REPORT TO CONGRESS 

Injuries and Fatalities of Workers 

Struck by Vehicles 

on Airport Aprons 

 

 

 

 Prepared by 

U.S. Department of Transportation 

Federal Aviation Administration 

Office of the Associate Administrator 

for Airports 

 

 

 

July 2002
I. Executive Summary

Section 520 of the Wendell H. Ford Aviation Investment and Reform Act for the 21st Century 

(AIR-21) required the Federal Aviation Administration (FAA) to conduct the study described 

below and report the results to Congress by April 5, 2001: 

The Administrator shall conduct a study to determine the number of persons working at 

airports who are injured or killed as a result of being struck by a moving vehicle while on an 

airport tarmac, the seriousness of the injuries to such persons, and whether or not reflective 

safety vests or other actions should be required to enhance the safety of such workers. 

A review of the FAA, Occupational Safety and Health Administration (OSHA), and Bureau of 

Labor Statistics (BLS) of the U.S. Department of Labor (DOL) databases found that between 

1985 and August 2000, 11 workers were fatally injured when struck by vehicles on airport 

aprons. Of the 11 fatalities, only two occurred between 1995 and 2000. Increased emphasis on 

ramp safety by the airline industry and airports could be a contributing factor to the decline in 

“struck by” injuries. 

The lack of comprehensive nonfatal injury data makes it impossible to determine accurately the 

number and severity of nonfatal struck by injuries. The data suggest that airline industry workers 

actually sustain significantly fewer struck by injuries than workers in most other industries. 

According to 60 airport operators responding to an August 2000 Airport Council International–

North America (ACI-NA) questionnaire, 84 struck by injuries, none of which were fatal, 

occurred between 1994 and 1999 at their airports; 98 percent of the reported injuries were at 

large or medium hubs. Questionnaire respondents reported that ramp safety could be most 

improved through training, awareness, the use of high visibility clothing, and reduced speed. 

A major airline that requires workers to wear high visibility clothing averaged 12 struck by 

injuries annually over a 31⁄2-year time period. It appeared that high visibility clothing would have 

made no difference in at least 19 percent of the injuries; no determination could be made about 

the impact of high visibility clothing in the remaining 81 percent of the incidents. 

Determining whether high visibility clothing would have prevented or reduced the severity of 

struck by apron accidents was difficult. Insufficient detail in accident descriptions and the recent 

implementation by airlines and airports of high visibility clothing requirements for workers cloud 

cause/effect analysis. None of the accident reports addressed whether the victim was wearing 

high visibility clothing. 

The analysis of struck by fatalities and injuries conducted as part of this study was inconclusive 

as to the effect high visibility clothing would have had in preventing these accidents. However, 

the information provided by the airlines and airports suggests that an overall ramp safety 

program that includes high visibility clothing would enhance the occupational safety of airport 

apron workers. 

Page i
 Table of Contents 

I. Executive Summary i 

II. Introduction 1 

A. Background 1 

B. Purpose 1

C. Scope 1

III. Approach 2 

A. Injury Data Review 2 

1. General 2 

2. Definitions 2 

3. Review of Standards and Requirements 2 

4. Databases 2 

5. Supplemental Data Sources 3 

B. Occupational Safety and Health Requirements, Practices, 

 and Enhancements 4 

C. High Visibility Clothing and Other Safety Enhancements for 

Apron Workers 4 

 

IV. Regulatory and Jurisdictional Considerations 5 

V. Findings 5 

A. Fatal Injuries 5 

1. OSHA Database 5 

2. FAA Database 7 

3. BLS Database 7 

4. Input from Airlines 8 

5. ACI Survey Information 8 

6. ACI–NA “Struck By” Questionnaire 8 

7. Summary of Fatal Injuries 8 

 

B. Nonfatal Injuries 10 

1. OSHA, FAA, and BLS Data Sources 10 

2. Supplemental Data from Airlines 11 

3. Supplemental Data from Airline A 11 

4. Supplemental Injury Information from Airline B 12 

5. ACI Survey 13 

6. ACI–NA “Struck By” Questionnaire 13 

a. Airport Size 13 

b. Significance of Struck By Injuries to Overall Safety 13 

c. High Visibility Clothing 14 

 

VI. Conclusions 16 

 

Page ii
List of Tables

Table Page

1 Summary of Fatal Struck By Injuries to Workers on Airport Aprons, 

1985 through 1999 6 

2 Summary Reports of Fatal Struck By Injuries Since 1985 from the FAA’s

Accident Investigation Database of Ramp/Gate Accidents 8 

3 Total Job-Related and Struck By Fatalities Reported by the Bureau of 

Labor Statistics for 1998: Fatalities for Selected Industries 9 

4 Summary of Nonfatal Struck By Injuries Since 1985 from the FAA’s 

Accident Investigation Database of Ramp/Gate Accidents 10 

5 Summary of Airport Operator Responses Rating Apron Struck By Injuries 

in Terms of Overall Safety Concerns by Airport Type and Number of 

Injuries from the ACI–NA “Struck By” Questionnaire 14 

6 Summary of Injuries According to High Visibility Clothing (HVC) 

Requirements of Airport Operators and Airport Size from the ACI–NA 

“Struck By” Questionnaire 15 

7 Summary of Injuries at Airports with Tenant Requirements for High 

Visibility Clothing (HVC) from the ACI–NA “Struck By” Questionnaire 15 

8 Summary of Airport Operator Opinions of Worker Compliance with High 

Visibility Clothing Requirements from the ACI–NA “Struck By” 

Questionnaire 16 

9 Airport Operator Opinions About Impacts of High Visibility Clothing by 

Tenant Requirements from the ACI–NA “Struck By” Questionnaire 17 

Figures 

Figure Page

1 Types of Vehicles Involved in Nonfatal Struck By Injuries, 1997 through 

April 2000 12 

Appendices 

Appendix Page 

A Definition of Terms from Section 520 of the Wendell H. Ford Aviation 

Investment and Reform Act for the 21st Century 18 

B ACI–NA Questionnaire on Workers Being Struck By Vehicles on Airport

Aprons and High Visibility Clothing 19 

C Discussion of High Visibility Clothing Relative to Apron Workers 21 

D Summary of Responses from the ACI–NA “Struck By” Questionnaire: 

Suggested Actions to Improve Worker Safety on Airport Aprons 25 

E Summary of Response for Comments, Suggestions, or Study Input 

to the ACI–NA “Struck By” Questionnaire 27 

F Sources of Information 28 

G References 30

Page iii
II. Introduction

A. Background 

Airport aprons are unique and potentially hazardous work environments. Servicing, maintaining, 

and supporting aircraft operations require all-weather efforts and minimal aircraft turnaround 

time by cargo handlers, fuelers, lavatory and water system servicers, catering support, snow 

removal workers, Government representatives, aircraft and equipment servicers, maintenance 

workers, and others. Work is fast paced to meet airline schedules. Aprons are congested, noisy, 

and packed with a diverse fleet of vehicles, traveling at a variety of speeds. 

In 1998, the BLS, the Nation's keeper of information on workplace fatalities and injuries, 

reported that 6.9 percent of all job-related fatalities nationwide resulted from workers being 

struck by vehicles. The largest number of fatalities occurred in the highway and street 

construction industry; air transportation, meanwhile, exhibited one of the lowest fatality rates. 

The possibility of being struck by vehicles on the airport apron, however, is one of the 

occupational hazards that face apron workers, and until this report, there was little quantification 

or analysis of “struck by” injuries to these workers. 

B. Purpose 

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (AIR-21) 

required the FAA to study injuries to airport apron workers who were struck by a vehicle and to 

investigate actions that could enhance apron worker safety. Section 520 of AIR-21 states the 

following: 

The Administrator shall conduct a study to determine the number of persons working at 

airports who are injured or killed as a result of being struck by a moving vehicle while on 

an airport tarmac, the seriousness of the injuries to such persons, and whether or not 

reflective safety vests or other actions should be required to enhance the safety of such 

workers.

C. Scope 

Though airport apron workers suffer occupational injuries from a variety of causes, this report 

considered only those injuries, fatal and nonfatal, to workers struck by a vehicle on an airport 

apron. For brevity, such injuries are referred to as “struck by” injuries. The report identifies 

possible remedial occupational safety actions that might prevent or reduce the number or severity 

of struck by injuries and evaluates safety vests or high visibility clothing only in terms of their 

general effectiveness. It was not the charge or intent of this report to evaluate design, 

performance specifications, and visibility requirements for specific high visibility garments—

aspects of HVC that American National Standards Institute (ANSI), Inc., standards, 

American National Standard for High-Visibility Safety Apparel, thoroughly address1

. 

 

Page 1

1 ANSI is a private, non-profit organization that administers and coordinates the U.S. voluntary standardization and conformity

assessment system.
III. Approach 

A. Injury Data Review

1. General 

In this report, the FAA establishes common definitions for terms contained in AIR-21, reviews 

standards and requirements, identifies and searches available Federal databases for injury 

information, investigates other sources of data to fill information gaps, and evaluates common 

industry practices. 

