. • Safety Policy and Objectives: Safety 

Committee Expectations• Safety Risk Management: Requirements• 

Safety Risk Management: Ongoing Risk Reductions (this is the biggest 

gap between industry standards and the FAA / ICAO SMS) the FAA/ ICAO

 seems to stop at a one-time treat and mitigate, rather than ongoing risk 

reductions.• Safety Risk Management: Incident Investigations and Root 

Cause Analysis.• Safety Risk Management: Emphasize the Risk 
FAA 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 Continuous Improvement 

and Risk Reduction.• Safety Promotion: Recognition and Encouragement

ESIS recommends that FAA refer to OSHA’s VPP 9Voluntary Protection 

Program) and ANSZI Z 10 Health and Safety Management Systems) for 

better clarification of the above integration and expansion suggestions,

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

47000

DBQ 0 4 No Couldn’t recall

50000

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

51217 informal safety resolution procedures. The airport would take care of 

issues as notified. The SMS processes allowed airport personnel to 

actively communicate with the airport users.

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

58000 was no area where they were fully compliant with SMS.

JQF 1 0 No Management and front line personnel had different interpretation and 

60000 opinion of safety. This revealed gaps in communication, 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. Formality of safety 

73000 program required for SMS. More paperwork and process. Proactive 

Safety policy and promotion.

SIU 1 0 Yes Safety must be formalized through: 1) Adjusting documentation 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. Have a lot of issues 

94614 inside the gate & baggage areas.

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

105000 currently unintentionally meet some parts of the SMS guidelines. The 

Gap Analysis identified weaknesses in resolving maintenance items, 

record keeping and training. As a result these areas 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 mail 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 reveal 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 review our 

144563 organizational structure and assign specific duties related to SMS. 

Additionally, we found that we could improve upon safety promotion 

efforts. Finally, we found that we were in need of an incident reporting 

database that would allow for the easy review of incidents 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 later date.

150000

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

176914 Non-punitive reporting systems, Implementation Plan, detailed SRA 

documentation, approval and follow-up of mitigations by senior 

management, description of airport risk management program, selfauditing process, plan to integrate SMS program into overall airport 

operations, promotion of safety awareness, documentation of lessons 

learned

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

178484

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

268005 specifics).

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

280000 marking and lighting. Safety area focus at BI intersection.

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

313143 documentation of practices at the airport, and SMS standards revealed 

that in some instances certain practices or procedures are in place, but 

may not be collectively gathered or documented to meet the intent of a 

formal SMS. In other instances, data collection or record-keeping is 

being completed as part of a database managed by CCDOA, but has not 

been formally included as part of the SMS program. 

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

318000 picture and requires more judgment.

DAB 1 0 No FBO, NASCAR, ERAU, Flight schools...how do we get them 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 consultant as part of 

652261 first pilot study. Several SMS elements are present, though not yet all 

formalized, and, therefore, not consistently or systematically applied. 

Need to establish/refine formal “safety policy.” Responsibilities – need 

to clarify with respect to SMS at all level so Coordination – many SMS 

processes require cross-functional working coordination and 

cooperation, this occurs on a case-by-case basis currently but 

organizational processes will need to be improved. Documentation – 

with the exception of all those required by regulation, 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 part of all processes, in

 particular with regard to current airside hazards facing the organization 

and change management. Communication – there is a need for a 

formalized and systematic process and mechanism to promote and 

ensure the free exchange of safety information between staff at all 

levels of the organization, between sections and departments, between 

divisions and with external service providers. Accountability – current 

FAA framework does not extend airport authority to the non-movement 

area. The efforts made by the Airport to improve safety performance by 

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.

o Performance Indicators – there will need to be a process 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

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

950119 City of Atlanta and DOA have internal safety policies in safety manuals. 

Did not have Safety Risk Assessment Process

DTW 1 0 1 No response received.

4622520
FAA SMS Pilot Studies Technical Report May 2011 

Page 19 

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

#of tasked SMS development and implementation?

Operations Employees FTEs?

FTE / PT

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

24000 relating to the issue with tug operations on the air carrier ramp. Other 

SRAs were conducted for system changes; Active Safety Committee: 

Good participation in SRAs, considering safety-related work is a 

collateral duty for most of the SRMP members; Tracking System: System 

is in development; One party identified as responsible/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, too early to tell. There 

is an anticipated cost reduction similar to the workers' comp multiplier. 

Cost savings under 139 may not be significant because it is already 

saving costs by preventing accidents; Others: Relationship with tenants 

improved. The process inherently and actively involves 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 collaborative 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 deems is necessary to 

41000 exist for 50 out of 52 weeks each year. The two other weeks it is a well 

run, well-staffed, well-protected facility with numerous safety programs in

 place. Once 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 lead to a catastrophic incident or accident. SMS provides 

management with the ability to deal effectively with accidents and near 

misses so that valuable lessons are applied to improve safety and 

efficiency. Research has shown that safety and efficiency 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 experience really enforced the 

50000 big picture mentality 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 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 holding 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. Creation 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) communication 

across the organizations needs to be improved (4) lower costs by 

preventing litigation, (5) effective documentation system is key
FAA SMS Pilot Studies Technical Report May 2011 

Page 20 

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

#of tasked SMS development and implementation?

Operations Employees FTEs?

FTE / PT

JAN 0 1 Unsure More safety awareness for the staff - cultural changes

65000

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

73000 Formalizing movement of vehicles. 3. Wildlife mitigation - 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 experienced cost savings 

yet, it will cost to hire new staff person.

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

80000 longer term, continuing SRAs as opposed to multiple SRAs on individual 

issues that are all related. SMS is building a culture that, combined with 

improved data collection, will bring out hazards more efficiently. A more 

active safety committee: Results in more activity - information sharing. 

People respond to the tone set by the airport manager through the Safety 

Committee, which leads to improved identification of hazards. 

Formalization of the safety culture through elements like the safety 

committee establishes the SMS's credibility among users. A tracking 

system that leads to a more proactive approach: Incident Reporter by 

OMNI Air Group (data collection software) was cumbersome. SIU 

developed a web-based data collection site that collects, organizes and 

tracks data, reducing workload on the person responsible for monitoring 

the system (currently airport manager). Email functionality 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 based data collection 

system. The system allows one person to address issues more 

efficiently. With efficient data collection and notification, 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 boon to SIU for 

professional development, aviation industry and airports. 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 documenting the process. 

