International Air Transport Association 

800 Place Victoria, B.P. 113 

Montreal, Quebec 

Canada H4Z 1M1 

Tel: +1 (514) 874 0202 

Fax: +1 (514) 874 2662 

www.iata.org 

DTW Safety Management System Manual and Program

Final Gap Analysis 

April 18, 2008 

 In Association with Jacobsen/Daniels Associates 

Version No: 1.01 

Status FINAL/Released

Controlled Copy 
DTW SMS Manual and Program 

Gap Analysis 3 

Proprietary Notice 

The information furnished in this document shall not be disclosed, duplicated or used in whole 

or in part for any purpose other than to evaluate the document. If a contract is awarded 

subsequent to this offer as a result of, or in connection with, the submission of such information, 

the Client shall have the right to duplicate, use or disclose this information to the extent provided 

in the contract. 
DTW SMS Manual and Program 

Gap Analysis 4 

Document Revision and Control History 

Version Number Date Description 

1.01 4/18/2008 Final/Released 

 

 

 

 

 Signature Date 

Approved 

Reviewed 

Reviewed 

Approved 

Approved 
DTW SMS Manual and Program 

Gap Analysis 5 

1 Introduction 

1.1 Project Description 

In November 2005, the International Civil Aviation Organization (ICAO) amended Appendix 

14, Volume I (Aerodrome Design and Operations), to require member States to have 

certificated international airports establish a SMS. The FAA supports harmonization of 

international standards and has worked to make U.S. aviation safety regulations consistent 

with ICAO standards and recommended practices. 

The FAA intends to implement the use of SMS at U.S. airports to meet the intent of the ICAO 

standard in a way that complements existing airport safety regulations in 14 CFR Part 139, 

Certification of Airports. 

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

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

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

individual airport. This experience will provide SMS best practices and lessons learned that 

the FAA can use as it considers whether to incorporate SMS into Title 14 Code of Federal 

Regulations (CFR), Part 139, Certification of Airports. 

As part of the pilot program, the International Air Transport Association (IATA) and Jacobsen/ 

Daniels Associates (JDA) have been hired to prepare a Safety Management System Manual 

and Program Plan for the Detroit Metropolitan Wayne County Airport. 

1.2 Project Kick-off 

A WCAA SMS Kickoff Meeting to provide a framework for the project was held on 

February, 15, 2008 at the WCAA Administration Offices. 

1.3 On site interviews 17 to 20th March 

Two introductory SMS training sessions were held. The first session took place on 

Monday 17th March at 1:00 pm, and the second session on Tuesday 18 March at 

9:00 am. The SMS training session participants from WCAA were as shown in the 

following table. 

Name Department 

Monday 17th March 2008 

Debra Seig Public Safety 

Matt LaFleur Airfield Operations 

Bruce Greenberg Airfield Operations 

Ken Szymanski –Airfield Operations 

Chris Kaminski Risk Management 

Tuesday 18th March 2008 

Mary C. Walker Fleet Maintenance training 
DTW SMS Manual and Program 

Gap Analysis 6 

Joe McCabe Field Maintenance 

Tom Snell Fleet Services 

Chris Kaminski Risk Management 

Devin O’Rourke Field Maintenance 

Matt Orzech Facilities Maintenance 

Sean Brosnan Emergency Management 

Interviews were held at the Detroit Metro Airport on March 18th, 19th, and 20th. WCAA 

personnel participating in the interviews were as shown in the following table: 

Name Department 

Tuesday 3/18/2008 – Policy Statement/Organizational structure 

Chris Kaminski Risk Management 

Dianne Walker Airfield Operations 

Mark DeBeau Public Safety 

Leigh Stepaniak Risk Management 

Mary Muhammad Public Safety 

Tuesday 3/18/2008 – Traffic and Wind Socks/Wildlife Hazard & 

Mitigation/Aircraft Index 

Bruce Greenberg Airfield Operations 

Matt LaFleur Airfield Operations 

Chris Kaminski Risk Management 

Tuesday 3/18/2008 –Internal Audits/Pedestrians and Ground Vehicles 

Bruce Greenberg Airfield Operations 

Matt LaFleur Airfield Operations 

Chris Kaminski Risk Management 

Mary C. Walker Fleet Maintenance training 

Kevin Wick ARFF 

Michael Evans ARFF 

Wednesday 3/19/2008 –Training/Communications/Records 

Gary Dust 

Matt LaFleur Airfield Operations 

Mary C. Walker Fleet Maintenance training 

Wednesday 3/19/2008 –Safety Risk Management/Hazard Identification/Risk 

Assessment/ Risk Mitigation/Risk Tracking 

Chris Kaminski Risk Management 

Joe McCabe Field Maintenance 

Alex Gonzales Field Maintenance 
DTW SMS Manual and Program 

Gap Analysis 7 

Name Department 

Bruce Greenberg Airfield Operations 

Kevin J. Grammes FAA-ATCT 

Bryan Wagoner WCAA Environmental 

Ken Szymanski Airfield Operations 

Wednesday 3/19/2008 –ARFF/HAZMAT 

Michael Evans ARFF 

Matt LaFleur Airfield Operations 

Mary C. Walker Fleet Maintenance training 

Craig Carnell ARFF 

Wednesday 3/19/2008 –Emergency Action Plan 

Sean Brosnan Emergency Management 

Denine Alfaro Emergency Management 

Sandy Altschul Emergency Management 

Thursday 3/20/2008 –Procedures/Safety Objectives/Culture 

Gale LaRoche Human Resources 

Thursday 3/20/2008 –Construction/Paved Areas 

Steve T. Wiesner Planning 

Bruce Greenberg Airfield Operations 

Thursday 3/20/2008 –Personnel 

Bruce Greenberg Airfield Operations 

Matt LaFleur Airfield Operations 

Mary C. Walker Fleet Maintenance training 

Thursday 3/20/2008 –Self Inspection 

Bruce Greenberg Airfield Operations 

Matt LaFleur Airfield Operations 

Mary C. Walker Fleet Maintenance training 

Thursday 3/20/2008 –Verify Operational Requirements 

Bruce Greenberg Airfield Operations 

Matt LaFleur Airfield Operations 

Tom Snell Airfield Operations 

Thursday 3/20/2008 –Condition Reporting 

Bruce Greenberg Airfield Operations 

Matt LaFleur Airfield Operations 

Thursday 3/20/2008 –Markings/Signage/Lighting 

Bruce Greenberg Airfield Operations 

Matt LaFleur Airfield Operations 

Joe McCabe Field Maintenance 
DTW SMS Manual and Program 

Gap Analysis 8 

2 Literature Review 

Available SMS-related documentation available was reviewed. Reviewed documents are 

listed in Appendix A. For the purpose of this project, we found that the two following 

documents were most useful: 

