# Gap Analysis

Kona International Airport at Keahole (KOA) Safety Management System

Submitted to: 

## State of Hawaii Department of Transportation Airports Division
Submitted by: 

## Jacobs Consultancy

Final Report - June 2008Gap Analy sis Kona International Airpo rt at Keahole Safety Manage ment Sy stem JT71 5500 

## Gap Analysis Kona International Airport at Keahole Safety Management System

Table of Cont ents Section Page

EXECUTIVE SUMMARY .............................................................................................................. .................................................................. i
I. IN TRODUCTION ................................................................................................................... ........................................................ 1 Background..................................................................................................................... ................................................................. 1 Objectives ..................................................................................................................... .................................................................... 1 Methodology....................................................................................................................

............................................................... 1 Oper ations at KOA.............................................................................................................. ......................................................... 2 Struct ure of The Gap Analysis .................................................................................................. .............................................. 3
II. SAFETY P OLICIES AN D OBJECTIVES ................................................................................................. ................................. 6 Key Features................................................................................................................... .................................................................. 6 Existing Policies And Object ives ............................................................................................... ............................................ 6 Gaps and Development Required.................................................................................................. ...................................... 7
III. SAFETY ORGAN IZATION ............................................................................................................ ............................................. 9 Key Features................................................................................................................... .................................................................. 9 Existing Policies, Pr actices and Sy stem s....................................................................................... ..................................... 10 Gaps and Development Required.................................................................................................. ...................................... 16
IV. SAFETY R ISK MAN AGEMENT.........................................................................................................

........................................ 19 Key Features...................................................................................................................

.................................................................. 19 Existing Pract ices and Syst ems.................................................................................................

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

...................................... 19
V. SAFETY ASSURANCE...............................................................................................................

.................................................... 21 Key Features...................................................................................................................

.................................................................. 21 Existing Pract ices And Syst ems.................................................................................................

............................................. 22 Gaps and Development Required..................................................................................................

...................................... 24
VI. SAFETY PR OMOTION - TRAININ G....................................................................................................

................................. 25 Key Features...................................................................................................................

.................................................................. 25 Existing Policies, Pr actices and Sy stem s.......................................................................................

..................................... 25 Gaps and Development Required..................................................................................................

...................................... 26
VII. SAFETY PR OMOTION - COMMUNICATION S..............................................................................................

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

.................................................................. 27 Existing Policies, Pr actices and Sy stem s.......................................................................................

..................................... 27 Gaps and Development Required..................................................................................................

...................................... 27 Dele ted: 2 Dele ted: 2 0 Dele ted: 1 9 Dele ted: 2 0 Dele ted: 1 9 Dele ted: 2 0 Dele ted: 1 9 Dele ted: 2 0 Dele ted: 1 9 Dele ted: 2 2 Dele ted: 2 1 Dele ted: 2 2 Dele ted: 2 1 Dele ted: 2 3 Dele ted: 2 2 Dele ted: 2 5 Dele ted: 2 4 Dele ted: 2 7 Dele ted: 2 6 Dele ted: 2 7 Dele ted: 2 6 Dele ted: 2 7 Dele ted: 2 6 Dele ted: 2 8 Dele ted: 2 7 Dele ted: 2 9 Dele ted: 2 8 Dele ted: 2 9 Dele ted: 2 8 Dele ted: 2 9 Dele ted: 2 8 Dele ted: 2 9 Dele ted: 2 8Gap An aly si s Kon a International Airpo rt at K eahole Safety Management System JT 7155 00 LIST OF APPENDICES Appendix A Draft St atem ent Of Wor k - FAA SMS Airpor t Pilot Study Appendix B Saf ety Issues Appendix C Inspection Checklists Appendix D Exam ples of Saf ety and Sec ur it y Enforcem ent ProgramsGap Analy sis Kona International Airpo rt at Keahole Safety Manage ment Sy stem JT71 5500 i 

## EXECU TIVE SUMMA RY In Februar y 2007 the FAA issued Advisory Circular, AC 150/5200-37, Int roduction to Safety Managem ent Systems (SMS) for Airport Operator s , to int roduce the concepts of SMS. The FAA also init iated a pilot program to assist airports in the development of an SMS specific t o their sit uation and oper ations, and to shar e their acquired experience on SMS development and implem entation with other airports and the FAA. The Hawaii Depar tment of Tr ansport ation, Air por ts Division (HDOT-A) has dec ided to take a leadership r ole in the development and im plem entation of SMS at the Kona Internat ional Air port at Keahole (KOA) by part icipating in the FAA pilot program . The purpose of this docum ent is t o provide a Gap Analysis to ident ify procedur es, policies, docum entation, and act ions that HDOT-A and KOA need to implement as part of its SMS that go beyond the c urrent FARs Part 139 requirem ents . The Gap Analysis out lines SMS requirements and com pares them with Part 139 requir ements. As detailed in t his report, the gaps between exist ing requir ements and the FAA’s anticipated SMS r egulat ions and guidance mat erial are as follows: 

### Safety Policies and Objectives  Specific aviation saf ety policies and objectives need to be developed for inclusion in the SMS. The Gap Analysis outlines key fact ors t hat should be consider ed in Safety Objectives and t hat will be further elabor ated in the SMS Manual. 

### Safety Organization  HDOT-A and KOA do not have an or ganizat ional structur e defined specific ally for addr essing the requirement s of an SMS including the role of top management. The Gap Analysis details the pot ential safety or ganization for consideration f or the SMS Manual, including the role of the Dist rict Engineer in conducting safety risk management assessments ( operational risk assessm ents) for projects. 

### Safety Risk Management  KOA current ly does not have a formal Saf ety Risk Management ( SRM) process f or aviation saf ety. The SRM process will be d eveloped and documented during Phase 2. 

### Safety Assurance  Phase 2 will dev elop:

o Non-punitive reporting.

o System atic reviews and audits.

o Safety over sight .Gap An aly si s Kon a International Airpo rt at K eahole Safety Management System JT 7155 00 ii 

### Safety Training and Communication  Gaps include:

o SMS training.

o Av iat ion safet y pr ograms. Phase 2 will dev elop the SMS based on the gaps identif ied . During the Gap Analysis, J acobs Consultancy also made a num ber of observations on existing prac tic es and policies curr ently required under FARs Part 139. Not necessar ily part of an SMS, these observations for considerat ion by KOA and HDOT-A are as follows:
 The HDOT-A should consider making the wearing of safety vests mandatory for all personnel working on the AOA.  HDOT-A should consider a m ore structured Enfor cement Progr am for specif ied airsid e safety violat ions.  HDOT-A should strengthen the training funct ion at KOA and HDOT-A t o ensur e suf fic ient resources are availab le.  Existing tr aining at KOA should be augmented with material from the FAA and other sources such as the American Association of Airport Exec ut ives.  ARFF per sonnel should be tr ained to conduct inspections of all f ueling oper ations on the air port.  HDOT-A should develop and pr ovide a training module in inspection tec hniques. During Jac obs Consultancy ’s visits to KOA, a number of issues were ident if ied that have the pot ential to impact the safety of passengers, air por t employ ees or dam age equipment. These issues should be reviewed by KOA, the Air por t Safety Comm ittee and Saf ety Risk Managem ent as part of the SMS proc ess. The SMS Manual w ill descr ibe these pr ocesses. These issues will also be used for SMS training purposes. The issues, outlined in Appendix B of t his r epor t, ar e as f ollows:  Ramp congestion, part icularly with increasing t raff ic volumes;  Operations at the commuter ter minal;  Fueling operations and the lack of fuel st orage capacity; and  Very rough terr ain due t o lava fields outside of the graded runway safety ar eas.Gap Analy sis 1 Kona International Airpo rt at Keahole Safety Manage ment Sy stem JT71 5500 

## I. INTRODUCTION Background In Februar y 2007 the FAA issued Advisory Circular, AC 150/5200-37, Int roduction to Safety Managem ent Systems (SMS) for Airport Operator s , t o introduce the concepts of SMS. The F AA has also opened a r ulem aking project to consider f ormal requir ements for SMS at certified airports. In support of t his rulemaking effort , the FAA has init iat ed a pilot pr ogram to assist airpor ts in the developm ent of an SMS specif ic to their sit uation and operat ions, and t o shar e their acquired exper ienc e on SMS dev elopm ent and implement ation with other airports and the FAA. The Hawaii Depar tment of Tr ansport ation, Air por ts Division (HDOT-A) has dec ided to take a leadership role in the development and im plem entation of SMS at the Kona Internat ional Air port at Keahole (KOA) by part icipating in the FAA pilot program . As part of t he pilot program, HDOT-A has r etained the services of Jacobs Consult ancy t o provide consult ing ser vic es to develop a Saf ety Managem ent System (SMS) Program f or KOA. 

## Objectives The specific objectives and deliv erables of t he SMS dev elopment pr oject include:
1. A Gap Analysis: The gap analysis will ident ify procedur es, policies, doc um entat ion, and actions that HDOTA and K OA need t o implement as par t of its SMS t hat go beyond the current Par t 139 r equir ements.
2. A Draf t Plan: A draft of t he com plete SMS Manual and Program Plan.
3. The Final Plan: The final copy of SMS Manual and Progr am Plan ready f or implement ation by KOA and HDOT-A. The FAA’s requirem ents for the Gap Analysis, SMS Manual and Progr am Plan are included in Appendix A.
4. Training of KOA and HDOT-A Divisional employees in SMS. This repor t addresses t he Gap Analysis. Phase 2 of t he SMS pr oject will develop the SMS for KOA and document it in an SMS Manual and Progr am Plan. The Gap Analysis addr esses what needs to be developed and im plem ented beyond the requirem ents of current Part 139. Our analy sis was not an audit of existing KOA polic ies and procedures as t o their adequacy, completeness or c ompliance wit h Par t 139 requirem ents. This is t he subject of detailed F AA c er tification audits which is well beyond t he scope of this project. However, based on our review of document ation and discussions wit h KOA and HDOT-A managers, we have added in the r eport, where appropriate, a number of obser vations on ex ist ing practices and policies for considerat ion by HDOT-A. Dur ing Jacobs Consult ancy’s visits to KOA, a number of issues were also identified that have the potential to impact the safet y of passenger s, air port em ployees or damage equipm ent. These issues should be reviewed by KOA, the Airport Safety Committee and Saf ety Risk Managem ent as part of the SMS pr oc ess. The SMS Manual will describe t hese processes. These issues will also be used for SMS t raining pur poses. The issues are outlined in Appendix B. 

