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34 The combined review, survey results, and interviews provide a snapshot of the current ramp area safety issues, operations, and practices in the United States. Generally, the findings focus on the following key conclusions: ⢠Airport ramp areas are complex regardless of airport size or configuration. ⢠No comprehensive U.S. standards exist with regard to non-movement area ramp markings, ground operations, or safety training. ⢠Ramps are inherently dangerous (based on the limited accident and incident data that are currently available), but no data repository exists that presents a complete analysis of accident types, root causes, and trends to demonstrate mitigation successes (such as training). ⢠Airlines and ground service providers (GSPs) surveyed typically individualize training programs to meet or exceed Code of Federal Regulations Part 121 and Occu- pational Safety and Health Administration (OSHA) regulatory requirements and introduce various levels of safety programs such as audits and inspections. ⢠Airports, airlines, and GSPs have various roles and responsibilities depending on airport contractual and operational agreements. ⢠Various FAA, industry, and technology safety initia- tives are underway. SURVEY FINDINGS Of the airports, airlines, and GSPs surveyed and interviewed, all respondents were aware of ramp concerns with regard to safety. This knowledge indicates that ramp safety is not a new topic; some of the earliest research reviewed was initiated in the early 1990s. Based on the synthesis study survey, no distinct safety man- agement trends or practices emerged with regard to airport size, location, or management oversight. Many of the airports have introduced ramp safety programs through both informal and structured committees and meetings, ramp inspection and collaborative foreign object debris/damage programs, citation and education initiatives, and safety training. Some of the small and non hub airports indicated through survey comments that their safety relationship with tenants occurred informally through well-established communication practices and regular onsite presence. General aviation airport representatives found the synthesis survey challenging because of their noncommer- cial, nongate airport operations. General aviation ramp over- sight is geared toward private pilot, charter, and small corpo- rate operations with a strong fixed-base operator role in ramp and aviation management, including fueling and catering ser- vices. Additionally, some large hub airports have multiple and complex tenant relationships depending on lease agreements and gate and ramp management, including ramp towers oper- ated by airlines and third-party providers. Among the 10 airlines and GSPs participating in the syn- thesis survey, respondents provided consistent replies with regard to safety operations, training, and reporting. All air- lines and GSPs surveyed focus on comprehensive training programs that either meet or exceed OSHA safety or 14 CFR Part 121 training requirements. Nationally and locally, air- lines and GSPs reported various methods such as safety briefings, peer reviews, audits, and inspections to promote general safety awareness and compliance. Airlines and GSPs invest significant time and expense to staff training and therefore when staff self-report infractions, the errors, inci- dents, or accidents are typically resolved through re-training efforts or additional supervision. RAMP OPERATIONS Industry can point to a number of reasons for the increase in ramp accidents and incidents, such as outsourcing staff; higher volumes of flights; increased congestion in the ramp area; larger aircraft; fewer airport operations staff; and cost-cutting measures with regard to training, equipment, and staff super- vision. Measures to mitigate these changes have included, for some, increased training, safety promotional programs, re- training as a means to correct hazardous behaviors, nonpuni- tive reporting, open communication, and safety committees. Today there is no clear single ownership and supervision of the ramp area. Tenants lease gates, passenger loading bridges, equipment staging areas, etc., in a variety of agreements and configurations. Airports surveyed indicated that both common use and leased gates typically make up their airport facility con- figurations. In a few cases, airports manage all their gate areas; in others, an airportâs only oversight is of common use gates. This complexity and diversity can lead to a lack of clear man- agement of the ramp area. In addition, no U.S. standards or reg- ulatory requirements exist for airport ramp markings, signage, or operations. Each air carrier manages operations to their com- pany guidelines; these guidelines are often used as a foundation CHAPTER SEVEN CONCLUSIONS
