# Austin-Bergstrom International Airport

Federal Aviation Administration

Safety Management System (SMS)

Pilot Program

GAP Analysis Findings

May 27, 2008

ABIA SMS GAP ANALYSIS REPORT

Prepared by: Jacobs Carter Burgess

Fort Worth, Texas

# Austin-Bergstrom International Airport (ABIA)

Gap Analysis Report

The FAA has identified select airports ac ross the United States to participate in

the Safety Management System Pilot Program (“SMS”) in an effort to develop a

nationwide standard and requisite regulation. The FAA has required all airports

participating in the SMS Pilot Study comple te a Gap Analysis as part of the SMS

developmental process. FAA guidance on the Gap Analysis directs the Gap

Analysis to identify procedures, policies, documentation and actions airports are

to implement as part of its SMS progr am extending beyond current Part 139

requirements identified in the airport’s Airport Certification Manual (ACM).

Airports today must balance many shar ed challenges including safety, security,

financial, and human resources. Those cha llenges, individually and collectively,

generate simultaneous high priorities that demand airport management teams

balance in an effective manner. The devel opment and implementation of a Safety

Management System in today’s airports mu st be tailored to the operational needs

and resources available at that airport. The development of a SMS Program

must utilize available resources and workload while meeting the intent of SMS

and Safety Risk Management (SRM) principles.

The Austin-Bergstrom Inter national Airport (ABIA), located in Austin, Texas, was

one of the airports selected by the FAA to participate in the SMS Pilot Program.

ABIA (Department of Aviati on, “DOA”) is a department wit hin the City of Austin

and thereby interacts as a functionar y of city government with the DOA

maintained under an Executive Director. Both the Executive Director and

Aviation Director expressed their commitment to safety improvements, which was

their impetus for the application to the SMS Pilot Progr am. ABIA has an

outstanding safety record and a resolve to improve their safety and quality

management process. They welcome the Gap Analysis and the continued

development and implementation of their SMS Pr ogram and Manual.

The purpose of the GAP Analysis is to document existing gaps or deficiencies in

the airport’s procedures, policies, doc umentation and actions existing between

current operations outlined in the ACM as co mpared to the principles identified in

the SMS. There are twenty- one (21) basic elements incorporated in to the SMS

Manual and Program in the SMS Pilot Study Participants Guide.

ABIA SMS GAP ANALYSIS REPORT

Prepared by: Jacobs Carter Burgess

Fort Worth, Texas

# The FAA published a requirement that the SMS Manual and program should

“....identify which elements of the airport operator’s existing practices and

guidance materials currently meet SM S requirements, which elements do not,

and how these latter practices and documents will be revised in the future for

consistency with the SMS Pl an”. Three classifications have been selected to

identify to what degree existing SMS el ements meet requirements. The three

classifications are defined as follows:

1. “Existing” (E) – currently in existence and in use.

2. “In Progress” (IP) – ei ther in process of being developed, or in process of

being implemented.

3. “GAP” (G) – there is no existing policy or procedure currently in place.

A few elements have a multi-classification due to differing areas of

responsibilities and procedures and are so noted. Discrepancies not pertinent to

the GAP Analysis will be discussed under separate cover as specific

recommendation to ABIA airport.

In order to conduct the analysis, ther e must be identified benchmarks and best

practices learned from interviews, su rveys, and analysis, which will then be

compared to the four elements of SMS:

• Safety Policy and Objectives

• Safety Risk Management

• Safety Assurance

• Safety Promotion

The Gap Analysis performed at ABIA compar es ABIA’s current status relative to

the 21 elements of the SMS Manual and Program in the SMS Pilot Study

Participants Guide. A complete analysis was performed by comparing both the

ACM and Part 139 to the 21 tenants of SMS i dentified by the FAA. Presented is

a checklist in worksheet format along with a narrative summary of how ABIA’s

procedures relate to the 21 elements.

The ACM was reviewed by subject and compared to Part 139 and SMS

requirements. Then, Part 139 was re viewed and compared by line item to

existing conditions and requirements. The organization and layout of the

worksheets were designed to facilitate and crosscheck the assessments for the

Gap Analysis and to provide a basis fo r the foundation and dev elopment of the

SMS Manual. Methods utilized for determi ning status and existing conditions

were interviews, document reviews, and observations at ABIA.

ABIA SMS GAP ANALYSIS REPORT

Prepared by: Jacobs Carter Burgess

Fort Worth, Texas

# SMS GAP ANALYSIS SUMMARY - ABIA

The following is a summary of the GAP A nalysis performed at t he Austin Bergstrom

International Airport. This summary corre lates to the 21 elem ents of the Federal

Aviation Administration’s (FAA) Safety Management System (SMS) Manual and

Program, as identified in the FAA SMS Pilot Study Partici pants Guide, dated April 6,

2007. Those findings are as follows;

1) Written safety policy statement and communication plan

Status – GAP

Currently, there is no written safety policy or communication plan. Management is in

the process of reviewing a draft policy to reflect the best practices of SMS with

emphasis on a safety policy for the Avia tion division. A communication plan will be

developed later, as part of the SMS Safety Assurance Section, which will reflect the

organizational goals, objectives and operation.

2) Identification and description of the airport safety goals

Status

– GAP

Safety goals are presently referenced only in Airport Public Information publications.

There is no stated airport safety policy whic h reflects ABIA’s safety goals identified

and described in a written format although ABIA exhibits a strong commitment to

airport safety. As the over-all policy statement is formulated and implemented, it is

recommended that safety goals be expressed from both an operational viewpoint and

enveloped into the safety culture in a formalized document.

3) A plan for employee SMS indoctrination and training

Status – GAP

There currently is no employee SMS indoctrination and training program. SMS

training program curriculum required under SMS will be developed in the SMS

training section of the Safety Program Manual.

4) Documented process to identify training requirements for systems safety

Status – In Progress

ABIA currently has a training program which meets the requirement of Part 139 and

City of Austin policies and regulations. Additional recommendations were made to

assist with record keeping in movement area recurrent training. Training specific to

SMS will be further integrated in to new and existing programs.

5) A plan to validate training effectiveness and the process to gain training

feedback, including usable metrics

Status – In Progress

Airport Operations has limited measures currently in place to validate training

effectiveness through its record keeping functions. Additional measures for

effectiveness are recommended to be integrated into the SMS Manual as SMS is

developed and implemented.

ABIA SMS GAP ANALYSIS REPORT

Prepared by: Jacobs Carter Burgess

Fort Worth, Texas

# 6) A defined process to communica te safety policies and objectives

throughout the organization

Status – Existing

The Department of Aviation has developed current practices for promoting safety

awareness at all levels. Regular safety meetings are held resulting in detailed

debriefs posted on paper and electronically, as required. Safety bulletin boards are

posted in all main workplaces with newly installed safety/hazard reporting boxes

where employees can report safety concerns observed, even on an anonymous

basis. As the Non-Punitive Safety Reporting System is developed, further

enhancements will be integrated into existing safety communication methods and

practices.

7) A plan and description of employee Non-Punitive R e porting Systems,

existing and planned.

Status – GAP

There is currently no formalized Safety Reporting System in place. Several divisions

within the Department of Aviation currently utilize an informal, but successful safety

reporting policy. As SMS is developed and implemented, the Department of Aviation

will need to formalize and expan d their current system to a ddress the requirements of

the SMS program. ABIA’s primary emphasis and focus continues to be safety

reporting rather than ho w the non-punitive aspects of t he system will affect or protect

their employees.

8) An organizational chart identifying the names and safety responsibilities of

all key personnel such as the following: Top Management, Safety Manager,

Department Heads/Managers, Estab lished Safety Committees and Chairs.

Status – Existing

Multiple organizational charts exist with unclear titles and responsibilities which may

not accurately reflect current organizational structure. ABIA has not chosen to

specifically identify a single position or person titled “Safety Manager”. The

Operations Division currently does have an Operations Supervisor with many safety

responsibilities, some of which include operations safety, training, and the

coordination of joint monthly Safety Committee meetings. ABIA’s safety management

concept and procedures has developed beyond a traditional process of chain of

command reporting into an active process of incident command response. This

allows for immediate response and implementation of safety procedures and decision

making abilities by many personnel levels within the organization. ABIA is in the

process of developing an organizational chart that will clearly identify their

organizational lines of authority and responsibility, while simultaneously supporting

139 requirements.

9) Description of the safety risk manage ment process, including application of

“The Five Phases of SRM (Safety Risk Management)” as outlined in AC

150/5200-37, Introduction to Safety Management Systems for Airport

Operators.

Status – GAP

The Department of Aviation currently does not have existing policies and procedures

for the implementation of SRM and the Five Phases of SRM. As part of the pilot

program one will be developed and integrated into SMS.