1. SMS Implementation at Airports Outside the United States 

 Interview Summaries 

The interview summaries contained in SMS Implementation at Airports Outside the 

United States was developed out of research conducted during in the development of 

ACRP Report 1, Volume 1: Overview of Safety Management Systems for Airports. 

The summaries consist of notes that were compiled through interviews with foreign 

airport officials and civil aviation authority personnel who are involved in the 

implementation of safety management systems (SMS) in their organization. They 

describe experiences and lessons learned during the SMS adoption at airports 

outside the United States and may be useful to executives within the United States 

who are planning to implement SMS in their organization. 

2. Airport Cooperative Research Program 

 Report 1, Volume 1: Overview 

This report explains what a safety management system (SMS) is and how a systems 

approach to safety management will benefit both the safety and business aspects of 

airports. It describes the advantages associated with instituting such a system and 

explains the four components or pillars (safety policy, safety risk management, safety 

assurance, and safety promotion) that are part of an SMS. The report also provides 

background information on the International Civil Aviation Organization’s 

requirements for SMS at airports and relates the experiences of airports located 

outside the United States in implementing SMS. 

The four components of SMS identified in this report were the basis for the structure of the 

questionnaire used in the interviews with WCAA staff to identify gaps between existing 

practices and SMS requirements. 

3 Safety Management Gap Analysis 

3.1 SMS Gap Analysis 

The SMS Gap analysis requirement under the Pilot Study is meant to determine whether 

deficiencies exist between components found in current operations compared to SMS 

program as it relates to FAR Part 139. These requirements were separated into four (4) 

distinct elements: 

1. Safety Policy and Objective 

2. Safety Risk Management 

3. Safety Assurance 

4. Safety Promotion 
DTW SMS Manual and Program 

Gap Analysis 9 

Item Status 

Action 

Required 

SAFETY POLICY AND OBJECTIVE 

Policy 

 No formal Safety Policy/Mission 

Statement related to SMS has been 

developed as it relates to Part 139. 

However, WCAA has issued a 

comprehensive Safety Policy meant 

to provide employees with a safe and 

healthful work environment, in 

essence the Policy deals with 

Occupational Health and Safety 

Administration (OSHA). 

Although SMS and OSHA both deal 

with safety and need to establish a 

safety culture to be successful, they 

are different in their respective area 

of application. OSHA deals with 

safety in the workplace and focuses 

on protection from hazards and risks 

arising out of, linked with or occurring 

in the course of employment. OHS 

deals on how these risks and 

hazards affect people (employees 

and others). SMS is aimed at 

applying the best safety management 

practices in order to reduce the 

frequency and severity of aviation 

incidents and accidents. 

We can easily acknowledge that both 

programs must work in harmony to 

be successful. Operational 

requirements, i.e. tasks that are 

Develop an SMS Policy document that 

will include a policy statement, 

objectives and goals and roles and 

responsibilities. 
DTW SMS Manual and Program 

Gap Analysis 10 

Item Status 

Action 

Required 

needed to create a safe environment 

for aviation (SMS), must be carried 

out by people applying best safety 

practices (OSHA). 
DTW SMS Manual and Program 

Gap Analysis 11 

Item Status 

Action 

Required 

Senior Management 

Commitment 

No formal written policy in place. The Policy should be endorsed 

by the CEO.

Commitment to 

continual safety 

improvement 

No formal written policy in place. As with the OHSA Policy, the 

Safety Policy should confirm that 

the goal is not only to maintain a 

status but continue to improve in 

incident prevention.

Commitment in 

establishing a nonpunitive environment 

No such program presently in place. 

A zero tolerance practice is now 

observed for serious safety breaches 

(i.e. runway incursions). 

Draft a non punitive reporting 

policy or program that will not 

allow for deliberate, unlawful or 

grossly negligent incidents.

Commitment for 

providing necessary 

resources 

No formal commitment in place Should be part of the safety 

policy.

Commitment to make 

safety the highest 

priority 

The Airport’s Mission Statement 

states, “To operate safe, secure 

and dynamic air transportation 

facilities for our customers, 

creating economic vitality by 

providing global travel, cargo and 

business opportunities. 

Safety is the highest priority of 

the Airport

Approval of the Safety 

Policy 

No formal written policy in place. The CEO should approve the 

SMS Safety Policy
DTW SMS Manual and Program 

Gap Analysis 12 

Item Status 

Action 

Required 

Promotion of the Safety 

Policy 

No policy in place. The policy should be subject to 

wide promotion starting from the 

CEO and then to every 

managerial level of the 

organization.

Periodic review of the 

Safety Policy 

No policy in place. A process should be developed 

in order to insure that the policy 

is reviewed periodically.

Communication of the 

Safety Policy to all 

employees 

No policy in place. A process should be developed 

to ensure that all employees 

receive a copy of the policy and 

are made aware of their role and 

responsibilities regarding safety.

Organizational Structure 

Appointment of a senior 

manager 

Not required under FAA guidelines. The appointment of a senior 

manager for Safety is 

constructive in ensuring that an 

SMS culture is being created 

and enforces managerial 

commitment in making safety a 

high priority.
DTW SMS Manual and Program 

Gap Analysis 13 

Item Status 

Action 

Required 

Senior manager control 

over financial and 

human resources 

 Naming the Executive VicePresident Operations as the 

Safety Senior Manager should 

ensure that this requirement is 

met.

