SOUTHERN ILLINOIS AIRPORT GAP ANALYSIS

The following gap analysis was constructed following interviews with airport 

personnel and an exhaustive review of literature, including: Airport Certification Manual 

(FAA Part 139), Southern Illinois Airport (SIA) Certification Manual, SIA Safety Manual, 

FAA Advisory Circular (AC) 120-92, FAA AC 150-5200-37, Airport Cooperative 

Research Program (ACRP) Report 1: Safety Management Systems (SMS) for Airports,

International Civil Aviation Organization (ICAO) Safety Management Manual, and 

Transport Canada AC 300-002. 

These interviews and documents were used to establish benchmarks associated 

with the existing safety climate at SIA.

COMPONENT 1: SAFETY POLICY

Element 1.1: Safety Policy

1. Is an SMS with defined components established, maintained and adhered to?

Status: Unsatisfactory. An SMS is not in place.

Action Needed: An SMS must be developed.

2. Is the SMS appropriate to the size and complexity of the organization?

Status: Unsatisfactory. An SMS program is not in place.

Action Needed: An SMS must be developed that is appropriate in size and scope to 

SIA.

3. Is there a safety policy in place?

Status: Unsatisfactory. One exists, but, not in SMS format. It is outlined in the SIA 

Safety Manual. However, the manual was developed to comply with workmen's 

compensation directives and requires revision to reflect SMS policies.
Action Needed: New Safety Policy Statement with SMS components

4. Is the safety policy approved by the accountable executive?

Status: Satisfactory. The existing safety policy is approved by the airport manager and 

the SIA airport authority.

5. Is the safety policy reviewed periodically?

Status: Unsatisfactory. The safety policy does not undergo formal, periodic review.

Action Needed: A formal, periodic review schedule must be established.

6. Is the safety policy communicated to all employees, with the intent to make them 

aware of their individual safety obligations?

Status: Unsatisfactory. Personnel assigned to potentially hazardous positions, e.g. 

flight line personnel, receive safety training related to their specific function.

Action Needed: An SMS indoctrination and recurrent training program must be 

developed for all airport personnel.

Element 1.2: Non-Punitive Reporting Policy

1. Is there a policy in place that provides immunity from disciplinary action for 

employees who report safety deficiencies, hazards or occurrences?

Status: Unsatisfactory. A non-punitive reporting policy is not in place.

Action Needed: A non-punitive reporting policy must be developed.

Element 1.3: Roles, Responsibilities and Employee Involvement

1. Has an accountable executive been appointed with responsibility for ensuring that 

the SMS is properly implemented and performing to requirements in all areas of the 

organization?
Status: Satisfactory. The airport manager will oversee the development and 

implementation of the SMS.

2. Does the accountable executive have control of the financial and human resources 

required for the proper execution of their SMS responsibilities?

Status: Satisfactory. The airport manager has the responsibility to oversee fiscal and 

human resource issues associated with the execution of SMS responsibilities.

3. Has a qualified person been appointed to manage the operation of the SMS?

Status: Satisfactory. The airport manager will manage the SMS. The airport manager 

has indicated that the employment of a safety officer may be required to manage the 

implementation and oversight of SMS.

4. Are the safety-related responsibilities of personnel at all levels of the Airport 

Authority defined and documented in an organization chart?

Status: Unsatisfactory. Responsibilities not defined.

Action Needed: Safety-related responsibilities must be defined for top management, 

safety manager, department heads/managers, established safety committees and 

chairpersons.

5. Is the SMS plan fully integrated into the operation of the airport?

Status: Unsatisfactory. There is currently no SMS plan.

Action Needed: Once it is created, a description of how to fully integrate the SMS into 

the operation of the airport needs to be provided.
Element 1.4: Safety Planning, Objectives and Goals

1. Have measurable safety objectives been established?

Status: Unsatisfactory. Measureable safety objectives have not been established.

Action Needed: Measurable safety objectives require development.