## Methodology2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem JT 7155 00 Jac obs Consultancy pr epared the Gap Analy sis based on:  Relevant FAA documentation including:

 Advisor y Circular, AC 150/ 5200-37, February 2007

 The Draf t Statem ent of Work (SOW) for t he SMS Airport Pilot St udy  Relevant HDOT-A and KOA documentat ion;  Selected inter views w it h HDOT-A Div ision manager s and KOA m anagers and supervisors;  Guidelines regarding SMS from the Inter national Civil Av iation Organization (ICAO) ; and  The consult ing team ’s exper ience wit h t he preparation of SMS f or other air ports. 

## Operations at KOA Kona Internat ional Airport at Keahole (KOA) is located on the luxurious Kona Gold Coast of West Hawaii. KOA is operat ed by the Stat e of Hawaii’s Departm ent of Tr ansportation Air ports Div ision and occupies 4,204 acr es of land 9 miles northwest of the central business distr ict of Kailua/Kona. The single story open-air set of terminal st ructur es is locat ed on the eastern edge of the airport and accomm odatesdomestic overseas, inter national, interisland, c om muter/air t axi, and general aviation activities. Kona International’s daily operations include a wide r angeof air craft such as CRJ-200, B-767, B737, B-757, B-717, B-777 and B-747 aircraft from m any domest ic and inter national air car riers as well as general aviat ion and U.S. military airc raft. In 2006 there were 143,411 operations, 3,033,000 passengers, 23.900 tons of cargo and 8,512 tons of mail. The Airport has an 11,000-f oot r unway and a com plex of f acilities at t he sout hern edge of the airf ield f or air car go and mail, air por t suppor t, and general aviat ion operations. An additional complex of facilit ies, used primar ily by rental car agencies f or r eturns, gener al maintenance, and storage is located along the air port access r oadway , midway between the passenger terminals and the main highway . General aviation, cargo, and related fac ilit ies are located to t he south of the passenger terminals and the access roadway.Gap Analy sis 3 Kona International Airpo rt at Keahole Safety Manage ment Sy stem JT71 5500 

## Stru cture of the Gap An alysi s The Gap Analysis is structur ed to addr ess the f our element s of an SMS as out lined in the F AA’s Advisory Circular. As well, we have added a separate element for Safet y Organization which t he Advisory Circular descr ibed under Safety Policy and Objectives. In previous FAA pilot pr oject s that we conducted, the FAA SMS Progr am Of fice agr eed t o t his st ructur e.
1. Safet y Polic ies and Objectives
2. Safet y Organization
3. Safet y Risk Managem ent
4. Safet y Assurance
5. Safet y Pr omotion Under each of these five element s, the Gap Analysis addresses t he FAA’s detailed SMS Program content outlined in the FAA Advisor y Circular, AC 150/5200-37, and the F AA Draft St atem ent of Wor k (Appendix A).4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem JT 7155 00 Mor e specif ically f or each element , the Gap Analysis:
1. Summ arizes the F AA’s SMS guidance doc um entat ion, internat ional guidance m ater ial where appropriate and J acob’s Consultancy Team ’s SMS experience;
2. Describes what systems, policies and practices ex ist at KOA; and then
3. Ident if ies procedures, policies, object ives, organizational issues and document ation (i.e., Gaps) that need to be developed for SMS and how they will be addr essed in t he subsequent tasks to develop the SMS Manual and Saf ety Program Plan.


### Intent of SMS The intent of SMS is t o im prove aviation safety. The elimination of av iat ion acc idents is a desir able goal. However, no human activity or human-made syst em can be guar anteed t o be absolutely safe. Failur es and err ors will occur, in spite of best eff orts to avoid them. Alt hough major air disasters are rare events, less cat astrophic accident s and a whole range of incidents occur more fr equently. Ignor ing these underlying saf ety hazar ds could pot entially pave the way for an inc rease in t he number of more serious accidents. The air transportat ion indust ry’s future viabilit y may well be pr ed icat ed on its ability to sust ain the public’s perceived safety while traveling. The m anagement of safety is therefore a pr erequisite for a sustainable aviation business. The accident rate in t he air transport industry has decreased dram atically between t he early 60’s and t he m id 80’s from 30 to near 2 per million departures. It could be easily argued t hat this rate was achieved f rom continuing efforts by the industry t o m ake air tr avel a saf e m ode of tr ansport ation. But as the following diagram illustr ates, bet ween the mid eighties and now, we find an 80% incr ease in air tr aff ic and a 73% inc rease in the number of accidents. Alt hough the accident rate per million departures rem ains st eady at 2, air tr avel saf ety as perceived by the public is likely to dec line if traf fic gr owt h and accident rate per million depart ures rem ain the sam e. Air t ravel relat ed accidents make instant worldwide news and there will be m ore and more reports even while maintaining a relat ively low accident rat e. Safet y m anagement when well in p lace within the industry will be a key f actor in f urther reducing the accident r ate and achieving act ual and perceived impr ov ement in aviation safety.Gap Analy sis 5 Kona International Airpo rt at Keahole Safety Manage ment Sy stem JT71 5500 Sou rce: In tern a l Jacobs Con su ltancy for illu stra tive p u rpose s6 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem JT 7155 00 

## II. SAFETY POLICIES AND OBJECTIVES Key Featu res The FAA SOW f or SMS stat es that Safety Policies and Object ives should include:
 Written saf ety policy stat ement (s) and a descr iption of how it is communicat ed to airport em ployees; and  Ident if icat ion and description of the air port saf ety goals. The FAA Adv isor y Circular under Saf ety Policy indic ates that managem ent’s c ommitm ent to safety should be formally expr essed in a stat ement of safety policy t hat reflects the airpor t’s safety philosophy and that is signed by Top Management. Key attr ibutes of t he policy could also include the following:  The commitm ent of senior m anagem ent to implem ent SMS;  Stat es the air port’s intentions, management princ iples and comm it ment to continuous improvement to safety at the air port;  Is com municated to all employ ees;  Is implemented at all levels of the airport;  Confir ms that safet y is every one’s responsibility ; and  Recognizes that there will alway s be threats to safety and that the air port will provide the highest reasonable standard of safety. The Advisory Cir cular refers to a comm it ment to make safet y t he highest priorit y which m ay have a diff erent meaning. The Adv isor y Circular under Safet y Objectives ( Section 2.2.2) does not address object ives but deals w it h the organization f or safety. The Advisory Circular does r efer to safety perform ance indicat ors and tar gets under Saf ety Assurance ( Section 2.4). SMS guidelines, inc luding the FAA Advisory Circular, g ive very lit tle practical advice on safety goals or objectives. The t erms “goals” and “objectives”, as well as “targets” are frequently used interchangeably. The intent in the guidelines; nonetheless, is to have measurable indicators of safety. 

## Existing Poli cies an d Objectives HDOT-A has an Em ployee Safet y and Health Pr ogram which is based primarily on the r equir ements of the Hawaii Occupational Safety and Health (HIOSH) standards for the benefit and general welfare of HDOT-A em ployees. HDOT-A’s occupational saf ety and health st ated policy is t o provide a safe, accident-free, and healthy wor k environm ent for its employees in ar eas such as:Gap Analy sis 7 Kona International Airpo rt at Keahole Safety Manage ment Sy stem JT71 5500  Personal Pr otect ive Equipment (PPE) ;  Respiratory Pr otection;  Hazardous Wast e Operat ions;  Noise Exposure;  Hazard Communication;  Biological Agent s/ SARS/Blood borne Pathogens;  Confined Space; and  Vio lence in the Wor kplac e. The Employee Health and Safet y Program is not direct ly related to air side aviation safety which is t he intent of SMS. HDOT-A does not currently have a writt en saf ety policy endorsed by Senior Exec ut ive (Top Managem ent) to indicat e t heir com mitment t o aviation safet y which is a key element of an SMS. 

## Gaps and Developmen t Required Safety Policies Phase 2 of the SMS project will need to develop and docum ent aviation safety policies that should be endorsed by HDOT-A.
Note: In the developm ent of SMS, som e airports have consider ed com bining SMS and employee safety in one document . Initial comm ents from HDOT-A managem ent have also suggested that this integrat ion be considered. However , one docum ent will likely not be feasible or pract icable. Jacobs Consultancy discussions wit h the FAA have indicated that SMS will event ually be part of the Airport Cer tification Manual (ACM) in the fut ure and that they are not interest ed or concerned with Occupational Saf ety and Health Issues or requirem ents. Requirem ents by t he Hawaii Occupational and Health and by the F AA are not the sam e (for exam ple, r eporting and risk analyses differ ). Although one safet y docum ent is not pr acticable, we do believe that wit hin t he KOA and HDOT-A organiz ation, t hose cur rently involved in safety could pot entially also be involved in SMS; f or example, a safet y of fice or off ic er that addresses both SMS and HIOSH requirem ents. This organization ar rangem ent will be considered further in t he subsequent Phase 2 of this project to develop the SMS. 