Appointment of a Safety 

Manager 

No SMS Manager has been 

identified. Present Safety Manager’s 

role is identified to OSHA. 

Consideration should be given 

to assign the responsibility to the 

existing Safety Manager dealing 

with OSHA since the roles and 

responsibilities are similar.

Safety Manager to 

report to the highest 

level of management 

Not the case with the present OSHA 

Safety Manager. 

When appointing a Safety 

Manager, consideration should 

be given to changes in the 

organization.

Safety Manager role 

and responsibilities 

clearly defined 

They are clearly defined with OSHA. Safety Manager to engage in a 

counselling role with line 

managers to ensure that safety 

processes are carried out within 

every department.

Cross-functional Safety 

Committee 

Airfield Coordination and Safety 

Committee now in place but focused 

on FAR Part 139 

This committee could be a 

subcommittee of the Executive 

Safety Committee. Safety issues 

should be tabled at a crossfunctional SMS committee such 

as the quarterly Executive 

Safety Committee for discussion 

and resolve. Terms of reference 

for this committee should be 

clearly stated, including roles 

and responsibilities for 

members.

Safety authorities, They are clearly defined with OSHA. These need to be described and 
DTW SMS Manual and Program 

Gap Analysis 14 

Item Status 

Action 

Required 

responsibilities and 

accountabilities for 

personnel at all levels 

mandates defined in a model 

established in the OSHA policy 

document.

Personnel aware of 

their authorities, 

responsibilities and 

accountabilities with 

SMS 

Not yet defined Will need to be described and 

issued in a formal process 

before assessment.

Procedures 

Safety process to 

identify and attenuate 

safety risk 

No process in place Develop a process.

Issue of new and 

revision of current 

safety procedures 

No process in place Develop a process.

Changes and revision 

clearly communicated 

to staff 

No process in place Develop a process.

Easy accessible 

procedures to all 

personnel for 

continuous training 

purposes 

No process in place Develop a process.

Performance indicators, goals and objectives 

Performance indicators No performance indicators have 

been identified and no development 

process has been established. 

Develop a process to identify 

performance indicators. 
DTW SMS Manual and Program 

Gap Analysis 15 

Item Status 

Action 

Required 

Safety objectives – 

Establishment, 

distribution and 

publicizing 

No formal safety objectives have 

been identified 

Corporate safety objectives will 

need to be identified and 

disseminated throughout the 

organization where each 

department will formulate their 

specific supporting objectives.

SAFETY RISK MANAGEMENT 

Hazard identification 

Reactive process for 

capture of internal 

information (incidents, 

accidents and data) 

A formal self inspection program is 

carried out and operations specialists 

will also report on otherwise 

observed incidents and system 

failures. No formal process exist 

A formal process will need to be 

developed showing reporting 

levels, follow-through, etc. 

Reactive reports 

reviewed at the 

appropriate level 

No documented process in place. The reporting process should 

clearly identity reporting levels 

within a documented process.

Feedback to 

contributors 

Some feedback is provided on 

occasion. 

The reporting process should 

include a requirement for 

feedback on all reports.

Monitoring and 

analyzing trends 

Trends are not monitored. A process should be developed 

to insure that trends found in the 

reactive reporting system are 

analyzed at the appropriate 

level.
DTW SMS Manual and Program 

Gap Analysis 16 

Item Status 

Action 

Required 

Corrective and 

preventive action 

following event analysis 

Practice shows that corrective action 

is taken following reporting of an 

event or serious concern. No formal 

written process is in place to ensure 

that corrective and preventive actions 

are taken 

Process to be documented. 

Proactive process for 

capture of internal 

information (incidents, 

accidents and data) 

The self inspection program is a 

proactive procedure for capture of 

information, but no formal proactive 

process is in existence. 

Process to be documented.

Proactive reporting 

process simple, 

accessible and 

commensurate to the 

size of the organization 

The airport self-inspection program is 

a form of proactive reporting system. 

The self-inspection program 

should be complemented to 

ensure proactive reporting of all 

safety-critical systems. Process 

to be documented.

Procedure to identify 

hazards that the 

organization faces in its 

operational 

environment 

No formal procedure in place. Process to be documented.
DTW SMS Manual and Program 

Gap Analysis 17 

Item Status 

Action 

Required 

Procedure to identify 

hazards resulting from 

change in systems, 

operations or 

procedures 

No written procedure in place. A written procedure should be 

developed to ensure that safety 

hazards are identified when 

changes occur in operational 

systems, operations or 

procedures.

Systematic review of 

daily self-inspections, 

assessments, reports, 

safety risk analysis and 

safety audits 

No written procedures for systematic 

reviews 

The process will need to be 

documented.

All identified hazards 

are documented and 

analyzed and 

associated risk are 

assessed 

Systematic hazard reporting and risk 

analysis are not formally carried out. 

Processes to be developed.

Risk assessment 

Reported occurrences 

and deficiencies are 

investigated 

No written process is in place that 

ensures that reported occurrences 

and deficiencies are being 

investigated. 

Process should be developed
DTW SMS Manual and Program 

Gap Analysis 18 

Item Status 

Action 

Required 

Reported occurrences 

and deficiencies are 

fully analyzed to 

contributing and root 

causes 

No formal process in place. Some 

occurrences and deficiencies are 

analyzed by the operations 

department, no root cause elements 

seem to be sought. 

A written process should be 

developed

Risk assessment 

process expressed in 

terms of probability of 

occurrence and level of 

exposure 

Although some risk assessment is 

being done mostly in reaction to 

events or reports but no formal 

structured process is in place to 

systematically identify and assess all 

risks. 

Develop a Risk Assessment 

Process. 

