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17 CHAPTER THREE CURRENT PRACTICES IN RAMP SAFETY This chapter focuses specifically on existing safety training FAA 14 CFR section 139.321 (e)(1) requirements. A further practices including type and duration of training, recurring breakdown of safety training based on airport type is provided training, and frequency and re-training procedures for safety in Table 14 and airport associated comments are presented in violations or infractions. Table 15. Many of these training courses are delivered by general orientation sessions and video, classroom, and on-the- job training formats. An overview of training approaches GENERAL is provided in Table 16 to demonstrate how personnel are trained on each required element. In a 1997 study by GSE Today, 35% of respondents (ramp operation managers around the world) reported that reasons for ramp accidents included inadequate training and inexperi- TRAINING REQUIREMENTS enced crews (Prill 1999). The GSE Today survey also indicated that these inadequacies in training and experience resulted from The ground service area is a complex network of vehicles and inconsistency in standards, operating practices, and manage- individuals operating together to accomplish the same under- ment that can be overcome through initial and recurrent train- lying goal. This goal however may be vulnerable, with loosely ing programs for employees. defined ramp procedures, poor communication, and disparity within ramp practices. Parallel safety training among airports, As part of this Ramp Safety Synthesis study, airports, airlines, and GSPs helps close the gap in errors by the ground airlines, and GSPs were asked a variety of questions regard- crew. The following paragraphs outline the training require- ing training formats, frequency, and strategies as part of the ments that airports, airlines, and GSPs provided as current survey questionnaire. Based on the results of the survey, practices. 37.9% of airport respondents indicated they require airside safety training for tenants [not including Air Operations Airports Area (AOA) or Airport Movement Area (AMA) driving]. One hundred percent of reporting airlines and GSPs responded that The complexities within training begin with the type of instruc- all ground support staff are required to participate in safety tion that airports must offer to a variety of constituents. training. Although the study findings may not provide a large Tables 14, 15, and 16 in the previous section outline the vari- representative sample, survey results may offer a baseline for ation in training requirements for ground handlers at airports. analyzing the type of training required by the typical avia- Training is directly influenced by the type of service delivered tion organizations. See Figure 5 for a breakdown of training at airports. Training components may include, but are not lim- requirements by airport type and Table 13 for comments col- ited to, general orientation, hands-on (supervised), video train- lected from the survey outlining airside safety requirements ing, classroom training, on-line training, and rules and regula- from airport respondents. Most of the airport-required train- tions review. Of the surveyed airports, all agreed that it is ing relates to driving programs, FOD, construction, passen- important that a mixture of these practices be utilized to pro- ger loading bridges, and pedestrian safety including use of vide training to tenants. Redundancy in fueling training is the PPE (safety vests). most commonly reported practice that airports have employed. According the results of the survey, 36% of respondents com- Safety training that personnel receive is directly related to bine both airport and tenant safety training. company policy and the day-to-day responsibilities of each individual. Variation on training is a result of airport, airline, Recurrent or refresher training can be delivered after spe- GSP, FBO, and tenant policy and is typically subject to change cific periods of time have passed to promote safety standards dependent on job-specific duties. Supplementary or special- and make changes in safety practices. The always changing ized instruction for ground operations such as de-icing, aircraft landscapes of airport ramp areas introduce hazards that can- towing and pushback, and marshalling is required to ensure not always be recognized by initial training alone. In a study that techniques, equipment, and safety operations are consis- conducted by Prill (1999), 45% of respondents stated that a tently maintained. The most common required training is fuel lack of motivation and knowledge among crew members were service, which is audited to verify that operators are meeting the primary reasons for ramp accidents. To ensure thorough

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18 9 8 7 6 Count 5 4 No 3 Yes 2 1 0 General Large Hub Medium Hub Non Hub Small Hub Aviation Airport Ramp Safety Training Required by Type FIGURE 5 Airport ramp safety training required. [Does your airport require airside safety training for tenants (not including AOA or AMA driving)?] TABLE 13 AIRPORT RAMP SAFETY TRAINING COMMENTS Type Response Comment General No Staff is required to complete general safety training as an organization and Aviation specific safety training based on their job requirements. Large Hub No Basic safety training is part of driver training. Also, airport tenants expected to provide ramp safety training to employees. Large Hub No Cal OSHA requires safety training and tenants are held to their own internal policies and procedures as well as compliance with Cal OSHA requirements. Large Hub No We hope to develop this as a separate training module to our existing AOA/AMA driving class under our on-going SMS implementation plan. Medium