Seattle-Tacoma International Airport 

SMS Minimum Standards 

Prepared For: Federal Aviation Administration 

Office of Airports 

Airport Safety and Operations Division 

Prepared By: Landry Consultants LLC, on behalf of Seattle-Tacoma International Airport and 

 Operations Senior Manager, Mark Coates 

 

Date: 11/25/2009 
SMS Minimum Standards 

Revision History 

Date Version Summary 

10/15/09 v.0.1 Initial draft for SEA review 

11/21/09 v.0.2 Updated draft 

11/23/09 v.0.3 Revised final draft 

11/25/09 v.1.0 Final 

Prepared in Support of Statement of Work Section C – Safety Assurance, 

Task 4: 

Develop a minimum standard for safe operations on the ramp and in the 

bagwell (if applicable). 

As discussed under Task 3, the ramp and bagwell are not currently regulated 

under Part 139 and present increased potential for incidents and accidents. 

Under this task, the airport will develop a minimum standard for safe operations; 

identifying areas of concern or potential for increased incident and/or accidents; 

and, list baseline incidents and accidents for trending. 

Safety Assurance i 
SMS Minimum Standards 

Safety Assurance ii 

Table of Contents 

1. Introduction .................................................................................................... 1

2. Airport Role .................................................................................................... 1

2.1 Developing Minimum Standards ......................................................................... 1

2.2 Minimum Standards ............................................................................................ 2

3. The Role of Accidents/Incidents .................................................................... 3

4. Operator Responsibilities and Compliance .................................................... 3

5. Summary of Findings ..................................................................................... 4
SMS Minimum Standards 

1. Introduction 

According to Advisory Circular (AC) 150/5190-5 Exclusive Rights and Minimum 

Standards for Commercial Aeronautical Activities, airports that have accepted Federal 

assistance are encouraged to establish minimum standards for aeronautical services. 

These minimum standards establish, in writing, what is needed to conduct business 

services at an airport without granting an exclusive right to one company and to ensure 

the opportunity for fair competition. Specifically AC 150/5190-5 states that “The FAA’s 

policy on exclusive rights and its recommendation for the development of minimum 

standards stem from the airport sponsor’s general assurances to make the airport 

available for public use on reasonable conditions and without unjust discrimination.” 

With regard to safety objectives, the AC advises the following. “The FAA policy for 

recommending the development of minimum standards serves the objective of 

promoting safety in all airport activities, maintaining a higher quality of service for airport 

users, protecting airport users from unlicensed and unauthorized products and services, 

enhancing the availability of adequate services for all airport users...” 

This documents presents information regarding minimum standards as they relate to 

Safety Management System (SMS) implementation at airports. Since minimum 

standards are not required at airports and many airports do not have minimum standards 

in place at this time, the extension of minimum standards to the ramp and bagwell may 

be an opportunity for airports to develop new, comprehensive standards for the entire 

operation. However, to most effective, minimum standards should align with the SMS 

Policy underlying goals and objectives. It may also be advisable for some airports to 

delay developing minimum standards until accident/incident and hazard data can be 

baselined to assist with defining areas of concern. 

2. Airport Role 

The role of the airport with regard to minimum standards is to ensure those who operate 

at the facility have no unfair advantages and conduct business in a safe and responsible 

manner. Minimum standards should reflect the airport’s type of operations and tenants 

and should apply consistently and equally to all including ground services providers 

(GSPs), caterers, fuelers, etc. As such, minimum standards must be broad enough to 

be applied over a variety of services, but also must include a level of detail to allow for 

ensuring tenant compliance. 

2.1 Developing Minimum Standards 

A variety of minimum standard guides exist to aid in the development process including 

the Aircraft Owners and Pilots Association (AOPA) Minimum Standards for Commercial 

Aeronautical Activities and the American Association of Airport Executives and National 

Air Transportation Association’s Airport Sponsor’s Guide to Preparing Minimum 

Standards for Airport Aeronautical Service Providers and Airport Operating Rules and 

Regulations. These guides assist airports in collecting information and shaping the 

content of the minimum standard to reflect the airport’s specific operations and tenant 

community services governed by the standards. Important to the development of these 

standards is the public review process that ensures tenants can comply with standards 

without undue burden or disadvantage to other providers. Airports should allow enough 

time for a variety of public review and comment sessions as part of the development 

process. Additionally, airports need to commit to the staffing levels necessary to 

Safety Assurance 1 
SMS Minimum Standards 

develop and publish minimum standards that are thorough and relevant. Under the 

SMS, developing and implementing minimum standards is an important aspect of 

creating a comprehensive safety program. In fact, the FAA cautions airports in AC 

150/5190-5 (8 c. How to Develop Minimum Standards) that “Minimum standards should 

be tailored to the airport to which they will apply...the FAA will not endorse “fill-in-the 

blanks” minimum standards and blanket adoption of another airport’s standards because 

of the high probability that many airport sponsors would adopt the document without 

modifying it to the needs of their particular airport.” The Safety Manager assigned to 

develop the airport Safety Policy will need to incorporate minimum standards as part of 

the Policy and its associated goals and objectives. 