Risk evaluation criteria 

tolerable to the 

organization acceptable 

levels 

No formal criteria in existence Criteria will need to be 

developed in the risk 

assessment process. 

Risk control strategies 

that include corrective 

and preventive action 

plans 

No systematic process in place. Risk assessment process 

should include requirements for 

risk control strategies and 

provisions for corrective and 

preventive action plans.
DTW SMS Manual and Program 

Gap Analysis 19 

Item Status 

Action 

Required 

Risk mitigation 

Adequate resourcing to 

address identified 

safety concerns 

Unable to assess until SMS is 

implemented 

Communicate findings 

to staff and implement 

mitigation strategies 

14 CFR part 139 requires this for 

actions covered by regulation. 

The risk assessment process 

should provide for feedback to 

staff. 

Documentation of 

corrective and 

preventive actions 

Actions are documented. 

Risk tracking 

Evaluation of 

effectiveness of 

corrective and 

preventive measures 

No formal process in place, no 

evidence that this is being carried 

out. 

A process should be developed.
DTW SMS Manual and Program 

Gap Analysis 20 

Item Status 

Action 

Required 

SAFETY ASSURANCE 

Internal Audits 

Departmental audits 

performed to measure 

compliance with 

procedures and 

processes and meeting 

of safety goals and 

objectives 

Processes, goals and objectives are 

not in place, no internal audits are 

performed. 

Safety goals and objectives 

should be developed. A formal 

operational internal audit 

process should be developed.

Evaluation of short and 

long term effectiveness 

of safety actions 

No formal evaluation is carried out. Processes describing safety 

action plans should include 

evaluation of their short and long 

term effectiveness.

Periodic review of the 

organization’s safety 

performance and 

achievement including 

SMS. 

SMS not in yet place. Formal system review process 

to be developed.
DTW SMS Manual and Program 

Gap Analysis 21 

Item Status 

Action 

Required 

External Audits 

External audits 

conducted as part of 

the independent 

organization safety 

oversight 

Part 139 Audits are conducted by the 

FAA 

A process should be developed 

to address external audits of the 

Safety Management System.

Corrective Action 

Corrective action plans 

to resolve findings 

ensuing from audit 

reports 

Corrective action is taken following 

FAA audit reports as per an 

established procedure. 

Corrective action plans following 

SMS audits should be 

established in a documented 

process.

Documentation 

Identification of 

regulatory requirements 

procedure documented 

and maintained 

No database or formal process 

established. 

A process will need to show how 

regulatory requirements are 

being identified.
DTW SMS Manual and Program 

Gap Analysis 22 

Item Status 

Action 

Required 

Periodic review of 

regulations, standards 

and exemptions 

No formal process in place. Development of a process which 

will ensure that the organization 

is kept up to date on regulations, 

standards and exemptions 

regarding safety issues.

SMS and the 

interrelationship 

between all of its 

elements are described 

in a consolidated 

document. 

SMS not in yet place. SMS manual to be developed.

SMS manual to be 

incorporated by 

reference into approved 

documentation 

SMS not in yet place. The SMS manual to be 

incorporated by reference in the 

Airport Certification Manual if 

regulatory requirements 

warrants.

Records system that 

ensures the generation 

and retention of all 

records necessary to 

document and support 

operational 

requirements. 

Records system meets FAR 139 

requirements. 

The system will need to be 

complemented to meet all of 

SMS documentary 

requirements.

Records system 

provides control 

processes necessary to 

ensure appropriate 

identification, legibility, 

storage, protection, 

archiving, retrieval, 

retention time, and 

disposition of records. 

There are no control processes. 

Maximo is an airport maintenance 

system. IT controls the database. 

Airfield maintenance is excluded. 

However a system of checks and 

balances is in place. 

Process to be developed. 
DTW SMS Manual and Program 

Gap Analysis 23 

Item Status 

Action 

Required 

Quality Assurance 

Establishment of a 

quality assurance 

system 

No evidence was found that a quality 

assurance system is in place. 

SMS requires a comprehensive 

quality assurance function 

covering all SMS elements will 

need to be developed and 

established.
DTW SMS Manual and Program 

Gap Analysis 24 

Item Status 

Action 

Required 

SAFETY PROMOTION 

Culture 

All employees are 

responsible for safety 

Perception is present. Will further develop within a 

safety culture.

 

Top management leads 

by example 

Varies with individual manager. 

Employees fully trust 

they have management 

support 

This aspect of the safety culture is 

perfectible. 

Employees understand 

that intentional safety 

breaches will not be 

tolerated 

Well understood. 

There is a non-punitive 

environment for 

reporting safety issues 

No program in place. Program to be drafted, 

consultation with labour leaders 

conducted and employees well 

educated on processes 

involved.
DTW SMS Manual and Program 

Gap Analysis 25 

Item Status 

Action 

Required 

Training 

Process to identify 

training requirements 

For OSHA, there is a “Training 

Circle” which identifies where staff is 

going to work, and training required. 

Process to identify other training 

requirements is not documented. 

Airfield Operations keeps training 

records. 

A formal process for SMS 

training to be developed.

Training includes initial, 

recurrent and update 

training 

Current training programs include 

those requirements. 

SMS training programs should 

model after them.

SMS training 

incorporated in 

indoctrination training 

on employment 

 This is to be included in the 

SMS training process.

There is emergency 

preparedness and 

response training for 

affected personnel 

ACM section 325 refers. Personnel 

are trained within their respective 

administrative units. 

All emergency responding groups are 

coordinated through the Airport 

Emergency Management Division. 

Annually these groups come together 

for either a tabletop or live exercise 

to test emergency response and the 

cooperation among operational units. 

A review of the emergency 

preparedness training processes 

should be undertaken.

Validation of training 

effectiveness 

Emergency Management Division 

has written critiques of all training 

exercises. 

Process to be developed. 
DTW SMS Manual and Program 

Gap Analysis 26 

Item Status 

Action 

Required 

Initial (general safety) 

job-specific training 

Training is OSHA oriented. Program should be modified to 

include SMS issues

Human and 

organizational factors 

included in training 

requirements 

Not included. Process to be developed.

