Current Airport Inspection Practices Regarding FOD (Foreign Object Debris/Damage) (2011)

Below is the uncorrected machine-read text of this chapter, intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text of each book. Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.

31 Accurate Data + Thorough Analysis + Effective Action = Fewer FOD Incidents (Messenger 2004a, p. 37). Once FOD is removed, it is essential that it be properly docu- mented, especially debris removed from movement areas. This step may not appear as important as the previously dis- cussed steps of inspection, detection, and removal; however, documentation plays a critical role in the overall process. Without documentation and subsequent analysis of the data, the airport operator or FOD manager has no record of previ- ous FOD events and little idea how to proactively minimize future FOD incidents. Analysis is an important part of this process, so that trends can be revealed and FOD “hot spots” be discovered. Airports can effectively “know their FOD” by properly documenting it. Indeed, the documentation of FOD supports the risk assessment process detailed in chapter three; for without knowing the types of FOD collected and the typi- cal locations from which the FOD is removed it is difficult to understand the risk prevented by FOD at an airport. As Messenger (2004a, p. 38) states, “The purpose of your data is to identify problems and implement lasting solutions.” In gen- eral terms, the documentation phase consists of the process of writing down on paper, or electronically, and then storing what type of FOD was detected, where it was located, the risk/hazard it presented, and how the situation was dealt with. DOCUMENTED ITEMS Documentation is an important component of FOD manage- ment, as it provides the airport operator or FOD manager with historical FOD data for the airport. By analyzing past FOD events, the airport operator or FOD manager can take appro- priate action to minimize future FOD events and enact best practices. In should be noted, however, that there is no expec- tation to document FOD removed from apron areas, although airports may weigh the amount of debris collected in contain- ers placed in and around gate areas for the purpose of gaug- ing the severity of the FOD problem. FOD is generally docu- mented when removed from movement areas (runways and taxiways). Through AC 150/5210-24, the FAA recommends the following seven specific items that should be documented in every case of FOD that an airport handles (FAA 2010a): 1. How the FOD object was detected. 2. Date and time of FOD detection and retrieval. 3. Description of FOD retrieved (category, size, and color) and/or image (if available). 4. Location of FOD object (coordinates and reference to the AOA location). 5. Possible source. 6. Name of personnel detecting/investigating FOD item. 7. Airport operations and weather data during the FOD detection event. Regarding the manner in which FOD is described, it is very effective to also generate categories in which to place documented FOD. According to Morse (2004), 70%–75% of FOD events have historically been categorized as “cause unknown.” This makes trend analysis difficult. Thus, Morse (2004, p. 181) proposes that airports allow for the following categories when documenting FOD: • Internal • Ice • Concrete/stone • Aircraft hardware • GSE hardware • Luggage hardware • Wildlife strikes • Tool • Constructional material • Soft body. Although documenting FOD may appear simple enough, it does require initiative on the part of the employee han- dling the FOD event. This is best accomplished by requiring proper documentation as part of the airport’s FOD Standard Operating Procedure or policy and conveying this require- ment through training and awareness (as discussed in chap- ter six). DATABASE To efficiently record FOD occurrences and allow for trend analysis airports may find it beneficial to develop an actual recording database. Records of individual FOD cases should include the seven items listed previously. As stated in AC 150/5210-24, “These records may be required in the event of a formal investigation of an accident or serious incident, and can also be used to identify any trends, repeats, unusual con- ditions, etc., in order for corrective action to be initiated” CHAPTER FIVE DOCUMENTATION AND ANALYSIS OF DATA