2. Is a formal process used to develop a coherent set of safety objectives?

Status: Unsatisfactory. A formal process is not in place.

Action Needed: A formal process requires development.

3. Are measureable safety objectives publicized and distributed?

Status: Unsatisfactory. Measurable safety objectives are not in place.

Action Needed: Safety objectives require increased communication.

Element 1.5: Management Review

1. Are regular and periodic reviews of the organization's safety performance conducted 

to ensure its continuing suitability, adequacy and effectiveness?

Status: Unsatisfactory. Periodic reviews are conducted as required by FAR Part 139 

and Workmen's Compensation, but not with respect to SMS.

Action Needed: Formal SMS performance reviews require establishment.

2. Is there a process to evaluate the effectiveness of corrective actions?

Status: Unsatisfactory. An evaluation process is not in place.

Action Needed: An evaluation process requires development.

Element 1.6: Identification and Maintenance of Applicable Regulations

1. Are regulations and standards periodically reviewed to ensure that the most current 

information is available?
Status: Satisfactory. Regulations and standards are reviewed upon notification of FAA 

updates or modifications.

Element 1.7: Records Management

1. Does the organization have a records system that ensures the generation and 

retention of all records necessary to document and support operational requirements, 

and is in accordance with applicable regulatory requirements?

Status: Satisfactory. SIA maintains personnel training and medical records IAW Illinois 

Department of Labor Standard 29 CFR 1910.20. 

2. Does the system provide the control processes necessary to ensure appropriate 

identification, storage, protection, archiving, retrieval, retention time, and disposition of 

records?

Status: Satisfactory. Records maintained by the SIA administrative assistant

3. Is there a process in place that outlines how safety risk management documents are 

managed?

Status: Unsatisfactory.

Action Needed: A process must be developed to manage safety risk management 

documents.

COMPONENT 2: RISK MANAGEMENT

Element 2.1: Processes

1. Is there a description of the safety risk management (SRM) process, including 

application of the “Five Phases of SRM as discussed in AC 150/5200-37?

Status: Unsatisfactory. There is not a current SMS plan in place.
Action Needed: Provide a description of the SRM process including application of the 

“Five Phases of SRM as discussed in AC 150/5200-37.

2. Is there a structured process for the assessment of risk associated with identified 

hazards, expressed in terms of severity, level of exposure and probability of 

occurrence?

Status: Unsatisfactory. A risk management process not in place.

Action Needed: A SRM process must be developed.

3. Are there criteria for evaluating risk and the tolerable level of risk the organization is 

willing to accept?

Status: Unsatisfactory. A SRM process not in place.

Action Needed: Criteria for evaluating risk are required.

4. Does the organization have risk control strategies that include corrective and 

preventive action plans to prevent recurrence of reported occurrences and deficiencies?

Status: Unsatisfactory. A SRM process not in place.

Action Needed: A SRM process must be developed.

5. Does the organization have a process for evaluating the effectiveness of the 

corrective and preventive measures that have been developed?

Status: Unsatisfactory. A follow-up process is not in place.

Action Needed: A follow-up process must be developed.

6. Are corrective and preventive actions, including timelines, documented?

Status: Unsatisfactory. Documentation of corrective and preventative actions is not in 

place.

Action Needed: A documentation process must be developed.
7. Is there a process in place to monitor and analyze SRM related trends?

Status: Unsatisfactory. A process is not in place.

Action Needed: Develop a SRM trend analysis process.

Element 2.2: Reporting Systems

1. Does the organization have a safety reporting system for the identification of 

hazards, incidents and other data relevant to SMS?

Status: Unsatisfactory: A safety reporting system is outlined in the SIA Safety Manual. 

However, the system requires modification to reflect SMS.

Action Needed: Modify safety reporting system to reflect SMS principles.

2. Is the safety reporting process simple, accessible and commensurate with the size of 

the organization?

