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

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13 Adequately controlling FOD at any airport begins with a regularly scheduled inspection program. Inspection refers to examining something closely, typically to assess the condition or to discover any shortcomings. In this case, it would be in the form of proactively conducting airfield inspections to mon- itor for and mitigate any hazards related to FOD. Reactively, this might be in the form of response to FOD as reported by the ATC. With this response, debris can then be removed from the AOA. Whether reactive or proactive, the inspec- tion component is integral to an effective FOD management program. ducting daily inspections and having procedures in place for FOD to be reported upon discovery by pilots, especially at non-towered airports that are at times unattended, airports can play an active role in FOD prevention. Whether proce- dures dictate that observed debris be communicated to the on-call airport representative or the FBO, it is important for sufficient emphasis to be placed on FOD detection and removal to enable removal of debris even during nighttime or weekend hours. In addition to FAA guidelines for U.S. airports, inter- national airports located outside the United States must also comply with various inspection requirements. For instance, ICAO recommends that airports, by means of ICAO Annex 14, Aerodrome Design and Operation, conduct inspections four times daily, or about every 6 h (ICAO n.d.). This standard was actually set by the Provisional ICAO in 1944. At the time, Chicago was the largest airport in the world and the four per day routine required inspecting the runway every 10 to 15 move- ments. Although the four per day standard has been pre- served in Europe and Australia, the United States soon adopted a one per day requirement, which remains in effect (McCreary 2010). INSPECTION AREAS A critical aspect of the inspection component of any FOD management program includes knowing the most common areas in which debris are found. These areas vary among air- ports and, as McCreary (2010, p. 138) explains, these areas are influenced by many factors, including: • Airport age • Airline ramp practices • Aircraft types • Distance to repair hangars • Construction activity • The nearness of buildings • Aircraft loading practices • The mix of passenger versus cargo traffic • Cargo types • Mix of ground vehicles in use • Pavement types • Surface cleaning/sweeping regime • Weather and the number of winter operations • Maintenance practices. CHAPTER TWO INSPECTION Imagine standing on an empty highway at night. It is two miles long and ten lanes across. You are told that someone may or may not have dropped a two inch long, dark colored metal fastener somewhere out here, and your job is to make sure the route is clear before an airplane rolls down the high- way. Find the FOD. You have two minutes. . . . Source: McCreary 2010, p. 177 CURRENT REQUIREMENTS AND GUIDELINES Current inspection requirements for certificated airports in the United States are primarily found within Part 139 (FAA 2004a). Section 327 of Part 139, Self-Inspection Program, spells out that certificated airports are required to conduct daily self-inspections. Specifically, certificated airports are required to conduct daily self-inspections when required by any unusual activity and immediately after an accident or incident. Although U.S. airports typically conduct inspections twice daily, once during daylight hours and once at night, the night inspection is not required and meant to mainly check lighting. The FAA provides guidance in conducting inspec- tions, both within Part 139 and in ACs. For instance, AC 150/5200-18C, Airport Safety Self-Inspection, stresses that the “inspector should continuously check for, and remove any FOD in movement areas, aircraft parking areas, and loading ramps” (FAA 2004b, p. 12). Although there is no regulatory requirement for GA air- ports to conduct inspections, it is a recognized best practice for all airports, including the smallest GA airport, to regu- larly inspect the AOA for FOD, among other items. By con-

The first and perhaps most critical inspection area on the AOA is the movement area, encompassing both runways and taxiways. The movement area is critical because it is used by each arriving and departing aircraft and hosts the most critical stages of flight; that is, take-offs and landings. As McCreary (2010, p. 121) explains, “While a clean ramp is certainly important, forensic analysis shows that 50% of strikes occur on the runway. . . . [Therefore,] the runway is the key to improved safety and reduced costs.” Stated another way, “FOD awareness programs [sic] tend to focus attention on the ramp, where most debris is found, rather than on the runway where most strikes occur” (McCreary 2010, p. 103). One source of FOD on paved surfaces is from cracked, chipped, and broken pavement. Pieces of concrete and asphalt may break loose owing to fatigue, requiring older pavements to undergo more frequent inspections. Broken pieces of pavement can also collect on the edges of ramps, and be carried onto the movement areas by prop wash, jet blast, or the tires of airline or operations equipment or vehicles. By closely