ABIA SMS GAP ANALYSIS REPORT

Prepared by: Jacobs Carter Burgess

Fort Worth, Texas

# 10) Guidance on the use of SRM and trend analysis.

Status – GAP

Currently there is no guidance on the use of SRM, nor data being collected to allow

for development of trends or trend analysis. The ability to ascertain both short and

long term trend analysis of risk management will depend on the level of involvement

of management in the SRM process.

11) Defined process for documenti ng the results of SRM, including a

description of how documents will be stored, i.e., electronic or paper.

Status – GAP

As there is no SRM currently in effect, there is not a clearly defined process for

documenting the results of SRM, nor procedures identified for proper management of

records related to SRM.

12) Descriptions of how top manage ment will follow up on SRM to ensure

safety mitigation strategies are appropriate.

Status – GAP

Because there is no SRM in place there is no method currently established to ensure

safety mitigation strategies. The Department of Aviation will need to develop policies

and procedures for the implementation of SRM and the five phases of the SMS

program as the manual evolves. The Covey Strategic Management Process, which

has been successfully implemented at ABIA, would provide an excellent vehicle for

the development and implementation of SRM. By aligning SRM with “The Four

Disciplines of Execution”, a framework al ready in place, SMS can be painlessly

incorporated into current operations. These four disciplines involve: goals, metrics,

actions and accounta bility processes

13) A description of the airport quality management and/or risk management

program (if applicable) and its integration into the airport SMS.

Status – GAP

There is currently no airport quality management and/or risk management program.

As part of the SMS development process, the Department of Aviation will create a

Risk Management program as part of the SMS manual.

14) Description of a plan to integrate apron safety management into the airport

SMS.

Status – Gap

No apron safety management program currently exists. As part of the developing

SMS program, the recommendation has been made that ABIA include an apron

safety program into the implementation of SMS and Manual.

15) A detailed method to document sel f-auditing processes and their findings.

Status – Gap

Currently, there is no method or process in the Operations department for selfauditing in place. Although, no formalized self auditing process exists, ABIA has

resources (personnel, reporting systems, databases) in other parts of the Aviation

Department that currently performs audits in program areas such as Finance, Human

Resources and Information Resources. Currently, ABIA utilizes the Airport Security

ABIA SMS GAP ANALYSIS REPORT

Prepared by: Jacobs Carter Burgess

Fort Worth, Texas

# Operations Compliance System (ASOCS), for day to day airport conditions in

accordance with Part 139. The ASOCS program may contain performance measure

features which can have the capability to sort metrics and evaluate data to implement

measures and procedures for satisfying SMS requirements. The development of the

ABIA SMS Assurance Program could utilize the existing staff for this requirement.

Management has identified their interest and commitment to develop a self auditing

process which will comply and exceed Part 139.327. This program will be reviewed,

modified, and developed to support the SMS program.

16) A detailed method to document self-inspection reviews, analysis, and

findings.

Status – Existing

The documentation methods under Part 139 and the City of Austin are acceptable.

The development and implementation of SM S will enhance the existing reviews,

analysis, findings and documentation. As SMS develops, their current self inspection

program can be further modified to satisfy SMS requirements.

17) A description or plan to integrate the tailored SMS program plan into the

overall operation of the airport.

Status – GAP

There is no plan currently in existence to integrate an SMS program into airport

operations. The implementation and integrat ion of SMS will involve management/staff

decisions, with airport divisions assigned accountability and responsibility for various

safety actions.

18) Documented plan for training and education, safety communication,

competency, and continuous improvement process.

Status – In Progress

Currently, The Department of Aviation ha s documented training and education as

defined under Part 139. Additional enhancements will need to be developed and

implemented to meet the requirement of the SMS program and integrated into the

manual. Additional enhancements may include formalized procedures and consistent

processes throughout the organization in safety communication and safety risk.

These safety communication requirements may be best implemented through ABIA’s

Covey Strategic Planning Program, currently in use. At ABIA, each division has the

directive to develop Wildly Important Goals (WIG’s) to address issues and processes

which are measured by actual results.

19) Procedures to promote safety aw areness and participation in non-punitive

reporting systems

Status – Gap

Currently, there are no formalized procedures to promote safety awareness or allow

participation in a non-puniti ve reporting system. Howeve r, ABIA does promote safety

awareness in general training. ABIA has developed an open door safety policy

throughout the organization that has not been formalized into a non-punitive reporting

system. As the non-punitive reporting procedures are developed and implemented

into SMS, employees at all levels will be directed and encouraged to be proactive

participants in the safety culture.

ABIA SMS GAP ANALYSIS REPORT

Prepared by: Jacobs Carter Burgess

Fort Worth, Texas

# 20) Process to document and review lessons learned from within the

organization.

Status – GAP

There is no formal process to document and disseminate lessons learned from within

the organization. As SMS further develops, a formal process will be developed by

management who will lead the way in the promotion of a safety culture and promote

the individual’s safety responsi bilities within the organization.

21) Schedule for implementation and anticipated associated costs.

Status – In Progress

The Department of Aviation and the SMS consultant group has developed an initial

program schedule to be reviewed monthly as the project proceeds. Implementation

costs will be provided separately from the SMS Manual.



# The Following SMS GAP Analysis Summa ry Table presents the GAP Analysis

findings in a table format. The worksheet lists the 21 elements followed by three

columns denoting the current status of eac h element. The “E” column identifies

those elements that are existing, the “I” column identifies those elements that are “In

Progress”, and the “G” column identifies t hose elements do not currently exist and

are considered GAP. The COMMENTS column explains the status of each

element.

ABIA SMS GAP ANALYSIS REPORT

Prepared by: Jacobs Carter Burgess

Fort Worth, Texas

# SMS PROGRAM ELEMENTS E I G COMMENTS

1 Written Safety Policy & Communication

Plan X To be developed

2 Identification & description of Airport Safety

Goals X Exists in Airport Public Information

Publications only

3 Plan for employee SMS Indoctrination and

Training X SMS - To be developed

4 Documented process to Ident Training req

for systems safety X 139 Training documented - SMS sys to be

developed

5 Plan to validate training effectiveness &

feedback process X Air Ops has training validation - enhance

with SMS development

6 Process to communicate safety policies &

objectives X Airside 139 Safety awareness items

adequate

7 Non-Punitive Safety reporting, existing and

proposed X SMS - To be developed

8 Org Chart with names & safety

responsibilities of key personnel X Does not reflect current organizational

structure

9 Description SRM Process & Five Phases of

SRM X SMS - To be developed

10 Guidance on Safety Risk Management Use

& Trend Analysis X SMS - To be developed

11 Documentation SRM results - Process &

Storage X SMS - To be developed

12 SRM follow up ensuring appropriate

mitigation strategies X SMS - To be developed

13 Plan for SMS Integration to Operations and

SMS X SMS - To be developed

14 Plan to integrate Apron Safety into airport

SMS X SMS - To be developed

15 Documentation Self Auditing & Findings X Self inspect 139 - Self audit needs

development modification

16 Documentation of Self Inspection Program X Documentation under 139.327 - Requires

SRM enhancement

17 Integration Plan for SMS Program into

airport operations X SMS - To be developed

18 Doc plan trng, comm, compentency &

improvement process X Some elements exist - will be further

developed with SMS

19 Promote Safety Awareness & Non-Punitive

reporting partic X Needs incorporation - Will be enhanced

with non-punitive reporting

20 Document & Review Lessons Learned X SMS - To be developed

21 SMS Implementation Schedule &

Anticipated Costs X Schedule and Budget to be determined 

# SMS GAP ANALYSIS SUMMARY TABLE

ABIA SMS GAP ANALYSIS REPORT

Prepared by: Jacobs Carter Burgess

Fort Worth, Texas

# ABIA GAP Analysis

FAR Part 139 Worksheet

The FAR Part 139 worksheet is designed to compare the

requirements of Part 139 with the Airport Certification Manual.

This worksheet is not designed to car ry out a Part 139 Certification

Audit.

The information derived from th e worksheet will be used to

ascertain what components of Part 139 and the ACM can be

included as part of the SMS Program and Manual.