Organization’s safety 

philosophy, policies, 

procedures and 

practices understood 

No formal process in place to 

corroborate. 

Process to be developed.

Personnel have 

knowledge of their role 

and responsibilities in 

SMS framework 

 Formal process to be developed 

that will verify this requirement.

Communication 

Safety goals and 

procedures 

communicated to 

employees 

 Safety goals and procedures to 

be developed and 

communicated to employees. 

Processes to achieve this are to 

be initiated.

Communication to 

affected employees 

safety analysis results 

associated with new 

operational procedures 

OSHA safety analysis information is 

provided to all division managers by 

the Airport Safety Manager on a 

monthly basis. 

Need for development of such a 

process to ensure 

communication to affected 

employees of results of safety 

analysis of safety-critical 

systems.

Communication of SMS 

development, 

implementation and 

 Processes to be developed to 

ensure proper communication to 

all affected staff – Part of Safety 
DTW SMS Manual and Program 

Gap Analysis 27 

Item Status 

Action 

Required 

updated status on 

elements 

Manager role and 

responsibilities.

Broad distribution of 

documents on lessons 

learned, safety 

investigations results, 

case history and 

experience 

 Processes to be developed to 

ensure proper distribution of 

material from internal and 

external sources to all affected 

staff – Part of Safety Manager 

role and responsibilities.

Safety seminars Yearly runway incursion seminar is 

conducted. 

Other proposed seminar 

subjects should be evaluated in 

safety committees.

Safety letters, notices 

and bulletins 

Posters are distributed. Other means involving wide 

distribution should be evaluated.

Dissemination of 

lessons-learned 

Incorporated in training. 

Use of bulletin boards, 

drop boxes, web-site 

and e-mail 

Bulletin Boards are in use. Other means to be developed.

Exchange of safetyrelated information with 

other airport operators 

 There are professional 

organizations that could be 

solicited (ACI, f) to establish a 

forum to exchange safety 

related issues and concerns.

Monitoring of the 

effectiveness of the 

communication process 

 A process to be developed to 

evaluate the communication 

process effectiveness.

3.2 Operational Procedural Gap Analysis 
DTW SMS Manual and Program 

Gap Analysis 28 

3.2.1 Background 

The team developed and conducted a survey to determine current operational practices, 

procedures, and programs that could be used as a basis for an airport SMS. The IATA/JDA 

Team met with staff from the Airport to identify current Standard Operating Procedures and 

Programs. The schedule of interviews is attached as Appendix B. A checklist was developed 

to examine a number of components that focus on the Airports Part 139 certification including: 

- Identification of Advisory Circulars that WCAA may be following in order to meet Part 

139. 

- Identification of operational activities that go above and beyond the requirements of 

an Advisory Circular or Part 139 (as it relates to Part 139 only). 

- Identification of and verification the locations of training records, and who maintains 

the records as specified in Part 139 (139.301). 

- Identification of and verification that those personnel are trained per the requirement 

in Part 139.303 as it relates to Part 139. 

- Identification of how WCAA Operations comply with Part 139.305 – Part 139.311. 

- Identification of any safety issues that may not be included in the WCAA Snow and 

Ice Removal plan as it pertains to part 139. 

- Identification of any safety gaps on firefighter operations. 

- Identification of who are all the approved Certificate Holders at WCAA who receive 

hazardous cargo at WCAA. Verify how those Certificate Holders comply with Part 

139.321. 

- Verification of how WCAA complies with Part 139.323. 

- Verification that the emergency action plan is current per Part 139. Verify that 

personnel are trained as required per Part 139.325 

- Verification that there are procedures for the Self-Inspection Plan per Part 139.327. 

- Verification that compliance with Part 139.329 as it relates to ground vehicles in 

movement areas. 

- Verification that WCAA complies with its Wildlife management plan as it relates to the 

safety of the flying public per Part 139.337. 

- Verification of airport condition reporting procedures as it relates to Part 139.339. 

- Verification of marking and lighting procedures during construction is in compliance 

within Part 139.341 

- Identification of how non-compliance procedures are reported. 

3.2.2 Advisory Circulars 

The Operational gap analysis includes an identification of Advisory Circulars that WCAA may 

be following in order to meet Part 139. The identified Advisory Circulars are listed in the 

following table: 

Advisory Circulars relating to Part 139 

Ref AC Number AC Title 

139.201 150/5210-22 Airport Certification Manual (ACM) 

150/5380-6B Guidelines and procedures for maintenance of airport

pavement 

139.305 

150/5380-7A Airport pavement management program 

139.311 150/5340-1J Standards for airport markings 

 150/5370-2E Operational safety on airports during construction 
DTW SMS Manual and Program 