94614 Proactive about documenting hazards and 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.
FAA SMS Pilot Studies Technical Report May 2011 

Page 21 

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

#of tasked SMS development and implementation?

Operations Employees FTEs?

FTE / PT

AFW 2 0 Yes a. Unknown hazards. Nothing identified during or after 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 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 better tracking system

 for open items such as damaged airport signs and missing 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. Better application and 

consistency would allow for more detailed trend analysis, better long 

term planning, and could show unknown problems with the airport 

environment. d. One party identified as being responsible/in charge of 

safety concerns. Senior Leaders do play an active role in safety and 

have implemented several components from the SMS pilot study. e. 

Lower long-term cost- None at this time. Although we 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 involved- they check the 

118000 reporting hotline daily, 3- Hard to quantify cost savings, 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 part of SMS. The safety

123772 committee should have been better developed. It took a year after the 

consultant/Engineers and FAA program Manager went out to the site to 

improve the process. Tracking system consists of email 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 greater safety awareness 

144563 among employees. Once role out is complete, we anticipate improved 

means of monitoring and trending safety incidents/hazards. Finally, we 

have received positive input from our liability insurance carrier resulting 

from our use of SMS, though no reduction in rates have been realized. 

TEB 0 0 No More safety awareness for the staff - cultural changes

150000

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

150000 did discover some potential hazards that we resolved, so did result in 

improved safety.

AUS 0 1 Yes Not yet implemented. 

176914
FAA SMS Pilot Studies Technical Report May 2011 

Page 22 

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

#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 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.

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 Awareness.

280000

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

313143 pilot study only a few specific test items were subjected to the process. 

Benefits cannot be determined until a large sampling of items can be 

achieved.

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

318000 previous studies proposed policies and practices, develop a quality 

management program, align airport, airline, ground handler safety 

programs, incorporate non-movement areas into inspections/audits, 

reinforce safety culture, improve safety awareness

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

350000 major component of monthly tenant meetings. Interns 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” but accountability at all 

levels within the organization (in theory)o Lower long-term costs – quite 

possibly difficult to measure/quantify or categorize. Enhanced 

collaboration between departments regarding 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

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

950119 projects and changes on the airfield; Establishing a SMS Work Group 

with tenant involvement 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 system 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.

4622520
FAA 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 current activity relative to safety

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

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

41000 City, and the Airport Board uses its funds to match FAA/AIP projects. The 

FBO runs the airport on a day-to-day basis, and their 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 about Safety and SMS 

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

50000 of hangars and gate areas. Training and fatigue issues, 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 issues amongst airports

58000 Governance and legal, ATC and airports have different 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, Identification verbiage for 

severity and probability variances, Definitions developed over time, 

Tolerance levels vary, Assessments became more calculated

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 happens for safety in non73000 movement areas.

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

80000 direct specific attention to safety issues and mitigation. SRAs were 

valuable in bringing together different perspectives and allowing 

participants to understand the perspectives of the other parties involved.

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

94614 then once foundation is set, easy to modify. 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 Implementation 
FAA 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 closed out with documentation.

 Work toward better airport visibility for SMS, need a platform for organizing

 safety & outstanding work orders in the same manner that you have a 

platform for security.

KOA 1 0 Yes Require additional: Driver's training, SMS qualified 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 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 

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 implement 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 prevalent findings were 

313143 ascertained. We are only in the process of defining the SMS.

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

318000 interpretation) to SMS looking at root cause and this 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 involvement and 

350000

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

652261 components of SMS – just need to refine and “formalize” 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 Management Office, DOA and 

City of Atlanta Safety Policy Manuals

DTW 1 0 1 No response received.

4622520
FAA 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-punitive 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 activities (e.g., getting air 

carriers to report incidents/damage to their equipment 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 SMSs for ATO, ARP, AVS, Air Carriers - how 

will multiple SMSs be integrated / correlated to prevent duplication of 

effort?; Addressing the issue of LOBs convening competing SRMPs to 

produce a desired outcome; 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 subject to FOIA. Appendix A of the Follow-On 

report SBM submitted details these alternatives.

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

41000 the nearby speedway. Also, staff during these periods 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. Problems 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 other times)

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

50000 resources in a challenging budget environment?

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

51217 wouldn’t promote unsafe activities. We didn’t really 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 learned that we are already 

communicating hazards fairly well since we are a smaller airport. Daily 

interaction with our tenants has provided a good flow of communication. 

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

58000 technology development, "Non-Punitive" Policy, Definitions for SRM, 

Budget: Implementation, Corrective Actions, Staffing SMS when employees

 already wear several hats. Airport pilot similarities: all had 139 Safety 

Self-Inspections, Gap Analyses varied in size/complexity, Full time SMS 

employee is challenging, Budgeting will be difficult, All had some 

technology for support, Training tracking could 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 resources including technology, Smaller airports can implement more 

easily, Employee turnover at small airports is lower
FAA 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. Financial incentives to help with

60000 the safety efforts did not work. Use of field-tough 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. Challenge was to get buy in 

73000 from wider airport community to collect hazards. Experimenting with 

different hazard reporting models. Education of IT staff takes time. Overall,

 not as challenging as we had thought. It will take a long time to change the

 culture.

SIU 1 0 Yes 1) How do airports get funding for staffing, training 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 acted on? This may 

create a risk of airport sponsors minimizing hazards to avoid spending 

money. Lessons Learned: 1) Ensuring management involvement / buy-in. 

Leadership is critical. 2) Communication should come 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 reports- too archaic. 

94614 Instead went 'high tech' with a web based report designed by a local 

contractor. Promotion is a major challenge, have to be a cheerleader to 

promote the program.

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

105000 SMS. We often find that making the time to manage the SMS process is our 

main obstacle. Some areas within SMS require additional 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 interest, "Bleed Safety". 

118000 Developed posters, banners, safety candy jars, lanyards, badge reels etc. 

Make a BIG DEAL about safety. Patterned his program off of military 

aviation Risk management program called "ANY MOUSE".