### Safety Objectives Saf ety objectives are also requir ed to allow for assessm ent of saf ety performance and developments at the airport. Safet y objectives should be linked to f actor s such as:
 Safety hazards identified during inspections; e.g., type and quantity of FOD (Not e: the airport ’s selfinspect ion program captur es this infor mat ion but does not systematically monitor tr ends in this information);8 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem JT 7155 00  Airsid e safety violations;  Aircr aft bird strikes;  Incursions of vehicles, aircraf t, or pedest rians on movement ar eas;  Ac cidents and incident s on the AOA and/or the contr olled m ov ement area involving air carr ier aircraft and/or ground v ehicles;  Oper able time of lighting systems;  Number of airside based employees who have received safety and SMS r elat ed t raining;  Non-punitive safet y r eports; and  Airport Tower operat ing times. The safety object ives will need t o be inc luded in the Airport Dist rict Manager’s st atem ent of policy and objectives and then communicated to all of the organization. They should be no diff erent f rom other organizational objectives in that they should be:  Specific and measurable;  Achiev able and challenging; and  Realized within a specific t im e fram e. Mor e specif ic saf ety object ives applicable to KOA will be d eveloped during Phase 2 of the SMS pilot project.Gap Analy sis 9 Kona International Airpo rt at Keahole Safety Manage ment Sy stem JT71 5500 

## III . SAFETY ORGANIZATION Key Featu res The FAA SOW f or SMS describes the follow ing requirem ent related to t he safety organizat ion.  An organizational chart identifying the names and safety r esponsibilit ies of all key per sonnel, such as the following:

 Top Management

 Saf ety Manager

 Depart ment Heads/Managers

 Established Saf ety Com mittees and Chairpersons The Adv isor y Circular pr ov ides considerable guidance on how an airport should be or ganized for saf ety. The key feat ures descr ibed in the Advisory Cir cular ar e as follows:  SMS requires that Top Management in the organizat ion (also r efer red to in t he Advisory Circular as Senior Managem ent), one with t he aut hority to adequately c ontrol r esources, be assigned SMS r esponsibilit ies.  Defined saf ety authorities and responsibilities f or all key personnel that are assigned to the air port.  Ident if icat ion within the system of som eone r esponsible for adm inistr ation of the overall SMS. Often, that one responsible person will be t he Safety Manager. This person report s to the highest level of managem ent to assur e appr opriate consider ation of all repor ts, r ecomm endations, and issues.  At m any air por ts, oper ations m ay support the Safety Manager being a f ull-time perm anent employ ee and in som e cases having a support st aff

.  The responsibilities of the Safety Manager are clearly defined along w ith identif ied lines of communicat ion within the or ganizat ion.  Depending on the size and com plex ity of the air por t’s oper ation, it may be useful to establish an Air port Safet y Committee (ASC). The safety committ ee ac ts as a source of ex pertise for the Safet y Manager and is chaired by the Saf ety Manager. The SMS should also address how, and to what extent , t enants at t he airport such as the air lines, fueling companies, and ground handler s are integr ated into the airport SMS. ICAO has m ade very strong ref erence to the inclusion of t enants at an airport . ICAO’s Safet y Managem ent Manual, Doc 9859 A/460, Fir st Edition – 2006, chapter 18, – AER ODROME OPERATIONS, states t hat:1 0 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem JT 7155 00 Subsection 18. 3.1 (...) Within the framework of an aerodrom e SMS, the aerodrom e management must oversee the activit ies of all the service pr ovider s, tenants, contractors and ot hers to ensure t he saf est and most efficient perform ance of the aerodrom e.
Subsection 18. 3.8 Given the complexit y of the factors cr eating risk potential at aerodromes, the aerodr ome managem ent must coordinate the act ivities of the diverse stakeholders at an aerodr ome – often with conflic ting expectations and pr iorities. The sharing of a common focus among t he stakeholders, most of whom are employ ees of agencies other t han t he aer odrome author ity , needs to be f ostered. In add it ion, r esource commitm ents from the airlines and other ser vice providers m ust be obt ained. The FAA Circular does not addr ess t his organizat ional requir ement to any extent . Tenants ar e major contr ibutors to accident s at an airport and if they ar e not int egrated into t he airport ’s SMS, then the SMS may not be very effective. Yet at the same time, an airport does not have direct accountabilit y for t enant operat ions. There are num ber of means that tenant s could be included or par tic ipate in the airport SMS including:  The vehicle operator perm it system ;  The air por t’s self inspect ion program ;  Participation in Safety Comm itt ees;  Safet y audits; and  New and revised airport t enant use and lease agreem ents. 

## Existing Poli cies, Pr actices and Systems The organizational str ucture for KOA is depicted in Exhibit III-1.The key positions that have a direct impact on aviation safety at KOA include:
 The Airport s Division Sen ior Management ;
 The Airport District Manager;
 The Assistant Airport Superintendent;
 The Distr ict Engineer;
 The Gener al Construct ion and Maint enance Supervisor;
 The Airport Operat ions Control Supervisor;Gap Analy sis 11 Kona International Airpo rt at Keahole Safety Manage ment Sy stem JT71 5500  The Airport Saf ety, Security and Cert if icat ion Specialist;
 The Chief, ARFF ; and
 The Cont ract Control Tower .

Exhibit III-1. KOA Organizat ion Structure
The Airport District Manager ( ADM) r eports t o the Airports Administrator at the Airports Division. As well, the ADM r eceives functional direct ion, advice and assistance from t he Airports Division Senior Management as detailed subsequent ly. The ADM m anages, oper ates and m aintains KOA in conform it y with St ate and Feder al laws and regulations, as well as HDOT- A polic ies and procedur es. The Airport District Manager is r esponsible for ensuring that the Airport Certification Manual (ACM) is kept curr ent and for direct ing its implement ation. As such, the Airport Distr ict Manager is accountable f or the safe operat ion of aviat ion activities, m aint enance and construction of all f acilities at K OA. The Airpor t District Manager also has overall responsibility for dealing with emergencies that occur wit hin the boundaries of the Kona Inter national Air por t at Keahole. It is his responsibility to pr epare and prom ulgat e an em ergency plan. During an emergenc y, he is responsible for dir ecting act ions of the air por t emergenc y st aff , providing liaison with suppor ting County, State and Federal agencies and providing liaison with t he pr ess 

### . The ADM is also responsible for managing General Lyman Field, Waimea-Kohala Airport and Upolu Airport. AIRPORT DISTRICT M ANAGER

ASSISTANT AIRPORT SUPERINTENDENT DISTRICT ENGINEER

SAFETY, SECURITY & CERTIFICATION SPECIALIST

ARFF SECTIO N

Airport Fire Commander OPERATIONS CONTROL SECTION Ops. Cont rol Supervisor M AINTENANCE SECTION General Const ruction & Maint enance

Su p ervisor CONTRACTED CONTROL TOW ER AIRPORT DIVISION SENIOR M ANAGEMENT1 2 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem JT 7155 00 

### The Assistant Airport Superintendent at KOA provides administrative assistance to the Airport District Manager, particularly in the area of property management. He also provides management relief for the District Manager. He does not play a direct role in the daily activities of aviation safety.
The District Engineer is responsible for identifying, planning, coordinating and monitoring airport maintenance projects. He is responsible for monitoring and inspecting the work of contractors and vendors and ensuring that they follow construction practices that ensure safe airside operations. The District Engineer also coordinates the planning and implementation of capital projects controlled by Divisional Engineering. As such, he is responsible for safe construction practices at KOA including the AOA. The General Construction and Maintenance Supervisor and his staff have important responsibilities that impact aviation directly. These responsibilities include:  

### Maintaining the concrete and asphalt integrity of all runways, taxiways and ramp to provide a high level of physical safety;  

### Daily, weekly, monthly and random inspections of runways and taxiways, beacon and wind sock, airfield lighting, fencing and vegetation growth;  

### Implementing wildlife control on the AOA if and when required;  

### Maintaining runway and taxiway paint markings to help in the prevention of runway incursions;  

### Runway rubber removal maintenance to comply with FAA Standards;  

### Monitoring and removal of any FOD on all runways, taxiways, and ramps for prevention of accidents;  

### Maintaining service roadway system to provide easy access around the airfield without interfering with air traffic;  

### Installation, cleaning and replacement of signs on all AOA and access roads for safety to prevent vehicle and aircraft accidents;  

### Maintaining the perimeter fence line to prevent wildlife and unauthoriz ed persons from entering the AOA to provide for safe aircraft operations;  

### Maintaining all airfield lighting for runways, taxiways, and ramps for safe aviation operations; and  

### Maintaining emergency generator for airfield lighting. The Airport Operations Control Supervisor supervises the work of the Airport Operations Control Section which consists of 5 employees (including the supervisor) and airport policing services provided by contracted security services. The Operations Control Section is responsible for:
 

### Enforcing Title IXX provisions, quarterly T-Hanger inspections, ensuring proper invoicing of scheduled and itinerant aircraft;
 

### Staffing and operating the Airport Operations Control Center;Gap Analy sis 13 Kona International Airpo rt at Keahole Safety Manage ment Sy stem JT71 5500  

### Assigning aircraft to gates when required (e.g., when a preferential gate is occupied as a result of delays in departures of another aircraft or early arrivals);
 

### Conducting daily inspections of the runways, taxiways, ramps and aprons to check for FOD, wildlife, obstructions and other hazardous conditions;
 

### Patrols of airport operational areas to monitor and control, as required, the movement of aircraft, vehicles and support personnel;
 

### Distributing Notice to Airmen (NOTAMs). These may be prepared by the District Airport Manager, the Airport Operations Supervisor or the General Construction and Maintenance Supervisor;
 