monitoring ser- vice roads that intersect taxiways, airports can quickly detect and remove FOD from taxiways left by vehicles using the service road. Unpaved shoulders adjacent to pavement, espe- cially if not stabilized, may also generate FOD. Paved shoul- ders mitigate this concern to a great degree. By inspecting pavement joints, additional sources of FOD can be detected. Turf areas, in the form of safety areas and object-free areas, may collect and retain a large amount of debris, such as paper, cardboard, and plastic. This debris can be blown into areas travelled by aircraft unless collected regularly. Finally, fence lines can collect trash during windy conditions. This debris should be collected before the wind direction changes or increases to avoid debris being blown onto areas travelled by aircraft (FAA 2010a). The second main portion of the airport to be inspected for FOD includes apron areas (FAA 2010a). By inspecting apron areas, especially at larger airports that offer air carrier service, debris can be detected and removed to prevent damage to air- craft. GA ramps and terminals also accumulate FOD that pre- sents dangers to aircraft. Any areas on the apron upon which ground vehicles operate have the ability to produce FOD. The third area to be inspected includes areas hosting air- craft servicing operations. Although much of this activity may occur on airport aprons, the FAA differentiates this activity because of its ability to generate substantial FOD, as contrasted with an empty ramp area. As baggage is handled, FOD can be generated in the form of an entire piece of lug- gage, a wheel, luggage tag, carrying strap, or TSA security tags. Refueling operations can also generate FOD in the form of unsecured fuel caps, ladders, traffic cones, and fuel spills. Likewise, catering activities can generate substantial amounts of FOD. The food provided by catering services often comes in a variety of cardboard and plastic packaging, which, if not properly disposed of, can easily be blown onto the terminal or a movement area. FOD may also collect at both ends of the conveyor, and between the baggage cart and the conveyor 14 belt (FAA 2010a). As McCreary (2010, p. 139) notes, “The ramp is a major source [of FOD], with the gate as the ‘dirtiest’ source.” Fourth, it is important to regularly inspect air cargo oper- ations for FOD. Air cargo operators deal with substantial amounts of cargo, which can come packaged in a number of ways. All of this packaging creates the potential for blow- ing debris, especially in the form of plastic wrappers, plastic strapping bands, and cardboard. Continuous surveillance and fencing are two traditional remedies for the FOD problems that may accompany cargo operations (FAA 2010a). Yet another area to be considered concerns those capital improvement and maintenance projects that can result in FOD. Outside contractors often do not understand the significance of FOD and will not make an effort to prevent FOD if not prop- erly trained by the airport. By educating contractors about FOD and the risks it creates, contractors will be more likely to curb construction debris and regularly clean up the construc- tion site. When planning for projects on the AOA, whether performed in-house or by outside contractors, airports may wish to consider including a means for routinely checking and restricting debris. As previously mentioned, the FAA has issued AC 150/5370-2 to address FOD and other safety-related items during construction projects. The AC encourages air- ports to hold contractors responsible for complying with the requirements of the airport’s FOD management program and any construction safety plans (FAA 2003). In addition, accord- ing to the FAA the airport operator should inspect all con- struction areas for debris on a daily basis, as well as remaining aware of the potential for vehicles to track FOD from con- struction areas onto the airport’s movement areas. Smaller pieces of FOD, such as gravel, can become lodged in the tires of a vehicle, and then become dislodged on a runway or taxi- way if the tires of the vehicles travelling between these two areas are not inspected before every trip. Some airports have found it a best practice to require the contractor to follow all vehicles traversing paved areas with a sweeper truck to remove any debris immediately. Another option, in the form of rumble strips, is discussed in chapter four (FAA 2010a). The final area considered important for FOD inspection includes aircraft maintenance areas. A large number of tools and hardware are typically used in maintenance areas and these items may inadvertently be left on an aircraft or vehicle, which may find its way onto the ramp or taxiway. Within hangars, airlines perform FOD checks as part of daily safety checks, have FOD free verification on work cards, and ensure end-of-shift and task clean-ups. In component areas, there are clean-up days and routine vacuuming and metal pick- up. Line maintenance typically performs worksite analysis and housekeeping, daily safety briefings, and FOD accident investigations. Additionally, visual aids may be used to assist mechanics in this pursuit, specifically checklists, shadow boards (composed of an outline of each tool’s proper storage location), or tool trays (FAA 2010a).