2. Definitions 

As the first task, the FAA established definitions for the terms listed in AIR-21 since definitions

vary within and between agencies. In the DOL, OSHA established definitions and 

recordkeeping guidelines for the injury and illness data logged by the BLS. However, these 

terms did not always match those used within the Department of Transportation (DOT) by the 

FAA or the Federal Highway Administration (FHWA). 

This report includes the OSHA definition of “vehicle,” rather than the FHWA definition, 

because it is consistent with the BLS and OSHA data used. Terms such as “tarmac” and 

“safety vest” have no established Federal definitions, so the FAA extrapolated definitions from

other Federal definitions and industry terminology. In addition, the terms airport “apron” or 

“ramp” take the place of “tarmac,” and “high visibility clothing” substitutes for “safety vests” 

since high visibility clothing comprises any of a variety of garments that increases the 

conspicuity of the wearer. The definitions used in this report appear in Appendix A. 

3. Review of Standards and Requirements 

The FAA reviewed Federal safety and health requirements, standards, and regulations to identify 

possible sources of data, jurisdictional issues, and current safety requirements applicable to apron 

workers. 

4. Databases 

The FAA determined that in conjunction with its own database, the databases of the BLS and 

OSHA contained the most comprehensive national data on fatal and nonfatal struck by injuries; 

however, data on nonfatal injuries from these sources were limited. The report makes use of 

1985 through August 2000 data from these sources as well as OSHA accident investigation 

report summaries of fatal injuries, which the author reviewed in detail for similarities, potential 

trends, and actions that could be taken to enhance worker safety. 

Page 2

Data on nonfatal injuries were more difficult to obtain. The level of detail contained in the FAA 

and OSHA databases made it difficult to determine if the reported injuries met the struck by 

definition of this report. Reported BLS data made use of the occupational structure of the DOL’s 

Standard Occupational Classification Manual, which provides different levels of aggregation 

(Major Group, Minor Group, Broad Occupation, and Detailed Occupation) as well as 

occupational titles and definitions. While the levels of data aggregation were not sufficiently 
detailed to quantify struck by injuries on airport aprons, the FAA used the BLS injury data to 

make relative comparisons with other industries. 

Some contend that to be useful, injury and illness data must be reported in greater detail. In a 

statement issued by the International Safety Equipment Association (ISEA) at the FAA’s Airport 

Worker Safety Public Hearing on December 10, 1999, for example, ISEA argued that the BLS 

data for struck by injuries were inadequate due to the absence of a “site” code for airports. ISEA 

suggested that improved data quality would assist employers, health and safety professionals, the 

Government, and suppliers in determining risk exposures for employees in the air transportation 

system. 

5. Supplemental Data Sources 

In the absence of comprehensive national data on nonfatal injuries of apron workers, the FAA 

evaluated information from a variety of other sources from which injury occurrence rates and 

severity could be assessed. The FAA contacted several major airlines, airports, air carriers, and 

smaller airlines during the course of this study and asked them to provide corporate data. There 

were no standard reporting criteria, so the amount and format of data varied substantially with 

the source. Each supplemental data source was evaluated separately. The report incorporates data 

as it was provided, and with only a few exceptions, the information was not verified. The 

supplemental data sources asked that individual companies and airports remain anonymous; 

therefore, data are provided without mentioning either the location or source or are presented in a 

consolidated form. 

One major airline, referred to as “Airline A,” allowed the FAA to view, analyze, and evaluate 

internal data specifically related to employees who suffered struck by injuries between 1997 and 

mid-2000. Other airlines, including a major airline referred to as “Airline B,” provided 

information on the number of injuries that occurred between 1999 through May 2000. 

The Airports Council International (ACI)—a nonprofit, international organization whose mission 

is to foster cooperation among its member airports and governmental, airline, and aircraft 

manufacturing organizations to improve aviation worldwide—provided supplemental injury and 

accident information. ACI has a membership of 550 airports operators; these members operate 

over 1,442 airports in 165 countries and territories. Through member surveys, ACI has evaluated 

all aspects of airport apron safety, including accident trends and apron safety-related activities 

initiated by airports, and has tracked the number of incidents and accidents involving worker 

injuries and damage to aircraft or equipment. 

In June 1997, ACI adopted a resolution on apron safety that in part called for reporting all 

incidents and accidents occurring on the movement area to the airport operator. In 1999, ACI 

expanded their annual “Survey of Apron Incidents/Accidents” to include data for a full calendar 

year. ACI defines “accident” in terms of both injuries and aircraft damage and “incident” as an 

occurrence other than an accident that could affect safe aircraft operation. The 1999 data, 

released in September 2000, contained information from 341 airport operators around the world. 

While this information provided insight into overall apron safety, it did not separate struck by 

injuries from other causes of apron worker injuries. 

Page 3
Airports Council International–North America (ACI–NA), the largest region of the worldwide 

ACI, represents approximately 150 airport operators in the United States and Canada. In 

August 2000, ACI–NA sent member airports in the United States a “Questionnaire on Workers 

Being Struck by Vehicles on Airport Aprons and High Visibility Clothing” (Appendix B). This 

survey, the results of which ACI–NA allowed the FAA to review, addressed issues relevant to 

the charge of AIR-21. 

Sixty airport operators returned surveys. Since some members represented airport systems with 

more than one airport, the data encompassed a total of 68 airports in the United States. During 

data evaluation for this report, the FAA chose to consider each questionnaire as reporting for an 

airport rather than a system, a method believed acceptable since none of the airport systems 

reported more than two injuries. In the evaluations requiring airport size, the FAA reported the 

questionnaire results based on the largest airport in the system. 

B. Occupational Safety and Health Requirements, Practices, and Enhancements 

The FAA sought to identify recommendations of recognized safety and health organizations and 

current industry practice, nationally and internationally. The ACI–NA questionnaire provided 

insight from the perspective of airport operators relative to suggestions for improving the safety 

of airport apron workers. The FAA examined information specific to the effectiveness and 

applicability of high visibility clothing to the aviation industry and in other industries. 

C. High Visibility Clothing and Other Safety Enhancements for Apron Workers

The author conducted a literature review of high visibility clothing —garments designed to make 

wearers stand out from their surroundings. High visibility clothing may include vests, jackets, 

bib/jumpsuit coveralls, trousers, or harnesses. 

Highway safety experts have conducted much of the high visibility clothing research on 

pedestrians. Studies at the University of Michigan concluded that reduced visibility contributes 

significantly to pedestrian accidents at night. In addition, the Virginia Transportation Research 

Council found that fluorescent colors enhanced the daytime conspicuity of highway worker’s 

clothing. Safety professionals recommend different types of clothing depending on lighting 

conditions, job responsibilities, and background. 

Appendix C contains the results of the high visibility clothing review, which addresses the 

following sources: the ANSI’s American National Standard for High Visibility Safety Apparel, 

adopted June 1, 1999; DOT requirements; the OSHA General Duty Clause and personal 

protective equipment requirements; an OSHA opinion regarding high visibility clothing for 

apron workers; results from the ACI–NA “Struck By” Questionnaire; high visibility clothing 

requirements at O’Hare International Airport and Midway Airport; British requirements; 

U.S. Air Force requirements; and National Safety Council recommendations. 

IV. Regulatory and Jurisdictional Considerations 

Page 4

Section 4 (b)(1) of the Occupational Safety and Health Act of 1970, Public Law 91-596 (OSH 

Act), allows other Federal agencies to prescribe or enforce standards or regulations affecting 

occupational safety or health. On July 2, 1975, the FAA exercised this authority in 40 FR 29114, 
“Notice of Occupational Safety or Health Standards for Aircraft Crewmembers.” The FAA 

claimed exclusive responsibility for prescribing and enforcing occupational safety and health 

standards for U.S.-registered civil aircraft in operation. The term “in operation” was defined as 

the time from when a crewmember, preparatory to a flight, first boards an aircraft to the time 

when the last crewmember leaves the aircraft after the completion of that flight, including stops 

on the ground during which at least one crewmember remains on the aircraft, even if the engines 

are shut down. 

On December 10, 1999, the FAA held a public meeting on “Occupational Safety and Health 

Issues for Airline Employees.” The Federal Register notice for the meeting (64 FR 56275, 

October 19, 1999), dated October 4, 1999, listed several specific issues impacting apron workers 

on which the FAA sought comments. In August 2000, the FAA and OSHA issued a joint 

Memorandum of Understanding (MOU) to enhance safety and health in the aviation industry. 

The MOU states, “With respect to other aviation industry employees, such as maintenance 

personnel and ground support personnel, OSHA has been enforcing, and will continue to 

enforce, OSHA requirements to the extent allowed under Section 4(b)(1) of the OSHA [sic] Act.” 