STATUS LEGEND

E Existing

I In Progress

G GAP

RESPONSIBILITY LEGEND

ABIA Austin-Bergstrom Intnl Airpor t DOM Department of Maintenance

AIRCAR Air Carrier ED Executive Director

AO Airport Operations F AA Federal Aviation Authority

AOM Airport Operations Manager FMM Field Maintenance Manager

ARFFC ARFF Chief FBO Fixed Base Operator

BMM Building Maintenance Manager SO Safety Office

COA City of Austin TEN Tenant

DOA Department of Aviation

ABIA SMS GAP ANALYSIS REPORT

Prepared by: Jacobs Carter Burgess

Fort Worth, TexasAustin Bergstrom International Airport - Part 139 WorksheetAIRPORT CERTIFICATION MANUAL (ACM) E I G Resp COMMENTSPart 139.200-3001 139.201 General requirements2(a)Adopts & complies with an ACM that:COAPreface4(1)Has been approved by the Adiministrator (ADMIN)XED-DOAACM 1-15(2)Contents approved by ADMINXED-DOAACM 1-16(3)Cert holders responsibility to operate by ACM - signedXED-DOAACM 1-17(4)Easy to revise and organizeXED-DOAACM 1-18(b)Cert holder must:COAPreface9(1) Keep ACM current at all timesXAOMACM 1-111(2) Complete & current copy on airportXAOMACM 1-112(3) Provide portions ACM to those responsible for implementingX AOMACM 1-113(c)Regional Airports Div Mgr compliance & current copyXAOMACM 1-11416 139.301 Records18(a)Furnish on request by ADMIN, all records required by 139XABIAACM 2-120(b) Maintain records as follows:XABIAACM 2-121(1)Pers Training - 24 Consecutive Calendar Months (CCM)XABIAMaintained at Airport Operations ACM 2-123(2)Emergency Personnel, A/C rescue & FF, EMS 24 CCMXSO-COAMaintained at ARFF Station25(3)Airport fueling agent inspection - 12 CCMXABIAMaintained at Office of each FBO - copy AO27(4)Fueling personnel trng - 12 CCMXABIAMaintained at Airport Operations ACM 2-129(5)Self Inspection - 12 CCMXABIAMaintained at Airport Operations ACM 2-131(6)Movement & Safety area training - 24 CMXABIAMaintained at Airport Operations ACM 2-133(7)Accident & Incident air carrier grnd vehicle 12 CCMXABIAMaintained at Airport Operations ACM 2-135(8)Airport condition dissemination - 12 CCMXABIAMaintained at Airport Operations ACM 2-137(c)Make/maintain any records req by ADMINXABIAACM 2-142Daily logXAOMMaintained at Airport Operations ACM 2-1May 21, 2008 Prepared by: Jacobs Carter Burgess System Safety Team, Fort Worth, Texas Part 139 Page 1 of 11Austin Bergstrom International Airport - Part 139 WorksheetAIRPORT CERTIFICATION MANUAL (ACM) E I G Resp COMMENTS43 139.303 Personnel44(a) Provide sufficient/qualified personnelXDOAACM 3-147(b) Equip Personnel. with sufficient resources to complyXDOAACM 3-150(c) Train to ACM prior to initial duty & every 12 CCMXDOAACM 3-152(1) Airport famiiliarizationXDOAACM 3-153(2) Process to access movement area .329XDOAACM 3-154(3) Airport Communication / twr and operationsXDOAACM 3-155(4) Duties required under ACM & FAR 139XDOAACM 3-156(5) Airfield inspections & additional reqXDOAACM 3-157(6) Instruction on Airport Emergency PlanXDOAACM 3-158(d) Make record of all training - maintain 24 CCMXED-DOAACM 3-161(e) Comply with the following training reqmtsXED-DOAACM 3-163(1) Aircraft rescue and firefighting139.319XARFFCACM 10-164(2) Hndlg and storage of HAZMAT139.321XTENACM 11-165(3) Self Inspection Program139.327XAOACM 14-166(4) Pedestrians and Ground Vehicles139.329XED-DOAACM 15-167(5) Wildlife Hazard management139.337XDO&DOMProcedure letter 11/17/0668(6) Airport condition reporting139.339XAOACM 14-169(f) Use of independent organization to comply with ACMNA70(1) ...if authorized by the AdminisratorNA71(2) Description of responsibilities and dutiesNA72(3) Prepare records to satisfaction of AdministratorNA7374 139.305 Paved Areas75(a) Maintain and Repair pavement areasXFMMACM 4-178(1) Pavement edge exceedencesXFMMACM 4-179(2) HolesXFMMACM 4-180(3) Free of cracks & deteriorationXFMMACM 4-181(4) Loose impediment clean upXFMMACM 4-182(5) Chemical solvent clean up removalXFMMACM 4-183(6) Pavement drainingXFMMACM 4-184(b) Exceptions to snow and iceXAO/FM/BMAMC 4-285(c) Use of Advisory Circulars Advisory - Review A/C's for best practices86May 21, 2008 Prepared by: Jacobs Carter Burgess System Safety Team, Fort Worth, Texas Part 139 Page 2 of 11Austin Bergstrom International Airport - Part 139 WorksheetAIRPORT CERTIFICATION MANUAL (ACM) E I G Resp COMMENTS87 139.307 Unpaved Areas88(a)Maintain and Repair of unpaved movement areasXACM 4-1 - No unpaved movement areas8990 139.309 Safety Areas91(a) Provide runway & taxiway safety areas of at leastXFMMACM 5-294(1) ...that existed on specific datesXFMMACM 5-295(2) Authorized at the time of constructionXFMMACM 5-296(b) Maintenance of safety areasXFMMACM 5-299(c) Use of Advisory circularsAdvisory - Review A/C's for best practices100101 139.311 Marking Signs and Lighting102(a) Provide and Maintain marking systemsXFMMACM 6-1104MarkingsXFMMMarkings not addressed in daily inspection105(1) Rwy markings for takeoff and landingsXFMMACM 6-1106(2) Taxiway center lineXFMMACM 6-1107(3) Taxiway edge markings as appropriateXFMMACM 6-1108(4) Holding position markingsXFMMACM 6-1109(5) ILS critical area markingsXFMMACM 6-1110(b) SignageXBMM111XSignage not addressed in daily inspection112(1) ...for air carrier operationsXBMMACM 6-1113(i) taxiing routes on movement areasXBMMACM 6-1114(ii) holding linesXBMMACM 6-1115(iii) ILS critical area signsXBMMACM 6-1116(2) Internally lit signs Class I, II, and IV aptsXBMMACM 6-1117(3) Internally lit signs Class III aptsXBMMACM 6-1118(c) LIghtingXBMMACM 6-1120(1) Rwy lighting for takeoff and landingsXBMMACM 6-1121(2) Taxiway lighting systemsXBMMACM 6-1122(3) Airport beaconXBMMACM 6-1123(4) Approach lightingXFAAACM 6-3124(5) Obstruction markings and lightingXBMMPart of daily inspection 16-1125(d) Maintenance of Markings and LightingXFMM/BMMACM 6-2128(e) Lighting interferenceXNot mentioned129(f) Use of Advisory CircularsAdvisory - Review A/C's for best practices130May 21, 2008 Prepared by: Jacobs Carter Burgess System Safety Team, Fort Worth, Texas Part 139 Page 3 of 11Austin Bergstrom International Airport - Part 139 WorksheetAIRPORT CERTIFICATION MANUAL (ACM) E I G Resp COMMENTS131 139.313 Snow and Ice Control132(a) ...if located in a snow and ice areaXAO/FM/BMParagraphs conflicting information ACM 7-1135(b) ...control plan must include instructions & procedures for:XAO/FM/BMNo instructions/Training mentioned ACM 7-1- 7-3136(1) Prompt removal as practicalXAO/FM/BMNo instructions/Training mentioned ACM 7-1- 7-3137(2) Positioning of removed snowXAO/FM/BMNo instructions/Training mentioned ACM 7-1- 7-3138(3) Material to adhere to snow and iceXAO/FM/BMNo instructions/Training mentioned ACM 7-1- 7-3139(4) Timely commencement of control operationsXAO/FM/BMNo instructions/Training mentioned ACM 7-1- 7-3140(5) Prompt notification to air carriersXAOAirport Operations141(c) Use of Advisory CircularsAdvisory - Review A/C's for best practices144145 139.315 Acft rescue & firefi Indx determination146(a) Index is required for....XCOA - ABIA149(1) length of air carrier aircraft andXCOA - ABIA150(2) Average daily