Hub No The airport requires tenants to have a safety program and to follow the airport's rules and regulations. The airport requires contractors to go through safety training prior to starting a job. FOD is required safety training for tenants. Safety vest requirements are trained to tenants. Medium Hub Yes Under SMS we will Non Hub No Atlanta Fire Department requires training for fuelers. Non Hub No Everyone with AOA access receives Driver/Pedestrian Training to obtain airport access. Small Hub No Required--Only related to fueling--receiving, handling, and dispensing. Airport does offer an optional class for Aircraft Maintenance Technicians who are involved with towing aircraft. Small Hub No We only require airside safety training for those with ramp or movement area drivers privileges. Tenants often have required safety training for their employees who work around aircraft. Small Hub No Only for jet bridge operations. Comments for: "Does your airport require airside safety training for tenants (not including AOA or AMA driving)?" TABLE 14 SAFETY TRAINING REQUIRED OF GSPS (BY AIRPORTS) A/C A/C Lav Cargo A/C Airport Baggage Handling Passenger A/C Other None Fueling Ground and Catering and Mail Load Type Handling and Handling Maintenance Services Movement Water Handling Control Loading General 1 3 0 0 1 0 0 0 0 0 0 0 Aviation Large 2 5 2 2 2 1 1 1 1 0 0 2 Hub Medium 0 4 2 2 2 1 1 3 2 2 0 0 Hub Non 0 4 2 2 2 2 2 2 1 2 1 1 Hub Small 1 4 4 4 4 3 2 4 2 2 3 1 Hub Total 4 20 10 10 11 7 6 10 6 6 4 4 Count "What types of service providers at your airport are required to have safety training?"

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19 TABLE 15 AIRPORT TRAINING REQUIREMENTS FOR GROUND HANDLER COMMENTS Type Comment General Aviation All general aviation line services including fueling, marshalling, and towing General Aviation The airport provides for all of the listed service except A/C maintenance and catering. We do have our own internal safety training for these functions. Large Hub All companies are required to have safety training programs. Fueling is one that the airport ensures is done by train the trainer and by conducting audits. In general the tenants train their own employees on the rules of the company and what is best practice for the industry. Safety vests is another aspect of required safety training for all people who work on the airfield; vestsare to be worn when 15 feet or more from the building. Medium Hub We do not control what the air carriers do in terms of training. We do know that air carriers conduct training with their employees and contractors for the abovementioned. Since we do provide fueling and lav/water services, safety training is required for those services. Medium Hub Any safety training provided is the responsibility of the tenant company. Medium Hub No safety training is governed by the airport authority for these types of services. Safety training is per individual company policy. Non Hub Bangor Airport is the FBO for the airport and provides all ground services so airport employees perform the above services and receive airport safety training. Non Hub NATA Safety 1st Program is used by the airport FBOs and meets FAA Part 139 requirements. Specific safety training for airlines, ground handlers, and aircraft maintenance is provided by each carrier separately. Non Hub Anyone with a badge must have security and airport safety training. The airport only requires fuelers to have job-specific training. Comments for: "What types of service providers at your airport are required to have safety training? Select all that apply." understanding of responsibilities, recurrent training programs According to the results of this synthesis survey, 85.2% (23 that aimed to reduce complacency might be used. of 27 airport respondents) believe that additional safety training would benefit their airport, its tenants, and GSPs (two airport As outlined in the results of the participating airports in this respondents skipped this question). A common suggestion study, 62.1% do not require airside refresher safety training for from the survey respondents was to control training variables tenants (18 of 29 participants). Just over 24% (7 of 29 par- by relying on airline safety training programs, but enhance out- ticipants) of survey respondents stated that they are currently comes with monthly safety meetings to address key issues. The engaged in refresher training during annual recurrent fueling major gap within the current state of enhanced safety training examinations and access control badge renewal processes. If is that a high rate of respondents understands the benefits of recurrent training is practiced, it is delivered by either the air- increased training, but only 57.1% (16 of 28 participants) are port or the tenant 66.7% of the time. Annual recurrent training planning to increase the amount of safety training. In contrast, is the most common timeframe for refresher courses and is 28.6% of respondents stated they had no plans in the foresee- used 58.3% of the time. able future to increase the amount of safety training. TABLE 16 SERVICE PROVIDERS AND SAFETY TRAINING REQUIREMENTS (BY AIRPORTS) A/C All A/C Lav Cargo A/C Training Baggage Handling Passenger A/C Service Fueling Ground and Catering and Mail Load Types Handling and Handling Maintenance Providers Movement Water Handling Control Loading General 9 12 5 4 4 3 0 4 1 1 2 Orientation Hands-on/ 3 11 5 4 4 4 0 4 1 1 2 Supervised Video 4 11 2 2 2 2 1 2 1 0 1 Training Classroom 2 10 4 3 3 2 1 2 1 0 1 Training On-line 2 8 2 3 3 2 1 1 0 0 1 Training Rules and 7 13 2 3 3 2 1 2 0 0 0 Regulations Review Other 2 1 0 0 0 0 0 0 0 0 0 Total 29 66 20 19 19 15 4 15 4 2 7 Count "If yes, what type of safety training is required? Are training requirements different by service? Select all that apply."