The MOU established a process for the FAA and OSHA to develop a procedure for coordinating 

and supporting enforcement of the OSH Act with respect to the working conditions of employees 

in aircraft in operation (other than flight deck crew), for resolving jurisdictional questions, and 

for review of the 1975 notice. In December 2000, the FAA/OSHA Aviation Safety and Health 

Team released their first report, Application of OSHA’s Requirements to Employees on Aircraft 

in Operation. This report addresses recordkeeping and other issues but nothing specifically 

related to struck by injuries or high visibility clothing. 

V. Findings 

A. Fatal Injuries 

1. OSHA Database 

Between 1985 and August 2000, the OSHA database reported nine fatal job-related struck by 

injuries to workers on airport aprons, only two of which occurred after 1995. With one 

exception, the OSHA data reviewed for this report did not specify the airport’s location. Table 1 

provides a summary listing of the fatalities. Using the OSHA accident investigation reports, 

which varied in detail, the FAA reviewed the following types of information: lighting conditions, 

employee information, type of vehicle striking workers, type of accident, and possible causes. 

Using the limited information provided by the accident reports, we evaluated each fatality to 

determine the possible impact that high visibility clothing might have had in preventing or 

reducing the severity of each accident and found the following: 

• Lighting conditions may have been a factor in at least six of the fatal accidents. All accident 

summary reports that listed the time of the fatal injuries showed the accident occurred during 

darkness or low-light conditions. 

• Five of the nine fatally injured workers identified in the OSHA database were killed by a 

vehicle backing up—an activity during which an operator’s field of vision is limited. 

Page 5
• None of the OSHA accident reports listed whether the fatally injured worker was wearing 

high visibility clothing, making it difficult to determine the impact such clothing might have 

had on the accidents. Since many companies over the past several years have required or 

enforced existing company policies requiring that apron workers wear high visibility clothing, 

some of the fatally injured workers may have been wearing high visibility clothing when 

struck. 

Table 1 

Summary of Fatal Struck By Injuries to Workers on Airport Aprons 

1985 through 1999 

from the OSHA Database 

Source: OSHA Accident Search Detail

Date/ 

Local 

Time if 

Known

Employer 

Information 

Description of Accident Possible Cause/ 

Contributing

Factors 

10/24/98 

Time not 

reported 

Aviation Support 

Worker

A worker was struck in the back by a fuel truck 

that was backing up after fueling an airplane. 

Fuel truck did not 

have a spotter. 

3/27/97 

6:40 PM 

Airline

Wingwalker 

A wingwalker was run over by the moving 

aircraft when he moved forward to retrieve a 

headset cord used to communicate with the 

aircraft’s flightcrew during push back. 

Inattention 

7/25/94 

12:05 AM 

Aviation Support 

Worker

An equipment operator backed into the 

coworker directing him, crushing the worker 

against a parked piece of equipment. 

Inattention 

7/11/91 

12:55 AM 

Inspector for 

Airport 

A loading truck on an airport construction

project backed over a construction inspector. 

Noise, 

communication 

3/15/91 

7:27 PM 

Airline Worker A service vehicle struck an employee walking 

from an airplane in the passenger crosswalk. 

Inattention 

12/18/90 

Time not 

reported 

Airline 

Wingwalker 

A tug used to push a jet into takeoff position 

backed over a wingwalker. 

11/14/88 

Time not 

reported 

Air Freight/ 

Delivery Worker

A motorized vehicle used to deliver and pick up 

packages struck an employee. 

11/07/88 

8:00 PM 

Airline 

Wingwalker 

A fuel truck struck a wingwalker wearing a 

yellow rain slicker and raising lighted wands to 

signal vehicular traffic to stop for an aircraft. 

Weather was rainy and foggy. 

Poor visibility

11/20/86 

6:20 AM 

Aviation Support 

Worker

A forklift struck an employee. Obstructed view, 

inattention 

• Followup information on the November 7, 1988, fatality found that OSHA determined that 

high visibility clothing might have helped the worker. 

• Due to the nature of the accident, it is doubtful that high visibility clothing would have made 

any difference in the March 27, 1997, fatality in which an aircraft backed over an employee. 

Page 6
2. FAA Database 

The FAA database listed three struck by fatalities since 1985 (Table 2). In all cases, the accidents 

occurred during aircraft pushback. On two occasions, an aircraft struck the fatally injured 

worker. The third worker was killed after being struck by the tug used in pushing back the 

aircraft. Reports from the National Transportation Safety Board (NTSB) provided additional 

information on these fatalities, which are described below. 

Both the FAA and OSHA databases listed the March 27, 1997, fatality of a wingwalker for a 

major airline who died after being run over by an aircraft he was helping to push back. A pilot’s 

visibility relative to apron workers on the ground is extremely limited, so radio communication is 

used. The wingwalker was killed when he walked in front of the plane’s nose gear to retrieve the 

headset cord used in radio communication with the flightcrew. High visibility clothing would 

probably not have made any difference in this accident. 

The OSHA database did not contain the other two accident reports. In both cases, the worker 

stumbled while the aircraft was being pushed back. In the San Juan, Puerto Rico, accident on 

July 12, 1989, the NTSB reported that the nose gear tires of the aircraft rolled over the worker’s 

upper body after the worker stumbled as he walked behind the nose gear for at least the second 

time. NTSB cited the probable cause as failure of the ramp guide to follow normal safety 

procedures and a contributing factor as the worker’s over confidence in his personal ability. It is 

unlikely that high visibility clothing would have influenced the outcome of the accident. 

According to the NTSB, the worker killed on December 8, 1992, was using a 15-foot headset 

cord, which restricted his ability to stay clear of the nosewheel, tug, and towbar. The tug operator 

reported seeing the worker fall in his peripheral vision and being unable to stop the tug before it 

struck the worker. NTSB cited the lack of adequate clearance between the wingwalker and the 

tug as a probable cause of the accident. The tug operator saw the worker fall, so it does not 

appear that high visibility clothing would have had any impact on the outcome.

3. BLS Database 

Table 3, which uses 1998 BLS data specific to workers struck by vehicles, compares fatal 

injuries of airport workers to those of other industries. According to the OSHA database, there 

was one struck by fatality reported on an airport apron in 1998; however, a single fatality was not 

enough to meet the BLS reporting criteria. Of the total 413 job-related struck by fatalities in 

1998, the Transportation and Public Utilities industry accounted for 19.6 percent (81 fatalities). 

Although this was the second-highest percentage, following construction with 24.9 percent 

(103 fatalities), reported for an industry that year, the air transportation group represented only a 

fraction or 0.2 percent (1 fatality) of the total. 

Page 7
Table 2 

Summary Reports of Fatal Struck By Injuries Since 1985 

from the FAA’s Accident Investigation Database 

of Ramp/Gate Accidents 

Date Airline Location Accident Summary

07/12/89 American San Juan

(SJU) 

A ramp worker was killed by an aircraft on pushback. 

12/08/92 USAir New York

(LGA) 

A ground worker was fatally hit by a tug on aircraft pushback. 

03/27/97 Delta New York

(JFK) 

On pushback, the nose gear of an aircraft struck and killed a

wingwalker.

Source: FAA’s Accident Investigation Database of Ramp/Gate Accidents

 

4. Input from Airlines 

The supplemental database from a major airline, Airline A, covered injuries occurring in 

calendar year 1997 through mid-2000. Data were consistent with OSHA and FAA databases and 

did not reveal any additional fatalities. Discussions with several other airlines similarly did not 

reveal any additional fatalities unaccounted for in the Federal databases. 

 

5. ACI Survey Information 

The 310 airport operators responding to the 1999 ACI “Survey of Apron Incidents/Accidents” 

reported 11 fatal apron accidents worldwide, none of which occurred in the United States. This is 

consistent with the FAA and OSHA databases. In 1999, ACI recorded a total of 4,893 apron 

accidents and incidents among the 23,476,235 aircraft movements worldwide for a total of one 

incident per 4,798 aircraft movements or one fatality for every 2,134,203 movements. 

6. ACI–NA “Struck By” Questionnaire 

Airport operators responding to the August 2000 ACI–NA questionnaire reported three fatal 

struck by injuries between 1994 and 1999. The FAA contacted the two airport authorities 

reporting the deaths and concluded that one fatality was the same as the July 11, 1991, death 

reported in the OSHA database. In the cases of the two other deaths, the airport authority 

verified that two apron workers had been killed in separate incidents, but neither worker was 

struck by a vehicle. Consequently, these deaths were not included in this report; the number of 

struck by fatalities remained unchanged by this data. 

7. Summary of Fatal Injuries 

In summary, there were nine struck by fatalities included in the OSHA database between 1985 

and August 2000. For this same period, the FAA database contained three fatal injuries to 

workers who were struck and killed during pushback of an aircraft. Only one of these injuries 

was contained in the OSHA database; the other two were not. Using these two data sources, the 

FAA identified 11 fatal struck by injuries since 1985, only two of which occurred after 1995. 