15 INSPECTION TECHNIQUES There are currently two ACs that provide techniques for con- ducting inspections for FOD. First, AC 150/5200-18C, Airport Safety Self Inspection (FAA 2004b, p. 4) suggests: Inspectors should vary the pattern of the inspection. Fixed inspec- tion patterns, while easy to learn, do not provide for an adequate inspection. The use of such fixed inspection patterns can lead to complacency and to the possibility of missing items that are in need of correction. When conducting an inspection on a run- way and when there is time to do only one pass on that runway, inspection personnel, whenever practical, should drive towards the direction of landing aircraft with high intensity flashing bea- con and headlights on day and night. This practice will enable self-inspection personnel to see approaching aircraft and improve visibility of the vehicle to pilots. However, it is recommended that a runway inspection be done in both directions. Inspection personnel should also drive the stub taxiways between the runway and parallel taxiway as these areas are commonly overlooked. Although AC 150/5200-18 refers to all types of self- inspections, AC 150/5210-24 refers specifically to FOD inspections. Specifically (FAA 2010a, p. 17): The FAA and ICAO require a daily, daylight inspection of aircraft operating areas. Operational areas must be inspected at least once each day, with additional inspections being made in construction areas and immediately after any aircraft or ground vehicle accident or incident or any spill of material which may cause slippery con- ditions. In addition to performing these inspections at the beginning of the day or shift, personnel in the AOA should practice a clean- as-you-go technique of looking for FOD during their normal shifts in the course of their regular duties. Inspections occurring at night, taking place after the runway is closed or before the runway is opened, also occur frequently. During night time inspections, personnel and vehicles should be equipped with additional lights/ lighting systems to better detect FOD. In addition to these ACs, there are some additional inspec- tion techniques that airports may wish to consider. First, air- ports may differentiate between proactive inspections and reac- tive inspections. Proactive inspections are those conducted on a regular basis, whether once per day or every 6 h, to inspect for FOD (as well as other airfield items). Reactive inspections are necessary once FOD has been reported. This involves reacting to a FOD event by responding to the AOA and removing the debris, initiating any corrective action, and documenting the FOD event. All successful FOD management programs use both proactive and reactive inspections. When conducting a reactive inspection (i.e., responding to a FOD report), it is beneficial to inspect areas in addition to that where debris were reported; FOD may have relocated since it was reported. Likewise, location reports may be inaccurate. If, for example, a rock was reported and that rock was removed, inspection of the surrounding area might reveal a larger spall with additional debris that need removing. If inspection personnel respond to a FOD report and discover nothing, it is important that additional areas (both pavement and non- pavement) be inspected in an attempt to locate the debris. This may mean that a reactive inspection transforms into a pro- active inspection, as inspection personnel begin searching for additional FOD that may have not been reported. Next, although many airports utilize operations personnel to conduct inspections for FOD, some airports also rely on Aircraft Rescue and Fire Fighting (ARFF) personnel, mainte- nance personnel, and police personnel. At some airports, such as Vancouver International Airport, ARFF personnel may respond to remove debris, because ARFF personnel can often do this more expeditiously than operations personnel who may be inside a terminal building at the time (B. Patterson, personal communication, 2010). Next, when considering the actual time to conduct an inspection, airports may wish to consider shoulder periods; that is, those lower traffic periods either before or after peak. At many U.S. airports this tends to be around 9:00 a.m. local time. When conducting inspections at night, by focusing on active runways, inspection personnel can then inspect inactive runways before they are used. It may also be helpful to integrate inspections with aircraft arrivals and departures. At Vancouver International Airport, for instance, self-inspections are integrated within aircraft arrivals and departures by filing for two departure slots to allow the inspection personnel the time to sufficiently perform an inspection on the runway. This allows about 3 min per runway, every 6 h (B. Patterson, personal communication, 2010). Yet another issue when conducting inspections is the type of aircraft using the airport. If only propeller aircraft use the airport, inspection personnel may wish to consider prop wash and focus near the center of pavement areas. Airports serv- ing wide-body jets, on the other hand, may wish to con- sider the consequences of jet blast and focus inspections on runway and taxiway shoulders, in addition to the center of pavement areas. Airports with jet service that do not have asphalt paved runway shoulders may wish to consider this airfield improvement. PREVENTION TECHNIQUES In addition to inspections for debris, proper housekeeping can go a long way in preventing FOD on the front end. As shared by Reid (2004, p. 30), “Almost every FOD incident can be traced back to bad housekeeping.” Although this may not be true for wildlife and other natural FOD, it is certainly true for items such as packing material and tools. Therefore, good housekeeping practices are an essential part of FOD prevention techniques. Specifically, as promoted by Reid (2004, pp. 30–31): • Keep your house and equipment in good repair – Equipment that is worn out and broken may leave a part behind, not noticed until someone runs up an engine. • Watch your “stuff ”—materials, packaging, etc. – All packing material, binding tapes and wires, string, pieces of cardboard, wood, and plastic must be picked up and disposed of properly. Delivery personnel must