Status: Unsatisfactory: The safety reporting system is entirely verbal and, if not 

brought to the direct attention of the SIA Manager, is provided to him through verbal 

channels.

Action Needed: Develop a formal, simple, accessible safety reporting process.

3. Are safety reports reviewed at the appropriate level of management?

Status: Unsatisfactory: The SIA Manager advises that safety issues rise to his level 

regardless of their perceived impact upon of safety. However, since a nonverbal, 

documented safety reporting process is not in place this area is identified as 

unsatisfactory.

Action Needed: Develop a formal, simple, accessible safety reporting process that 

ensures management review.
4. Is there a feedback process to notify contributors that their reports have been 

received, and to share the results of the analysis?

Status: Unsatisfactory: The SIA Manager reports that safety reporting process is 

entirely verbal, however, feedback is regularly provided to those that initiate a report.

Action Needed: Develop a formal, simple and accessible safety reporting process that 

ensures feedback from management.

5. Is there a process in place to monitor and analyze safety trends?

Status: Unsatisfactory: The SIA Manager reports that a trend analysis program is not 

in place.

Action Needed: Develop a safety trend analysis tool/program.

6. Are corrective and preventive actions generated in response to hazard analysis?

Status: Unsatisfactory: The SIA Manager reports that problems are dealt with on a 

per issue basis. The process is more reactionary rather than preventative.

Action Needed: Develop a formal, simple and accessible safety reporting process that 

ensures corrective and preventive actions are generated in response to reported 

hazards and hazard analysis.

8. Is a process in place for analyzing changes in operations for hazards?

Status: Unsatisfactory. An analytical process is not in place.

Action Needed: Develop an analytical process.

COMPONENT: 3 SAFETY ASSURANCE

Element 3.1: Safety Audits

1. Does the organization conduct internal reviews and audits of its safety processes, 

procedures, analyses and training?
Status: Unsatisfactory: A self-inspection program exists and is outlined in the SIA 

Certification Manual. However, the focus of the program appears to be on daily 

operational inspections.

Action Needed: The development of a comprehensive internal safety audit program.

2. Does the organization conduct external reviews and audits of its safety processes,

procedures, analyses and training?

Status: Unsatisfactory. The airport is audited by the FAA and Workmen's 

Compensation representatives. However, reviews of safety specific functions by 

external parties are not conducted.

Action Needed: Create a safety-specific audit process.

3. Does the organization have a system to monitor the safety audit process and the 

completion of corrective actions?

Status: Unsatisfactory: Audits of safety specific functions by external parties are not 

conducted.

Action Needed: Develop procedures that monitor the safety audit process and the 

completion of corrective actions.

4. Are audit scope, criteria, frequency and methods defined?

Status: Unsatisfactory: A self-inspection program exists and is outlined in the SIA 

Certification Manual. However, the focus appears to be on daily operational inspections 

rather than scheduled, periodic inspections of airport safety components.

Action Needed: A process that outlines safety audit scope, criteria, frequency and 

methods requires development.

5. Is there a procedure for reporting safety audit results and maintaining records?
Status: Unsatisfactory. A safety-specific audit program does not exist.

Action Needed: A procedure for reporting safety-specific audit results and maintaining 

records is required.

6. Is there a procedure outlining requirements for timely corrective and preventive 

action in response to safety audit results?

Status: Unsatisfactory. A safety-specific audit program does not exist.

Action Needed: A procedure outlining requirements for timely corrective and preventive 

action in response to safety audit results is required.

7. Is there a process in place for auditing ramp safety at SIA?

Status: Unsatisfactory. Currently, the Airport Authority follows safety management 

and reporting practices under FAR 139 and also reports any ramp aircraft accidents to 

the National Transportation Safety Board or the Flight Standards District Office of the 

Federal Aviation Administration. A proactive ramp safety program that includes tenant 

participation and review (perhaps via a new safety committee) does not yet exist.

Action Needed: Propose a new, proactive, ramp safety program at SIA as part of the 

SMS plan.