KOA 1 0 Yes Selection of a well-qualified consultant is paramount. 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 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 a position remains to 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 management 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 draft, but overall a 

150000 positive experience, was handled by manager groups only

SMF No The challenges were primarily addressed by the consultant

150000

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

176914

SAT 2 2 Unsure Need to communicate with stakeholders, understand the 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 organization and Legal Dept. 

268005 Highly suggest hiring a consultant to develop the manual and 

implementation plan. Said they brought an outside perspective 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, database.
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 includes the introduction 

and maintenance of SMS training records for all airport employees, 

documentation of hazard identification and analysis, documentation of the 

effectiveness of corrective and preventative measures 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 hire of a full time 

Management Analyst I at $84,460 annually including benefits. The 

SMS process includes new requirements for initial and annual recurrent 

training of airport employees in overall airport safety objectives, safety risk 

management principles, safety assurance topics, airport rules and 

regulations, and overall department organization and functions. A plan to 

validate training effectiveness and a process to obtain 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. Assuming an average hourly

 wage of $28 for each CCDOA employee, CCDOA training 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 costs total $57,120. SMS 

requires change management, a formal process to identify, anticipate, and 

prepare for potential hazards introduced into the airport environment. 

Trigger events 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 regulations. The airport embraces a nonpunitive safety reporting policy as outlined in the Clark County Workplace 

Safety and Health Policy. However, certain violations of applicable laws, 

policies, or procedures may require additional disciplinary action. This 

issue is not addressed by SMS. Safety communication to promote a 

safety culture through all levels of the airport organization is a requirement 

of SMS. Although some communication processes are currently in place, 

such as newsletters and tenant meetings, other systems for disseminating 

information regarding airport operations, facility maintenance, airfield 

construction, employee safety awareness, tenant safety awareness, airside 

safety, and wildlife safety would be required. The additional cost cannot be 

calculated until the specific media are selected, but the expense would be 

significant. Implementation and maintenance of SMS would be challenging 

and labor intensive, particularly at North Las Vegas Airport. A new 

management analyst position would be required at $84,460. Annual training

 costs are estimated at $57,120. These staffing and training costs together 

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 Director of Aviation, General Aviation as SMS 

Responsible Executive, or the duties of the Airport Manager under the draft 

SMS manual submitted to the FAA. The annual cost of communication and 

file storage would also be a significant factor. This 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 overlapping assignments, 

318000 roles, responsibilities; Will FAA defer safety to SRA process in lieu of their 

"intuition" or expert opinion; FAA ARP does not have staff or resources to 

support participation or facilitation of SRAs, their 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 meetings challenging – 

652261 possibly establish a “core” identified group committed to the effort that can 

easily 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, also they realize 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 oversight. 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 harmonization of the decision 

making process and defining 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 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 carrier 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 regulatory 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 under government 

disclosures laws, (b) possession and control of the data acquired, (c) use of

 accident and incident data in tenant risk assessment exercises, and (d) 

use of stakeholder data for creating and or modifying 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 foundation 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 with all divisions that 

are accountable for the airfield, while you learn to understand and develop 

the four main components of SMS. Develop, improve, and/or recreate all 

reports and information structured, or organized, reflective of the functions 

(Safety Critical Systems-SCS) of the airfield and outlined in FAR 139. Engage

 your airport’s cross functional SME’s to champion each SCS throughout the

 development. Utilize computer and mobile technology to streamline 

reporting, foster decision making, improve asset management, track and 

trend risks, reduce frustration, and build relationships. 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 guidance 

Operations Employees FTEs? material?

FTE / PT

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

24000 networking with other airports. With basics laid out by the FAA, the 

study became a "community thing." The guidance got parties started 

down the road and left enough leeway for interpretation. 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 information about operations 

outside of 139, can the ACSI inspect and cite the airport for violations in 

those areas? Will the airport need to maintain 2 SMSs - 1 within the 

ACM and another for everything outside of 139? This will be 

counterproductive. Make sure the AC does not move airports too far 

toward procedure-based documents (overreliance on checklists). 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 (in terms of what is 

47000 applicable - and scalability). Need clear definition 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 will affect the overall 

program. They felt they had a good grasp on what they needed. They said

 they relied heavily on the consultants to create the 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 with recording and 

tracking hazards, and Safety Policy language and some sort of 

clearinghouse where safety information can be distributed to all 

participants. An example would be a place that will provide safety 

videos and hazard mitigation courses without too much 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 following 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 ACM 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 consultants) 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 guidance 

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 documentation 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 could be strengthened 

105000 and more clearly defined. The FAA issued the AC in early 2007 that 

addressed the “concepts”. In our opinion airports would benefit by 

knowing the particulars of the SMS regulation. The SMS AC was written 

in a broad sense and ultimately offered a basic understanding and not 

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 standards as Class I airports?) Having a breakdown of the 

requirements 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 information to the airports 

division before and during the rewrite of the AC. Overall better 

alignment with ACs and current 139 regulations would 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 minimum qualifications,

 reporting relationships etc. Describe specifically 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 staff 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; even in the circulars. 

The topics covered in the present circular AC150-5200-37, are sufficient.

 I would just add forms and templates.

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

144563 in the final SMS rule making. This document was developed as a 

general guidance document and in order to provide an orientation to 

SMS. It would also be beneficial to clarify how various 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 everything per the AC. 

150000 Need better risk matrix definitions, training requirements, how is SMS 

going to be implemented?, specify a baseline vs. gap analysis

SMF No Many areas need clarification.

150000

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

176914 laws/ordinances relating to open records make it nearly impossible to 

protect identities of individuals who identify hazards.
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 guidance 

Operations Employees FTEs? material?

FTE / PT

SAT 2 2 Unsure Yes, but with some limitations. We appreciate the cooperation 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 cover/look for 5. Define 

step by step process for implementing SMS 6. Clear and specific 

auditing requirements 7. SRM documentation 8. Policy statement 

requirement 9. What are the requirements for training / education? 10. 

Define non-punitive reporting 11. How is data protected (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 signage 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 imposing SMS 

313143 responsibilities on airports for non-movement areas under the control of

 tenants. The operational costs (including especially personnel, 

recordkeeping, training and liability) for airports and the mechanisms by 

which airports will fund compliance with their ongoing SMS obligations.