(FAA 2010a, p. 26). Additionally, however, an airport may choose to include data resulting from audits or inspections and customer or tenant feedback. By maintaining FOD records for at least two years, airports will have valuable information that will help in FOD detection and removal in the future, as well as “ensure traceability of all significant safety-related deci- sions” (FAA 2010a, p. 26). Some airports advocate that records be maintained for periods longer than two years to allow for historical trend analysis. It is worth noting that the FAA recently initiated efforts to develop a national FOD database, which would work to highlight FOD trends on a national level. Once implemented, the system will operate on a vol- untary basis, with airports being encouraged to participate in the database. ASSESSING PERFORMANCE To determine the effectiveness of the FOD management program and various FOD prevention techniques that have been adopted as part of that program, airports will find it use- ful to assess their performance in relation to FOD. As NAFPI (n.d., p. 6) states, “The operational target in any FOD Pre- vention Program should always be ‘zero.’ ” To determine the degree to which an airport is successful in achieving this target, performance can be assessed. Various methods are available to airports in proving this information, according to NAFPI (n.d., p. 6): • Visibility charts/statistical graphics derived from audit or incident data. Usually provided on an isochronic sched- ule; that is, weekly or monthly. • Trend analysis—Where have you been? Where are you going? • Report card—A checklist of areas routinely inspected that shows specific problem areas. • Performance review—A review of worker conformance to standards and expectations. • Customer comments, concerns, or complaints. Successful FOD prevention programs incorporate trend analysis on a regular basis. To analyze trends, after the documentation process has been completed, it is critical that the documents be kept for at least 24 calendar months. Trend analysis involves the review of each FOD occur- rence at an airport, including how often each type of debris are found, at what locations the majority of the debris are found, what sizes of debris exist, in what weather condi- tions debris are found, and so on. In reality, trend analysis may be performed on any of the variables recorded during FOD documentation. The purpose of analyzing each FOD occurrence is so that trends may be discovered to assist the FOD manager in improving their inspection, detection, and removal techniques, and possibly to even take steps to 32 eliminate certain types of debris. Airports will benefit from the final steps of documentation and analysis, and the FOD management program will have a longer lasting effect than its short-term goal of immediately removing FOD that has been discovered. Risk Assessment As first presented in chapter three, risk assessment in FOD management is a two-part process. The first involves an instan- taneous risk assessment, which may take place during the inspection/detection stage, and the other part is a more tradi- tional risk assessment, which may take place during the doc- umentation and analysis stage. The overall process of any risk assessment is much the same and is, according to the FAA, as follows (FAA 2007b): 1. Describe the system 2. Identify the hazards 3. Determine the risk 4. Assess and analyze the risk 5. Treat the risk (i.e., mitigate, monitor, and track). Risk assessment during and after the documentation stage is one aspect of the trend analysis process. The documentation stage can be very critical to any FOD management program because the strengths and weaknesses of the entire program can be examined. Through documentation, discoveries may be made that reveal where FOD items are generally located, what they are composed of, the time of day and weather conditions that generally accompany these occurrences, and other items. When these items are known, a formal risk assessment involv- ing the five previously mentioned steps of a risk assessment may take place. The first phase is to describe the system, which entails describing the operating environment in which the hazards will be identified. System description serves as the boundaries for hazard identification. For airports, characteristics of any operational, procedural, conditional, or physical nature are included in the system description (FAA 2010a). The second phase (identify the hazards), can occur in a variety of ways, and may include the use of a chart. When using a chart, the identifier may list a sampling of common FOD that has been found at the airport, including the hazard, and frequency of the occurrences. For example, a piece of concrete would be classified as having a high expected hazard and a common frequency, whereas a bro- ken runway sign would also have a high expected hazard score, but be deemed uncommon with regard to frequency (FAA 2010a). The third phase of FOD risk assessment involves deter- mining the risk associated with each piece of debris. In this