### Monitoring tenant activity in T-hangars;
 

### Supervising contract security services which includes:

 

### Implementing the airport badging and vehicle identification program, and related driver training and testing described subsequently;

 

### Perimeter patrols; and

 

### Terminal, landside and airside policing. Three of the contract security services’ officers have police powers as law enforcement officers.
The Safety, Security and Certification Specialist is responsible for participating in FAA certification inspections and ensuring correction of deficiencies. He is also responsible for implementing the Employee Health and Safety Program at KOA. The Safety, Security and Certification Specialist is a hands-on supervisor that will report and correct airside safety and security issues when he identifies them to ensure the enforcement of airport rules and regulations. The Airport Fire Commander directs KOA’s Airport Rescue and Fire Fighting (ARFF) personnel and equipment. He is responsible for ensuring ARFF training and operations at the airport are in accordance with FAA regulations. Based on the largest type of aircraft used at the Airport, the Airport has been designated as Category D for Aircraft Rescue and Firefighting ( ARFF). The Fire Department has three (3) ARFF vehicles with one operator for each vehicle available at all times during operating hours of the airport. KOA ARFF is a 24/7 operation. According to the ACM, ARFF is responsible for conducting inspections of fuel farm/storage and mobile fuelers. KOA management expressed concerns that they did not have capability or expertise to do these inspections. ARFF personnel should be trained to conduct inspections of all fueling operations on the airport. The training could be provided under an agreement with HCC.
The Control Tower is contracted out to Air Services Pacific which is required to provide services in accordance with FAA regulations governing air traffic control (ATC). Airport Committees There are a number of committees at KOA that deal with a wide range of tenant, operations and related safety issues. The committees include:1 4 Gap An aly si s Kona Inte rnational Airpo rt at Keahole Safety Management Sy stem JT 7155 00  

### An Airport Operators Committee (AOC) that is chaired by an airline station manager meets monthly. Airport management attends this meeting. Safety is discussed if it is raised as an issue by anyone on the committee.
 

### HDOT-A Employee Safety Committee that deals with occupational health and safety. This committee generally meets monthly. One of the Airport’s supervisor or superintendents chairs the meeting.
 

### A General Aviation ( GA) Committee that usually meets quarterly to address GA concerns such as leases. HDOT-A Divisional Organization S tructure The Airport District Manager reports to the Airports Administrator who heads the Airports Division which is part of the Department of Transportation in the State of Hawaii. The Airports Divisional organization structure is shown in Exhibit III-2. The key organiz ational units that have an impact on aviation safety are as follows: 1
 

### The Airport Operations Office which includes:

 

### ARFF Staff

 

### Certification, Security and Safety Staff

 

### General Aviation Staff  

### The Engineering Branch

1 The organiza tion charts provided by HDOT-A have been sim plified to focus on sa fety r elated organizational units.Ga p Analysis 15 Ko na In te rnationa l A irpo rt at Keahole Sa fety Man ag eme nt System

JT7 15500Exhibit III-2. Divisiona l Organizational StructureAIRPORTS DIVISIONAirport AdministratorARFF STAFFAirports Fire ChiefCERTIFICATION,SECURITY &SAFETY STAFFCert, Secur ity, &Safety SpecialistGENERALAVI ATION STAFFGeneral AviationOfficerAIRPORTS OPERATION OFFICEAirpor ts Operations OfficerENGINEERING BRANCHEng ineer ing Programs ManagerSTAFF SERVICESBRANCHINFORMATIONTECHNOLOGY OFFICEVISITOR INFORMATIONPROGRAM OFFICEOAHUDISTRICTMAUIDISTRICTHAWAIIDISTRICTKAUAIDISTRICT1 6 Gap An aly si s Kona Inte rna tional Airpo rt a t Kea hole Sa fety Management Sy stem JT 7155 00 

### The Airport Operations Office provides functional direction, advice and assistance to the Airport Districts and airports in Hawaii. More specifically under the direction of the Airports Operational Of ficer, the ARFF Staf f for all the airports, including KOA, provides functional direction to the ARFF units, exercises functional supervision of the Fire Commanders, plans and conduct statewide ARFF training, and inspects ARFF activities to ensure compliance with policies and regulations.
The Certification, Security and Safety Section provides f unctional guidance in airport certification, security and saf ety including standardized procedures and manuals, compliance inspection of related policies and procedures, and administration of the division’s insurance risk management program including accident reporting. The Section to-date has primarily dealt with employee safety ( e.g., the Employee Health and Saf ety Program Manual). The section officer also participates in the state wide contracting of airport security services and monitors the badging programs in the Districts.
The General Aviation Section provides functional guidance related to GA facilities, coordinates the aircraft registration process, and supports GA educational programs and flying saf ety programs in consultation with the FAA.
The Engineering Branch is responsible for:
 

### Preparing master plans that need to take into account aviation saf ety issues and regulations;
 

### Managing special maintenance projects at all airports; and
 

### Managing capital improvement projects including construction management. They are responsible for ensuring that there is a construction safety program in place to ensure continued aviation safety during construction activities. For large projects, a construction management plan is developed by the contractor and reviewed and approved by the Divisional Project Manager in consultation with the District Engineer. The Divisional Project Manager or the District Engineer is responsible for inspections to ensure the contractor is f ollowing the construction safety management plan. 

## Gaps and Developmen t Required HDOT-A and KOA do not have an organizational structure def ined specifically for addressing the requirements of an SMS such as an SMS Safety Manager and Senior (Top) Management responsibilities for SMS. As detailed above, HDOT-A and KOA do, of course, have managers, superintendents, supervisors and officers that have responsibilities that have a direct impact on the saf ety of aviation operations. Considering the size of KOA, particularly in terms of staff members, the Airport District Manager should be the senior manager responsible for SMS. He has the authority to control resources within the mandates set out by the Airports Division. As outlined in the ACM, the Airport District Manager manages, operates and maintains KOA in conformity with State and Federal laws and regulations, as well as HDOT-A po licies and procedures. At this stage of developing the SMS, we recommend that the responsibilities of the Airport District Manager for SMS would include:  

### Approval of the SMS for KOA;Gap Ana ly sis 17 Kona Int erna tional Airpo rt a t Kea hole Sa fety Manage ment Sy stem JT71 5500  

### Approval of saf ety policy and goals;  

### Chairing the Airport Safety Committee;  

### Periodic reviews and updates of the SMS, saf ety policy and goals for KOA; and  

### Deploying f inancial and human resources, within his control, for proper execution of the SMS. Phase 2 SMS development will need to:
1. Confirm that the Airport District Manager will be responsible f or the SMS at KOA.
2. Determine who at KOA will be responsible for administering the SMS and associated responsibilities. These responsibilities include:
 

### Participating in the Airport Safety Committee, as the Secretariat;
 

### Leading safety risk management assessments of hazards, incidents and accidents to determine action required;
 

### Conducting trend analysis of safety concerns, hazards, incidents and accidents and determining action required, in consultation with other airport staff ;
 

### Ensuring appropriate action is taken in response to safety concerns, hazards, incidents and accidents;
 

### Keeping records of all saf ety related reports, incidents and accidents, and conducting trend analysis;
 

### Providing and coordinating safety promotion;  

### Ensuring the provision of safety training for airport employees and tenants located or working in the AOA;
 

### Implementing a non-punitive reporting system;
 

### Ensuring that safety audits are conducted when required;
 

### Measuring safety performance in relation to safety objectives; and
 

### Annual review of the saf ety policy and safety objectives.
3. Describe the composition and role of the Airport Safety Committee in addressing aviation safety issues. The current Airport Operators Committee could f orm the basis of the Airport Safety Committee. It may not need to meet as frequently as the Airport Operators Committee and it should be chaired by the Airport District Manager.
4. Define how tenants would be integrated into the SMS. For example, participation in the Airport Saf ety Committee, audits of tenant saf ety plans or programs.1 8 Gap An aly si s Kona Inte rna tional Airpo rt a t Kea hole Sa fety Management Sy stem JT 7155 00 

### 5. Determine and describe the role of the Division in SMS. Our initial views are as follows;
 

### The Airports Administrator would be responsible for:

 

### Approval of SMS safety policies and SMS plans f or each State airport;

 

### Periodic reviews and updates of HDOT-A SMS safety policies and goals;

 

### Ensuring that f inancial and human resources required f or proper execution of SMS are available at airports in Hawaii; and

 

### Appointment of a SMS saf ety advisor at the Division.  

### The SMS Safety Advisor would be responsible for:

 

### Providing advice to airport safety of ficers and the Divisional Engineering Branch on SMS practices particularly the hazard identification and safety risk assessment process;

 

### Providing advice in the data bases that should be established for State airports for conducting trend analysis of saf ety concerns, hazards, incidents and accidents;

 

### Providing advice to airport saf ety officers on establishing and updating airport SMS;

 

### Developing SMS and related safety training material and programs that can be used by State airports;

 

### Monitoring implementation of the SMS at each airport;

 

### Conducting periodic audits of the safety plans and programs of tenants at HDOT-A airports; and

 

### Collecting relevant saf ety information f rom each airport and preparing a corporate safety report annually. 6. The District Engineer should be responsible for conducting formal hazards identification and safety risk management assessments (sometimes referred to as “operational risk assessment”) whenever new equipment is being planned or installed, or when new f acilities are being constructed that may have an impact on saf ety at the airport. 7. Determine the skills and knowledge required by those administering the SMS at KOA and the Divisional SMS Advisor to ensure that personnel are capable of implementing SMS. (This will likely be included in the Management Plan for implementing SMS) . In consultation with HDOT-A and KOA managers, Phase 2 of this project will develop the organization structure f or safety and will def ine safety responsibilities f or key organizational units at KOA and the Division.Gap Ana ly sis 19 Kona Int erna tional Airpo rt a t Kea hole Sa fety Manage ment Sy stem JT71 5500 

## IV. SAFETY RISK MANAGEMENT Key Featu res The FAA SOW f or SMS describes the following requirements related to Safety Risk Management (SRM) .  