The manner by which airports should resolve conflicts or competing 

obligations imposed by the proposed part 139 SMS manual, by other 

SMS requirements (including, but not limited to, Order 5200.11), SMS 

requirements imposed on other airfield users (including part 121 

operators and ATO), existing contractual obligations, and other grant 

assurance obligations. The liability and public information issues 

raised by the obligation to prepare safety risk assessments 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 complex airports. The 

agency needs to provide a clear and unequivocal hierarchy of authority 

among the various proposed and forthcoming SMS requirements so that

 airports do not have to guess who has authority and 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 for FAA Airports 

Division, and one for ATO. There should be some language that gives 

relief with regard to data sharing, i.e. exempt from FOIA requests and 

some anonymousness. Much more to learn as we continue to 

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

350000 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 and 

flight schools that we're all in this together. Templates would be a good 

idea, similar to the template for the AEP. Need a guideline to walk 

someone through the process (especially the airports without a 
FAA 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 guidance 

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 the FAA should be 

better aligned with one another and include consistent 

verbiage/definitions (i.e. SRA vs. Safety Assessment 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 (maybe 2 or 3)?

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

950119 studies; However the airport collaboration has helped 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 area. 

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 format, 

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. Overall Awareness. 

What were the key findings at your 

airport, as part of the Pilot Study? 

This caused BFI to focus on unique elements on airport 

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 what 

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, WA 
FAA 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 airport 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 scope 

and the extent, beyond 139.(2) Non-punitive reporting 

was (and still is) an issue. It contradicts the City's 

regulations. Airport employees are city employees. (3) 

Trying to keep attendance at "SMS' safety committees 

was an issue, especially for non-airport participants 

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) managing 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. Financial 

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 following 

is desirable: Flexibility, Scalability, and Encouragement to 

use technology, i.e. use of simple to use reporting and 

training systems 

May we put your information on the Yes, did send copies already 
FAA 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, NC 
FAA 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 airports. 

Problem interpreting and applying the Gap Analysis, not 

sure how to use SMS for different parts of the airport 

What types of risks/hazards did 

you put through the SRM process 

during the Pilot Study? 

1. Annual Sports Car Event, 2. Snow removal equipment, 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. 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 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 changes. 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 (in terms 

of what is applicable - and scalability). Need clear definition 

of responsible parties: e.g. for runways - AT vs. the airport 

May we put your information on No, not at this time
FAA 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, OH 
FAA 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 and 

assisted in third. 

What were your challenges in 

interpreting the SMS process? 

Definitions- What is significant, catastrophic. Auditor 

Inspection requirements that could be foreseen. Technology 

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 approach 

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 compliant. 

What difficulties/ challenges have 

you experienced during the Pilot 

Study? Lessons learned? 

Public Disclosure Protection, SMS in Non Movement Tenant 

Areas, SMS Technology Development, "Non Punitive" 

Policy, Definitions for SRM, Budget: Implementation, 

Corrective Actions, Staffing SMS when employees already 

wear several hats. 

Airport Pilot Similarities: All had 139 Safety Self Inspections, 

Gap Analysis varied in size/complexity, Full time SMS 

employee is challenging, Budgeting will be difficult, All had 

some technology for support, Training tracking could 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 resources 

including technology, Smaller airports can implement more 

easily, Employee turnover at small airports is lower 

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 through 

cracks 
FAA 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 issues 

amongst airports 

• Governance and Legal, ATC and airports have different 

focus 

• ATC hazard life risk only 

• SMS is a PROCESS that must fit the airport, not the 

other way around 

• Risk Matrix Chart color variations 

• Identification verbiage for Severity and Probability 

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 more clearly 

defined in AC for a regulatory environment. See other 

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, WY 
FAA 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 part time 

Do you envision FTEs or 

consultants managing your SMS 

after implementation? Probably not- Maybe use a vender 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 explore 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. Formality of 

safety program required for SMS. More paperwork and 

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. Challenge 

was to get buy in from wider airport community to collect 

hazards. Experimenting with different hazard reporting 

models. Education of IT staff takes time. Overall, 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 when tower 

has been closed. 4. Formal lines of communication on 

safety has been facilitated, they now meet quarterly. 4. 

Brings in a culture of safety. 5. Have not experienced 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 happens 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 April 
FAA 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, OH
FAA 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 yet 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 Statement, 

Training, Non-punitive reporting systems, Implementation 

Plan, detailed SRA documentation, approval and follow-up 

of mitigations by senior management, description of airport 

risk management program, self-auditing process, plan to 

integrate SMS program into overall airport operations, 

promotion of safety awareness, documentation of lessons 

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. However, the 

timeline for incorporating airport tenants is unreasonable (we 

need to put the SMS in-place for airport owner employees 

first). State and local laws/ordinances relating to open 

records make it nearly impossible to protect identities of 

individuals who identify hazards. 

Did you feel the FAA guidance The FAA guidance is sufficient in most areas. State and 
FAA 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, TX 
FAA 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 basis 

with SMS 

Do you anticipate adding FTEs when 

implementation is complete? Will depend upon requirements 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 initial 

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 some 

safety initiatives, participation of stakeholders in the SRA 

process and getting usable information from the previous 

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 good base for SMS 

What difficulties/ challenges have 

you experienced during the Pilot 

Study? Lessons learned? 

Need to communicate with stakeholders, understand the 

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 Airports 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 airports. 

SAT would suggest that a working group of the Pilot

Study airports be developed to discuss their experiences, 

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, TX 
FAA 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. Current 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 (Airport 

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 willing 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 organization 

and Legal Dept. Highly suggest hiring a consultant to 

develop the manual and implementation plan. Said they 

brought an outside perspective and viewpoint that is 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 have 

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 throughout 

the organization, quality of training and safety awareness 

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 step 

process for implementing SMS 6. Clear and specific 

auditing requirements 7. SRM documentation 8. Policy 

statement requirement 9. What are the requirements for 

training / education 10. Define non-punitive reporting 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, MD
FAA SMS Pilot Studies Technical Report May 2011 

Page 50 

Airport: Daytona Beach 

International Airport, Daytona 

Beach, FL

Team Member: Laurie Jane 

Dragonas 

Airport 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 own 

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 staffing is 

issue. 2. Vehicle Pedestrian deviations. 3. Pilot training, 

have a lot of flight schools on airport, ERAU has 250 ops / 

day at peak 

What did the Gap Analysis Reveal? 