departures of carrier acftXCOA - ABIA151(b) Aircraft lengths are grouped as followsXCOA - ABIA152(1-5) see actual regulationXCOA - ABIA153(c) Index determinationXCOA - ABIAARFF Index D154(d) Minimum designagted index must be Index AXCOA - ABIA155(e) Exceptions and yet comply NA156157 139.317 Aircraft rescue Equip. and agentsARFFC160(a) Index ANA161(b) Index BNA162(c) Index CNA163(d) Index DXED-DOAEstablished ACM 8-1164(e) Index ENA165(f) Foam discharge capacityXARFFCACM 9-3166(g) Agent discharge capacityXARFFCACM 9-3167(h) Extinguishing agent substitutionsXARFFCACM 9-3168(i) AFFF quantity requirementsXARFFCACM 9-3169(j) Methods and proceduresXARFFC174May 21, 2008 Prepared by: Jacobs Carter Burgess System Safety Team, Fort Worth, Texas Part 139 Page 4 of 11Austin Bergstrom International Airport - Part 139 WorksheetAIRPORT CERTIFICATION MANUAL (ACM) E I G Resp COMMENTS175 139.319 Acft rescue & firefighting Ops req'sXARFFC178(a) CapabilitiesXARFFCACM 8-1179(b) Increase in IndexesXARFFCACM 8-1180(c) Reduction rescue and firefightingXCOAACM 8-1181(d) Procedures for reduction in capabilityXAOMACM 9-1182(1-3) see reg.XAOMACM 9-1184(e) Vehicle communicationXARFFCACM 9-1185(1-4) see reg.XARFFCACM 9-1186(f) Vehicle marking and lightingXARFFCACM 9-1187(1) flashing or rotating lightsXARFFCACM 9-1188(2) Markings of contrasting colorsXARFFCACM 9-1189(g) Vehicle readinessXARFFCACM 9-1190(1-3) see reg.XARFFCACM 9-1192(h) Response requirementsXARFFCACM 10-1194(1) insure the followingXARFFCACM 10-1195(i) respond to every air carrier emergencyXARFFCACM 10-1196(ii) Administrator requestsXARFFCACM 10-1197(2) Response must achieve the followingXARFFCACM 10-1198(i) withing 3 minutes.. Midpoint of furthest runwayXARFFCACM 10-1199(ii) within 4 min ...all other vehiclesXARFFCACM 10-1200(i) Personnel - Cert must ensure:XARFFCACM 10-1 10-2202(1)Equipped protective clothing & equip as per ADMINXARFFCACM 10-1 10-2203(2)Prop trained-prior to init duty & every 12 CCMXARFFCACM 10-1 10-2204(3)Partic in live-drill b4 init duty & every 12 CCMXARFFCACM 10-1 10-2205(4)Least one trained & current EMS avail air opsXARFFCACM 10-1 10-2206(5)Record all training for each for 24 CCM aft complnXARFFCACM 10-1 10-2207(6)Sufficient personnel during air opsXARFFCACM 10-1 10-2208(7)Proc for alerting rescue & FF auth by ADMINXARFFCACM 10-1 10-2209(8)N.Amer Emer Resp Guidebook in vehiclesXARFFCACM 10-1 10-2210(j) Hazardous materials guidance.XARFFCACM 11-1212(k) Emergency access roadsXDon't have emergency access roads at ABIA213(l) Advisory Circular useAdvisory - Review A/C's for best practices215May 21, 2008 Prepared by: Jacobs Carter Burgess System Safety Team, Fort Worth, Texas Part 139 Page 5 of 11Austin Bergstrom International Airport - Part 139 WorksheetAIRPORT CERTIFICATION MANUAL (ACM) E I G Resp COMMENTS219 139.321 Handling and storing of HAZMATXAO & ARFFCACM 11-1220(a) Protection of persons and propertyXAIRCAR/FBOACM 11-1222(1) designated persons to receive trainingXAIRCAR/FBOACM 11-1223(2) Shipper assurancesXAIRCAR/FBOACM 11-1224(b) Standards for fire & explosive protectionXDOADOA for compliance - exempt from training req226(1-7) see reg.XDOAProcedure letters 11/17/06227 Spill Response Plan?XDOAExcellent Spill Response Plan229(c) Fueling agent requirementsXTENACM 11-3232(d) Inspect physical facilitiesX ARFFCARFF inspect once every 3 mths-Records Maintain 12CCM235(e) TrainingXTENMaintenanceain records 12 CCM238(1) Fueling Agent SupervisorXTENACM 11-3 11-4239(2) Fueling personnelXTENTrained & recurrent every 24 CCM240(f) Tenent training confirmationX TENWritten confirmation to Cert holder trng req - every12CCM243(g) noncompliance methodsX ADO&MAsst Dir of Ops & Maint report non-compliance to FAA245(h) Use of advisory circularsAdvisory - Review A/C's for best practices246247 139.323 Traffic and wind direction indicatorsAO-BMM250(a) wind conesXAO-BMMACM 12-1251(b) traffic pattern indicator around wind coneXAO-BMMACM 12-1252(c) Use of Advisory CircularAdvisory - Review A/C's for best practices254255May 21, 2008 Prepared by: Jacobs Carter Burgess System Safety Team, Fort Worth, Texas Part 139 Page 6 of 11Austin Bergstrom International Airport - Part 139 WorksheetAIRPORT CERTIFICATION MANUAL (ACM) E I G Resp COMMENTS256 139. 325 Airport emergency plan257(a) Develop and maintain a planXED-DOAPreface AEP260(1) procedures for prompt responseXED-DOAAEP 2-1, 3-1261(2) sufficient guidance detailXED-DOAAEP 2-1, 3-1262(3) response to the largest aircraftXED-DOAAEP 2-1, 3-1263(b) Instructions for responseXED-DOAAEP 2-1, 3-1265(1) Aircraft Incidents & AccidentsXED-DOAAccident Response Plan266(2) Bomb incidentsXED-DOAAEP 13-1 & Proc letter 11/17/2006l,267(3) Structual firesXED-DOAAEP 14-1268(4) Fires at fuel farms or fuel storage areasXED-DOAAEP 19-1269(5) Natural disasterXED-DOAAEP 12-1 & ABIA Foul Weather Emergency Plan270(6) HAZMAT incidentsXED-DOAAEP 15-1271(7) Sabotage, hijack etcXED-DOAAEP 16-1272(8) Power failure for movement lightingXED-DOAAEP 17-1273(9) Water rescue situationsXED-DOAAEP 18-1275(c) plan must addressXED-DOAAEP 1-1276(1) medical servicesXED-DOAAEP 8-1277(2) local hospital info.XED-DOAAEP 9-6278(3) local ambulance and rescue companiesXED-DOAAEP 9-6279(4) transportation of injuredXED-DOAAEP 9-6280(5) list of hangar facilitiesXED-DOANot Found281(6) crowd controlXED-DOAAEP 5-1& 20-1282(7) Proc. For removing disabled acft.XED-DOAProcedure letter 2/8/08283(d) Other requirementsXED-DOAInteragency Aircraft Accident Response Plan284(1) Accident survivorsXED-DOAAEP 9-6285(2) Removal of disabled aircraftXED-DOA COAProcedure letter 2/8/08286(3)Emergency alarm or notification systemXED-DOA COAAEP 2-1, 3-1287(4)Coordination Airport & Control Tower functionsXED-DOA COAAEP Proc letter 12/15/2004289(e) plan for notifying other participantsXED-DOA COAInteragency Aircraft Accident Response Plan291(f) water and marshland recoveriesXED-DOA COAInteragency Aircraft Accident Response Plan293(g) each certificate holder must....XED-DOA COAAEP 6-1295(1) coordinate with law enforcementXED-DOA COAAEP 6-1296(2) provide for participationXED-DOA COAAEP 6-1297(3) all familiar w assignments & trainedXED-DOA COAAEP 6-1298(4) plan review every 12 monthsXED-DOA COAAEP 6-1299(h) full scale excercisesXED-DOA COAEvery 36 CALENDAR MONTHS300(i) Security rules and regulationsXED-DOA COANot Found302(j) Use of Advisory CircularsAdvisory - Review A/C's for best practicesMay 21, 2008 Prepared by: Jacobs Carter Burgess System Safety Team, Fort Worth, Texas Part 139 Page 7 of 11Austin Bergstrom International Airport - Part 139 WorksheetAIRPORT CERTIFICATION MANUAL (ACM) E I G Resp COMMENTS307 139.327 Self-inspection programXAO & FMM308(a) Must inspect airport ....XAOACM 14-1310(1) dailyXAOACM 14-1311(2) when requiredXAOACM 14-1312(3) after an accidentXAOACM 14-1313(b) provide the followingXAO & FMMACM 14-4315(1) equip. for conducting inspectionsXAO & FMMACM 14-4316(2) equipment for dissemination of info.XAO & FMMACM 14-4317(3) Procedures to insure qualified personnelXAOACM 14-4318(I) Airport