Gap Analysis 29 

Advisory Circulars relating to Part 139 

Ref AC Number AC Title 

139.309 150/5300-13 Airport design 

150/5220-22A Engineered Materials Arresting Systems (EMAS) for

aircraft overruns 

139.313 150/5200-30B Airport winter safety and operations 

150/5210-6D Aircraft fire and rescue facilities and extinguishing

agents 

139.317 

150/5220-10D Guide specification for aircraft rescue and fire fighting

vehicles 

139.311 150/5340-26A Maintenance of airport visual aid facilities 

139.311 150/5340-30C Design and installation details for airport visual aids 

139.327 150/5200-18C Airport safety self-inspection 

 150/5200-28D Notices to Airmen (NOTAMS) for airport operators 

139.325 150/5200-31A Airport emergency plan 

150/5200-32A Reporting wildlife aircraft strikes 

150/5200-33B Hazardous wildlife attractants on or near airports 

139.337 

150/5200-36 Qualifications for wildlife biologist conducting wildlife

hazard assessments and training curriculums for airport

personnel involved in controlling wildlife hazards on

airports 

 150/5200-37 Introduction to Safety Management Systems (SMS) for

airport operators 

 150/5210-5C Painting, marking, and lighting of vehicles used on an

airport 

 150/5210-7C Aircraft rescue and firefighting communications 

139.317 150/5210-14A Airport fire and rescue personnel protective clothing 

139.319 150/5210-17A Programs for training of aircraft rescue and firefighting

personnel 

139.319 150/5210-18 Systems for interactive training of airport personnel 

 150/5210-20 Ground vehicle operations on airports 

139.317 150/5220-4B Water supply systems for aircraft fire and rescue

protection 

 150/5230-4A Aircraft fuel storage, handling, and dispensing on

airports 

 150/5320-15 Management of airport industrial waste 

139.311 150/5340-18D Standards for airport sign systems 

 150/5380-5B Debris hazards at civil airports 

121-27 Guide for Air Carriers, Freight Forwarders, and

Shippers in Obtaining Information Dealing with the

Transportation of Hazardous Materials by Air 

139.321 

121-38 Reporting Hazardous Materials Discrepancies to the

Federal Aviation Administration 
DTW SMS Manual and Program 

Gap Analysis 30 

Advisory Circulars relating to Part 139 

Ref AC Number AC Title 

121-37 Voluntary Disclosure Reporting Program - Hazardous

Materials 

139.323 150/5345-27D Specification for wind cone assemblies

150/5340-5C Segmented circle airport marker system

139.341 AC70/7460-1K Obstruction Marking and Lighting 
DTW SMS Manual and Program 

Gap Analysis 31 

4. Findings 

4.1 Compliance with FAR Part 139 

Operational practices, procedures, and programs at the Detroit Metro airport were found to 

comply with all FAR 139 requirements. This is further confirmed by the FAA inspections of 

December 2006 and December 2007 which found no discrepancies with FAR Part 139. SMS 

requires that an organization ensures it meets all regulatory requirements; therefore WCAA 

already meets this criterion. 

4.2 Records and documentation 

There are comprehensive records of all required training. These are held by various 

departments. Usually, the department responsible for carrying out the training holds records. 

Records may be either both in hard copy or electronic format. 

SMS implementation will require Safety Training which will have to be documented in 

individual training files. WCAA will have to determine whether the existing systems of training 

records will be augmented with safety training or if a more comprehensive method of 

maintaining training records should be implemented. 

There are presently no written procedures for the management of training records (Filing, 

access and privacy issues, management of semi-active or inactive records; storage, 

inventories, and destruction). The existing record management processes will have to be 

documented, reviewed and standardized as necessary. 

Some operational processes are not documented while others have documentation which 

does not meet SMS requirements (self-inspection, snow and ice control, access control of 

pedestrians and ground vehicles). SMS requires that all safety-critical processes be reviewed 

to ensure their adequacy and that the following items be documented: 

- Identification and coordinates of responsible agencies 

- Responsibilities for the process 

- Regulatory and internal requirements 

- Description of the process (checklists, tables, reference documents) 

- List and description of equipment used 

- Description of facilities being inspected or used 

- Training requirements 

- Any applicable emergency procedures 

- Identified Hazards and Risks 

- Quality Assurance procedures 

4.3 Quality Assurance 

We did not find any evidence of any structured quality assurance function. External auditing is 

carried out by the FAA, but there is no internal audit of operational systems and procedures. 

This component of SMS will therefore have to be developed in its entirety. 

4.4 Reporting 
DTW SMS Manual and Program 

Gap Analysis 32 

The existing reporting system is reactive in nature: Accident or incident reports are completed 

by the responding officers (usually from Airfield Operations) and an accident/incident 

investigation team (from Public Safety) does the report. Incidents and infractions to airport 

traffic regulations result in disciplinary action. 

The existing reactive process will have to be reviewed to ensure investigations identify the 

root causes of any incident and track any recommended remedial action. Investigators will 

have to be trained for that purpose and responsibilities assigned for monitoring of remedial 

actions. The safety policy will have to narrow down and define the circumstances which may 

result in disciplinary action. 

A proactive non-punitive reporting process will have to be developed and implemented. The 

airport condition reporting process is documented (ACM section 339) and can be integrated 

into the future SMS. There should however be a regular review of issued NOTAM as part of 

the QA program to be developed. 

4.5 Wildlife Hazard Management Plan (WHMP) 

The WHMP is well-documented, training is carried out annually, and the plan is reviewed on 

an annual basis. This plan can be easily integrated in its present form into the future SMS. 

4.6 Emergency Planning 

The Emergency Plan (Section 325 and Exhibit 13 of the Airport Certification Manual) was 

checked against the Emergency Plan Review Checklist included in AC No: 150/5200-31A and 

found satisfactory (Appendix C). This plan can be integrated into the future SMS, however 

there should be a review of all emergency training carried out at WCAA to ensure it is 

complete and avoid any potential overlap. 

There are presently a number of plans dealing with various emergencies: 

1. Part 139 

2. Significant incident response plan (similar but outside scope of 139) 

3. Emergency command centre procedures 

4. Water emergency plan (facilities) 

5. Snow emergency plan (airfield operations) same as snow and ice control plan 

6. Evacuation plan 

7. Family assistance plan (in collaboration with the airlines) 

8. Family assistance center 

9. Passenger reception center 

10. Unification center 

The SMS implementation plan should include a review of all emergency plans with a view to 

integrate and simplify them as much as possible. There should also be a documented 

process for the review and coordination of all emergency plans. 

5 Conclusions and recommendations of operational 

gap analysis 

WCAA is fully compliant with FAR Part 139. 
DTW SMS Manual and Program 

Gap Analysis 33 

Processes required ensuring compliance with Part 139 safety requirements are in place but 

need to be fully documented in order to conform to an effective SMS. 

This could be done by identifying, reviewing and documenting existing safety-critical 

processes within the scope of the WCAA SMS. Quality assurance procedures must be 

developed to ensure processes are consistently carried out according to instructions and 

procedures reviewed regularly to adapt to the airport’s changing environment. 