FBO, Nasser, ERAU, Flight schools...how do we get them 

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 tenantsthey have weekly meetings to talk about safety issues. 

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, safety is 

now a major component of monthly tenant meetings. 

Interns from Embry Riddle are tracking projects such 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 understand 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 we're all 

in this together. Templates would be a good idea, similar 

to the template for the AEP. need a guideline to walk 

someone through the process ( specially the airports 

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 

Dragonas 

Airport 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 NOTAM, 

gap analysis, manual and SMS implementation plan 

Table 9 – Daytona Beach International, FL 
FAA 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 adding 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 that 

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 aircraft 

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 current 

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 this 

experience really enforced the big picture mentality 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 safety 

reporting hotline on their website starting soon. The 

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 pulling 

aircraft into and out of hangars and gate areas. Training 

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 scope 

and complexity will affect the overall program. They felt 

they had a good grasp on what they needed. They said 

they relied heavily on the consultants to create the 

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, IA 
FAA 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 complicated, What 

is the threshold? Participation of tenants is a challenge. Not 

all airlines participate because they have their own SMS 

programs. If not all tenants participate, the airport'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 movements 

What did the Gap Analysis 

Reveal? 

Risk analysis process needs to be put in place. Have 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 reportstoo archaic. Instead went 'high tech' with a web-based report 

designed by a local contractor. Promotion is a major 

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 documenting 

the process. Proactive about documenting hazards and 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 SMS to 

get a grasp, then once foundation is set, easy to modify. 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 implementation 

plan 

Did you feel the FAA guidance Guidance was adequate. It was easy to tap in to SMS from 
FAA 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 documentation 

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 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, FL 
FAA 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 person 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 with 

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 poor job 

assessing the hazard 

What did the Gap Analysis 

Reveal? 

Gap Analysis for ICAO vs FAR part 139 did not reveal 

anything too earthshaking , but there was issues with 

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 paramount. In 

order for ANY safety plan, program or management system 

to be effective it MUST have dedicated staff to administer 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 position 

remains to be established at Kona. 

A more robust driver's training program should be part of 

SMS. The safety committee should have been better 

developed. It took a year after the consultant/Engineers and 

FAA program Manager went out to the site to improve the 

process. Tracking system consists of email 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 

What were the key findings at 

your airport, as part of the Pilot 

Study? 

Require additional: Driver's training, SMS qualified training, 

Self inspection training 

Did you feel the FAA guidance 

was sufficient? What would you 

Many airports, not just in Hawaii, do not have staff enough to 

produce the kinds of documents and training to promote and 
FAA 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 cultural change 

and therefore should receive any and all coverage to 

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 allowable documents 

Table 12 – Kona International, HI 
FAA 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 positions 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 other 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 (ramps, 

perimeter, etc) 

What did the Gap Analysis 

Reveal? Have no answer at this time, will comment at a later date 

What difficulties/ challenges have 

you experienced during the Pilot 

Study? Lessons learned? The challenges were primarily 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 has 

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 details 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 clearance from upper management 

Table 13 – Sacramento International, CA 
FAA 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 provided 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 document 

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 tenants. 

There were informal safety resolution procedures. The 

airport would take care of issues as notified. The SMS 

process allowed airport personnel to actively communicate 

with the airport users 

What difficulties/ challenges have 

you experienced during the Pilot 

Study? Lessons learned? 

Development of a true safety policy and objective was hard 

since you really wouldn’t promote unsafe activities. We didn’t 

really 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 learned that we are already communicating hazards 

fairly well since we are a smaller airport. Daily interaction 

with our tenants has provided a good flow of communication 

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 holding 

tenant safety meetings using the local FAA Safety Team 

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 to add 

another layer of bureaucracy into a community that already 
FAA 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 flexibility with 

recording and tracking hazards. Safety Policy language and 

some sort of clearinghouse where safety information can be 

distributed to all participants. Such as, a place that 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 documents 

Table 14 – Santa Maria Municipal, CA 
FAA 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 are 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 position is 

planned to be maintained after implementation and other 

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 Study and is 

currently being used for the implementation study 

Applied Research Associates (ARA) has been the principle 

consultant for all deliverables/activities in both Pilot Studies 

(they have enlisted the assistance of sub-consultants in their 

efforts 

What were your challenges in 

interpreting the SMS process? 

Interpretation of possible legal/liability issues with no 

guidance 

Accountability of tenants not defined/regulated 

Methodology for “inspection”/FAA oversight of SMS within 

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 (AMA) 

Construction ramp safety (DFW Terminal Redevelopment 

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 all 

formalized, and, therefore, not consistently or 

systematically applied. Need to establish/refine formal 

“safety policy.” 

• Responsibilities – need to clarify with respect to SMS at 

all levels 

• Coordination – many SMS processes require crossfunctional working coordination and cooperation, this 

occurs on a case-by-case basis currently but 

organizational processes will need to be improved 

• Documentation – with the exception of all those required 

by regulation, 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 part of all processes, in particular with regard 

to current airside hazards facing the organization and 

change management 
FAA 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 and 

systematic process and mechanism to promote and 

ensure the free exchange of safety information between 

staff at all levels of the organization, between sections 

and departments, between divisions and with external 

service providers 

• Accountability – current FAA framework does not extend 

airport authority to the non-movement area. The efforts 

made by the Airport to improve safety performance by 

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 process 

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 easily 

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, also 

they realize that identification of hazards may “create 

work” for their organization, these may skew their hazard 

risk ratings (lower risk) 

• Non-movement area inclusion will be a challenge without 

more explicit regulatory oversight 

• 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. 

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 charge of 

safety concerns - not just the “accountable executive” 

but accountability at all levels within the organization (in 

theory) 

• Lower long-term costs – quite possibly difficult to 

measure/quantify or categorize 

• Enhanced collaboration between departments regarding 
FAA 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 “formalize” 

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 another 

and include consistent verbiage/definitions (i.e. SRA 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, SMS 

implementation plan, and SMS manual (?) 