35 for safety and operational training. Some lease agreements allow for air carriers to use unique markings at the gate areas; this practice assists with pilot and ground service crew famil- iarity at the gate. Because one size does not fit all, the challenge relating to ramp management is difficult to resolve. Each avia- tion partner faces various safety and operational hurdles, and even with collaboration, communication, and standardization, the ramp will remain complex and congested. RAMP SAFETY TRAINING Because no national or centralized incident and accident data repository exists, it is unclear whether changes to ramp pro- grams such as increased training or improved situational awareness result in reduced incidents and accidents. Nonethe- less, based on the synthesis surveys and the review conducted, additional training has been identified as a means to reduce accidents and incidents on the ramp. Surveyed airlines and GSPs presented additional or repeat training as one of the first mitigations required for safety violators. The FAAâs recent Notice of Proposed Rule Making (NPRM) regarding airport oversight of ramp training (as part of an airportâs Part 139 certification program) may introduce new opportunities for centralized training and trending of training information; however, the challenges facing small airports to design, deploy, and manage recordkeeping require- ments for such programs may be prohibitive. DATA COLLECTION AND REPORTING With regard to data collection and reporting, the challenge to airports, airlines, and GSPs is to develop a method to share safety data in a useful and purposeful way. Although the Air- ports Council International (ACI) Apron Accident Survey compiles information from approximately 150 airport mem- bers, this airport-centric accident and incident information is limited. Rarely do air carriers or GSPs report internal acci- dents and incidents to airports. To understand the cause and effect of training, human factors, and types of training, a cen- tralized database would greatly improve the ability to trend and track best practices. However, this goal could be difficult given current airport/airline relationships, public disclosure laws, and the competitive business of ground operations. ROLES AND RESPONSIBILITIES Airports, airlines, and GSPs support aviation businesses through a collection of processes, training, and operations, yet at this time very few of these collective operations are shared. Most of those airports responding to the synthesis survey indi- cated that relationships with tenants are typically managed through lease and license agreements, rules and regulations, safety violations and citations programs, and both formal and informal safety committee meetings. Sixty-two percent of the surveyed airports indicated that some form of regular safety meetings exist within their airport/tenant operations. A variety of formats and frequencies exist, but airports consis- tently responded that safety meetings focus on resolving identified safety concerns. As a consistent practice, safety meetings appear to be a means to bridge airport, airline, and GSP responsibilities at least with regard to resolving safety hazards and associated risks. CURRENT GAPS Two identified gaps based on the synthesis study results include the lack of mandatory safety committees with inte- grated aviation partner roles and the introduction of ramp standards for markings, operations, and associated operator cer- tifications. Both the Airport Operations Safety Panel (AOSP) and ACI member surveys indicate that safety meetings can be vehicles to enhanced communication and resolution of safety issues. Formal safety reporting and review is recommended as part of the Safety Management System (SMS) and required in OSHAâs Voluntary Protection Program. If SMS programs are introduced and ultimately mandated by the FAA for all regu- lated aviation operations (such as airports and airlines), safety meetings would be expected as part of the SMS program. The AOSP panel and ACI members also recommend that ramp oversight be delegated to each airport and that ramp standards, audits, certifications, and enforcement policies be implemented and managed by airport operators. Airport staffing and bud- getary challenges associated with these proposed suggestions are not addressed in the survey results. FUTURE TRENDS As the FAAâs NextGen initiatives and other technical advance- ments continue to improve aviation technologies, airports may benefit from solutions such as ground surface radars, Auto- matic Dependent Surveillance-Broadcast, and collaborative data sharing. Aircraft movements on the ramp area including near misses and incursion data can assist airports and airlines with jointly mitigating facility or operational constraints. Air- portsâ roles in offering ground support services are a future trend that may improve the integration of airport and ramp operation functions. The opportunity for an airport operator to understand challenges faced by GSPs may assist in bridging gaps for improved collaboration and efficiencies. During the course of this ramp safety synthesis study and survey effort, two NPRMs were introduced by the FAA. Each of the NPRMs proposes new regulatory programs to provide additional oversight of the ramp area. Docket No. FAA-2010-0997 introduces the SMS as a required airport program and Docket No. FAA-2010-0247 proposes an air- port non-movement area training program. Depending on the final rulemaking outcome, these NPRMs could change the cur- rent structure of airport ramp operations, especially with regard to the airportâs roles and responsibilities in ramp safety and oversight.