Page 8
Table 3 

Total Job-Related and Struck By Fatalities 

Reported by the Bureau of Labor Statistics for 1998: 

Fatalities for Selected Industries 

Industry

Total Fatalities 

in Industry

Struck By Fatalities 

in Industry†

% of Fatalities in 

Industry Division,

Group, or Subgroup 

Due to Struck By Events

Total 6,026 413 6.9 

Agriculture, Forestry, and Fishing

(SIC Division A) 831 48 5.8

Mining (SIC Division B) 146 -* -*

Construction (SIC Division C) 1,171 103 8.8

Heavy Construction, Except Building 

Construction (SIC Group 16) 271 71 26.2 

Highway and Street Construction 

(SIC 1611) 104 45 43.3

Other Subgroups 167 26 15.6 

Other Groups 900 32 3.6 

Manufacturing (SIC Division D) 694 31 4.5

Transportation and Public Utilities

(SIC Division E) 909 81 8.9 

Railroad Transportation (Group 40) 17 4 23.5 

Trucking and Warehousing (Group 

42) 562 56 10.0

Water Transportation (Group 44) 52 8 15.4 

Air Transportation (Group 45) 74 -* (1) -* (1.4) 

Scheduled Air Transportation 

(SIC 4512) 8 - - 

Air Courier (SIC 4513) 13 -* -* 

Nonscheduled Air 

Transportation (SIC 4522) 41 -* -* 

Airports, Flying Fields, and 

Services (SIC 4518) 10 -* (1) -* (10.0) 

Other Subgroups 2 0 0.0 

Communications, Electric, Gas, and 

Sanitary Service (Group 48) 83 9 10.8 

Other Groups 121 4 3.3 

Wholesale Trade (SIC Division F) 228 9 3.9

Retail Trade 569 23 4.0

Finance, Insurance, and Real Estate 92 -* -*

Services 757 51 6.7

Public Sector 598 65 10.9

Other Divisions 31 2 6.5

*BLS states that data was not listed because it did not meet the publication criteria. Numbers in parentheses were added based

on an OSHA fatality report shown in Table 1.

† Bold added by author for emphasis.

Note: BLS reports that percentages may not add up to 100 because of rounding. 

Source: BLS Table of Fatal Occupational Injuries 

Resulting from Transportation Incidents and Homicides by Industry, 1998 

Table A-2, reported 8/4/99 

Page 9
In one of the fatal accidents listed in the OSHA database, OSHA investigators determined high 

visibility clothing might have prevented or lessened the severity of the injury. The circumstances 

of the three fatal injuries in the FAA database (one of which also appeared in the OSHA system) 

seem to indicate that high visibility clothing would have made no difference to the outcome of 

those accidents. No determination could be made about the impact of high visibility clothing on 

the remaining seven accidents in the OSHA database. 

B. Nonfatal Injuries 

1. OSHA, FAA, and BLS Data Sources 

Standard, comprehensive data from OSHA were not available to assess accurately nonfatal 

injuries to airport apron workers who had been struck by a vehicle. Though the BLS maintains 

data of nonfatal lost-time injuries by event and industrial classification, the database 

distinguishes the struck by injuries only by the broad industry categories. The air transportation 

industry (Group 45) was responsible for only 1 percent (1 fatality) of the 81 fatalities within the 

transportation and public utilities category (Table 3). Assuming the industry was responsible for 

an equal number of nonfatal injuries, of which BLS reported there were 1,268 in 1998, there 

would have been about 100 nonfatal injuries nationwide to air transportation workers (including 

air couriers), and of these, only a fraction would have been struck by vehicles in parking lots or 

nonroadway areas. 

Table 4 contains accident summaries from the FAA database. In every case, an aircraft struck the 

worker. There was insufficient detail in the database to determine conclusively if high visibility 

clothing would have made a difference, but given the cockpit crew’s constrained field of vision, 

the FAA concluded it was unlikely that high visibility clothing would have prevented or reduced 

the severity of injuries. 

Table 4 

Summary of Nonfatal Struck By Injuries Since 1985

from the FAA’s Accident Investigation Database 

of Ramp/Gate Accidents 

Date Airline Location Accident Summary

11/06/89 America West Phoenix, AZ On aircraft pushback, a ground handler walked under the 

fuselage and stumbled. With the tug driver unable to stop, the

nose gear ran over the worker, seriously injuring him. 

03/21/92 United Phoenix, AZ On aircraft pushback, a ramp agent was run over by the nose

gear, crushing and severing a leg.

3/27/92 American Hayden, CO The nose wheel ran over an agent’s foot and leg on pushback. 

The worker was seriously injured.

11/13/92 Delta Atlanta, GA On pushback, a ground worker was seriously injured when he

became entangled in the left main gear. The worker’s legs were

run over. 

12/22/96 Sun Country Las Vegas, 

NV 

On pushback, a DC-10 hit a ramp worker. The worker sustained 

serious injuries. 

Source: FAA’s Accident Investigation Database of Ramp/Gate Accidents

Page 10
2. Supplemental Data from Airlines 

 

A number of airlines were contacted for information on struck by injuries. None of the airlines 

interviewed, including Airlines A and B, thought that struck by injuries were the most pressing 

occupational safety hazard for apron workers, and most stated that preventing or reducing struck 

by accidents should be considered as part of an overall ramp safety program. 

3. Supplemental Data from Airline A 

Airline A, a major airline, allowed the FAA to review approximately 31⁄2 years of struck by 

injury information in their database. During the time period in which the data was gathered, 

Airline A required apron workers to wear high visibility clothing at all times; however,

compliance with this company policy varied. 

Forty-two injuries, an average of 12 per year, met the struck by criteria of the report. Airline A’s 

data did not list the time of occurrence, employee duties, or possible causes, so the FAA could 

not correlate the data with the findings from the OSHA and BLS databases. 

Airline A tracked injury information in terms of insurance costs. Thirty-six percent of the claims

were less than $500 and nearly 20 percent were over $5,000. Two claims exceeded $100,000. 

Over 76 percent of the injuries were to the legs or feet; in six of the accidents, worker's feet were 

injured when coworkers ran over them. In general, the most costly injuries were those to a 

worker’s abdomen, chest, or back. 

Figure 1 shows a distribution of injuries based on the types of vehicles striking the worker.2

 A 

tractor (also referred to as tug) was most frequently the striking vehicle. In general, it appeared 

workers struck by larger vehicles suffered more serious injuries in terms of cost. 

Airline A does not define an aircraft as a vehicle; therefore, any incidents of workers being 

struck by aircraft would not be reflected in the data. Since the FAA database does not list any 

workers struck by aircraft during this timeframe, the author concluded that Airline A probably 

did not experience any such accidents. Under the OSHA definition, dollies are not considered 

vehicles, yet dollies were responsible for injuries in 7 percent of the cases reported by Airline A. 

In the 42 nonfatal accidents reported by Airline A, high visibility clothing would probably not 

have made any difference in at least 8 (19 percent) of the occurrences, which included such 

accidents as a driver accelerating rather than braking, equipment malfunction, and workers 

whose feet were run over because they left the equipment they were operating in gear when they 

got out. For the remaining 34 accidents, the data were not sufficiently detailed to determine if the 

injured workers were wearing high visibility clothing or if a failure to wear high visibility 

clothing played a role in their accidents. In at least 1 accident, in which a worker's foot was 

injured, the worker was in the process of putting on her safety vest when the accident occurred. 

 

Page 11

2

 The term “cargo/jet veyor” used in Figure 1 is used by airlines to describe cargo/baggage conveyors and loaders. 
Figure 1 

Types of Vehicles Involved in Nonfatal Struck By Injuries 

1997 through April 2000 

from the Airline A Supplemental Database

Dollies are not considered a vehicle by the OSHA definition that was adopted for this report.

Type of Vehicles Striking Apron 

Workers Cargo/Jet

Veyor (6)

14%

Cart (2)

5%

Truck (2)

5%

Dolly (3)

7%

Other (2)

5%

Tractor/tugs

(22)

52%

Vans (5)

12%

Source: Accident summary information 

from a major airline that asked to remain anonymous 

Though Airline A serves airports of all sizes, all injuries in the database were sustained at large 

hub airports.3

 Not surprisingly, the greatest numbers of injuries were reported at the airports 

where the airline has hub operations. 

4. Supplemental Injury Information from Airline B 

Airline B, a major airline that requires apron workers to wear high visibility clothing, reported 

that with a workforce of approximately 50,000 workers, there were 11 vehicle-related accidents 

on airport aprons that resulted in lost work time in 1999 and 10 accidents reported in the first 

three quarters of 2000. Not all of these accidents, however, met the struck by criteria defined in 

this report. The most costly injury, for instance, involved a nonstruck by injury in which a driver 

fell from a belt loader that then proceeded, unmanned, to hit an object that forced a dolly into 

another worker. 