2.2 Minimum Standards 

As mentioned in the introduction, minimum standards are not mandatory, but highly 

recommended to establish the threshold entry criteria for those who wish provide 

aeronautical services at an airport. In some cases, airports may include minimum 

standard language in Lease or License Agreements; however, this is not recommended 

as the minimum standards should be a separate document or set of documents that can 

be reviewed and updated independent of the Lease or License Agreements. Also, while 

rules and regulations often provide operational guidelines that support minimum 

standards they are also typically separate documents. The list below presents the 

document and its purpose: 

1) Minimum Standards – tenant entry criteria including financial, qualifications, and 

safety standards for relevant types of commercial aeronautical activities. 

2) Lease or License to Operate Agreements – agreements to operate on the facility 

including fees, terms of agreement, areas and hours of operations, 

indemnification, insurance, permits, financial audits, compliance with laws, 

reference to Rules and Regulations, etc. 

3) Rules and Regulations – operational guidelines such as speed limits, number of 

carts allowed on the ramp and in the bagwell, smoking policy, fire regulations, 

hazardous materials management, aircraft operations, enforcement policies, and 

appeal processes. 

Typical minimum standards include financial, safety, and operational qualifications such 

as staff training and credentials; conformance to safety, health and sanitary codes; 

evidence of financial stability; and provision of stated indemnity and insurance 

minimums. For the purposes of this document and its discussion regarding minimum 

standards, only safety and associated operational issues will be addressed. 

To ensure levels of operational safety are met on the airfield and in the bagwell, airports 

can require tenants to provide staff certifications, attend driver training sessions, comply 

with Rules and Regulations, and meet minimum standards. Airports can approach 

minimum standards in a variety of ways: 

1) Adopt a nationally recognized safety standard such as the International Air

Transport Association’s (IATA) Safety Audit for Ground Operations (ISAGO). 

This program is founded on an audit system conducted in a standardized and 

consistent manner, using internationally recognized auditing principles. 

Safety Assurance 2 
SMS Minimum Standards 

2) Develop a set of minimum standards developed jointly by airport and tenant 

representatives. 

3) Allow for airline carriers/operators to develop, supervise, and audit minimum 

standards for their service providers. According to AC 120-92 Introduction to 

Safety Management Systems for Air Operators, the AC guidance indicates that: 

Title 49 of the United States Code, subtitle VII, chapter 447, section 44702 

states, in part, that “When issuing a certificate under this chapter, the 

Administrator shall consider the duty of an air carrier to provide service with the 

highest possible degree of safety in the public interest and differences between 

air transportation and other air commerce....” This section of the public law 

makes management of safety a specific legal responsibility for air carrier 

management teams and, as such, is a fundamental principle of the FAA 

oversight doctrine. While this section applies specifically to air carriers, the FAA 

expects all certificated organizations to make safety a top priority and holds their 

managements accountable for doing so.” This statement indicates that air 

carriers are responsible for the service provider safety as well as their own. 

4) Allow for multiple programs as long as tenants meet the equivalent of the 

established minimum standards. 

Regardless of the program, the airport’s role in facility oversight and safety, especially as 

part of an SMS, can increase safety awareness through minimum standards. But, if 

airports merely require the above and do not participate in the oversight of the program 

through tenant program reviews, the message is that safety is a matter of document 

compliance and not operational safety. If an airport decides to develop minimum 

standards as part of an SMS, a commitment to ongoing program administration and 

participation needs to be in place. 

3. The Role of Accidents/Incidents 

In developing minimum standards, airports can review trends through its collection of 

accident and incident information. The type and frequency of accidents and incidents 

can provide information on the current gaps that exist in Lease Agreements or Rules and 

Regulations. These gaps can be addressed through the adoption of more rigorous 

minimum standards especially with regard to safety. 

4. Operator Responsibilities and Compliance 

As a function of the minimum standard program, it is on the part of the operator to 

appropriately and reasonably show that they have met the airport's minimum standard. 

Also, if the operator submits an argument that they have met a minimum standard in a 

way not directly referenced in the minimum standards document, it needs to be 

incumbent on them (not the airport) to demonstrate a precedent that other airports have 

accepted it and it worked successfully. Most importantly, the airport needs to commit 

resources to reviewing and approving operator submissions to ensure disadvantages to 

the operator are not a result of the established minimum standards. 

Safety Assurance 3 
SMS Minimum Standards 

Safety Assurance 4 

5. Summary of Findings 

Establishing minimum standards, especially with regard to safety, can improve airport/air 

carrier/service provider awareness and establish a higher level of compliance to safety 

standards through either internal or external standard programs such as ISAGO. An 

airport’s role in maintaining safety standards needs to ensure fairness is maintained as 

part of (AC) 150/5190-5 and also assign an adequate level of staff for program oversight 

and review.