33 stage, the actual risk that each piece of FOD presents is deter- mined. For instance, if a small piece of concrete has been identified as a risk, the employee may determine that engine ingestion could be the actual hazard that would threaten an aircraft (FAA 2010a). The fourth and final phase of a FOD risk assessment process is to assess and analyze the risk. For the purpose of FOD detection, risk has been defined by the FAA as, “. . . the composite of the predicted severity and likelihood of the out- come or effect (harm) of the hazard in the worst credible sys- tem state” (FAA 2010b, Appendix 1, p 3). Severity is also considered in the risk matrix and has a different definition than likelihood. The likelihood of each risk occurring was determined in the second phase of the risk assessment. In the fourth stage, the severity or “worst credible potential out- come” is taken into consideration (FAA 2010a). A sample risk matrix is show in Figure 26. As shown in Figure 26, the likelihood and severity (or consequences) intersect to determine the level of risk. Gener- ally, three levels of risk may be found—low, medium, and high. It is worth noting that several risk matrix charts do include a fourth category, extreme or critical, which ranks above high risks (Stolzer et al. 2008). High risks are unacceptable in a safety-driven industry such as aviation. A level of medium risk is considered acceptable in many situations, meaning that operations can proceed normally; however, close supervision of the sce- nario should be maintained. Low risk is the goal of every safety program, and with the proper application of a risk matrix airport operators are most likely to achieve this goal (FAA 2010b). Finally, after the four phases of risk assessment have been completed, it is vital to treat the risk. At this point the airport operator or other qualified personnel may weigh the options that are presented to them in addressing a particular hazard. In addition, before a FOD management program can be implemented, it is necessary to consider how the program will be funded, who will oversee it, and the implementa- tion schedule. Decisions may have to be made on what to include and what to exclude from the program. It is impor- tant for the operator to remain objective during this process and “. . . implement appropriate and cost-effective risk mitiga- tion plans to mitigate hazards” (FAA 2007b, p. 13). When possible, airports may wish to include a diverse group of individuals in making these decisions, as their differing experiences and knowledge base will enrich the develop- ment of a risk assessment program (Stolzer et al. 2008, pp. 130–148). For further information on the risk profile of FOD, consult McCreary (2010). IMPROVING FOREIGN OBJECT DEBRIS MANAGEMENT Perhaps the most important aspect and end goal of the doc- umentation process is improving the entire FOD management program. By properly documenting FOD, airports are able to see how instances of FOD have been handled in the past and where improvements can be made, thus improving the safety performance of the airport. Furthermore, any FOD “hot spots” can be determined, thereby allowing a more focused effort in these areas. Based on data from Vancouver International Air- port, McCreary (2010) proposed that FOD hot spots may not exist. However, this may vary among airports, especially if for example an airport has an active FOD generator in the form of a construction site. In any event, it is helpful for the FOD man- ager to regularly review past findings and evaluate how their FOD management system operates. This may take the form of a Corrective Action Plan, which is based on the root causes of the FOD, and will likely present the steps to be taken to reduce any FOD problems. As Messenger (2004a, p. 45) noted, “Zero FOD is YOUR goal, and sound data coupled with commitment is a key in reaching it.” CURRENT EQUIPMENT AND TECHNOLOGY AVAILABLE FOR DOCUMENTATION Once FOD is collected and before disposal it needs to be properly documented. As previously discussed, documenta- tion is important for understanding trends and properly incor- porating continuous improvement into a FOD management program. Documentation begins with properly recording information once the debris are collected. This can easily be done on a form; however, documentation becomes more complex as an airport begins to analyze debris collected over a certain time period or in a defined location. In this instance, a computer database or FOD-specific software program becomes invaluable.FIGURE 26 Sample risk matrix. Source: Mobile Safety Solutions.

34 forms by means of a touch-screen tablet PC or notebook com- puter. They may also contain GPS and GIS capabilities, allow- ing the inspector to pinpoint exact locations at which FOD is removed. Others mimic a well-developed electronic database, which allows one to enter all required information about a FOD event. Whether obtained from a vendor or developed in-house, once recorded, data can then be analyzed by the variables used to enter the information. In this way, reports can be generated, thereby allowing for investigation, audits, and continuous improvement. Figure 27 shows an in-vehicle FOD documentation system. Interface with Foreign Object Debris Detection System Other manufacturers incorporate a documentation software program that interfaces with their FOD detection system. One manufacturer, for instance, has integrated its FOD documen- tation program with its FOD detection system so that FOD events are not only recorded, but actual images are archived as well. Another manufacturer provides a software toolbox that enables the airport to store, view, and analyze all detection data provided by the system. As a result, trends and patterns can be identified that will allow the airport to improve its overall FOD management program. This same provider’s program offers a heat map view, which graphically displays the density of FOD detected by area, overlaid on an airport map or image. This tool can quickly highlight potential problem areas or FOD hot spots, allowing efforts to be focused where they are most needed. Whether the FOD documentation software is included with the FOD detection system or must be acquired separately, airports may wish to consider how well the documentation system integrates with the detection system in use. Documentation Continuum Regardless of the degree of FOD documentation at an air- port, a number of solutions exist—ranging from fully man- ual to fully computerized. The continuum in Figure 28 has FIGURE 27 In-vehicle FOD documentation system. Source: Paul Khera, Alaska Department of Transportation. FIGURE 28 Continuum of technology and equipment available for FOD documentation. Stand-alone Tools The simplest form of documentation occurs with a manual sys- tem. With a FOD inspection checklist, wildlife reporting form, or other form/checklist, an airport employee with a clipboard and a pen can properly document FOD as it is collected. If a photograph(s) is taken, it can be printed and attached to the paper form. This system allows for a paper trail and can be effective in documenting FOD. However, trend analysis can prove cumbersome, requiring that many previously completed forms be reviewed to uncover trends. Stand-alone Technology The incorporation of technology into the documentation process may enhance an airport’s efficiency. Various manu- facturers currently offer stand-alone technological solutions to FOD documentation. Some of these solutions may be used within a vehicle and allow access to Part 139 inspection checklists, accident reports, operations manuals, and FOD