 

3

 The FAA classifies passenger service airports in terms of percent of total national 

enplanements. A large hub airport enplanes 1.00 percent or more; a medium hub, 0.25 to 

0.99 percent; a small hub, 0.05 to 0.24 percent; and a nonhub, less than 0.05 percent. 

Page 12
None of the 21 reported accidents were fatal. A representative of Airline B reported 

100-percent compliance with the high visibility clothing requirements. 

5. ACI Survey 

The 1999 ACI “Survey of Apron Incidents/Accidents” included all apron injuries, regardless of 

cause, reported by 310 airports worldwide. In that calendar year, there were 172 severe injuries 

and 1,228 minor injuries, which is less than one apron worker injury for every 16,000 aircraft 

movements. This study also examined data from the month of November 1999 and found that in 

terms of overall accident and incident rates, the incident rate at smaller airports, those with fewer 

than 6,000 movements, was 18 percent lower than that of larger airports. The rate for damage to 

equipment and facilities was 48 percent lower at the smaller airports, but the rate for damage to 

aircraft was 36 percent higher. The data were too general to draw conclusions regarding the 

impact of high visibility clothing on these incidents.

6. ACI–NA “Struck By” Questionnaire 

Sixty U.S.-member airport operators of ACI–NA responded to the “Struck By” Questionnaire, 

though not every airport answered every question. Of the respondents, 87 percent reported that 

they tracked injuries and deaths occurring on their airport aprons. Though eight airports, 

including three nonhubs, two small hubs, three medium hubs, and one large hub, reported they 

did not track injuries, all provided data. Of these nontracking airports, six reported no injuries; 

two medium hub airports reported one and nine injuries, respectively. 

There were no struck by injuries reported by 45 airport operators. The remaining 15 respondents 

reported a total of 84 injuries between 1994 and 1999. The most struck by injuries reported by a 

single airport, 18, occurred over a 5-year period for an average of 3.6 injuries per year. 

 

a. Airport Size 

Airport operators responding to the ACI–NA “Struck By” Questionnaire represented 15 large 

hubs, 17 medium hubs, 17 small hubs, and 11 nonhubs. Eighty percent of the reported injuries in 

the survey occurred on the aprons of large hub airports, 18 percent at medium hubs, 2 percent at 

small hubs, and none at nonhubs. The increased activity at large and medium hub airports often 

necessitates more complex apron configurations. 

Of the 84 injuries, 69 (82 percent) occurred at only six airports—five of which were large hubs 

and one was a medium hub that reportedly did not track injuries. At the five large hub airports, 

18, 14, 11, 9, and 8 injuries occurred. 

b. Significance of Struck By Injuries to Overall Safety 

The ACI–NA “Struck By” Questionnaire asked airport operators, “How would you rate workers 

being struck by vehicles on your airport in terms of overall safety concerns?” Table 5 

summarizes the operators’ responses. 

Page 13
There appears to be a relationship between the number of injuries per airport and the significance 

airport operators attribute to the problem. In general, those operators experiencing higher 

numbers of injuries rated the problem as more significant. 

c. High Visibility Clothing 

The ACI–NA “Struck By” Questionnaire provided yes/no response boxes for the question, 

“Does your airport require safety vests or other high visibility clothing?” A followup question 

asked under what conditions the clothing must be worn. Table 6 shows the survey results for 

high visibility clothing by airport size and number of injuries. 

Since the survey did not address when the high visibility clothing requirements went into effect, 

the FAA could not determine whether the airport operators enacted requirements in response to 

accidents or if injuries occurred despite the high visibility clothing. 

The ACI–NA “Struck By” Questionnaire asked airport operators if tenants, such as airlines, 

required high visibility clothing. Table 7 compares injuries with tenant requirements. Over 

57 percent of the airport operators reported that all or most of their tenants had requirements for 

high visibility clothing. Using a rough comparison of average injuries per airport, the FAA 

determined the lowest rate of injuries (where there was more than one airport reporting) occurred 

where all tenants required high visibility clothing. 

Table 5 

Summary of Airport Operator Responses 

Rating Apron Struck By Injuries in Terms of Overall Safety Concerns 

by Airport Type and Number of Injuries 

from the ACI–NA “Struck By” Questionnaire

HUB Size

Rating Large Medium Small Non Totals 

Extremely Serious 1 1 1 0 3 

Total Injuries Reported 

Avg. Injuries per Airport 

(9) 

9 

(9) 

9 

(0) 

0 

- (18)

6 

Serious 1 1 0 0 2

Total Injuries Reported 

Avg. Injuries per Airport 

(0) 

0 

(0) 

0 

- - (0)

0 

Moderate 4 1 1 0 6

Total Injuries Reported 

Avg. Injuries per Airport 

(32)

8 

(0) 

0 

(0) 

0 

- 

- 

(32)

4 

Fatalities (1) (0) (0) - (1)

Important, Not Critical 4 6 8 4 22 

Total Injuries Reported 

Avg. Injuries per Airport 

(15)

3.75 

(3) 

.5 

(2) 

.25 

(0) 

0 

(20)

.9 

Not Significant 4 8 7 7 26 

 Total Injuries Reported 

 Avg. Injuries per Airport 

(11)

2.75 

(3) 

.375 

(0) 

0 

(0) 

0 

(14)

.53 

Totals 14 17 17 11 59

Source: ACI–NA “Questionnaire on Workers Being Struck by Vehicles 

on Airport Aprons and High Visibility Clothing,” August 2000 

Page 14
Table 6 

Summary of Injuries According to High Visibility Clothing Requirements 

of Airport Operators and Airport Size 

 from the ACI–NA “Struck By” Questionnaire

Total 

Airport 

Operators 

Total 

Responding

No High 

Visibility

Clothing 

Requirements

Night/

Low

Visibility

By

Job 

Encouraged Always

Large Hub 15 14 8 4 0 1 1

 Injuries - - (44) (23) - (0) No data 

 Fatalities - - (0) (1) - (0) 

Medium Hub 17 17 15 1 0 1 0 

 Injuries (5) (9) - (0) - 

Small Hub 17 17 13 0 1 0 3 

 Injuries - - (2) - (0) - (0) 

Nonhub 11 11 8 2 0 0 1

 Injuries - - (0) (0) - - - 

Total 60 59 44 7 1 2 5

Source: ACI–NA “Questionnaire on Workers Being Struck by Vehicles 

 on Airport Aprons and High Visibility Clothing,” August 2000 

Table 7 

Summary of Injuries at Airports with Tenant Requirements for 

High Visibility Clothing

from the ACI–NA “Struck By” Questionnaire

Types of Tenants 

Requiring High 

Visibility Clothing 

# of Airports Total Injuries Percent of 

Total 

Injuries 

Avg. Injuries 

per Airport 

All 16 14 16.7 .88

 Large 2 2 2.3 1 

 Medium 4 10 11.9 2.5 

 Small 6 2 2.3 .33 

 Non 4 0 0 0 

Most 21 41 48.8 1.95

 Large 7 39 46.4 5.57 

 Medium 7 2 2.3 .28 

 Small 4 0 0 0 

 Non 3 0 0 0 

Some 25 29 34.5 1.32

 Large 5 26 31.0 5.2 

 Medium 6 3 3.5 0.5 

 Small 7 0 0 0 

 Non 4 0 0 0 

None 1 0 0 0

 Small 1 0 0 0 

Total 60 84 100 -

Source: ACI–NA “Questionnaire on Workers Being Struck by Vehicles 

on Airport Aprons and High Visibility Clothing,” August 2000

Page 15
ACI–NA also surveyed airport operators about compliance with high visibility clothing 

requirements by asking, “What do you estimate to be the compliance rate of workers regarding 

high visibility clothing requirements?” Table 8 summarizes the responses by airport size. 

The ACI–NA “Struck By” Questionnaire also asked airports whether they could detect a 

decrease in injuries as a result of workers wearing high visibility clothing. Survey results are 

summarized in Table 9. 

VI. Conclusions 

Airport aprons are complex work environments with a variety of safety hazards, one of which is 

the risk of being struck by a vehicle. There were 11 fatal struck by injuries reported since 1985. 

Fatal struck by injuries among airport apron workers did not appear to be higher than those in 

most other industries, and the number of persons killed on airport aprons from this cause has 

been declining. 

The time of the accident was included in 6 of the 11 fatal accident reports. All 6 of these 

fatalities occurred during darkness or low-light conditions. In addition, 7 of the fatal accidents 

involved a worker being struck by a vehicle backing up. This would lead one to presume worker 

conspicuity played a role in these accidents. 

With only a few exceptions, no conclusions could be drawn from the available data on whether 

high visibility clothing could have helped prevent the accidents. The OSHA accident reports 

generally did not address the worker’s clothing; however, in the November 7, 1988, fatality, 

OSHA determined that poor visibility was a factor and was prepared to cite the airline for failing 

to provide high visibility clothing to the worker. The three fatality reports contained in the FAA 

database did not address the worker’s clothing either, but supplemental information on 

circumstances of these accidents provided by the NTSB led the FAA to conclude that high 

visibility clothing would not have prevented these fatalities. 