Element 3.2: Emergency Preparedness and Response

1. Does the organization have an emergency preparedness procedure appropriate to 

the size, nature and complexity of the organization?

Status: Satisfactory. Emergency preparedness procedure is outlined in the SIA

Certification Manual.

2. Have the emergency preparedness procedures been documented, implemented and 

assigned to a responsible manager?
Status: Satisfactory. Emergency preparedness procedures are outlined in the SIA

Certification Manual, implemented and assigned to the airport manager

3. Have the emergency preparedness procedures been periodically reviewed as a part 

of the management review and after key personnel or organizational changes?

Status: Unsatisfactory. Periodic review is not conducted. Procedures are reviewed 

during Part 139 manual updates.

Action Needed: Scheduled and periodic review procedure requires development.

4. Does the organization have a process to distribute the emergency response 

plan (ERP) procedures and to communicate the content to all personnel?

Status: Satisfactory. Distribution list is available.

5. Has the organization conducted drills and exercises with all key personnel at 

intervals defined in the approved control manual?

Status: Satisfactory. Actual drills are conducted tri-annually and tabletop drills are 

conducted annually. The Airport Authority, in conjunction with local emergency 

responders, conducted a full scale test of the emergency response plan for SIA in 

October, 2006.

6. Does the airport have a phone tree for the notification of airport employees and 

tenants of an impending or existing emergency safety situation at the airport?

Status: Unsatisfactory. No phone tree exists according to the airport manager.

Action Needed: Create a phone tree that can be activated by the airport manager’s 

office in the event of an emergency.

7. Is there an existing ground evacuation plan for the airport?

Status: Unsatisfactory. One does not exist according to the airport manager.
Action Needed: Create a ground evacuation plan for SIA so that the occupants of each 

building know in advance how they are supposed to exit the airport in an emergency.

Element 3.3: Investigation and Analysis

1. Are there procedures in place for conducting accident/event investigations?

Status: Unsatisfactory. Investigative procedures currently in place apply to only FAR 

Part 139 issues. Additional investigative processes are informal.

Action Needed: Create a comprehensive accident/event investigation process

applicable to safety issues beyond the boundary of FAR Part 139.

2. Do measures exist that ensure all reported occurrences and deficiencies are 

investigated?

Status: Unsatisfactory: A formal investigative process is not in place.

Action Needed: Create a formal investigative process that addresses this issue.

3. Is there a process to ensure that occurrences and deficiencies reported are analyzed 

to identify contributing and root causes?

Status: Unsatisfactory: An analytical process does not exist.

Action Needed: Develop an analytical process.

4. Are corrective and preventative actions generated in response to accident/event 

investigation and analysis?

Status: Unsatisfactory: Corrective and preventative actions are performed following 

an FAR Part 139 accident/event investigation. However, a formal process is not in 

place for other than FAR Part 139 accidents/events.

Action Needed: Create a formal investigative process for other than FAR Part 139 

accidents/events.
COMPONENT 4: SAFETY PROMOTION

Element 4.1: Communication

1. Are there communication processes in place within the organization that allow the 

SMS to function effectively?

Status: Unsatisfactory. Processes exist in the SIA Safety Manual and Flying Safety 

Meetings. However, increased communication processes must be developed.

Action Needed: Develop communication processes that will allow the SMS to function 

effectively.

2. Does a formal airport safety committee exist at the airport?

Status: Unsatisfactory. The airport manager reported that the airport safety 

committee is composed of all airport employees. However, this committee does not 

meet regularly and does not have any committee by-laws or operating principles.

Action Needed: Examine the possibility of forming two safety committees. One for the 

Airport Authority to address internal safety/SMS matters and one used to interact with 

airport tenants (almost 70 tenants).

3. Are communication processes (written, meetings, electronic, etc.) commensurate 

with the size and scope of the organization?

Status: Unsatisfactory. Additional communication venues must be developed.

Action Needed: Identify and utilize additional communication venues.