### Description of the saf ety risk management process, including application of “The Five Phases of SRM (saf ety risk management) ,” as discussed in AC 150/5200-37;  

### Guidance on the use of SRM and trend analysis;  

### Defined process for documenting the results of SRM, including a description of how documents will be stored, i.e., electronic or paper; and  

### Descriptions of how top management will follow up on SRM to ensure safety mitigation strategies are appropriate. The FAA’s Advisory Circular indicates that safety risk management is a fundamental component of SMS. The principal steps in the safety risk management (SRM) process include: identif ication of a potential hazard, analysis of the risk, evaluation of the risk and development of an action plan to mitigate the risk if necessary. The Advisory Circular goes on to say that SRM should identify hazards to f ailures of the system (i.e., operations, equipment, people, and procedures). Possible sources of system f ailure could include:
 

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

### Operating environment (example: co ld, night, low visibility) ;  

### Human element (example: shif t work);  

### Operational procedures ( example: staff ing levels);  

### Maintenance procedures (example: nightly movement area inspections by airport electricians); and  

### External services ( example: ramp traffic by Fixed-Base Operator ( FBO) or law enf orcement vehicles) . 

## Existing Practi ces and Systems KOA currently does not have a formal Saf ety Risk Management process for aviation safety. 

## Gaps and Developmen t Required The Safety Risk Management ( SRM) process will need to be developed and documented during Phase 2 of the project. We will develop a practical approach to SRM appropriate to the size of KOA that will be qualitative in nature and understandable by KOA management. For example, we will develop simple paper-based f orms for conducting a safety risk assessment and a simplified risk evaluation matrix for summariz ing the results of an2 0 Gap An aly si s Kona Inte rna tional Airpo rt a t Kea hole Sa fety Management Sy stem JT 7155 00 

### assessment. The Jacobs Team will provide training in SRM to KOA managers, superintendent and supervisors at the end of the SMS development project.Gap Ana ly sis 21 Kona Int erna tional Airpo rt a t Kea hole Sa fety Manage ment Sy stem JT71 5500 

## V. SAFETY ASSURANCE Key Featu res The FAA SOW f or SMS describes the following requirements related to safety assurance:  

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

### A description of the airport quality management and/or risk management program ( if applicable) and its integration into the airport SMS.  

### Description of a plan to integrate apron safety management into the airport SMS. (The FAA’s review of the plan will be limited to measures f or preventing accidents or incidents involving aircraft.) The plan could include the following:

a. Description of current apron saf ety management practices, such as reporting requirements to the National Transportation Saf ety Board (NTSB), Flight Standards, or the Occupational Safety Health Administration ( OSHA). b. An explanation of how current apron safety management practices meet the intent of SMS. This could include the saf ety plans and practices of tenants and operators at the airport, which should complement the airport SMS.  

### A detailed method to document self-auditing processes and their findings. Self -auditing may be part of the airport self-inspection process. If it is, explain how the self -inspection process addresses systems safety, i.e. if the self-inspection program identifies a hazard on the airport it should determine the risk and document the process f or follow-up.  

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

### Process to document and review lessons learned from within the organization. The Advisory Circular states that saf ety assurance includes self-auditing, external auditing and safety oversight. According to the Advisory Circular safety oversight can be achieved through auditing and surveillance practices.The Advisory Circular also says that in addition to the airport operator’s existing responsibilities for selfinspection and correction of discrepancies under 14 CFR Part 139, an eff ective airport SMS audit program should:  

### Develop identif ied saf ety performance indicators and targets (Note: Jacobs Consultancy believes indicators and targets should be addressed as part of Safety Objectives).  

### Monitor adherence to saf ety policy through self-auditing;  

### Allocate adequate resources for safety oversight;  

### Solicit input through a non-punitive saf ety reporting system;2 2 Gap An aly si s Kona Inte rna tional Airpo rt a t Kea hole Sa fety Management Sy stem JT 7155 00  

### Systematically review all available feedback f rom daily self -inspections, assessments, reports, safety risk analysis, and safety audits;  

### Communicate f indings to staff and implement agreed-upon mitigation strategies (14 CFR Part 139 already requires this for actions covered by that regulation); and  

### Promote integration of a systems approach to safety into the overall operation of the airport. The Advisory Circular also provides further guidance on non-punitive safety reporting, self-auditing and saf ety perf ormance monitoring. This guidance material is provided below and generally f ollows international SMS guidance material.
 

### “The SMS should include a visible non-punitive safety reporting system supported by management. The safety reporting system should permit f eedback from personnel regarding hazards and safety-related concerns. The SMS should use this information to identify and address safety deficiencies. The safety reporting system may also identif y and correct non-conformance to safety policy.”
 

### “Saf ety auditing is a core saf ety management activity. Similar to financial audits, safety audits provide a means for systematically assessing how well the organization is meeting its saf ety objectives. Senior Management may choose to have an external agency audit the system ( e.g., by a consultant or another airport operator). The saf ety audit, together with other safety oversight activities, provides feedback to managers concerning the overall safety performance of the organization.”
 

### “Saf ety performance monitoring validates the SMS, confirming the organization’s safety objectives. Through regular review and evaluation, management can pursue continuous improvements in saf ety management and may revise safety objectives to ensure that the SMS remains eff ective and relevant to the organization’s operation.” 

## Existing Practi ces and Systems Airport S elf-Inspection Program As described in the ACM Section 14, KOA has a self -inspection program in place to meet the standards detailed in AC 150/5200-18 and FAR 139.327, Airport Saf ety Self-Inspection. Inspections by KOA and contracted security personnel are conducted as follows:
 

### Daily and periodically;  

### During and af ter construction or maintenance activity;  

### After storms, high winds and other major meteorological events;  

### After earth quakes of significant magnitude; and  

### Immediately after an incident or accident. According to the ACM as part of the self-inspection program, the ARFF Section is responsible f or conducting inspections of fuel farm/storage and mobile f uelers using a Fuel Farm Fire Saf ety Inspection Report Form (see Appendix C). It was not clear whether ARFF also inspects handling, refueling and storing of f uel. FAA AdvisoryGap Ana ly sis 23 Kona Int erna tional Airpo rt a t Kea hole Sa fety Manage ment Sy stem JT71 5500 

### Circular 150/5200-18C, page 9, “Airport Self-Inspection” ref ers to daily inspection of fueling operations. During the Gap Analysis , there was concern expressed that the Airport did not have the capacity to conduct fueling inspections. ARFF personnel should be trained to conduct inspections of all fueling operations on the airport. According to the ACM, the KOA Maintenance Section conducts daily and periodic inspections of paved areas, saf ety areas, marking and lighting, security fencing, traffic and wind direction indicators, and wildlif e activity using the form included in Appendix C of this report. In addition, the Operations Control Section, including contract security services personnel, conduct daily inspections of the runways, taxiways, ramps and aprons to check for FOD, wildlife, obstructions and other hazardous conditions. Inspection reports conducted by the Maintenance and Operations Control Sections are stored by the Maintenance Section. ARFF maintains records of f ueling inspections. Conditions that could affect air carrier operations are disseminated to the air carriers via N OTAMS. Maintenance staff initiates and records repairs as required. Both the Airport Inspection Checklists and associated work orders are kept on file f or 12 months. The Inspection Checklists are included as Appendix C. 

### Apron Safety KOA does not have a distinct Apron Safety Program – aircraft movement on the apron is not controlled. KOA does have “Procedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Area” to govern operation of vehicles. These procedures and regulations address:
 

### Operations on ramp and apron areas;
 

### Vehicle operations in proximity to public aircraft;
 

### Vehicles in proximity to parked aircraft;
 

### Vehicles in proximity to moving aircraft;
 

### Accident reporting;
 

### Speed limits;
 

### Access to restricted operational areas;
 

### Fire protection;
 

### Operational saf ety area; and
 

### Fire protection. These procedures and regulations are in accordance with Hawaii Administrative Rules, Title 19, Chapter 15.1, “Operation of Motor Vehicles at Public Airports”.2 4 Gap An aly si s Kona Inte rna tional Airpo rt a t Kea hole Sa fety Management Sy stem JT 7155 00 

### A review of these Procedures and Regulations indicates that the wearing of safety vests on the AOA is not specified. We observed that at least some of the airlines’ personnel were wearing saf ety vests but that KOA and contract security services personnel were not wearing saf ety vests. The wearing of safety vests is a standard saf ety practice at airports domestically and internationally. We recommend that the HDOT-A consider making this requirement mandatory f or all personnel working on the AOA. The ACM, Section 15, refers to a range of enforcement actions available at the discretion of the Airport District Manager including: an oral reprimand, a written reprimand, recurrent training, loss of authorization to operate on the AOA, a fine, and recommended termination of employment for State employees. Those that we interviewed believed that these enforcement actions were too arbitrary in a union environment and that a more rigorous and well defined enforcement program with demerit points for inf ractions/violations and specific penalties was required. Reference was made to the LAX Security and Airfield Enforcement Program (SAFE). A copy is attached as Appendix D. Although not necessarily part of an SMS, HDOT- A should consider such an Enforcement Program. 