Only 8 percent (5) of the 60 airport operators responding to an August 2000 ACI–NA 

questionnaire on struck by injuries and high visibility clothing said they believed that struck by 

injuries were an “extremely serious” or “serious” problem. 

Table 8 

Summary of Airport Operator Opinions of Worker Compliance 

with High Visibility Clothing Requirements 

from the ACI–NA “Struck By” Questionnaire

Excellent Good Fair None 

Large Hub 3 10 2 0

Medium Hub 4 7 5 0

Small Hub 4 6 6 0

Non Hub 5 5 1 0

Total 16 28 14 0

Source: ACI–NA “Questionnaire on Workers Being Struck by Vehicles 

 on Airport Aprons and High Visibility Clothing,” August 2000 

Page 16
Table 9 

Airport Operator Opinions About 

Impacts of High Visibility Clothing by Tenant Requirements 

from the ACI–NA “Struck By” Questionnaire

Tenants 

Requiring 

High Visibility

Clothing 

Decrease in 

Injuries 

Observed 

No Decrease

in Injuries 

Observed 

Don’t 

Know

Not 

Applicable 

Total 

All 4 8 1 1 14

Most 3 7 1 2 13 

Some 1 14 0 4 19 

None 0 0 0 0 0

Total 8 29 2 7 46

Source: ACI–NA “Questionnaire on Workers Being Struck by Vehicles 

 on Airport Aprons and High Visibility Clothing,” August 2000 

 Lack of comprehensive data prevented a quantified analysis of nonfatal struck by injuries, but 

airport operators and airline safety officials did not rate these injuries as the most pressing safety 

concern of apron workers. Officials of both airports and airlines stated that preventing or 

reducing struck by accidents should be considered as part of an overall ramp safety program. 

Supplemental data from airlines and airport operators indicate that struck by injuries are more 

likely to occur at large and medium hub airports where apron configuration and activities are 

more complex. The largest number of injuries per operator occurred at large hubs where there 

were no high visibility clothing requirements. 

This supplemental data seem to suggest that instituting high visibility clothing requirements at all 

large hub airports can prevent injuries. This conclusion, however, is somewhat weakened by the 

data provided by Airlines A and B. 

Though Airline A, a major airline, required workers to wear high visibility clothing, the airline 

still experienced 42 injuries over a 31⁄2-year period. All of these injuries occurred at large hubs. 

While the data indicate that high visibility clothing probably would not have had any impact in 

19 percent of the accidents, the data for the remaining 81 percent of the injuries were not 

sufficiently detailed to determine if the injured workers were either wearing high visibility 

clothing or, as in the case of the worker injured while putting on her safety vest, if failure to wear 

high visibility clothing played a role in the accident. 

Another major airline, Airline B, similarly continued to experience accidents despite the 

enactment of high visibility clothing requirements. During 1999 and the first three quarters

of 2000, Airline B experienced 21 accidents. Although not all of these accidents met the struck 

by criteria of this report, nonfatal injuries still occurred despite complete compliance with 

company high visibility clothing requirements. 

The analysis of struck by fatalities and injuries conducted as part of this study was inconclusive 

as to the effect high visibility clothing would have had in preventing these accidents. However, 

the information provided by the airlines and airports suggests that an overall ramp safety 

Page 17
program that includes high visibility clothing would enhance the occupational safety of airport 

apron workers. 

Page 18
Appendix A 

Definition of Terms from Section 520 of the 

Wendell H. Ford Aviation Investment and Reform Act for the 21st Century 

For the purposes of this study, the FAA defined terms contained in Section 520 of the 

Wendell H. Ford Aviation Investment and Reform Act for the 21st Century. This appendix 

includes definitions for all underlined terms in the Act.

The Administrator shall conduct a study to determine the number of persons working at airports who 

are injured or killed as a result of being struck by a moving vehicle while on an airport tarmac, the 

seriousness of the injuries to such persons, and whether or not reflective safety vests or other actions 

should be required to enhance the safety of such workers. 

(1) Working at airports (airport workers): Any worker employed by an airline, ground service 

handling company, airport, or any other organization who is involved in or concerned with any aspect of 

aircraft servicing or support and whose duties require their attendance on, in, and about the airport apron

areas. 

(2) Injured: Any injury, such as a cut, fracture, sprain, or amputation, that results from a work-related 

event or from a single instantaneous exposure in the work environment that involves lost worktime, 

medical treatment other than first aid, restriction of work or motion, loss of consciousness, or transfer to 

another job. [Bureau of Labor Statistics (BLS)—Occupational Safety and Health Definition]

(3) Killed: Any fatal occupational injury that results in the death of the worker regardless of the time 

between injury and death or the length of the illness. (BLS—Occupational Safety and Health Definition) 

(4) Struck by: The event whereby pedestrians or other nonvehicle occupants are hit by vehicles or other 

powered industrial mobile equipment where at least one vehicle was in regular operation and the impact 

was caused by a traffic accident or forward/backward travel of the vehicle. Injuries associated solely with 

the use of nontransport components of mobile equipment, such as rising forklifts, are not considered. 

[Occupational Safety and Health Administration (OSHA) Definition]

(5) Vehicle: Any highway vehicles—autos, buses, motorcycles, RV’s, other nonpowered highway

vehicles; air, rail, or water vehicles; offroad powered vehicles—ATV’s, golf carts, snowmobiles; plant 

and industrial powered vehicles and tractors-forklifts, tractors, and other powered carriers; powered 

mobile industrial or construction equipment—loaders, bulldozers, backhoes, etc.; and powered mobile 

agricultural equipment—harvesters, combines, mobile planters, etc. The definition does not include 

nonpowered industrial vehicles—dollies, carts, wheelbarrows; nonhighway mobile equipment; and 

wheelchairs—motorized and nonmotorized, stretchers, and wagons. (OSHA Definition) 

(6) Airport tarmac: For purposes of this report, the term airport apron will be substituted for airport 

tarmac. An airport apron is a defined area, on a land airport, intended to accommodate aircraft for 

purposes of loading or unloading passengers or cargo, refueling, parking, or maintenance. The term ramp

is often used interchangeably with apron. (FAA Glossary Definition for Apron) 

(7) Reflective Safety vests: For purposes of this report, the term high visibility clothing will be 

substituted for safety vest. High visibility clothing is apparel capable of visually signaling the wearer’s 

presence. 

Page 19
Appendix B 

ACI-NA Questionnaire on 

Workers Being Struck by Vehicles on Airport Aprons 

and High Visibility Clothing

Airport Name and Location: 

_____________________________________________________ 

Name of Person Completing the Survey:

___________________________________________ Phone: 

____________________________ 

How would you rate workers being struck by vehicles on your airport apron in terms of overall safety 

concerns?

Extremely serious problem __ Important, but not critical __ 

Serious problem __ Not significant at this airport __

Moderate concern __

Does your airport track injuries and deaths that occur on your airport apron? 

Yes __ No __

 

In calendar years 1994 through 1999, how many workers were killed on your airport apron by being 

struck by a moving vehicle?

In calendar years 1994 through 1999, how many workers were nonfatally injured on your airport apron by 

being struck by a moving vehicle?

Does your airport require safety vests or other high visibility clothing? 

Yes __ No __

If so, under what conditions must clothing be worn? E.g., nighttime only, etc. 

If your airport does not require high visibility clothing, do airport tenants such as airlines require high 

visibility clothing? 

All __ Most __ Some __ None __

What do you estimate to be the compliance rate of workers regarding high visibility clothing

requirements? 

Excellent __ Good __ Fair __ None __ 

 

Have you seen a decrease in the numbers or seriousness of injuries from workers being struck by 

vehicles since the institution of high visibility clothing requirements? 

Yes __ No __

Page 20
In your opinion, does high visibility clothing significantly decrease the risk of apron workers being struck 

by vehicles? 

Yes __ No __

In your opinion, what action would most improve the safety of workers on airport aprons? 

Please provide any comments, suggestions, or study input here. 

Page 21
Appendix C 

Discussion of High Visibility Clothing 

Relative to Apron Workers 

There are no Federal regulations covering the design and performance specifications for high 

visibility clothing. In response to manufacturer and consumer needs, the ANSI adopted the first 

U.S. standards, American National Standard for High-Visibility Safety Apparel, on June 1, 1999. 

The standard, ANSI 107-1999, addresses performance requirements for both daytime and 

nighttime conditions, colors, retroreflection, placement of materials, physical properties of 

background materials, and test methods. 

The standard identifies three classes of high visibility clothing dependent upon occupational 

exposures. ANSI identified airport baggage handlers and ground crew in Conspicuity Class 2, 

along with roadway construction workers, utility workers, survey crews, railway workers, school 

crossing guards, high-volume parking personnel, emergency response personnel, law 

enforcement personnel, and accident site investigators. Conspicuity Class 2 is used when the 

work environment requires greater visibility during inclement weather conditions, there are 

complex backgrounds, employees are performing tasks that divert attention from approaching 

vehicular traffic, traffic or moving equipment speeds exceed 25 mph, or work activities take 

place in or near proximity to vehicle traffic. 