FamiliarizationXAOACM 14-1319(ii) Airport Emergency PlanXAOACM 14-1320(iii) NOTAM ProceduresXAOACM 14-1321(iv) Proc for pedestrians & ground vehiclesXAOACM 14-1322(v) Discrepancy reporting proceduresXAOACM 14-1323(4) reporting system to correct unsafe conditionsXAOACM 14 1-3324(c) Each certificate holder mustXAOACM 14-1326(1) record of inspections every 12 monthsXAOACM 14-2327(2) Give training records to individualsXAOACM 14 4-5328(d) Use of Advisory CircularsAdvisory - Review A/C's for best practices329330 139.329 Pedestrians and ground vehiclesXAOProcedures letter 2/28/08331(a) Limit access to movement areasXED-DOAACM 15-2333(b) Implement procedures for safe accessXAOACM 15-1 15-2335(c) Insure tower control of peds and vehiclesXAOACM 15-1 15-2337(d) Control without an open control towerNA338(e) consequences of non-complianceXAOPublic Safety 15-4341(f) Maintain the following recordsXAO/SO/COATRAIN system344(1) description of date of trainingXAO/SO/COATRAIN system345(2) description of dates of any accidentsXAOProcedure letter 2/17/08351 139.331 ObstructionsXAO COAACM 15-1354Removed, marked or lightedXAOMaintenance-Austin Energy355May 21, 2008 Prepared by: Jacobs Carter Burgess System Safety Team, Fort Worth, Texas Part 139 Page 8 of 11Austin Bergstrom International Airport - Part 139 WorksheetAIRPORT CERTIFICATION MANUAL (ACM) E I G Resp COMMENTS356 139.333 Protection of NAVAIDSXDOA-FAAACM 17-1359(a) Prevent NAVAID obstructionsXDOA-FAAACM 17-1360(b) Protect NAVAIDS from theftXDOA-FAAACM 17-1361(c) Prevent disruption of signalsXAO/DOA/FAAACM 17-2362363 139.335 Public ProtectionXDOAACM 18-1364(a) Cert Holder must provideXDOAACM 18-1367(1)Safegrds to prevent inadvrt entry move areaXDOAACM 18-1368(2)Protect people & propertyfrom a/c blastXDOAACM 18-1369(b) Fencing FAA & TSA to facilitate a-1XDOAACM 18-1371372 139.337 Wildlife Hazard ManagementXAOACM 19-1373(a)Immed action alleviate wildlife hazardsXAOProcedure letter 11/17/2006375(b)Ensure wildlife hazard assess w follow eventsXDOMACM 19-1 & Procedure letter 11/17/06377(1)Air carrier has mult wildlife strikesXDOMACM 19-1 & Procedure letter 11/17/06378(2)Air carrier subst damage from wildlifeXDOMACM 19-1 & Procedure letter 11/17/06379(3)Air carrier engine ingestion of wildlifeXDOMACM 19-1 & Procedure letter 11/17/06380(4)Sizable wildlife w access or flt patternXDOMACM 19-1 & Procedure letter 11/17/06381(c)Para b assess by wildlife damage mgmnt biologistXDOMNot mentioned382(1)Analysis of eventXDOMACM 19-1 & Procedure letter 11/17/06383(2) Ident of wildlife & NumbersXDOMACM 19-1 & Procedure letter 11/17/06384(3)Ident Airport features attracting wildlifeXDOMACM 19-1 & Procedure letter 11/17/06385(4)Describe wildlife hazardsXDOMACM 19-1 & Procedure letter 11/17/06386(5)Rec actions to reduce wildlife hazardsXDOMACM 19-1 & Procedure letter 11/17/06387(d)Assess from b must be sent to ADMIN to considerXDOACM 19-1389(1)The wildlife hazard assessmentXDOMACM 19-1 & Procedure letter 11/17/06390(2)Rec actions from assessmentXDOMACM 19-1 & Procedure letter 11/17/06391(3)Aero activity at AirportXDOMACM 19-1 & Procedure letter 11/17/06392(4)Views of Certificate HolderXDOMACM 19-1 & Procedure letter 11/17/06393(5)Views of Airport usersXDOMACM 19-1 & Procedure letter 11/17/06394(6)Other known factorsXDOMACM 19-1 & Procedure letter 11/17/06395(e)When ADMIN det plan needed-cert hldr form planXDOACM 19-1397(1)Provd measures to alleviate hazard to air carriersXDOACM 19-1 & Procedure letter 11/17/06398(2)Plan submitted & apprv by ADMINXDOACM 19-1 & Procedure letter 11/17/06399(3)Becomes part of ACMXDOACM 19-1 & Procedure letter 11/17/06May 21, 2008 Prepared by: Jacobs Carter Burgess System Safety Team, Fort Worth, Texas Part 139 Page 9 of 11Austin Bergstrom International Airport - Part 139 WorksheetAIRPORT CERTIFICATION MANUAL (ACM) E I G Resp COMMENTS400(f)Plan must include the following:XDOACM 19-1 & Procedure letter 11/17/06402(1)Implementing authorityXDOACM 19-1 & Procedure letter 11/17/06403(2)Prioritizing following actionsXDOACM 19-1 & Procedure letter 11/17/06404(I)wildlife population mgmntXDOACM 19-1 & Procedure letter 11/17/06405(ii)Habitat modificationXDOACM 19-1 & Procedure letter 11/17/06406(iii)Land use changesXDOACM 19-1 & Procedure letter 11/17/06407(3)Req for & copies wildlife control permitsXDOACM 19-1 & Procedure letter 11/17/06408(4)Ident resources to implement planXDOACM 19-1 & Procedure letter 11/17/06409(5)Procedures to be followed during air carr opsXDOACM 19-1 & Procedure letter 11/17/06410(I)Desig pers for implementingXDOACM 19-1 & Procedure letter 11/17/06411(ii)Prov phys inspc of wildlife areas b4 ops beginXDOACM 19-1 & Procedure letter 11/17/06412(iii)wildlife hazard control measuresXDOACM 19-1 & Procedure letter 11/17/06413(iv)Effective comm btween wildlife cont & towerXDOACM 19-1 & Procedure letter 11/17/06414(6)Proc review & eval evry 12 mths or aft eventXDOACM 19-1 & Procedure letter 11/17/06415(I)Plan's effectivenessXDOACM 19-1 & Procedure letter 11/17/06416(ii)Reeval wildlife hazard assessmentXDOACM 19-1 & Procedure letter 11/17/06417(7)Trng prog by qual wildlife damage mgmnt biologistXDOACM 19-1 & Procedure letter 11/17/06418(g)FAA A/C contain proc acceptable to ADMINAdvisory - Review A/C's for best practices419420 139.339 Airport Condition ReportingXDOAACM 20-1421(a)Prov for coll & dissemination of Airport condition info to airlinesX AOACM 20-1423(b)NOTAM use and systems apprvd by ADMINX AOACM 20-1 & Figure 20-1 By fax to tenant air carriers425(c)Prov info Airport cond that may affect safe conditionsXAOACM 20-1427(1)ConstructionXAOACM 20-1428(2)Surface irregularitiesXAOACM 20-1429(3)Snow, ice, etcXAOACM 20-1430(4)Snow pilesXAOACM 20-1431(5)Objects contrary to 139.313XAOACM 20-1432(6)Malfunction lights, signs, ILS crit area signcXAOACM 20-1433(7)Unresolved wildlife hazards 139.337XAOACM 20-1434(8)Nonavail rescue firefighting capability 139.319XAOACM 20-1435(9)Other adverse conditionsXAOACM 20-1436(d)Record 12 CCM airport cond reportsXAOACM 20-1437RecordsX AONotification to air carriers records retained for 12 CCM438(e)FAA A/C's for NOTAM usage & dissemAdvisory - Review A/C's for best practicesMay 21, 2008 Prepared by: Jacobs Carter Burgess System Safety Team, Fort Worth, Texas Part 139 Page 10 of 11Austin Bergstrom International Airport - Part 139 WorksheetAIRPORT CERTIFICATION MANUAL (ACM) E I G Resp COMMENTS439 139.341 Ident,mark, light construction & unserv areasXAOACM 21-1 21-2440(a)Each certificate holder mustXAOACM 21-1 21-2442(1)Mark & Light if need be as auth by ADMINXAOACM 21-1 21-2443(I)Each constr & unserv areaXAOACM 21-1 21-2444(ii)Constr equip & roadwaysXAOACM 21-1 21-2445(iii)Adjacent area to NAVAIDSXAOACM 21-1 21-2446(2)Prov proc for avoiding util, cables, etcXAOACM 21-1 21-2447(b)FAA A/C's methods & proc ident constrAdvisory - Review A/C's for best practices448449 139.343 Any unsafe, cert must withhold serviceXDOAACM 22-1May 21, 2008 Prepared by: Jacobs Carter Burgess System Safety Team, Fort Worth, Texas Part 139 Page 11 of 11