35 been developed to present the range of options available to airports. CURRENT AIRPORT DOCUMENTATION PRACTICES Documentation of Foreign Object Debris Documentation of FOD varies by airport. Of the airports par- ticipating in this synthesis, 52% reported that they document FOD most times when debris are retrieved or removed. Almost 20% document FOD every time, with 19% documenting some- times and 10% never. When analyzing the data by airport hub size, it becomes clear that larger airports are more likely to document FOD. Specifically, although FOD is documented most times by 75% of large and medium hub airports and 60% by small hub airports, only 20% of non-hub airports and 33% of GA airports document FOD most times when it is retrieved or removed; furthermore, two-thirds of GA airports never document FOD. When queried about the manner in which they document FOD, the results were quite comprehensive. More than half of participating airports currently document FOD in the fol- lowing manner(s): • Location of FOD (84%) • Date and time of FOD detection and retrieval (68%) • Description of FOD retrieved (68%) • Name of personnel detecting/investigating/removing FOD (61%). Participating airports also document how the FOD was detected (41%), the possible source of the debris (32%), an image of the object retrieved (23%), airport operations data during the FOD detection event (18%), and weather data dur- ing the FOD detection event (9%). Analysis of Foreign Object Debris For the purpose of documenting FOD, 64% of participat- ing airports maintain an electronic database. Interestingly, this 64%, to a large extent, represents large hub airports; none of the participating medium hub, non-hub, and GA airports currently maintain an electronic database for FOD documentation. Although 28% of the participating airports do not have an electronic database for this purpose, 9% plan to adopt an electronic FOD documentation database in the near future. For those airports with an electronic database, Figure 29 shows how the data in this database are analyzed. It appears that just as the majority of parti- cipating airports document the location, date and time, and description of FOD, these are the same elements most often used in the analysis of FOD incidents. However, although the majority of participating airports also docu- ment the name(s) of those personnel who detect and remove the debris, this element is not a common way to analyze data in the database. The manner in which FOD was detected however is. When asked who analyzes the data in the database, 77% of survey respondents indicated that operations per- sonnel were the most likely candidates. However, other stakeholders also participated in data analysis (as shown in Figure 30). Similar to the previous question, participants were asked who uses the data stored in the FOD database. It appears that the operations department (87%) and airport management (73%) are the most frequent users (Figure 31). 8% 15% 15% 23% 23% 39% 69% 77% 92% 0% 20% 40% 60% 80% 100% Airport operations data Name of personnel Weather data Possible source Image of FOD object How FOD was detected Description of FOD retrieved Date and time Location of FOD FIGURE 29 FOD analysis by type. Note: Participants were able to select all that apply. Thus, percentages do not total 100%.

36 15% 15% 31% 39% 77% Safety officer Widlife biologist FOD manager Airport management Operations personnel FIGURE 30 FOD analysis by personnel. Note: Participants were able to select all that apply. Thus, percentages do not total 100%. 7% 20% 20% 27% 73% 87% State regulatory agency Air carriers FAA (or similar) Tenants/users Airport management Operations department FIGURE 31 Utilization of FOD data. Note: Participants were able to select all that apply. Thus, percentages do not total 100%.