The ANSI standards are being widely adopted by the 44,000 local jurisdictions concerned with 

meeting the highway safety standards of the Manual on Uniform Traffic Control Devices

(MUTCD). The MUTCD defines the standards used by Government officials nationwide to 

install and maintain traffic control devices on all streets and highways. The MUTCD is published 

by the U.S. DOT, FHWA, under 23 Code of Federal Regulations (CFR) Part 655, Subpart F. 

The MUTCD, section 6E, requires that flaggers, persons who provide temporary traffic control 

when permanent traffic control is not available, wear high visibility clothing in both daytime and 

nighttime situations. Retroflective garments are required at night. Section 6D-3 of the MUTCD 

states that construction workers close to the vehicular travel way should be attired in bright, 

highly visible clothing in the manner described for flaggers. Guidance rather than a standard 

covers the construction workers. 

Currently, there are no specific OSHA regulations for the aviation industry requiring airport 

apron workers to wear high visibility clothing. However, OSHA has used the personal protective 

equipment requirements codified at 29 CFR 1910.132(a) and the General Duty Clause, 

section 5(a)(1), of the OSH Act to cite airlines for violations. For example, OSHA cited an 

airline for willful violation of both provisions in 1998, after a pilot in Ohio suffered serious but 

nonfatal injuries when struck by a vehicle while waiting for a crew bus on an airport apron. The 

violation under 29 CFR 1910.132(a) states: 

Protective equipment, including personal protective equipment for eyes, face, head, and 

extremities, protective clothing, was not provided and used where necessary by reasons 

Page 22
of hazards of processes or environment encountered in a manner capable of causing 

injury: 

a) Reflective safety vests were not required to be worn by flight crews while they were 

exposed to potential contact with vehicular traffic while wearing dark clothing at 

night. 

The OSHA citation under the General Duty Clause states, 

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: the employer did not furnish 

employment and a place of employment which were free from recognized hazards that were 

causing or likely to cause death or serious physical harm to employees in that employees were 

exposed to the potential of being struck by forklifts and other vehicular traffic while waiting to 

catch or walking to transport buses...One feasible method of abatement among others, is to 

provide barriers or shields to protect employees as they waited for or walked to the transport 

buses. 

Several major airlines have implemented company policies requiring apron workers to wear 

high visibility clothing. Two airlines established the policies as part of negotiated settlements 

with OSHA following a fatal injury to an apron worker. A large hub airport responding to the 

ACI–NA “Struck By” Questionnaire stated that a survey of 12 major airlines —including 

Airtran, American, Comair, Continental, Delta, Midway, Northwest, Southwest, TWA, United, 

and US Air—found that 7 airlines used reflective belts and reflective lettering on shirts and 

jackets; 5 airlines did not have any high visibility clothing requirements. 

Many of the above airlines were contacted as part of this study. There was no standardization of 

the various corporate policies. Of the airlines requiring high visibility clothing, some required it 

in all lighting conditions, others only at night. The type and standards of high visibility clothing 

varied from vests worn over clothing to retroflective material integrated into the garment. 

Airlines also reported varying worker compliance rates with the high visibility clothing 

requirements. Two airlines stated that it was excellent, while another said they were meeting 

worker resistance, especially during hot weather conditions. 

One airline, not currently requiring high visibility clothing, mentioned that a future such 

requirement might be necessary if their insurance company felt that high visibility clothing had 

become an industry norm. In this case, the airline reported, the insurance company and 

regulatory officials might determine that a company not providing high visibility clothing had 

not acted prudently and within standard safe industry practices. 

Union/management issues were cited as the main reasons that one airline had not implemented a 

policy for high visibility clothing. 

Page 23

The Chicago Department of Aviation adopted reflective vest rules and regulations for 

O’Hare International and Midway Airports. In a April 6, 1999, memorandum informing airport 

tenants of the requirements, Mary Rose Loney, commissioner of aviation, stated that the purpose 

was to enhance the visibility and safety of personnel working in the secured ramp areas and to 

promote the safe operation of ground equipment and vehicles. 
The requirements, adopted in the Chicago Municipal Code, state 

Effective June 1, 1999, all Ramp Service Personnel employed by an Airline, a ground 

service handling company, or any other organization that is involved in or concerned 

with any aspect of aircraft servicing in the secured areas...at O’Hare International and 

Midway Airports will be required to wear “REFLECTIVE SAFETY VESTS” at all times 

in the performance of their assigned duties. 

Chicago established comprehensive minimum requirements for vest materials and construction 

that specify color, luminance, fluorescent trim, snaps, design variations, and other design 

elements. According to airport officials, Chicago adopted the vest requirement at the urging of 

the Mayor of Chicago who noticed that ramp workers at European airports wore 

high visibility clothing. Officials said that data were not yet available to analyze the effectiveness 

of the requirement in terms of reduction of the number or severity of struck by injuries to 

workers. However, they intuitively believe the program has been a success and that high 

visibility clothing is an important preventative safety measure. 

Officials report that one reason the program has been successful is the inclusion of enforcement 

provisions and penalties for noncompliance. A first offender may be fined up to $100 for failure 

to wear a vest. The fine for a second offender is up to $200 and up to $500 could be charged for 

each subsequent violation. Airport police provide enforcement. 

Several international airports require high visibility clothing, and a European standard has been 

established. The British Airport Authority (BAA) in OSI/13/99, Use of Personal Protective 

Equipment Airside, requires that airport apron workers wear high visibility clothing at all times 

in areas where aircraft and vehicles maneuver. The Health and Safety Executive (HSE), the 

British equivalent of OSHA, established high visibility clothing standards in British Standard 

EN 471, High Visibility Clothing. By risk assessment and personal protective equipment 

regulation, the HSE requires high visibility clothing for airside employees. To enforce the 

requirements, the BAA established policy OSI/48/97, The Handling of Airside Infringements. 

Five recorded failures to wear protective clothing and equipment results in a fine of £50. 

The HSE considers aircraft marshallers and movement controllers as special circumstances and 

concludes that they need to be distinguished from other workers wearing high visibility clothing 

as pilots taxiing aircraft can easily see them. 

Safety officials with the U.S. Air Force do not consider vehicles striking apron workers as a 

serious safety problem. Their records indicated no struck by injuries or fatalities in the past 

2 years. Ramp workers during daytime operations wear battle dress. Reflective clothing is 

required at night. 

Air Force officials speculate that military struck by accidents might be fewer because airfield 

access is more restricted than at civil airports, and ground crews do not have to conform to the 

demands of scheduled service. 

Page 24
In its Aviation Ground Operation Safety Handbook, 4th edition, the National Safety Council 

(NSC) recommends high visibility and night-hazard clothing for airport ramp workers.4

 NSC 

states that the garments are necessary and should be required for those employees exposed to 

traffic hazards. 

 

Page 25

4

 The NSC is the nation's leading advocate for safety and health. Founded in 1913 and chartered by the United 

States Congress in 1953, its mission is to “educate and influence society to adopt safety, health and environmental

policies, practices and procedures that prevent and mitigate human suffering and economic losses arising from

preventable causes.” 
Appendix D 

Summary of Responses from the ACI–NA “Struck By” Questionnaire: 

Suggested Actions to Improve Worker Safety on Airport Aprons 

• Training in situational awareness for drivers and workers on ramp

• I don’t think reflective clothing is helpful during the day (if a vehicle driver cannot see a 5 or 

6 foot tall person–I doubt reflective clothing will help). However, there may be some value to 

reflective clothing during hours of darkness. 

• Above listed high visibility clothing with conscientious employees 

• On going and continual refresher training 

• Reward/fine program for reporting safety violations to airport 

• Roving safety patrol on the ramp

• More reflective material on GSE 

• Reduced speed for tugs, etc. 

• Over time, a more quantified response can probably be made upon review of data 

• Combination of high visibility clothing, high awareness, and cautious driving 

• Training 

• Reduced speed 

• Safe backing program

• Conducting frequent safety meetings with employees to increase awareness 

• We have an excellent SIDA training program. 

• Safety training and awareness 

• Reducing speed limits 

• Restricting vehicles from certain locations

• Requiring stronger strobes on vehicles 

• During night-time hours, require all ramp workers to wear orange vests—discipline those 

who don’t. 

• Wearing of high visibility clothing and a training program

• Wearing high visibility vests 

• Training of vehicle operators 

• Reduced speed 

• Training and education 

• Training and education program by their respective management and safety personnel 

• Employee awareness of safe working habits 

• Being more alert and observant of driving rules 

• Being seen 

• Better and safer driving techniques 

• Increased requirements for spotters 

• Slowing down in congested ramp areas 

• Training and recurrent training on vehicle and equipment backing procedures 

• Airlines, fuelers, caterers, contractors, FAA, and airports need to train their personnel to be 

knowledgeable of the various activities that take place on the aprons. Employees who work 

on the aprons must take a personal responsibility to keep the apron areas safe. 