• Our manual is still a “living” document in its earliest 

stages of development and many components are 

undergoing revision/editing based on results from the 

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 possibility of 

publishing to the public docked internally 

Table 15 – Dallas Fort Worth, TX 
FAA 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 more 

staffing. NPRM should address the amount and type of 

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 required? Begin 

with trigger events? What does AA expect? Fuel needs to 

more specific about expectations, organizational structures, 

reporting relationships. It would help when final rule goes 

out with the rule requires specific positions and qualifying 

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 operations, such 

as during severe weather, or when airport is supporting a 

multitude of diversions from airports around the state. 3- 

Also studied water intrusion ( terminal roof project) 

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 struggling 

with staffing issues, how are ops supposed to interact 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 etc. Make 

a BIG DEAL about safety. Patterned his program off of 

military aviation Risk management program called "ANY 

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 involved- they 

check the reporting hotline daily, 3- Hard to quantify cost 

savings, yes if you save one life, 4- Better responsibility, 

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 is closed out w 

documentation. Work toward better airport visibility 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 implementation. 

Describe minimum qualifications, reporting relationships 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 everything 

from TLH 

Table 16 – Tallahassee Regional, FL 
FAA 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 added 

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 implementation. 

Our staff handles both the FBO and airport operation 

component and must multitask and balance time between 

airport operations and service delivery. Adding a SMS to 

FAR139 would require additional manpower to ensure 

appropriate application and compliance of SMS. 

Implementation of SMS will increase our operating and 

administrative budget, primarily for additional FTEs needed 

to support the program but also includes miscellaneous 

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 SMS 

overall is more of a mindset than actual regulation. During 

and after the SMS study we found that getting our FTEs to 

understand the process was challenging. We were asking 

them to take a process that would improve safety and apply 

it operational situations without providing particular areas of 

focus. In the end we found that our team was ultimately 

using SMS, such as SRM when evaluating air show planning 

and AOA construction. 

In my opinion the SMS process talks too broadly and ask the 

users to apply the tools where necessary without giving 

particular guidance, which is different than what most AC’s 

and FARs provide. As an example: One FTE might think 

that a SRM process is needed for a particular project, but 

another may see it differently; therefore they may feel that 

the process is not necessary. So how do you determine 

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 Taxiway 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 runway. 

What makes this intersection challenging is the fact that the 

main ramp and taxiway A are only separated by a nonmovement boundary marker. So if a pilot is task saturated 

during taxi or has failed to properly identify the intersection 

he/she could mistake the intersection as the entrance to the 

taxiway system from the main ramp and ultimately enter the 
FAA 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 together for our 

FTEs. Once they had a way to tie the SMS process to a 

particular process they began to understand the process 

What did the Gap Analysis 

Reveal? 

The Gap Analysis revealed that we meet all components of 

FAR139 and currently unintentionally meet some parts of the 

SMS guidelines. 

It identified weaknesses in resolving maintenance items, 

record keeping and training. As a result these areas were 

reviewed and strengthened. It helped identify programs such 

as, safety committees and showed the value of the program 

What difficulties/ challenges have 

you experienced during the Pilot 

Study? Lessons learned? 

We struggled, and currently struggle with the overall 

implementation of SMS. We often find that making the time 

to manage the SMS process is our main obstacle. Some 

areas within SMS require additional manpower to perform 

analysis, reports or training. Ultimately, this process 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 better 

tracking system for open items such as damaged airport 

signs and missing lights. Our challenge with this has been 

consistent application. In addition to this we still use the 

standard airport inspection to list and non-complying items 

found during the required airport inspections. Better 

application and consistency would allow for more detailed 

trend analysis, better long term planning and could show 

unknown problems with the airport environment. 

 

d. One party identified as being responsible/in charge of 

safety concerns 

Senior Leaders do play an active role in safety and have 

implemented several components from the SMS Pilot Study. 

 

e. Lower long-term cost- None at this time. Although we do 

anticipate lower cost in the future as it relates to tracking 

repair and maintenance issues. 

 

f. Others- None 

What were the key findings at a. Some aspects of the 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 could be 

strengthened and more clearly defined. The FAA issued the 

AC in early 2007 that addressed the “concepts”. In our 

opinion airports would benefit by knowing the particulars of 

the SMS regulation. This AC was written in a broad sense 

and ultimately offered a basic understanding and not 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 standards as 

Class I airports?) Having a breakdown of the requirements 

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 information 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 the public 

docket 

Table 17 – Alliance Fort Worth, TX 
FAA 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. Scope, 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 - cultural 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 measurable 

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, MS 
FAA 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. Who is the 

accountable executive, 3. What type of reporting system, 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 efforts 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 draft, but 

overall a positive experience, was handled by manager 

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 - cultural 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 everything per 

the AC. Need better risk matrix definitions, training 

requirements, how is it going to be implemented?, specify a 

baseline vs. gap analysis 
FAA 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, NJ 
FAA 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 assistance 

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 Pilot Study 

documents, especially with providing resource information 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 be 

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 allocation, 

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 Statement, 

although the City of Atlanta and DOA have internal safety 

policies in safety manuals. Did not have Safety Risk 

Assessment Process 

What difficulties/ challenges have 

you experienced during the Pilot 

Study? Lessons learned? 

Develop a documented process/protocol for the airport and 

its business partners ensuring acceptance and 

harmonization of the decision making process and defining 

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 from 

companies which were de-identified. 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 carrier 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 regulatory 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 

under government disclosures laws, (b) possession and 

control of the data acquired, (c) use of accident and incident 

data in tenant risk assessment exercises, and (d) use of 

stakeholder data for creating and or modifying processes for 

all tenant at an airport 
FAA 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 hazards with 

construction projects and changes on the airfield; 

Establishing a SMS Work Group with tenant involvement 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 system 

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, Risk 

Management Office, DOA and City of Atlanta Safety Policy 

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 available 

for the Pilot Studies. However the airport collaboration has 

helped in the area. We would like to see more guidance 

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, GA 
FAA 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 employing 

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 assist 

with gap analysis and draft the SMS Plan 

What were your challenges in 

interpreting the SMS process? 

Clarifying the extent to which leaseholds within the nonmovement area are subject to this SMS rule. Determining 

the responsibilities of the airport operator and third parties 

regarding the development and maintenance of SMS. 

Ascertaining if the airport sponsor can delegate SMS 

responsibilities to tenants within exclusive leaseholds. 