## Gaps and Developmen t Required KOA has a self-inspection program in place. Self -inspection deals primarily with ensuring compliance with detailed FAA standards but can form a key component of safety assurance; for example, trend analysis of reported def iciencies. Gaps that will require development in Phase 2 to meet the FAA’s detailed guidance material referred to previously include:  

### Non-punitive safety reporting;  

### Systematic reviews of feedback from self-inspection, assessments, reports, safety risk analysis and audits which will allow the monitoring of adherence to saf ety policy and the monitoring of safety performance indicators related to safety objectives;  

### Auditing; and  

### Safety oversight which we would define as regular Senior Management reviews and evaluations of the implementation of safety policies, progress to meeting saf ety objectives and lessons learned as means to continuous improvements in saf ety management. The FAA Advisory Circular says that non-punitive reporting systems should permit feedback from personnel regarding hazards and saf ety-related concerns. However, if it is to apply only to hazards and safety-related concerns 

### , then we question why does it need to be non-punit ive? 

### Our understanding is that a non-punitive system is a way to safeguard employees from disciplinary action when reporting incidents and accidents in which they are directly or indirectly involved. Deliberate or unlawf ul actions are excluded of course. This is consistent with a sy stem atic, explicit, and compr ehensive approach f or managing saf ety risk (AC, Paragr aph 3). 

### We have discussed this issue with FAA and have concluded that incidents and accidents should be included. The development of the non-punitive reporting system should also consider whether tenant employees should be part of this system, or whether the system should be limited to KOA employees. We have discussed this issue with the FAA and they have indicated that each airport is unique and should set up practices particular to their airport.Gap Ana ly sis 25 Kona Int erna tional Airpo rt a t Kea hole Sa fety Manage ment Sy stem JT71 5500 

## VI. SAFETY PROMOTION - TRAINING Key Featu res The FAA SOW for SMS describes the following requirements related to saf ety promotion, and training specifically.  

### A plan f or employee SMS indoctrination and training. SMS indoctrination training should provide an outline of proposed curriculum and resources.  

### Documented process to identify training requirements f or systems saf ety.  

### A plan to validate training eff ectiveness and the process to gain training feedback, including useable metrics. The Advisory Circular in addition to the above states that training and education should include:  

### Initial (general saf ety) job-specific training;  

### Recurrent safety training;  

### Training that includes human f actors and organizational f actors ; and  

### A training f ile f or each employee to identify and track employee training requirements and verify that the personnel have received the planned training. 

## Existing Poli cies, Pr actices and Systems The ACM refers to training for three major areas:  

### Pedestrians and vehicles on the AOA;  

### Inspection Techniques; and  

### ARFF. 

### Pedestrians and Vehicles on the AOA KOA’s training material consists of a document entitled, “Procedures and Regulations Pertaining to the Operation of Vehicles on the Airport Operations Area”, which was described previously under Section V. This document is augmented by “An FAA Guide, Airport Ground Vehicle Operations” which deals with airport markings and signage, and communications with the tower. Although these training documents meet the intent of Part 139, it could be augmented and improved by training material, especially audio-visual, available from the American Association of Airport Executives ( AAAE). The training material could also be improved by using pictures of actual signage and markings at KOA. We also note that the FAA Guide on Airport Ground Vehicle Operations appears to be more current than the copy available at the airport. The latest guide is available electronically from the FAA at www.f aa.gov/runwaysfety/asw/downloads/AGVO-guide.doc.2 6 Gap An aly si s Kona Inte rna tional Airpo rt a t Kea hole Sa fety Management Sy stem JT 7155 00 

### Two levels of training are provided at KOA: the first level is for those who must work on aprons and ramps but not on the movement areas. The second level is for those who must work on the movement areas – primarily KOA maintenance workers. After the trainee reads the applicable documentation, the trainee must write and pass a written test with 80%. Trainees are allowed to repeat the test until they get the correct answer and to ensure that they understand the basic requirements. New employees are required to pass the test before being issued a security badge. This badge is valid for five years concurrent with the employee’s State driver license. KOA employees are then provided two to three weeks OJT training. If the supervisor determines that the new employee has obtained the necessary skills, the employee is permitted to drive on the AOA alone. Tenants are also required to pass the basic driver training test, and if necessary the more advanced test for driving on the movement areas. Tenants are required to conduct their own OJT. The ACM ref ers to both initial and refresher training. However, only training for new employees is provided. Refresher training is reportedly provided only if signage and markings at KOA are changed which is likely not very often. 

### Inspection Techniques The ACM , Section 3 “Personnel” ref ers to a training program in addition to OJT f or Inspection Techniques and Record Keeping, and AC 150/5200-18B,”Airport Saf ety Self -Inspection”. The training material that we were provided did not include this material. Although KOA employees involved in this activity do not change frequently, apparently contract security services personnel do. HDOT-A should consider developing a training module in inspection techniques. 

### ARFF Training ARFF personnel, according to the ACM receive instruction in accordance with AC 150/5210-17, Programs for Training Aircraf t and Fire Fighting Personnel. According to the ACM, each fueling agent at the airport is required to have a supervisor complete an aviation fuel-training safety course acceptable to the FAA. The f ueling agent’s supervisor is required to have recurrent training at least once every 24 months. Other employees of the fueling agent involved in fueling operations are required to have OJT and recurrent training every 24 months provided by the agent’s trained supervisor. Written certif ication to Airport Management is required every 12 months. Records are to be maintained by ARFF. 

## Gaps and Developmen t Required We have provided a number of observations where existing Part 139 training could be improved for consideration by HDOT-A. The HDOT-A should also consider strengthening the training function at KOA and HDOT-A to ensure sufficient resources are available. With regard to SMS, given that there is no SMS in place, there is a Gap in SMS requirements for SMS indoctrination and training. SMS training will be developed and provided during Phase 2 of this project.Gap Ana ly sis 27 Kona Int erna tional Airpo rt a t Kea hole Sa fety Manage ment Sy stem JT71 5500 

## VII. SAFETY PROMOTION - COMMUNICATIONS Key Featu res The FAA SOW for SMS describes the following requirements related to saf ety promotion, and specifically for communications:  

### A defined process to communicate safety policies and objectives throughout the organization including examples of how information will be communicated and any processes for follow-up.  

### Procedures to promote saf ety awareness and participation in non-punitive reporting systems. Documented plan f or training and education, saf ety communication, competency, and continuous improvement processes. The Advisory Circular essentially reiterates the requirements above but also provides some examples including:  

### Safety seminars;  

### Safety letters, notices and bulletins;  

### Safety lessons-learned;  

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

### A method to exchange saf ety-related information with other airport operators through regional offices or professional organizations; and  

### In the future, voluntary posting of safety-related information on an existing FAA web-based safety reporting system currently being used by air operators.


## Existing Poli cies, Pr actices and Systems Although HDOT-A has a program for employee occupational health and safety, it does not have a formal promotional airside safety program as envisioned under SMS. HDOT-A also does not have a non-punitive reporting system f or aviation safety. 

## Gaps and Developmen t Required Phase 2 of the SMS will develop an aviation safety promotion program.

## Appendix A Draft Statement of Work FAA SMS Airport Pilot Study Requirements for the Final PlanGap Ana ly sis Kona Int erna tional Airpo rt a t Kea hole Sa fety Manage ment Sy stem JT71 5500Gap Ana ly sis A-1 Kona Int erna tional Airpo rt a t Kea hole Sa fety Manage ment Sy stem JT71 5500 

## DRAFT STATEMENT OF WORK FAA SMS A IRPORT PILOT STU DY

1. OBJECTI VE The FAA is conducting a pilot program to evaluate the implementation of Saf ety Management Systems (SMS) at airports of varying size and complexity. The pilot program will allow airports and the FAA to gain experience establishing airport specific SMS that are tailored for the individual airport. This information will provide FAA information on SMS best practices and lessons learned that will be helpf ul as FAA considers development of a N otice of Proposed Rulemaking to incorporate SMS into 14 C.F.R. Part 139, Cer tification of Airports


### . 2. BENEFITS AN TICIPATED For airport operators, the application of a systematic, proactive, and well-defined safety program as is inherent in SMS allows an airport to continue to improve safety in the f ace of significant forecasted growth in air traff ic activity. The use of SMS at airports can contribute to this effort by increasing the likelihood that Airport Operators will detect and correct safety problems bef ore they result in an aircraft accident or incident. The FAA benefits from the opportunity to assimilate the experience of airport operators in developing an SMS for airports of widely varying activity levels and operational complexity. The FAA anticipates moving to a more formal requirement for the use of SMS at U.S. airports, consistent with the recent ICAO amendment to Annex 14 to make SMS a mandatory standard at international airports. Experience gained through review of the SMS plans developed under this pilot program will be extremely usef ul in development of a general U.S. standard. 3. APPROACH Because SMS is not a regulatory requirement in the U.S. at this time, the SMS Manual and program developed under the pilot program should remain separate f rom the Airport Certification Manual (ACM) required in 14 CFR Part 139. (FAA would need to approve any changes to the ACM itself). FAA Airport Certification Saf ety Inspectors may ask to review the airport’s SMS documents, but will not consider the SMS (or lack of an SMS) a factor in compliance with Part 139. The SMS Manual and program plan should not simply apply existing guidance that has been developed in other countries with their own saf ety oversight rules, or duplicate SMS plans of airports subject to those rules. Rather, the SMS Manual and plan should complement existing U.S. saf ety requirements in 14 C.F.R. Part 139, and be consistent with Part 139, FAA Advisory Circulars, and the Airport Certification Manual specific to the airport’s current operation. Therefore, the SMS Manual and program plan should address which elements of the airport operator’s existing practices and guidance materials currently meet SMS requirements, which elements do not, and how these practices and documents will be revised in the future for consistency with the SMS plan. 4. DELIVERABLES The development of the SMS Manual and program should be completed 6 months after award of the AIP grant. To help FAA evaluate the SMS airport specific development process, copies of the f ollowing documents must be provided to the FAA as they are completed. The FAA encourages sponsors and their consultants to ref er other interim draft documents, questions, and comments to the FAA at any time in the process for consultation and information exchange.A-2 Gap An aly si s Kona Inte rna tional Airpo rt a t Kea hole Sa fety Management Sy stem JT 7155 00 