# ABIA GAP Analysis

SMS SPM Analysis Worksheet

This Jacobs Carter Burgess SMS Worksheet is designed to be a

user friendly examination of air port operations in a sequence that

follows the organization of the Airport Certification Manual.

The resulting information will be used to ascertain practices and

procedures in place, to identify those elements of Part 139, which

will be part of the SMS implementation.

Comparing this worksheet with th e Part 139 worksheet will serve as

a crosscheck for the accuracy and completen ess of the compiled

data.

STATUS LEGEND

E Existing

I In Progress

G GAP

RESPONSIBILITY LEGEND

ABIA Austin-Bergstrom Intnl Airpor t DOM Department of Maintenance

AIRCAR Air Carrier ED Executive Director

AO Airport Operations F AA Federal Aviation Authority

AOM Airport Operations Manager FMM Field Maintenance Manager

ARFFC ARFF Chief FBO Fixed Base Operator

BMM Building Maintenance Manager SO Safety Office

COA City of Austin TEN Tenant

DOA Department of Aviation

ABIA SMS GAP ANALYSIS REPORT

Prepared by: Jacobs Carter Burgess

Fort Worth, TexasAUSTIN-BERGSTROM INTERNATIONAL AIRPORT - GAP ANALYSISSMS SPM ANALYSIS WORKSHEETE I G Resp COMMENTS1Safety Policy & Objectives2Safety Policy in place?XED & ADIn development3Safety organization appropriate to airport?XSafety Manager and responsibilities not developed forSMS4ABIA Monthly Safety Meetings?XAO5Safety policy approved by senior management?XIn development6Policy reviewed by senior management?XIn development7Understand Responsibilities & Accountabilities?XJob titles & Responsibilities not clear8ACM 3-1 Lines of Succession Airport OperationsX ED & ADDelineated as per ACM - needs updated titles &responsibilities9Planning & Goals?XAirport Public Information Publications10Safety Goals11Top Management driven?XTo be developed12Top Management commitment safety improvement?XED & ADSMS Pilot Program13Top Management commitment implement SMS?XED & ADSMS Pilot Program14Top Management commit to Non-Punitive Reporting?XTo be developed15Top Management commit to Provide Resources?XEDTo comply with 13916Top Management commit make Safety highest priority?XNeeds to be stated in Safety policy17Top Management Approval for Implementation?XED & ADFinal approval18Top Management Promote Policy & Review ProcessXED & ADNeeds to be expanded and enhanced through SMS19Aviation Department Safety Committee?XAOMTo be formed20Safety Reporting21Non-Punitive Safety reporting?XTo be developed22Safety Risks/Deficiencies?XTo be developed23Events/Occurrences?XAOMComply with 13924Safety Resources - Top Management25Finances committed to Safety Policy?XED & AD26Finances committed to Human Resources?XED27Manager appointed to Manage SMS Ops?XAOOperations Supervisor28Emergency Response Procedures29Approved & Documented?XED & ADDepartment of Aviation (DOA) & COA30Reviewal Process?XADReview of Plan every 12 months with all parties31Procedural Dissemination Process?XAOMDistribution Lists & Safety meetings32Prescribed drills/exercises?XADFull scale every 3 years33Airport Emergency Plan Training?XADTrng Curriculum 11/27/200734Validation?XFAA validates in annual inspectionMay 26, 2008 Prepared by: Jacobs Carter Burgess System Safety Team , Fort Worth, Texas SPM Page 1 of 12AUSTIN-BERGSTROM INTERNATIONAL AIRPORT - GAP ANALYSISSMS SPM ANALYSIS WORKSHEETE I G Resp COMMENTS35ABIA Interagency Aircraft Accident Response PlanComponent of City of Austin Emer Ops Plan - AugmentsACM36Responsibilities?XCOA & EDPeriodically reviewed by all agencies37Training?XAOClassroom initial & annual recurrent training38Regulations, Exemptions, Standards39Awareness responsibility Procedures?XAOM40Compliance responsibility?XAD41Periodic Reviews?XFAA validates in annual inspection4243Manuals/Documentation/Records44Airport Certification Manual (ACM)?XAOM45ACM revision currency?XAOM46ACM Currency Procedures & Responsibility?XAOM47Responsibility to communicate changes?XAOM48Top Management Awareness & Review?XED & AD49Implementation responsibility?XAOM50Doc Mandatory 139 Required - Daily Log?XAOM51Document & Records control, dissemination &disposition?XFAA validates in annual inspection52Accident/Incident Records?53.301 Procedures for recordkeeping?XAD &AOM139.329 f 2 - maintain for 12 CCM54Airport Conditions Report55.301 Procedures for recordkeeping?XAOM56Procedures being followed?XAOM & SO12 CCM57Validation?XFAA validates in annual inspection58Other Required Records59Procedures for recordkeeping?XABIAACM 13960Trend analysis & monitoring reports?XAnalysis & reports not evident in doc reviews - To bedeveloped6162Safety Risk Management63Description SRM Process?XTo be developed SMS SPM64Determine Risks/Hazards - SRM65Internal Reporting System?XTo be developed SMS SPM66Report Responsibility?XTo be developed SMS SPM67Identification68Quality & Risk Management?XTo be developed SMS SPM69Internal communications of reports?XTo be developed SMS SPM70SRM - Probability/Severity Identification?XTo be developed SMS SPMMay 26, 2008 Prepared by: Jacobs Carter Burgess System Safety Team , Fort Worth, Texas SPM Page 2 of 12AUSTIN-BERGSTROM INTERNATIONAL AIRPORT - GAP ANALYSISSMS SPM ANALYSIS WORKSHEETE I G Resp COMMENTS71Analyze72Action Responsibility?XTo be developed SMS SPM73Probability Analysis Plan?XTo be developed SMS SPM74Assess75Action Responsibility?XTo be developed SMS SPM76Action Plan/Process?XTo be developed SMS SPM77Evaluate acceptable Risk?XTo be developed SMS SPM78Mitigation strategies - SRM79Action Responsibility?XTo be developed SMS SPM80Management follow-up & Review?XTo be developed SMS SPM81SRM- Monitor process & progress?XTo be developed SMS SPM82SRM- Corrective & Preventive Action Plan?XTo be developed SMS SPM83SRM- Tracking & Trend Analysis?XTo be developed SMS SPM84Documentation SRM results?XTo be developed SMS SPM8586SRM - Airport Functions & Responsibilities87Airport Condition Reporting .301b888Training?XAOMCourse 139-889Procedures?XAOM90Airport Condition Reports/NOTAMS 139.339XAOM12 CCM91Daily log?X AOMMandatory 139 req, division inspection & significantevents92Paved Areas .30593Maintenance Repair Pavement, Ramps, Etc?XFMM94Procedures?XDaily Inspection as part of self inspection95Completion Inspection?XAO96TrainingXAOM & SOCOA TRAIN sys - 24 CCM97Safety Areas .30998Maintenance Safety Areas?XFMM99Procedures/Responsibilities?XFMMACM 5-2100Completion Inspection?XAOM101TrainingXAOM102Markings, Signs, Lighting .311103139.311 Maintain Pavement Markings?XACM 14-1104Procedures?XFMMDaily ACM 6-2105Completion Inspection?XAOAt completion106Training?XCourse 139-4May 26, 2008 Prepared by: Jacobs Carter Burgess System Safety Team , Fort Worth, Texas SPM Page 3 of 12AUSTIN-BERGSTROM INTERNATIONAL AIRPORT - GAP ANALYSISSMS SPM ANALYSIS WORKSHEETE I G Resp COMMENTS107POFZ MarkingsX108Procedures?XMaintenance addressed, but inspection procedures notidentified109Maintain Signage System?110Procedures?XMaintenance addressed, but inspection procedures notidentified111Training?XCourse 139-4112Maintain Airfield Lighting?XBMMLead Electrician on duty113Procedures?XACM - no mention taxi edge or runway hold positionlighting sys114Completion Inspection?XAOProc letter 2/14/08 & 3/15/08115Runway Holding Position Lights?XNot in accordance with AC 120-57116Procedures?XACM 6-3117Completion iInspection?XACM 6-3118Airfield Lighting trainingXCourse 139-5119Maintain Airport Beacon?XACM 6-2 e120Procedures?XNot addressed in ACM121Completion Inspection?XNot addressed in ACM122MaintainApproach Lighting Systems?XFAA ACM 6-2123Procedures?XFAA ACM 6-2124Completion Inspection?XFAA125Inspection marking and/or light obstructions?XAOPart of Daily Inspection 16-1126Procedures?XFM/BMField/Building Maintenance127Completion Inspection?XAOAirport Operations128129Snow & Ice Control .313Responsibility? AOMACM 7-1130Prompt snow /ice removal?XFFMConflicting info Para's A & B131Procedures?XACM 7-2 Airport Operations, Field Maint, Building Maint132Completion Inspection?XACM 7-2133Positioning snow/ice off surfaces?XNot addressed in ACM134Procedures?XNot addressed in ACM135Completion Inspection?XACM 7-2136Authorized anti snow/ice materials?XFAA - need more specificity as to materials137Procedures?XNot addressed in ACM138Completion Inspection?XNot addressed in ACMMay 26, 2008 Prepared by: Jacobs Carter Burgess System Safety Team , Fort Worth, Texas SPM Page 4 of 12AUSTIN-BERGSTROM INTERNATIONAL AIRPORT - GAP ANALYSISSMS SPM ANALYSIS WORKSHEETE I G Resp COMMENTS139Timely snow/ice control?XAO/FM/BMACM 7-1, 7-2140Procedures?XACM 7-2141Notifications non snow/ice removal areas?XAOMNOTAMS to Tenants & San Angelo ATSS142Completion Inspection?XAOMMonitoring & information on snow conditions143Maintaining & Updating snow/ice removal plan?XNot addressed in ACM144Training snow/ice removal process?XNot addressed in ACM145Procedures?XNot addressed in ACM146A/C Rescue & Firefighting .315 .317 .319147ARFF Availability during Airport Operations X ARFFC24/7 - 3 Shifts ACM 8-1, ARFF Index D .317 Specificity148Procedures?XARFFC149ARFF Response & Recall Req?XARFFCACM Letter Agreement - AEP?150Procedures?XARFFCMonthly review & Drill Tested 0800 daily151Emergency Radio ContactsXARFFCACM Letter Agreement - AEP?152Procedures?XARFFC153Emergency vehicles properly marked?XARFFCACM 9-1154Emer Vehicles Maintained & Ready?XARFFCACM 9-1155Procedures?XARFFCDaily inspections156ARFF Index for airport being met?XARFFCACM 8-1, Index D157ARFF Equipment & Agents?XARFFCACM 9-3158Vehicle turret discharge capacity req?XARFFCACM 9-3159Adequate agent/water available being met?XARFFC160Emergency Response Requirements?XARFFC3 Minutes to midpoint ACM 10-1161Immediate Replacement inop Emer Vehicles?XDOAACM 8 -1162Procedures?XARFFCACM 8-1163Reports?XED & ADRegional Airports Division Manager164Sufficient trained ARFF to meet req 139?XARFFCACM 10-1165Ensuring rapid response to EmergenciesXARFFC166Emergency personnel equipped protective gear?XARFFCAC 150/5210-17 & ACM 10-1 & OSHA167PPE, Hardhats, Eye protection, Face protection.XARFFCSafety Office168Rescue & ARFF properly trained for duties? XARFFCACM 10 - 1 Monthly testing169Procedures?XARFFCRecurrent trng every 12 months Records 24 CCM170Personnel live drill before initial duty?XARFFCTexas A&M and/or Salt Lake City ACM 10 - 1171Procedures?XARFFCACM 10 - 1172May 26, 2008 Prepared by: Jacobs Carter Burgess System Safety Team , Fort Worth, Texas SPM Page 5 of 12AUSTIN-BERGSTROM INTERNATIONAL AIRPORT - GAP ANALYSISSMS SPM ANALYSIS WORKSHEETE I G Resp COMMENTS173Emergency Medical Service PersonnelXARFFCRecords 24 months174Procedures?XARFFCRecurrent training every 12 months175TrainingXARFFCCOA TRAIN sys - Records 24 CCM176Emergency Medical Service available during AirOps? X ARFFCACM 10-2177Alert System & Maintenance Emer Pers?XARFFCTested 0800 daily178Procedures?XARFFCAEP & IAARP179.303 & .327 Emergency Check Lists for VehiclesXXARFFCGrid map needs improvement180Inspection?XARFFCAt start of each shift181Fire or Bomb Threat Evacuation (Terminal)XADProcedure Letter182N. American Emergency Response Guide invehicles? X ARFFC183Emergency Roads maintained all weatheroperations? XNo Emergency Roads184Severe Weather Operations/NotificationsXAOM185186HAZMAT - Handling & Storage .321AOM/ARFFAirport Operations & ARFF Monitor187Does Airport act as Cargo Handling agent? No188Proper Cargo Identification?XTEN189Procedures?XTEN190Applicable Cargo handling?XTENTenant handling191Procedures?XTEN192Material Safety Data Sheets - MSDSXTENReq by OSHA - Tenants - Spill kits193Special HAZMAT Storage Areas?XAIRCAR/FBODesignate areas194Procedures?XAIRCAR/FBOPrescribe rules & procedures195HAZMAT Advisory Signage?XTEN139.321 (a)( 3)196Procedures?XTEN197Storage Areas Properly Maintained?XTEN198Procedures?XTENDOT EPA TCEQ TDH199HAZMAT Manual Readily Available?XTENMSDS, OSHA200Procedures?XTEN201Responsibility, Revisions, Validation?XTEN202Spill Response?XTENDOA & Dir Facilities Services? & EC203Procedures?X TENSpill Response Plan F-11 - Spill Responders - ARFFsecondary204Training?X TENSpill Responder training & Spill Response Plan training F15205Notifications?XTENEPA, FAA, TCEQ, COA, DOAMay 26, 2008 Prepared by: Jacobs Carter Burgess System Safety Team , Fort Worth, Texas SPM Page 6 of 12AUSTIN-BERGSTROM INTERNATIONAL AIRPORT - GAP ANALYSISSMS SPM ANALYSIS WORKSHEETE I G Resp COMMENTS206HAZMAT Training?XTENSpill Responder Training207Procedures?XTENFirst Responder Awareness Trng208HAZMAT Contamination Suits - Required? No - HAZMAT Teams from city209Baggage AlertsXED & ADProcedure Letter210Fueling - Aircraft & Vehicles211Fuel Handling - Fire & Explosion?XDOA212What are standards?XDOA213Procedures?XTEN214Compliance with Fueling Standards?XTENTenants/Contractors215Procedures?XTENTenants/Contractors216Immediate Action fueling Standards breached?XTENTenants/Contractors217HAZMAT & SWPPP Procedures?XTEN/AOMDOA Environmental Compliance Specialist - Kane C.218Fueling truck inspections?XARFF quarterly checks219Fueling Training220Airport Fueling Agent InspectorXARFFCARFF every 3 months221Procedure?XARFFCARFF Records for 12 CCM222RecordsXARFFC223Airport Fueling Personnel Training? X TENCertification report to Airport Operations every 12 months224RecordsXTENRecords at each FBO225Procedure?XTENSupervisor - Recurrent every 24 CCM226Fuel farm Inspections?XARFFC227Procedures?XARFFC228Validation?XARFFC229Emergency Fuel Shutoffs?XTENContractor fueler Manager230Inspection?XTEN231Portable Fire Fighting Agents?XTEN232Procedures?XTEN233Inspection?XTEN234235Airport Emergency Plan .325XDOA & FAA - Scope & Objectives excellent236Prompt Response?XED/ADARFF237Procedures?XED/ADATC Initiates238Responsibility & Dissemination?XED/ADReview AEP every 12 months with all parties239Validation?XED/ADFull scale Emergency Exercise once three yearsMay 26, 2008 Prepared by: Jacobs Carter Burgess System Safety Team , Fort Worth, Texas SPM Page 7 of 12AUSTIN-BERGSTROM INTERNATIONAL AIRPORT - GAP ANALYSISSMS SPM ANALYSIS WORKSHEETE I G Resp COMMENTS240AEP Plan & Guidance?XED/ADACM 9-2 Outdated241Procedures Documented & Implemented?XDOA/COAReview of Plan every 12 m with all parties242Procedures review?XADFull scale every 3 years243Validation & Review?XADDistribution Lists244Training?XNo Training provisions mentioned in AEP245Removal disabled aircraft?XAOM246Procedures?XAOMProcedures Letter 2/08/2008247AEP Notifications in Emergencies?XCOD/EDATC notifies ARFF248Procedures?XAlert 1, 2, 3 121.9 128.35 Twr249AEP Coord with Agencies/Organizations?XCOA/EDIncident Command Post - Unified Command250Validation?XDaily 0800 Test251Communications?XRing-down system & Pagers252Aircraft bomb threat?XProcedure letter 2/09/08 & AEP 3-1253Procedures?XAOMAEP254Security Breach?XProcedures Letter255ABIA Interagency Aircraft Accident Response Plan X COA/EDSeparate from AEP - dated 12/07/2007256Self-Inspection Program .327Daily airfield, General, Special Need Inspections257Airport Daily Inspections?XAOM258Procedures?XFMM/BMMACM 14-1, -2259Deficiencies?XACM 14-1 -- Airport Inspection Log & Airfield DiscrepancyReport260Validation?XAOM261139.327 Training?XCourse 139-7262Special Needs Inspections?XAO&FMMUnusual conditions, accident, meteorological events263Hazardous deficiencies?XPossible NOTAM & ATIS264Post Accident/Incident/Event Inspections?XAOM & FMM265Procedures?XAOM & FMM266Documentation?XTo be maintained 5 years267Equipment to perform inspections adequate?XAOMTwo way radios & Amber rotating beacons268269270Inspectors Qualified & Trained?X139.303 Recurrent 12 CCM months271Procedures?XAOMACM 14-5 Records kept 24 CCM272Validation?XFAA