Determining legal liabilities of the accountable executive and 

acceptance of know risks identified on the risk assessment 

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 escorts 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, runways, and 

construction areas 

What did the Gap Analysis 

Reveal? 

The results of comparisons between existing conditions, 

including the documentation of practices at the Airport, and 

SMS standards revealed that in some instances certain 

practices or procedures are in place, but may not be 

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 managed 

by CCDOA, but has not been formally included as part 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 maintenance of 

SMS training records for all airport employees, 

documentation of hazard identification and analysis, 

documentation of the effectiveness of corrective and 

preventative measures 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 hire of a full time Management Analyst 
FAA 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 initial and 

annual recurrent training of airport employees in overall 

airport safety objectives, safety risk management principles, 

safety assurance topics, airport rules and regulations, and 

overall department organization and functions. A plan to 

validate training effectiveness and a process to obtain 

feedback, including useable metrics, is also required. 

Providing 8 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. 

Assuming an average hourly wage of $28 for each CCDOA 

employee, CCDOA training 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 costs total $57,120. 

SMS requires change management, a formal process to

identify, anticipate, and prepare for potential hazards 

introduced into the airport environment. Trigger events 

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 regulations. 

The airport embraces a non-punitive safety reporting policy 

as outlined in the Clark County Workplace Safety and Health 

Policy. However, certain violations of applicable laws, 

policies, or procedures may require additional disciplinary 

action. This issue is not addressed by SMS. 

 Safety communication to promote a safety culture through 

all levels of the airport organization is a requirement of SMS. 

Although some communication processes are currently in 

place, such as newsletters and tenant meetings, other 

systems for disseminating information regarding airport 

operations, facility maintenance, airfield construction, 

employee safety awareness, tenant safety awareness,

airside safety, and wildlife safety would be required. The 

additional cost cannot be calculated until the specific media 

are selected, but the expense would be significant.

Implementation and maintenance of SMS would be 

challenging and labor intensive, particularly at North Las 

Vegas Airport. A new management analyst position would 

be required at $84,460. Annual training costs are estimated 

at $57,120. These staffing and training costs together 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 Director of 

Aviation, General Aviation as SMS Responsible Executive, 

or the duties of the Airport Manager under the draft SMS 

manual submitted to the FAA. The annual cost of 
FAA 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 significant 

factor. This represents a financial and administrative 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 airport. 

During the Pilot Study only a few specific test items were 

subjected to the process. Benefits cannot be determined 

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 prevalent 

findings were ascertained. We are only in the process 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 imposing SMS 

responsibilities on airports for non-movement areas under 

the control of tenants. 

The operational costs (including especially personnel, 

recordkeeping, training and liability) for airports and the 

mechanisms by which airports will fund compliance with their 

ongoing SMS obligations. 

The manner by which airports should resolve conflicts or 

competing obligations imposed by the proposed part 139 

SMS manual, by other SMS requirements (including, but not 

limited to, Order 5200.11), SMS requirements imposed on 

other airfield users (including part 121 operators and ATO), 

existing contractual obligations, and other grant assurance 

obligations. 

The liability and public information issues raised by the 

obligation to prepare safety risk assessments 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 complex airports. 

The agency needs to provide a clear and unequivocal

hierarchy of authority among the various proposed and 

forthcoming SMS requirements so that airports do not have 

to guess who has authority and which SMS program 

governs a particular activity. 

The proprietor’s safety obligations should be scaled and 

adapted depending upon (a) the activities that occur within 
FAA 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 within 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, NV 
FAA 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 implementation. We 

may use a consultant periodically to conduct an audit 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) to 

conduct GAP analysis and the drafting of our SMS Program 

and implementation plan 

What were your challenges in 

interpreting the SMS process? 

One difficulty in preparing our SMS plan was the fact 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 conduct 

three SRA. We have completed one dealing with Jetway 

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 review 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 we were in 

need of an incident reporting database that would allow for 

the easy review of incidents and hazards in order to 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 the 

documentation of the SRM process. Our desire to integrate 

incident reporting software with a legacy work order 

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 greater 

safety awareness among employees. Once role out is

complete, we anticipate improved means of monitoring and 

trending safety incidents/hazards. Finally, we have received 

positive input from our liability insurance carrier resulting 

from our use of SMS, though no reduction in rates have 

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 hazards 

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 significant 
FAA 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 reflect 

provisions specified in the final SMS rule making. This 

document was developed as a general guidance document 

and in order to provide an orientation to SMS. It would also 

be beneficial to clarify how various SMS initiatives (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, PA 
FAA 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 consultant 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 data 

collection, drafting documentation; used subcontractor help 

for hazard identification and legal work (non-punitive 

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, separate, 

redundant? Airport needed to figure out the "what" of SMS, 

then the "how". Next step was to sell it to the users. 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 identified 

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 or 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 self inspection 

practices (1 inspection per shift vice 1 per day in the ACM) in 

writing; Commercial aircraft operations ramp: Documenting 

specific inspection items on self inspection documentation; 

Safety Manager: Designate a Safety Manager to oversee 

SMS and ensure communication with senior management; 

Non-Punitive Reporting System: Establish a system;

Training Records: Document procedures for conducting the 

established practice of auditing FBO fueling personnel 

training records; Recurring Training: Establish consistent 

recurrent training timelines and consider establishing 12 

month cycle for all training; Condition Reports: Establish and 

document timelines for filing condition reports; 

Communication: Evaluate and capture current practices in 
FAA 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 Procedures: 

Evaluate content and effectiveness of training program; 

Obstructions: Identify ownership of obstructions and develop 

a notification / tracking system for ensuring obstructions 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-punitive 

reporting system; Presenting SMS to an industry structure 

and culture that has changed greatly (employee/employer 

loyalty, subcontracting, dedication to aviation; Encouraging 

communication of safety related activities (e.g., getting air 

carriers to report incidents/damage to their equipment 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 prevent 

duplication of effort?; Addressing the issue of LOBs 

convening competing SRMPs to produce a desired outcome; 

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 subject to FOIA. 

The Follow-On report Appendix A details these alternatives. 