### a. Gap Analysis The gap analysis should identif y procedures, policies, documentation, and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 requirements addressed by the airport’s ACM. Estimated completion date: 2 months from project start b. Draft Plan A draft of the complete SMS Manual and program. The draft should address the gap analysis and describe saf ety risk management, risk mitigation strategies, and documentation processes. Estimated completion date: 5 months from project start c. Final Plan A copy of the final SMS Manual and program to be implemented by the sponsor. Estimated completion date: 6 months from project start The contents and scope of the SMS Manual and Program plan should address the following: 1) Written safety policy statement and description of how it is communicated to airport employees. 2) Identification and description of the airport safety goals. 3) A plan for employee SMS indoctrination and training. SMS indoctrination training should provide an outline of proposed curriculum and resources. 4) Documented process to identif y training requirements for systems safety. 5) A plan to validate training eff ectiveness and the process to gain training feedback, including useable metrics. 6) A defined process to communicate safety policies and objectives throughout the organization. Include examples of how information will be communicated and any processes for f ollow-up. 7) A plan and description of employee non-punitive reporting systems, existing and new. 8) An organizational chart identifying the names and saf ety responsibilities of all key personnel, such as the following:

 

### Top Management

 

### Safety Manager
 

### Department Heads/Managers

 

### Established Safety Committees and Chairpersons 9) Description of the safety risk management process, including application of “The Five Phases of SRM,” as discussed in the FAA Advisory Circular 150/5200-37, Introduction to Safety Management Systems for Airport Operators. 10) Guidance on the use of SRM and trend analysis. 11) Defined process for documenting the results of SRM to include a description of how documents will be stored, i.e., electronic or paper. 12) Description of how top management will follow-up on SRM to ensure safety mitigation strategies are appropriate.Gap Ana ly sis A-3 Kona Int erna tional Airpo rt a t Kea hole Sa fety Manage ment Sy stem JT71 5500 

### 13) A description of the airport quality management and/or risk management program (if applicable) and its integration into the Airport SMS. 14) Description of a plan to integrate apron saf ety management into the Airport SMS. ( FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft.) The plan could include: a. A description of current apron safety management practices already in place such as reporting requirements to the N TSB, Flight Standards, or the Occupational Saf ety Health Administration (OSHA) . b. An explanation of how current apron safety management practices meet the intent of SMS. This could include the safety plans and practices of tenants and operators at the airport, which should complement the airport SMS. 15) A detailed method to document self-auditing processes and their f indings. Self -auditing may be part of the airport self-inspection process. If it is, explain how the self-inspection process addresses systems safety, i.e. if the self-inspection program identifies a hazard on the airport it should determine the risk and document the process for follow-up. 16) A detailed method to document self-inspection reviews, analysis, and f indings. 17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport. 18) Documented plan f or training and education, safety communication, competency, and continuous improvement processes. 19) Procedures to promote safety awareness and participation in non-punitive reporting systems. 20) Process to document and review lessons learned from within the organization. 21) Schedule for implementation and anticipated associated costs. 5. INFORMATION FURN ISHED TO THE GOVERNMENT All documents submitted by a sponsor or its agent to the FAA for review under this grant remain the property of the sponsor. Final SMS documents and plans will be considered public information. Gap analyses, draf t SMS manuals and plans, and other interim documents may be submitted with a request for confidentiality. The Freedom of Information Act requirements of 5 U.S.C. § 552, as amended, w ill apply to any such request.Gap Ana ly sis Kona Int erna tional Airpo rt a t Kea hole Sa fety Manage ment Sy stem JT71 5500 

## Appendix B Safety IssuesGap Ana ly sis B-1 Kona Int erna tional Airpo rt a t Kea hole Sa fety Manage ment Sy stem JT71 5500 

### Saf ety Concerns and Issues Raised during Interviews May 1 – 4, 2008 and Correspondence Between Jacobs Consultancy, KOA and other Stakeholders During Jacobs Consultancy’s visits to Kona International Airport and correspondence with Jacobs, several issues were identified that could have the potential to impact the safety of passengers, airport employees or damage equipment. These include:  

### Rough Terrain Outside of the Runway Safety Areas;  

### Ramp Congestion;  

### Commuter Terminal Operations; and  

### Fueling Operations. Rough Terrain Outside of the Runway Safety Areas Runway Saf ety Areas (RSAs) are an important part of the runway environment at an airport and help to reduce the risk of damage to airplanes in the event of an undershoot, overshoot, or excursion from the runway. Part 139.309 requires a runway safety area (RSA) of 250 feet each side of the center line of the runway and 1000 feet at the end of the runway at KOA. This RSA is to be clear of all obstacles. KOA meets FAA criteria for dimensions and surface conditions. However, there is a concern regarding the rough terrain due to the lava field on which KOA is built. The majority of airports have graded areas beyond the RSA dimensions because the land is not cost prohibitive to develop. This reduces the risks and enhances the ability for emergency response should an aircraft go beyond the RSA. KOA is unique in that it is located in the middle of a lava field. The initial construction of the airport included escalating costs due to the geology of the land to be developed. Only those areas that had grading requirements were addressed. KOA has a higher risk, compared with most other airports, in providing emergency response to an incident should an aircraft exit or crash beyond the RSA. Emergency vehicles and personnel cannot operate on most of the lava field outside of the RSA at KOA and therefore could not easily assist in an aircraft crash outside of the RSA. From a safety risk management perspective, the probability of an aircraft crashing on the runway or the RSA is very remote. The probability of an aircraft exiting or crashing beyond the RSA is even more remote. Yet the consequences could be catastrophic. KOA and HDOT-A should conduct a comprehensive cost and risk assessment to determine if some of the areas outside of the RSA should be graded to remove obstacles. Due to the expected high capital costs, this study should include a numerical estimate of the actual risk in quantitative terms in order to do a rigorous cost-benefit analysis. The actual risk should be based on historical accident and incident records of aircraft crashing on, or ending up outside, the RSA. The study should also consider thenumber times that aircraft at KOA use the 17-35 runway during cross wind conditions due to the lack of a crosswind runway. Accident and incident reports are available from the FAA and world wide sources. The study should also address the areas and associated dimensions that should be graded to remove lava flow obstacles and what the costs would be. The results of the analysis should be used to set priorities for any corrective action in comparison with other capital works at KOA.B-2 Gap An aly si s Kona Inte rna tional Airpo rt a t Kea hole Sa fety Management Sy stem JT 7155 00 

### Ramp Congestion KOA was constructed to serve aviation inter-island passenger traf fic when passenger numbers were less and the aircraft being used on these routes were smaller. Due to the growing local economy and tourist activities, KOA passenger volumes has grown and has attracted air carriers from the mainland and Japan. The size of aircraft has also increased with U.S. flag carriers using aircraft as large as B-767’s and B-757’s and Japan Airlines flying a B-777. The conf iguration of the airport terminal buildings and ramp has lead to congestion as KOA has accommodated the air carriers. Activity on the ramp can be intense with large numbers of ground service vehicles, 10,000 gallon f ueling trucks and airline vehicles and employees perf orming airline operations. Through these activities passengers must enplane and deplane by walking across the ramp to and from the aircraft. Passengers are marshaled by employees of a contract security agency and airlines between the terminal and aircraf t. Passengers must use hard stands as jet bridges are currently not available. Saf ety concerns identified include:  

### Push back: The ramp is an uncontrolled movement area. Departing aircraft are pushed back away from the terminal by the airline where the aircraft powers up and departs to a taxiway. Aircraft power-in when arriving. Jet blast from these airplanes has the potential f or damaging equipment and injuring persons on the ramp. It has been suggested that lines be painted to show where aircraft should be parked. This way the carrier could position their ground equipment to service the aircraf t. Kona's problem is that in painting "the box", KOA would have to have "the box" for the largest aircraf t that would likely be at that gate and this means that KOA would likely loose gate positions.  

### Equipment operating near and around surrounding aircraft have the potential of striking other aircraft, equipment, employees and passengers in these tight spaces;  

### Lack of marked vehicle lanes does not direct the movement of ground vehicles potentially causing damage or injury;  

### Ground equipment owned and operated by the airlines or their sub-contractors has been leaking oil and hydraulic fluid on to the ramp. This has the potential of causing accidents and injuries. Some of equipment owners have not properly cleaned the spills or repaired the equipment causing on going spills. Bradley, who provides fuel for the air carriers, does not have building on airport to repair its vehicles and maintains them on the ramp which leads to spills.
Commuter Terminal Operations Commuter Airlines have been moved to a temporary terminal. This terminal and ramp is located in an area that includes cargo operations, helicopter tour and flight school operations and fueling operations. The temporary terminal is planned to be replaced in the near future to better handle passengers and airline tenants. Saf ety issues identif ied in this area include:  

### Inadequate ramp lighting in the commuter terminal area that may lead to damage to aircraft or vehicles, or injury to passengers and employees. There was a recent accident in this area where a commuter aircraft struck a light pole while attempting to maneuver in this constrained area;  

### The f ueling operations are located near the commuter operations. The movement of aircraft, fuel trucks and passengers in this confined area and the lack of lighting is a potential hazard;Gap Ana ly sis B-3 Kona Int erna tional Airpo rt a t Kea hole Sa fety Manage ment Sy stem JT71 5500  

### Tour helicopter operations and flight school operations are located adjacent to the commuter ramp. Several individuals expressed concern with the f light school and student pilots learning how to f ly helicopters operating in this area. Concerns included the flight path used and skill level of the new pilots using the adjacent ramp; and  

