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 CopyDTW 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
ApprovedDTW 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 evalua te 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 provi de 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 20 th 

## March
Two introductory SMS training sessions were held. The first session took place on Monday 17 th 

### March at 1:00 pm, and the second session on Tuesday 18 March at 9:00 am. The SMS training session partici pants from WCAA were as shown in the following table.

Name Department Monday 17 th March 2008 Debra Seig Public Safety Matt LaFleur Airfield Operations Bruce Greenberg Airfield Operations Ken Szymanski –Airfield Operations Chris Kaminski Risk Management Tuesday 18 th March 2008 Mary C. Walker Fleet Maintenance trainingDTW 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 18 th , 19 th , and 20 th . WCAA personnel participating in the interviews were as shown in the following table:

Name Department Tuesday 3/18/2008 – Policy Stat ement/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 MaintenanceDTW 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 MaintenanceDTW 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 inte rviews 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, safe ty risk management, safety assurance, and safety promotion) that are pa rt 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 PromotionDTW 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 inestablishing 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 PolicyDTW 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 andDTW 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 developedDTW 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 SafetyDTW 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 AnalysisDTW 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 Wi ldlife 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 airpor t 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 constructionDTW SMS Manual and Program Gap Analysis 29 

### Advisory Circulars relating to Part 139 Ref AC Number AC Title 150/5300-13 Airport design 139.309 150/5220-22A Engineered Materials Arresting Systems (EMAS) fo r aircraft overruns 139.313 150/5200-30B Airport winter safety and operations 150/5210-6D Aircraft fire and rescue facilities and extinguishin g agents 139.317

150/5220-10D Guide specification for aircraft rescue and fire fightin g 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 wildlif e hazard assessments and training curriculums for airpor t personnel involved in controlling wildlife hazards o n airports 150/5200-37 Introduction to Safety Management Systems (SMS) fo r airport operators 150/5210-5C Painting, marking, and lighting of vehicles used on a n 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 firefightin g 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 rescu e protection 150/5230-4A Aircraft fuel storage, handling, and dispensing o n 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, an d Shippers in Obtaining Information Dealing with th e Transportation of Hazardous Materials by Air 139.321

121-38 Reporting Hazardous Materials Discrepancies to th e Federal Aviation AdministrationDTW SMS Manual and Program Gap Analysis 30 

### Advisory Circulars relating to Part 139 Ref AC Number AC Title 121-37 Voluntary Disclosure Reporting Program - Hazardou s Materials
150/5345-27D Specification for wind cone assemblies 139.323
150/5340-5C Segmented circle airport marker system 139.341 AC70/7460-1K Obstruction Marking and LightingDTW SMS Manual and Program Gap Analysis 31



# 4. Findings

4.1 Complia nce 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 dete rmine 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 ReportingDTW 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 re viewed 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 res ponsibilities 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 Manage ment 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 recomm endations 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 orde r 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 implemen ted 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 2001DTW 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, 2007DTW SMS Manual and Program Gap Analysis 36 

## Appendix B: Schedule of InterviewsAppendix B: GAP Analysis Interview ScheduleSession Time LocationSteeringCommitteeChrisKaminskiDenineAlfaroSandyAltshul Dan AmanSeanBrosnanCraigCarnellLindaCoxAngelaCroftGaryDustDavidGarrettAlexGonzolezBruceGreenberg Jamie HinosaRonKeeseeMattLefluerJoeMacabeTimMcDonaldMikeEvansMaryMuhammadMary LouPosaLyndaRacey Joe ReinnaTomSnellLeighStepaniakKenSymanskiBryanWagonerMaryWalkerSteveWiesnerBarbaraWhiteKevinWickGary Ancinec(FAA ATC)Dave Welhouse(FAA ADO)Monday, March 17thSMS Introductory Training Session #11:00-4:00pm LC Smith Large Training RoomTuesday, March 18thSMS Introductory Training Session #29:00-noon Building 703 Training RoomPolicy Statement/Organizational Structure12:30 - 2:00pm (Lunch Provided) Building 703 Training Roomx xx xTraffic and Wind Socks (139.323), Wildlife Hazard(139.337) & Mitigation and Aircraft Index (139.315)2:00 pm- 3:00 pm Building 703 Training RoomxxxInternal Audits and Pedestrians/Ground Vehicles(139.329)3:00-4:00pm Building 703 Training Roomx Xx xWednesday, March 19thTraining, Communications and Records8:30-10:00am Building 703 Training Roomx x x xxx xxSafety Risk Management, Hazard Identification, RiskAssessment, Risk Mitigation and Risk Trackingnoon -2:00pm (Lunch Provided) Building 703 Training Roomx x x x x x 1/ x x x xARFF (139.317) and HAZMAT (139.321)2:00-3:00pm Building 703 Training Roomx xxxEmergency Action Plan (139.325)3:00-4:00pm Building 703 Training Roomx xx xNon-Compliance (139.343)4:00-4:30pm Building 703 Training RoomxxThursday, March 20thCorrective Action, Documentation, External Audits andQuality Assurance9:00-10:00am LC Smith Conference Room #4xx x xxxx xProceedures, Safety Objectives, Culture10:00 - 11:00 am LC Smith Conference Room #4xxConstruction (139.341) & Paved Areas (139.305)1:00-2:00pm LC Smith Conference Room #4xxx xPersonel (139.303)2:00-2:30pm LC Smith Conference Room #4x xxSelf Inspection (139.327)2:30-3:00pm LC Smith Conference Room #4x xx xVerify Operational Requirements (139-319)3:00-3:30pm LC Smith Conference Room #4x xx xCondition Reporting (139.339)3:30-4:00pm LC Smith Conference Room #4xxxMarkings, Signage & Lighting (139.311) and Snow & IceControl (139.313)4:00-4:30pm LC Smith Conference Room #4x xx x x x x x1/ Required for first hour (10:00-11:00am)AttendeesDTW SMS Manual and Program Gap Analysis 37 

## Appendix C: DTW Airport E mergency 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 EmergencyDTW 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 SDTW 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. ProceduresDTW 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