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 operations on 

the air carrier ramp. Other SRAs were conducted for system 

changes; Active Safety Committee: Good participation in 

SRAs, considering safety-related work is a collateral duty for 

most of the SRMP members; Tracking System: System is in 

development; One party identified as responsible/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, too early to tell. There's 

an anticipated cost reduction similar to the workers' comp 

multiplier. Cost savings under 139 may not be significant 

because it's already saving costs by preventing accidents; 

Others: Relationship with tenants improved. The process 

inherently and actively involves impacted parties/users to 

provide data that result in better communication / awareness 

of hazards and risk. It also forces the airport into a 

leadership role, bringing everyone into a collaborative 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 current activity 

relative to safety and provided ideas for formalizing and 
FAA 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 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 

information about operations outside of 139, can the ACSI 

inspect and cite the airport for violations in those areas? Will 

the airport need to maintain 2 SMSs - 1 within the ACM and 

another for everything outside of 139? This will be 

counterproductive. Make sure the AC does not move 

airports too far toward procedure-based documents 

(overreliance on checklists). Too much documentation 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, IN 
FAA 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 implementation 

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 through the 

process, with little idea of where the FAA wanted the 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 was 

intentionally vague on its instructions in order to spark 

creativity among airports. The Airport felt the Gap Analysis 

was challenging because of a lack of guidance. The Airport 

used ICAO as a reference to perform the Gap Analysis. 

What types of risks/hazards did 

you put through the SRM process 

during the Pilot Study? 

3 projects: 1) Impact of new buildings on pedestrian/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., providing 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, training 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 when 

mitigations are made known but not acted on? This may 

create a risk of Airport Sponsors minimizing hazards to avoid 

spending money. Lessons Learned: 1) Ensuring 

management involvement / buy-in. Leadership is critical. 2) 

Communication should come early and often to front-end 

load information from the FAA through the Airport to 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 efficiently 

dealt with using longer term, continuing SRAs as opposed to 

multiple SRAs on individual issues that are all related. SMS 

is building a culture that, combined with improved data 

collection, will bring out hazards more efficiently. A more 
FAA 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 set by the 

Airport Manager through the Safety Committee, which leads 

to improved identification of hazards. Formalization of the 

safety culture through elements like the safety committee 

establishes the SMS's credibility among users. A tracking 

system that leads to a more proactive approach: Incident 

Reporter by OMNI Air Group (data collection software) was 

cumbersome. SIU developed a web-based data collection 

site that collects, organizes and tracks data, reducing 

workload on the person responsible for monitoring the 

system (currently Airport Manager). Email functionality 

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 based data collection system. The 

system allows one person to address issues more efficiently. 

With efficient data collection and notification, 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 boon to SIU for professional development, aviation 

industry and airports. The system increases communication, 

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 value early 

on. It helped direct specific attention to safety issues and 

mitigation. SRAs were valuable in bringing together different 

perspectives and allowing participants to understand 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 ACM 

with SMS. 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 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, IL 
FAA 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 report 

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 sponsored 

Phase II Pilot Study. A gap analysis was performed, as well 

as a perception survey. A Sample SMS manual was also 

developed. 

What were your challenges in 

interpreting the SMS process? 

The match between Part 139 and the SMS was difficult to 

digest as well as trying to determine if Part 139 was 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 was or is 

provided. 

 In addition, the ICAO and FAA SMS ACs regarding SMS 

are not always consistent with industry SMS standards. 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 achieve 

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 particular, we 

added an element on Incident Investigations under Risk 

Management and Recognition under Safety Promotion, 

Encouragement. We also defined Business Integration 

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 was 

performed. 

What did the Gap Analysis 

Reveal? 

As part of the Gap Analysis, a Perception Survey was also 

performed, to gauge the perception of management 

commitment and safety program performance on the part 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 Talladega 

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% overall 

agreement between what is required by Part 139, and future 

SMS expectations (75-80% gap). However, one element in 

particular registered a score of 60% (Inspections and SelfAuditing) and along with Requirements, was the highest 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 expected 

of an SMS, however, the majority of the implementation 

strategy and responsibilities are undefined, except for 

Inspections, Integration of Maintenance and Emergency 

Preparedness. Some other element of SMS, (i.e., Tracking 

Systems, Roles and Responsibilities) would only provide 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 other 

industry SMS standards (ANSI Z10, OSHA’s VPP, OHSAS

18000, etc.), there are a number of gaps to the proposed 

FAA SMS. ESIS recommends that, at a minimum, FAA 

consider either adding or better integrating or expanding the 

concepts of: 

• Safety Policy and Objectives: Objective setting based on 

Leading Trend Data and Performance Indicators. 

• Safety Policy and Objectives: Safety Committee 

Expectations 

• Safety Risk Management: Requirements 

• Safety Risk Management: Ongoing Risk Reductions (this 

is the biggest gap between industry standards and the 

FAA / ICAO SMS) the FAA/ ICAO seem to stop at a onetime treat and mitigate, rather than ongoing risk 

reductions. 

• Safety Risk Management: Incident Investigations and 

Root Cause Analysis. 

• Safety Risk Management: Emphasize the Risk 

Management Portion, Especially in Terms of Continuous 

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 entities controlling life-safety issues during the race 
FAA 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 during these 

periods is subject to change, and specific training for the 

NASCAR events is on-going... race to race... year to year. 

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 deems is 

necessary to exist for 50 out of 52 weeks each year. The 

two other weeks it is a well run, well-staffed, well-protected 

facility with numerous safety programs in place. Once 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 lead to a 

catastrophic incident or accident. SMS provides 

management with the ability to deal effectively with 

accidents and near misses so that valuable lessons are 

applied to improve safety and efficiency. Research has 

shown that safety and efficiency are positively linked. 

What were the key findings at 

your airport, as part of the Pilot 

Study? 

This was basically a GA airport with 139 credentials. It is not 

funded by the City, and the Airport Board uses its funds to 

match FAA/AIP projects. The FBO runs the airport on a 

day-to-day basis, and their financial situation at the airport is 

poor, due to low revenues, etc. All of this contributed 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/ADO in 

Jackson had very little input during the preparation of the 

report, and the FAA in DC was non-responsive to on your 

GAP analysis submittal. The FAA/ADO is the one that told 

us to "wrap it up" so the AIP project could be closed 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 public 

docket. However, I need to compile the various segment of 

the final report into one large PDF file. 

Table 25 – Talladega, AL