• Standard uniforms should include reflective markings 

• Awareness training 

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• Spotters for vehicles that are moving in reverse 

• Have all tenants integrate high visibility strips on the uniform belts, shirts, and jackets.

• Good lighting, good marking 

• Airport and tenant training 

• Better education and training on the issue 

• Compliance with safety restrictions (i.e., speed of vehicles, use of designated lanes, etc.) 

• Minimize vehicle on DOA to essential only 

• Safety program aimed at employees from companies 

• Effective driver training program

• Enforcement of rules and regulations on apron 

• Reflective safety vests (high visibility clothing) 

• Uniform commitment by all managers and supervisors to support ramp safety actively

• Safety training-recurrent 

• Slowing down 

• Staying within marked roadways; not cutting corners 

• Adherence to rules and regulations governing speed limits and traffic flow 

• Make sure vehicle speed limits are set and enforced. 

• Continue safety awareness 

• Reduction of speed of vehicles moving on ramp aprons; employee paying attention to driving 

and slowing down. High speed turn around of aircraft (load/unload of passengers and 

luggage). 

• Paying attention 

• Thorough training on safety matters 

• Supervisions of safety personnel 

• Enforcement by airport of safety rules 

• High visibility clothing and safety training 

• Constant reminders about the dangers associated with working on airport aprons 

• Training 

• Adherence to safety procedures 

• Observance of speed limits 

• Good supervision 

• Ticket speeders 

• Awareness 

• Training drivers and strictly enforcing speed limits in congested areas 

• Low (5mph) driver speed limits 

• Situational awareness 

Note: Comments mentioning specific airports were omitted or rephrased to preserve the anonymity of the airport. 

Source: August 2000 ACI–NA “Questionnaire on Workers Being Struck By 

Vehicles on Airport Aprons and High Visibility Clothing”

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Appendix E 

Summary of Responses for

Comments, Suggestions, or Study Input 

to the ACI–NA “Struck By” Questionnaire 

• As indicated by our results of the survey, the use of high visibility clothing is apparent and 

therefore need not be regulated. 

• [At an airport with 11 injuries,] unsafe speed or unsafe backing were the major causes for 

most of these incidents. 

• When high visibility gear is worn, injury and death are less likely than without it. 

• Some airline employee clothing has reflective material which improves their safety level 

when worn. 

• Training of vehicle operators was mentioned as a very important factor (awareness of what is 

going on around them, etc.). 

• In most cases, the 8-10 accidents could have be avoided or significantly reduced if the site 

had been surveyed first and personnel had been briefed on the upcoming activity. 

• A survey of 12 major airlines revealed that 5 did not have any requirements for high visibility 

clothing. The remaining 7 airlines utilize reflective belts, reflective lettering on shirts and 

jackets. The survey included Airtran, American, Comair, Continental, Delta, Midway, 

Northwest, Southwest, TWA, United, and US Air. 

• Vests are super for use day or night. 

• Increase visibility and prevent injuries. 

• Vests are expensive and the better the vest, the higher the costs. Do not count on carriers 

going nationwide buying [the] best. 

• Safety, security checks, SIDA driving, etc., vests—all keep adding on more areas 

• Based on information furnished, the incident rate for this type of accident on the aprons of 

our airport is zero for the 5-year period 1994–1999. The three items mentioned above 

[three preceding bullets] significantly contribute to this. 

• I reviewed this recently for our employees—OSHA does not require reflective clothing 

unless we choose to interpret it under the General Duty Clause. We will eventually require it 

for all of our employees; however, some of our employees are already required. 

• Obviously, the level of activity related directly to the level or risk. At a small airport—such 

as ours, it is fairly simple to monitor activity and our ample space avoids issues that go with 

high levels of concentration. 

• FAA is once again trying to go stupidly beyond their regulatory mandate. 

Note: Comments mentioning specific airports were omitted or rephrased to preserve the anonymity of the airport. 

Source: August 2000 ACI–NA “Questionnaire on Workers Being Struck By 

Vehicles on Airport Aprons and High Visibility Clothing”

Page 28
Appendix F

Sources of Information 

Airports Council International–North America (ACI–NA) Headquarters, Technical Affairs 

Department, Washington, DC 

American Airlines Safety Department, DFW International Airport, TX 

British Standards Institution, London, United Kingdom

City of Chicago, Department of Aviation, Chicago, IL 

 

Continental Airlines, Ground Safety and Risk Management Department, Houston, TX 

Delta Airlines, Corporate Safety Department, Atlanta, GA 

Department of Census of Fatal Occupational Injuries, Bureau of Labor Statistics, 

Washington, DC 

Federal Express, Safety Department, Memphis, TN 

International Safety Equipment Association, St. Paul, MN 

Minnesota Department of Transportation, St. Paul, MN 

National Safety Council, Itasca, IL 

National Transportation Safety Board, Washington, DC 

Northwest Airlines, Safety Department, Eagan, MN 

OHSA Headquarters, Washington, DC 

OSHA Region 6, Dallas, TX 

OSHA Field Office, Harrisburg, PA 

OSHA Field Office, Fort Worth, TX 

Southwest Airlines, Safety Department, Dallas, TX 

Texas A&M University, National Work Zone Safety Information Clearinghouse, College 

Station, TX

Texas Transportation Institute, Information and Technology Exchange Center, Austin, TX 

U.S. Air Force, Flight Standards Agency, Washington, DC 

United Airlines, Safety Department, Chicago, IL

US Airways, Safety Department, Arlington, VA 

Page 29
Appendix G 

References

Airports Council International–North America (ACI–NA), 7th Annual World Assembly, 

Resolution #2, Safety at Airports, June 23, 1997. 

Airports Council International, “Survey on Apron Incident/Accidents,” November 1998. 

Airports Council International, “Survey on Apron Incidents/Accidents,” 1999. 

American National Standards Institute (ANSI), Inc., American National Standard for HighVisibility Safety Apparel, June 1, 1999. 

Birch, Stephen C., Development of a Safety Service Patrol Uniform Standard, Virginia 

Transportation Research Council, 1998. 

British Airport Authority, The Handling of Airside Infringements, OSI/48/97, November 26, 

1997. 

British Airport Authority, High Visibility Clothing, BS EN 471, 1994. 

British Airport Authority, Use of Personal Protective Equipment Airside, OSI/13/99, October 13, 

1999. 

British Health and Safety Executive, Personal Protective Equipment (PPE): High Visibility 

Clothing for Airport Workers, Air Transport Sheet 1, undated. 

Bureau of Labor Statistics (BLS), Occupational Injury and Illness Classification System

(OIICS), rev. April 19, 1999. 

Department of Labor, U.S. Standard Industrial Classification (SIC) Classification Manual, 1987. 

FAA, “Notice of Occupational Safety or Health Standards for Aircraft Crewmembers,” 

Federal Register Notice 40, July 10, 1975, p. 29114. 

FAA, “Occupational Safety and Health Issues for Airline Employees,” Federal Register

Notice 64:191, October 19, 1999, p. 56275 

FAA and Occupational Safety and Health Administration (OSHA), Memorandum of 

Understanding, “Safety and Health in the Aviation Industry,” August 8, 2000. 

FAA/OSHA Aviation Safety and Health Team, “First Report: Application of OSHA’s 

Requirements to Employees on Aircraft in Operation,” December 2000. 

Gerecke, Kenneth W., Assistant Regional Administrator for OSHA, Region 3, Letter to C&S 

Concrete Products, Inc., Philadelphia, PA, March 20, 1998. 

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International Safety Equipment Association, Statement Issued at the Airport Worker Safety 

Public Hearing, December 10, 1999 

Llody, A. T., “Ramp Rash,” Airliner, 1994. 

Luoma, Juha, Schumann, Josef, and Traube, Eric C., Effects of Reflector Positioning on 

Nighttime Recognition of Pedestrians, University of Michigan Transportation Research Institute, 

1995. 

National Safety Council, Aviation Ground Operation Safety Handbook, 4th edition, 1998. 

National Transportation Safety Board reports on accidents of July 12, 1989 and March 27, 1997. 

Occupational Safety and Health Act, Public Law 91-596, 91st Cong., December 29, 1970. 

OSHA, Assessing the Need for Personal Protective Equipment: A Guide for Small Business 

Employers, 1997. 

Owens, D. A. and Sivak, M., The Role Of Reduced Visibility In Nighttime Road Fatalities, 

University of Michigan Transportation Research Institute, 1993. 

U.S. Department of Transportation, Federal Highway Administration, Manual on Uniform 

Traffic Control Devices (MUTCD), rev. August 2000. 

Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (AIR-21), 

Public Law 106-181, 106 Cong., April 5, 2000.