4. Is there a process for the dissemination of safety information throughout the 

organization?

Status: Unsatisfactory. A process of dissemination is discussed in the SIA Safety 

Manual. However, the process requires modification to reflect SMS philosophies.
Action Needed: Develop a dissemination process that reflects SMS concepts.

5. Does the organization have a safety award program in place?

Status: Satisfactory. A safety award program is outlined in the SIA Safety Manual.

Element 4.2: Training, Awareness and Competence

1. Does the airport have a formalized safety-oriented training plan that addresses 

safety indoctrination for new employees as well as continuing safety education of 

existing employees?

Status: Unsatisfactory. There is a training plan, but, it is informal (not written) and 

needs to be formalized.

Action Needed: A formal training plan needs to be written for SIA employees, one for 

new employee indoctrination and one for the continuing safety education of existing 

employees.

2. Is there a formal process for systems safety management training (e. g., 

indoctrination on the basic SMS process, pillars and goals?).

Status: Unsatisfactory. There is no SMS plan in place.

Action Needed: Create a formal process for SMS training for employees and tenants 

including a plan to validate the training and provide feedback to participants.

3. Is the organization’s safety management training incorporated into indoctrination 

training upon employment?

Status: Unsatisfactory. Some airport personnel, e.g. maintenance and security police, 

receive safety training specific to their function. However, comprehensive SMS training 

is not provided to all airport employees.
Action Needed: Provide comprehensive SMS training to all employees during 

indoctrination training.

4. Is there emergency preparedness and response training for affected personnel?

Status: Satisfactory. Emergency preparedness and response training is outlined in 

the SIA Certification Manual.

5. Is there a driver training program for airport employees and non-airport employees 

who drive on the Airport Operations Area (AOA)?

Status: Unsatisfactory. A driver training program does not exist, according to the 

airport manager.

Action Needed: Create a driver training program for all airport and non-airport 

employees who drive on the Airport Operations Area (AOA).

6. Does the airport have a formal snow removal driver training plan?

Status: Unsatisfactory. A formal, written snow removal driver training plan was not 

provided in the available literature.

Action Needed: Create a formal snow removal driver training program for SIA.

7. Is there a formal aviation safety inspection training plan for airport employees who do 

the daily airport operations safety inspection of the airport?

Status: Unsatisfactory. The literature provided by the airport authority did not mention 

a formalized aviation safety inspection training plan for airport employees who do the 

daily airport operations safety inspections.

Action Needed: Create an aviation safety inspection training plan for airport employees 

who perform daily airport operations safety inspection.
8. Are non-airport personnel, e.g. construction contractors, farmers, etc. trained on the 

hazards associated with performing their functions in the airport environment?

Status: Unsatisfactory. According to the airport manager this area requires attention.

Action Needed: Create a training program to address this issue and develop a 

requirement for non-airport personnel engaged in activities on the airport to attend a 

training session.

Element 4.3: Relationships

1. Is there an adequate relationship with the FAA?

Status: Unsatisfactory. Relationship with FAA Area District Office (ADO) requires 

strengthening.

Action Needed: Increase communication and strengthen relationship with FAA ADO.

2. Is there an adequate relationship with state and local safety offices?

Status: Unsatisfactory. Increased cooperation needed between airport and state 

agencies on safety issues.

Action Needed: Communicate expectations to airport and state agencies.

3. Is there an adequate relationship with local air traffic control agencies?

Status: Satisfactory. Strong relationship exists with the local ATC facility. Open 

communication and letters of agreement in place.

4. Is there an adequate relationship with other regional airports?

Status: Satisfactory. Airport is well respected and maintains a strong relationship with 

other regional airports.

5. Is there an adequate relationship with military air traffic control agencies, if 

applicable?
Status: Not Applicable. Airport is not involved in military operations in any capacity.

6. Is there an adequate relationship with state aviation authorities?

Status: Satisfactory. Airport has an excellent relationship with state authorities.