A proactive reporting system should be implemented to complement the existing reactive 

reporting system. The reporting system should be non-punitive in nature to foster a free flow 

of information. 

Accident/incident investigators should be trained to identify root causes and 

recommendations to prevent reoccurrences should be tracked to ensure they are applied 

consistently and that they are effective. 
DTW SMS Manual and Program 

Gap Analysis 34 

Appendix A: Literature Review 

CAP 642 

Airside Safety Management 

28 Feb 2003 

© Civil Aviation Authority 2003 

ISBN 0 86039 909 5 

CAP 726 

Guidance for Developing and Auditing a Formal Safety Management System 

© Civil Aviation Authority 2003 

ISBN 0 86039 910 9 

Issue 1, 28 March 2003 

CAP 728 

The Management of Safety 

Guidance to Aerodromes and Air Traffic Service Units on the Development of Safety 

Management Systems 

© Civil Aviation Authority 2003 

ISBN 0 86039 912 5 

Issue 1, 28 March 2003 

CAP 729 

Guidance on Aerodrome Development Procedures 

© Civil Aviation Authority 2003 

ISBN 0 86039 941 9 

First Edition: 28 March 2003 

AC 139-16(0) March 2005 

Australian Civil Aviation Safety Authority 

Developing a safety management system at your aerodrome 

Department of defense standard practice for system safety 

MIL-STD-882D 

10 February 2000 

Guidelines to a systematic management of safety on aerodromes 

WP 093 

JAA 

AC No.: 300-002 

Transport Canada

Safety Management System Implementation Procedures for Airport Operators

31 Dec 2007 

Safety Management System for Aerodromes (SMS)

ADV Concept proposal 

4 Sep 2002 

Risk Management and Decision-Making in Civil Aviation

TP 13095 

Transport Canada 

1 April 2001 
DTW SMS Manual and Program 

Gap Analysis 35 

Introduction to Safety Management systems 

TP 13739 

Transport Canada 

March 2001 

Safety Management System Assessment Guide 

TP 14326 

Transport Canada 

May 2005 

Safety Management Manual 

ICAO 

Doc 9859 AN/460 

Safety Management Systems for Airports 

Volume 1: Overview 

Airport Cooperative Research Program 

2007 

FAA System Safety Handbook 

December 30, 2000 

Airport Risk Assessment: Examples, Models and Mitigations 

John Spriggs 

Roke Manor Research Limited 

February 2002 

Aerodrome Certification Manual 

ICAO 

Doc 9774 

2001 

Safety Management System, a Practical Initial Approach 

Eurocontrol/JAA Runway Incursion Task Force 

GASR WP 092 

June 2002 

Reducing Accidents and Improving Safety on the Ramp 

Airport Operations Safety Panel 

NTSB 

June 15, 2004 

Safety Management System (SMS) Pilot Study Participant’s Guide 

FAA Office of Airport Safety and Standards 

Airport Certification Program 

April 6, 2007 
DTW SMS Manual and Program 

Gap Analysis 36 

Appendix B: Schedule of Interviews 
Appendix B: GAP Analysis Interview Schedule

Session Time Location

Steering 

Committee

Chris 

Kaminski

Denine 

Alfaro 

Sandy 

Altshul Dan Aman

Sean 

Brosnan 

Craig 

Carnell 

Linda 

Cox

Angela 

Croft

Gary 

Dust

David 

Garrett 

Alex 

Gonzolez

Bruce 

Greenberg Jamie Hinosa

Ron 

Keesee

Matt 

Lefluer 

Joe 

Macabe

Tim 

McDona

Monday, March 17thSMS Introductory Training Session #1 1:00-4:00pm LC Smith Large Training RoomTuesday, March 18thSMS Introductory Training Session #2 9:00-noon Building 703 Training Room

Policy Statement/Organizational Structure 12:30 - 2:00pm (Lunch Provided) Building 703 Training Room x x 

Traffic and Wind Socks (139.323), Wildlife Hazard (139.337) & Mitigation and Aircraft Index (139.315) 2:00 pm- 3:00 pm Building 703 Training Room x x 

Internal Audits and Pedestrians/Ground Vehicles (139.329) 3:00-4:00pm Building 703 Training Room x X 

Wednesday, March 19thTraining, Communications and Records 8:30-10:00am Building 703 Training Room x x x xx 

Safety Risk Management, Hazard Identification, Risk Assessment, Risk Mitigation and Risk Tracking noon -2:00pm (Lunch Provided) Building 703 Training Room x x x x x 

ARFF (139.317) and HAZMAT (139.321) 2:00-3:00pm Building 703 Training Room x x

Emergency Action Plan (139.325) 3:00-4:00pm Building 703 Training Room x xx x

Non-Compliance (139.343) 4:00-4:30pm Building 703 Training Room x x

Thursday, March 20thCorrective Action, Documentation, External Audits and Quality Assurance 9:00-10:00am LC Smith Conference Room #4 x x x xxx 

Proceedures, Safety Objectives, Culture 10:00 - 11:00 am LC Smith Conference Room #4 x Construction (139.341) & Paved Areas (139.305) 1:00-2:00pm LC Smith Conference Room #4 x x 

Personel (139.303) 2:00-2:30pm LC Smith Conference Room #4 x x 

Self Inspection (139.327) 2:30-3:00pm LC Smith Conference Room #4 x x 

Verify Operational Requirements (139-319) 3:00-3:30pm LC Smith Conference Room #4 x x Condition Reporting (139.339) 3:30-4:00pm LC Smith Conference Room #4 x 

Markings, Signage & Lighting (139.311) and Snow & Ice Control (139.313) 4:00-4:30pm LC Smith Conference Room #4 x xx x x x x 1/ Required for first hour (10:00-11:00am)

Attendees
DTW SMS Manual and Program 

Gap Analysis 37 

Appendix C: DTW Airport Emergency Plan Review Checklist 

Ref: AC No: 150/5200-31A 

Item Page Ref. S U Remarks 

I. Aircraft Incidents and Accidents 

A. Plans 

1. Largest air carrier type Section 315 

ACM 

S Boeing 747-400 

2. Identification of response agencies/personnel 

a) Hospitals/Medical Facilities Para I, page 7 S Wayne County 

Homeland and 

Emergency 

Management Division 

(1) Name Pages 42 & 43 S 

(2) Location Pages 42 & 43 S 

(3) Telephone # Pages 42 & 43 S 

(4) Emergency capacity S In triage kit on the 

rescue equipment 

b) Medical personnel (doctors, nurses, etc.) 