### During the holiday season general aviat ion increases and all available parking is used to handle the number of aircraft including Taxiway B. This adds congestion to the activities already being conducted in this part of the airport. DOTA has identified an area for GA expansion to assist in reducing this risk.
Fueling Operations KOA has a lack of fuel storage capacity both on and near the airport. There is a small fuel farm located on the airport that includes a self serve Av Gas tank. This has lead to tanker trucks driving from Hilo to KOA to meet the Jet A fuel requirements at KOA. Fixed Based Operators (FBO’s) use 10,000 gallon fueling trucks to help off set the capacity shortage. The FBO’s do not have f acilities to house their vehicles and maintain them on the ramp as mentioned previously. Saf ety issues identif ied include:  

### The large vehicles add to the congestion on the ramp. They must maneuver around aircraft, other ground vehicles, airline personnel and passengers;  

### With the constant transf er of f uel there is concern that the fuel does not have the opportunity to settle long enough causing a potential for catastrophic events; and  

### As mentioned above, the aircraft ref ueling vehicles must be maintained on the ramp. This has lead to oil leaks causing the potential f or safety related issues.Gap Ana ly sis Kona Int erna tional Airpo rt a t Kea hole Sa fety Manage ment Sy stem JT71 5500 

## Appendix C Inspection ChecklistsGap Ana ly sis C-1 Kona Int erna tional Airpo rt a t Kea hole Sa fety Manage ment Sy ste m JT71 5500C-2 Gap An aly si s Kona Inte rna tional Airpo rt a t Kea hole Sa fety Management Sy stem JT 7155 00Gap Ana ly sis C-3 Kona Int erna tional Airpo rt a t Kea hole Sa fety Manage ment Sy ste m JT71 5500C-4 Gap An aly si s Kona Inte rna tional Airpo rt a t Kea hole Sa fety Management Sy stem JT 7155 00Gap Analy sis Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT715500 

## Appendix D Examples of Safety and Security Enforcement ProgramsGap Analy sis D-1 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT715500D-2 Gap Analy sis K ona Inte rnational Ai rp o rt a t Keahole Safety Manage ment Sy stem JT715500Gap Analy sis D-3 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT715500D-4 Gap Analy sis K ona Inte rnational Ai rp o rt a t Keahole Safety Manage ment Sy stem JT715500Gap Analy sis D-5 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT715500D-6 Gap Analy sis K ona Inte rnational Ai rp o rt a t Keahole Safety Manage ment Sy stem JT715500Gap Analy sis D-7 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT715500D-8 Gap Analy sis K ona Inte rnational Ai rp o rt a t Keahole Safety Manage ment Sy stem JT715500Gap Analy sis D-9 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT715500 

## Generic Safety Enforcement Program Saf ety is t he first r esponsibility of all airside driver s at . At no t im e do operational considerat ion such as t im e pressures, allow driver s to disobey this Airside SOP. The Air port Authority reserves the right to suspend Airside Vehic le Operat ors Per mit (AVOP) privileges, or have the AVOP holder c omplete additional tr aining and/or testing result ing fr om a violat ion (or violat ions) of this Airside SOP. Ther e are four m ain objectives of t he Demer it Point System :

1. To reinfor ce the importance of safe airside driv ing; 2. To have a fair, pred ictable and transparent method for reinf orcem ent; 3. To create a system f or progr essive discip line for repeat off enders; and 4. To have the r ight t o r evoke an AVOP f rom unsafe driver . Demerit Point Sy stem Any action which com prom ises safety will result in a Not ic e of Infr action Ticket and will be tr eated as an offense under the Demer it Point System . The Airport Safety Section, Airport Security Sec tion and other designated Airport Aut hority per sonnel have the aut hority to enf orce t hese procedures and issue t ickets. All air sid e driver s will c omm ence with zer o (0) points. Points will ac cumulate based on the inf ract ion a driver com mits. Pr evious r ecords/points will remain on file – as st ated in the violat ion chart. Mult iple violations at the same time will r esult in m ult iple point s. AVOP Suspension/r evocat ion:  6 point accumulat ion = 5 working day suspension.  10 point acc umulat ion = 10 working day suspension.  14 point acc umulat ion = 20 working day suspension.  18 point accumulation = AVOP r evocat ionD-1 0 Gap Analy sis K ona Inte rnational Ai rp o rt a t Keahole Safety Manage ment Sy stem JT715500 

### Char t of Violations
V i o l a t i o n O f f

e n c e ( s e

c t i o n & b r i e f d e s c r i p t i o n ) P e n a l t y

Class A  Failing to give r ight ofway to pedestrians  Refus ing to s ubmit a br eathalyzer 12 point

 Danger ous dr iving
 Driving under t he influence of alcohol/dr ugs  Driving gre ater than 25 km/hr above speed limit Record/6 years

Class B  Failing t o give r ight-ofway to aircraft or res ponding emer gency vehicle
 Care less driving

 Driving betwe en aircr aft and mars haller

 Failing t o c omply with AVOP enforcement per sonne l
 Smoking airside

 Runwa y inc ursion  Failing t o operat e a vehicle safely at all times.
 Driving wit hout a valid air port licens e
 Driving wit hout a valid Governme nt Driver s Licens e
 Driving 15 to 25 km/hr a bove speed limit 6 point

Record/ 4 years

Class C  Failing t o use vehicle corridor
 Failing t o e nter appr oximating a 90 degr ee angle
 Failing t o obey a stop sign
 Failing t o yie ld to traffic within ma in vehicle corridor
 Towing more tha n 4 car ts /dollies
 Failing t o r epor t an acc ide nt  Par king in unauthor ized par king loca tion

 Using a pers onal radio while dr iving airside
 Driving 1-14 k m/hr above speed limit 2 point s

Record/2 years

Class D  Violation of directives not c over ed in t he above classes. T o be deter minedGap Analy sis D-11 Kon a In ternational Airpo rt at Keah ole Safe ty Man agement Sy stem JT715500 

### Sp eed Limits N o per son shall oper ate a vehicle on a road at the airport at the rat e of speed that ex ceeds the speed limit post ed for that road or, where no speed lim it is posted, 50 km/h (30 mph) . The m aximum speed limits are:  10 km/h (6 mph) within 6 m . (20 f t.) of aircr aft or in congest ed areas and on the Head of Stand Road.  25 km/h (15 mph) on all apron areas, vehicle corr idors (not including Head of Stand Road) and airside roads.  50 km/h (31 mph) on the taxiway s and runways (with the exception of em ergency vehicles and Airpor t Authority vehicles in the cour se of their duties or other vehicles as requested by Air Traf fic Cont rol). Operators shall reduce speed and m aintain a car eful lookout when near air craf t and c orner s of buildings or other installations. N o per son shall operat e a vehicle in an air side ar ea in a manner that is danger ous to persons, aircraft, vehicles or equipment , having r egard to all the c ir cumstances including the am ount of tr aff ic ther eon or reasonably expect ed to be t hereon.D-1 2 Gap Analy sis K ona Inte rnational Ai rp o rt a t Keahole Safety Manage ment Sy stem JT715500 

### App eal Pr ocess 1 st Level Appea l A let ter de tailing t he infraction, t he points allott ed and the t otal points accumulate d to dat e will be forwar ded to the AVOP hold and his/her employer . Within seve n (7) days of the iss uance of this le tte r, an a ppeal ma y be ma de in the form of a letter including a de script ion of the circums tances and justificat ion of appeal. The appeal le tter must be forwar ded to Safet y Office, where t he Air port Safety Officer will invest igate the incident and conduct inter views as r equired. Ar guments citing oper ational neces sity will not be considered as a n appeal. A decision regarding the appea l will be s ent to t he AVOP holde r wit hin 7 days of t he date of the appe al notific ation. 2nd Level Appea l If the AVOP holder disagr ees with the r esult s of the 1 st appeal, a n a ppeal ma y be made by lette r to the Airport Director within 15 days of the decision. The Direct or may arr ange a meeting with the AVOP holder t o ass is t in considering the a ppeal and the AVOP holder may bring an agent to ass ist in t he present ation of the appe al. T he decision of t he Dir ector is final and c onclusive. Poi nt Accumulation Interviews The Air port Safety Officer may conduct int ervie ws with a ir side dr ivers who ha ve acc umula ted 6 or more point s for t he following purpos es:

 To act upon a pote ntially da ngerous situation;

 To re infor ce the element of safe air side driving at the a ir port ;

 To impres s upon the indivi dual the ser iousness of bad driving habits;

 To educate t he employee on acce ptable dr iving ha bit s. The Airpor t Safety Officer may de em it necessary to have an AVOP holder re-tes ted. 13. 0 Ve hic le Oper ati ng Pr ocedure Vehicle operat ors s hall use service and per imet er roa ds to reach field locat ions when thes e roads are available and t ime per mits . A vehicle ope rator approaching an aircr aft (with anti-c ollision lights on) on pushback or power out shall gi ve way and come t o a complete st op. Do not drive between a marshaller , their equipment and the aircraft or pr oceed behind the aircr aft unles s cleared by t he ma rshaller . Onc e t he aircr aft and ma rshalling crew are clear of vehicle corridor, operators may proc eed. No pe rson shall opera te a vehicle within 15 m (50 ft.) of an air craft being fuelled or defue lled e xcept for t he purpos e of ser vicing that a ircra ft or as r equired when oper ating wit hin a de signate d vehicle c orr idor. A vehicle operat or shall ensure the vehicle he /she is dr iving is in s ound mechanica l condition. A mal function shall be r epor ted to your supervisor, however t he vehicle oper ator is r esponsible for the vehicle/equipment he/s he is operat ing on airs ide.