Cert Inspection273Prompt corrections unsafe conditions found?XACM 14-3 - Notams - Add to ATIS274Procedures?XAO & FMMMay 26, 2008 Prepared by: Jacobs Carter Burgess System Safety Team , Fort Worth, Texas SPM Page 8 of 12AUSTIN-BERGSTROM INTERNATIONAL AIRPORT - GAP ANALYSISSMS SPM ANALYSIS WORKSHEETE I G Resp COMMENTS275Self-Inspection Records?XACM 14-1, 2 & Acc Prevention Plan276Procedures?XAOMAirport Operations Mgr - 12 CCM277Responsibility?XADReviewed by management278Pedestrians & Ground Vehicles .329279Limit access to movement & safety areas? X EDTraining - Airfield Driver Safety Training Prgm - AirportOperations280Procedures?XACM 15-1281Validation?XRecords 24 cm - FAA Certificate Insp282Training on non-compliance?XAOMACM 15-4283Procedures?XNotify Airport Public Safety or Air Operations284Prevention of unauthorized entry?XEDACM 15-1285Procedures?XACM 15-1, 2 Entry awareness286Wildlife Hazard Management .337ACM 19-1 & Procedures Letter287Wildlife Hazard AssesmentXDOADOA when req - ACM 19-1 & 139.337c288Adequate resources for wildlife plan?XAdraft plan has been identified, if required289Wildlife permits?XUSDA - Manage herd290Wildlife hazard communications?X.337 f 5 iv291Database?XProcedure letter - 11/17/2006292Designated & Trained Wildlife Personnel? XProcedure letter - 11/17/2006 - No Airport WildlifeCoordinator293Airport Condition Reporting .339XACM 20-1294Dissemination to Air Carriers?XACM 20-1295Procedures?XAORequest NOTAM from San Angelo FAA ACM 14296Records?X12 CCM airport conditions report to air carriers297Construction & Other Unservicable Areas .341 XObject Free Areas are not Safety Areas - 21-1 - morerestrictive298Construct safeguards regarding NAVAIDS?XACM 21-2 - Not complete - .314299NOTAM Issue ProceduresXFMMProcedure Letter ACM 21-1300Marking, identifying, lighting construction areas? FMM301Procedures?XACM 21-1 21-2302Marking & Identifying equipment & roadways? FMM303Procedures?XACM 21-1 21-2304Marking & Lighting NAVAIDS FMM305Procedures?ACM 21-1 21-2306May 26, 2008 Prepared by: Jacobs Carter Burgess System Safety Team , Fort Worth, Texas SPM Page 9 of 12AUSTIN-BERGSTROM INTERNATIONAL AIRPORT - GAP ANALYSISSMS SPM ANALYSIS WORKSHEETE I G Resp COMMENTS307Non-Complying Conditions .343ACM 22-1308Limiting Air Carriers to safe portions airportACM 22-1309Procedures?XDOADOA monitor airport310311Safety Assurance312Performance Indicators313Accident, Incident, event Reviews?XADVehicle Collision Review Committee314Planned reviews?XDOA Employees - Vehicle Collision Review Comm315Investigation Procedures & Responsibilities?XVaries - appears to be ad hoc - not formalized316Self-Auditing317Procedure to ensure all events investigated?XNo procedure plan318Internal auditsXNo internal audits319Responsibility?XAudited Readiness Assurance for Ops Work Grp320Safety Oversight Risk Strategies321Investigation Procedures & Responsibilities?XWill be developed SMS322Training competency?X323Planned/unplanned changes procedures?XWill be developed SMS324Planned/unplanned changes equipment?XWill be developed SMS325Planned/Unplanned changes Personnel?XWill be developed SMS326Planned/Unplanned changes fixtures?XWill be developed SMS327Feedback Reporting328Non-Punitive inputs & reports?XWill be developed SMS329Analysis reviewing procedures?XWill be developed SMS330External Safety reporting procedures?XWill be developed SMS331Communicate Findings & Status reporting?XWill be developed SMS332Communicate findings internally?XNo process outlined333Promote Safety Integration334Recommendations?X335External/Independent Audits/Assessments?XWill be developed SMS336Evaluations of corrective actions?XWill be developed SMS337Training Review?XWill be developed SMS338Documentation & Record Keeping?XWill be developed SMS339Documentation Review Lessons Learned Process?XWill be developed SMS340May 26, 2008 Prepared by: Jacobs Carter Burgess System Safety Team , Fort Worth, Texas SPM Page 10 of 12AUSTIN-BERGSTROM INTERNATIONAL AIRPORT - GAP ANALYSISSMS SPM ANALYSIS WORKSHEETE I G Resp COMMENTS341Safety Promotion342Training & Education343Plan for employee SMS Indoctrination Training?XAOMIn development344Means for measuring Safety training?XNone noted345Safety training for indoctrination & recurrent training?XAOMAirport Operations - FAR 139-1346Process to identify training requirements?XWill be enhanced with SMS development347Job specific training?XAOM348Human Factors integrated into training?XNone noted349Computer Based Instruction (CBI)?XPartial - hands on350Standardization checks on instructors?XNone noted351Validation training effectiveness?XNo evidence of means to measure352353139.301 Record Retention354Airport Personnel Training 139.303 & 139.327 24 CCMX AOM355Emergency Personnel Training 139.319 24 CCMXNot noted356Airport Fueling Agent Insp 139.321 12 CCMXAOM357Fueling Agent Personnel 139.321 12 CCMXAOM358Self Inspection 139.327 12 CCMXAOM359Movement Area Training 139.329 24 CMXAOMAirport Operations Excel program360Safety Area Training 139.329 24 CMXAOM361Accident & Incident Reports 139.329 12 CCMXAOM & SOCOA TRAIN Sys362A/P Condition Reports/NOTAMS 139.339 12 CCMXAOM363Recordkeeping Procedures & Recurrent TrainingXAOM & SOCOA TRAIN Sys364Emergency Preparedness Response Training365Emergency response training for specific pers?XNone noted other than marshalling points366Training records on file 24 months?XARFFC367Procedures for recordkeeping?XNot noted368AEP Training?XNo trng mentioned ACM AEP or A/C Acc Response-Have139-2369Emergency Medical Service Personnel370Training records on file 24 months?XARFFCARFF Station371Procedures for recordkeeping?XARFFCARFF Station372Fueling Training373Fueling Agent Inspection?XARFFCARFF every 3 months374Procedure?XACM 11-3375Procedure being followed?XInspection reports ARFF for 12CCM376Validated?XARFFCMay 26, 2008 Prepared by: Jacobs Carter Burgess System Safety Team , Fort Worth, Texas SPM Page 11 of 12AUSTIN-BERGSTROM INTERNATIONAL AIRPORT - GAP ANALYSISSMS SPM ANALYSIS WORKSHEETE I G Resp COMMENTS377Fueling Personnel Training Records?XAOMPaper File - written cert every 12 months from Tenants378Procedure being followed?XSupvr - Recurrent Trng every 24 CCM379Movement Area & Safety Area Training?380Procedures?X AOMPrior Initial Duty then at least every 12 CCM - FAR 139-3course381HAZMAT Storage382Procedures?XTENTenants train DOA standards383384Wildlife Hazard Management385Wildlife Coordinator?XNo Wildlife Coordinator designated386Procedures?XPlan drafted, not activated387Training?XCourse 139-10388389Non-Punitive Safety ReportingXTo be developed SMS390391Safety Communications392Communications allowing Safety functioningX AD/AOMDaily log, Safety Committee meeting minutes, bulletinboards393Electronic?XDeveloping394Written?XAOMOperations Daily Log395Meetings?XAOMMonthly Safety Meetings396Bulletins, NOTAMS, Security?XAOMDaily Log, bulletin boardsMay 26, 2008 Prepared by: Jacobs Carter Burgess System Safety Team , Fort Worth, Texas SPM Page 12 of 12

# ABIA SMS GAP ANALYSIS REPORT

Prepared by: Jacobs Carter Burgess

Fort Worth, Texas 

# Austin-Bergstrom International Airport

Federal Aviation Administration

Safety Management System (SMS)

Pilot Program

SMS Team Members

Jacobs Carter Burgess, Fort Worth, Texas

Richard Compton Project Manager

Rick Paddock Policy & Objectives

Alisa Rich Environmental Risk

Joe Oyler Risk Management & Safety Promotion

Bruce Bickhaus Risk Managem ent & Safety Promotion

Deborah Reiswebber Human Factors & Organizational Development

Victor Nartz Quality Assurance

Leslie Sagar Quality Cont rol / Quality Assurance



# Austin-Bergstrom International Airport

Loren Lintner Project Manager

Mary Anne Bertuglia Airport Operations Manger

Patti Edwards Director of Operations & Maintenance

Jim Smith Executive Director