(1) Business Address Page 42 S Location 

(2) Telephone # Page 42 S 

c) Rescue squad, ambulance service, military 

installation, government agency 

 

(1) Name Page 43 S 

(2) Location Page 43 S 

(3) Telephone # Page 43 S 

d) Law Enforcement Page 44 S 

e) Rescue and Firefighting 

(1) Name ARFF S 

(2) Location DTW S 

(3) Telephone # Page 8 S ETS 

f) Principal tenants (including air carriers and 

Control Tower) 

 

(1) Name Page 45 S 

(2) Telephone # Page 45 S 

g) Equipment inventory 

(1) Surface vehicles/aircraft to transport injured/ 

deceased 

Page 46 S 

(2) Hangars/buildings to accommodate 

uninjured, and deceased 

Page 46 S 

h) Removal of disabled aircraft agencies 

(responsibilities or capabilities) 

 

(1) Name Page 46 S 

(2) Location Page 46 S 

(3) Telephone # Page 46 S 

i) Agreements Page 8 S Mutual aid, in fire chief 

office and emergency 

mgt 

j) Communications network Page 8 S Emergency Telephone 

System (ETS) 

k) Plan Coordination S Emergency 
DTW SMS Manual and Program 

Gap Analysis 38 

Item Page Ref. S U Remarks 

management director 

reports to VP Operation 

l) Plan development S Emergency 

management director 

reports to VP Operation 

B. Procedures 

1. Injured and uninjured accident survivors 

a) Marshaling D Page 23 and 

24 

S 

b) Transportation D Page 23 and 

24 

S 

c) Care D Page 23 and 

24 

S 

2. Removal of disabled aircraft Page 35 S 

3. Emergency alarm systems Page 22 ACM S 

4. Airport/Control Tower emergency action 

coordination 

Para IV page 8 S 

5. Notification of support agencies of an aircraft 

accident 

 

a) Hospitals/Medical facilities Para 8 page 20 S 

b) Medical personnel Para 8 page 20 S 

c) Rescue squad, ambulance services, military 

installation, government agency 

Para 8 page 20 S 

d) Crowd control agencies Para 12 page 

20 

S 

e) Disabled aircraft removal agencies XIX page 35 S 

6. Water rescue 

a) Sufficient water rescue vehicles P 34 

S 

 Metro Airport Water 

Rescue Team (MAWRT) 

7. Triennial full scale exercise S August 2007 

Tabletop annual 

II. Bomb Incidents 

A. Plans 

1. Designated parking area Exhibit 13 S 

2. Identification of response agencies/ personnel 

a) Law Enforcement 

(1) Name Page 27 S 

(2) Location Page 27 S 

b) Rescue and firefighting 

(1) Name Pages 26 & 27 S 

(2) Location Pages 26 & 27 S 

(3) Telephone # Pages 26 & 27 S 

c) Principal tenants (including air carriers and 

Control Tower) 

 Web site 

(1) Name 

(2) Telephone # 

(1) Surface vehicles/aircraft to transport 

injured/deceased 

 Ambulances (44 

communities) and 

private compagnies 

(2) Hangars/buildings to accommodate 

uninjured, injured, and deceased 

 Nomads hangar 

e) Agreements Page 8 S 
DTW SMS Manual and Program 

Gap Analysis 39 

Item Page Ref. S U Remarks 

f) Communications Network 

III. Structural Fires 

A. Identification of response agencies / 

personnel 

 

1. Law enforcement 

a) Name 

b) Location 

2. Rescue and firefighting 

a) Name Page 29 S 

b) Location Page 29 S 

c) Telephone # Page 29 S 

5. Agreements Page 8 S 

IV. Natural Disasters 

A. Plans 

1. Identification of response agencies / personnel Page 29 S 

a) Law enforcement 

b) Name 

c) Location 

a) Name 

b) Location 

c) Telephone # 

5. Agreements Page 8 S 

V. Hazardous Materials 

A. Plans XIII page 29 

1. Identification of response agencies / personnel 

a) Law enforcement Page 29 S 

b) Name Page 29 S 

c) Location Page 29 S 

2. Rescue and firefighting 

a) Name Page 29 S 

b) Location Page 29 S 

c) Telephone # Page 29 S 

3. Principal tenants (including air carriers and 

Control Tower) 

 

a) Name Page 29 S 

b) Telephone # Page 29 S 

5. Agreements Page 8 S 

6. Communications network Page 29 S 

VI. Sabotage, hijack incidents, and other 

unlawful interferences with operations 

XIV and XV 

page 30 

 

A. Plans 

1. Identification of response agencies / personnel 

a) Law enforcement Page 30 S 

b) Name Page 30 S 

c) Location Page 30 S 

2. Rescue and firefighting 

a) Name Page 30 S 

b) Location Page 30 S 

c) Telephone # Page 30 S 

5. Agreements Page 8 S 

6. Communications network Page 31 S 

B. Procedures 
DTW SMS Manual and Program 

Gap Analysis 40 

Item Page Ref. S U Remarks 

VII. Failure of power for movement area lighting XVII Page 33 S 

A. Plans XVII Page 33 S 

B. Procedures XVII Page 33 S 

VIII. Water Rescue Situations XVIII Page 33 

A. Plans Pages 33 to 35 S 

B. Procedures Pages 33 to 35 S 

IX. Crowd Control XVI page 33 S 

A. Plans XVI page 33 S 

B. Procedures XVI page 33 S