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20 Airlines ments to identify gaps and trends to be addressed in future training. Part of identifying these hazards is increasing train- As previously mentioned, all seven reporting airlines (two ing. Based on the results, five of the seven responding air- respondents from one airline) require all ground support staff lines believe that additional safety training would benefit air- to participate in safety training. In addition, six of the seven line ground handling services. As with airport respondents, respondents require the same safety training for contracted only three of the surveyed airlines are planning to increase company staff providing ground support services. The remain- the amount of safety training to personnel and/or GSPs. The ing airline elaborated on its training requirements by stating other four airlines responded that they have no plans to increase that all training is not the same, but standard training covers all safety training or that it does not apply because safety is a daily Part 121 regulatory requirements. Furthermore, any required expectation. OSHA training and development is the responsibility of the vendor and is stated in the contract. Ground Service Providers Depicted in Figure 6 are the types of safety training prac- tices required by airlines. Specific training ranges from every Without examining statistics and previous studies, a common individual receiving a general safety orientation to only half misconception within the industry is that there is an even dis- of airline personnel receiving training in push back and com- tribution of incidents during arrivals and departures. It is munication practices. The airlines reported using both on- important to note that 58% of the time incidents occur during the-job and instructional training delivery methods to pro- aircraft arrival and 35% during departure (Chamberlin et al. mote the most thorough guidance as possible. n.d.). Standardized procedures may account for this dispar- ity; however, training aimed at overcoming inconsistency has The amount of time dedicated to training varies from proven useful. Four GSPs participated in this synthesis study. respondent to respondent. Three of the six responding airlines All four stated they train 100% of employees on general safety, reported that their duration period for training was three or OSHA standards, ramp operations, and airfield driving. Only more days. Each of the two categories, one day or less and two of the participating agencies went on to say they required one to two days, had one respondent each. All reporting air- training in push back operations, marshalling, communica- lines also required refresher training for ground services. The tion, and "other" (other was explained by participants as air- common practice within respondents was initial safety train- craft servicing and transportation of dangerous goods). Train- ing upon hire, with annual recurrent training on the anniver- ing was conducted using a mixture of classroom and on-the-job sary of employment (five of seven respondents). Training is instruction by all four respondents. Figure 7 illustrates the conducted twice a year or every two years for the remaining required training elements used by GSPs. two airlines, with each option having one response. Every participating airline provides the same level of ground han- All four GSPs stated that they conduct in-house training dling safety training at all locations. to control variables and external training gaps. The minimum training duration provided to employees was two to three days To further facilitate consistent safe operations, all seven (one of four reporting GSPs), whereas the remaining three of the participating airlines audit their safety training require- GSPs answered three or more days. One survey participant 8 7 6 5 Count 4 3 2 1 0 General Safety OSHA Ramp Push Back Driving Marshalling Communication Orientation Operations (phraseology) Airline Types of Ground Handling Training FIGURE 6 Airlines ground handling safety training. (If yes, what type of safety training is required? Select all that apply.)