also be attended to, to make certain they leave no debris behind. • Pretend the Tool Lady/Man is coming to visit – By pretending that management or “company” is com- ing for a visit or inspection personnel are motivated to tidy up. Tool control is of utmost importance and may take many forms, including foam cut-out tool shadow panels in toolboxes, formal checkout procedures, and electronic tracking. A best practice is to take only those tools needed for a job, carry, count, and use them with the same routine, and thoroughly check a work area when finished. • Parting is the key to avoiding “sweet sorrow” – The number of parts, pieces, connectors, caps, and fasteners must be tracked and controlled. Parts con- trol, as with tool control, is critical. • Track it and tie it down! – Prop wash and jet blast turn loose items into flying mis- siles. Personnel must operate as if someone is about to start an engine by keeping tools, materials, clipboards, and other items secure and in their proper places. • Write it down and talk it up – Personnel should be encouraged to observe, analyze, and communicate with supervisors to ensure that unsafe practices are eliminated and safety is improved. The European Organization for the Safety of Air Navigation (Eurocontrol) suggests European airports do the following to prevent FOD occurrences (Chadwick et al. 2010, p. 22): • Clear loose material from land adjacent to the movement areas. • Wash the tires of visiting vehicles before they are allowed to go airside. • Maintain all airside vehicles in a good state of repair and cleanliness. • Provide Foreign Object Bins for use by airport personnel. • Make sure all airside personnel are properly trained and made aware of foreign object damage. 16 • Communicate with all stakeholders and actors to main- tain awareness of foreign object damage. CURRENT EQUIPMENT AND TECHNOLOGY AVAILABLE FOR INSPECTION Inspection Continuum The equipment and technology available for airports in inspect- ing for FOD falls along a continuum. This continuum ranges from using a vehicle with a manual checklist to using a vehicle with a GPS/GIS-based inspection and database application. As with all technology, prices vary by the size of the airport and the degree of technology in use. Generally, more technology equates to higher costs, although each airport may wish to eval- uate the use of technology in its specific situation as the bene- fits in efficiency achieved with the adoption of technology may not only enhance employee morale and reduce operational staffing needs, but also improve the rate of debris detected on the airfield. The continuum in Figure 8 has been developed to present the range of options available to airports. Manual For most airports, the first line of defense against FOD has been, and continues to be, human observation. To aid the individual with the inspection, manual equipment (such as a vehicle) is often relied on, which typically involves an employee driving a vehicle onto the airport surface for obser- vation and completing a paper-based inspection or FOD checklist. Although this has been an accepted practice for years to meet FAA requirements, some airports have adopted various forms of technology to enhance this process and improve the efficiency of their human observations. Rather than completing a paper-based checklist, airports may imple- ment an electronic checklist, typically loaded onto a PDA (personal digital assistance), tablet personal computer, or note- book computer. This technology allows the individual to elec- FIGURE 8 Continuum of technology and equipment available for inspection.

17 tronically complete a daily self-inspection checklist or a FOD reporting form, typically while still in the vehicle. By syncing it with the airport’s inspection database records are easily maintained and trend analysis is easily performed. Technology-assisted Manual The final step on the continuum involves use of a GPS/ GIS-based inspection and database application. This technol- ogy provides the user with the ability to pinpoint the exact coordinates of FOD as well as other airfield discrepancies using GPS coordinates, allowing maintenance personnel, for example, to quickly locate discrepancies that were discov- ered by operations personnel, rather than relying on a written description of where a discrepancy is located. Prior to this technology, for example, edge lights along a runway were numbered and if a light needed attention the light number was forwarded to maintenance for resolution. Many of the GPS/ GIS-based platforms overlay the exact location of an item needing attention onto a graphic of the airfield, simplifying the subsequent location of identified items. CURRENT AIRPORT INSPECTION PRACTICES Degree of Problem Of the airports participating in this synthesis, only 18% believed that FOD was not a problem at their airfield. This minority was overshadowed by the 56% who stated that FOD is somewhat a problem, 24% that FOD is a moderate problem, and 2% who noted that FOD is a severe problem at their airfield. By inferring these results to airports nation- wide, one can conclude that FOD is clearly a problem of some degree at airports nationwide. Use of Foreign Object Debris Management Program Sixty-five percent of the airports participating in this synthesis currently have a FOD management program in place. Among the large hub airports, 75% have a FOD management program in place, whereas only one-third of GA airports have such a program. FOD management programs are typically formal programs with an emphasis on inspection, detection, removal, documentation, and promotion and awareness. Even so, of the 35% of participating airports that do not currently have a FOD management program in place, only 12% have plans to implement such a management program during the next 12 months. Methods in Use When queried about the inspection methods an airport cur- rently uses, not one airport answered that they do not inspect for FOD. Thus, all participating airports inspect for FOD using one or more methods. As can be seen in Table 1, on a daily basis, the majority of participating airports utilize a visual inspection process, not including FOD walks. This typically involves an airport employee (generally from either the oper- ations or maintenance department) driving a vehicle down taxiways and runways during a daily airfield inspection, all the while keeping an eye out for debris. On a daily basis, it appears that 26% of participants also use FOD walks to some degree along with their visual inspection method. FOD walks appear to be used by an additional 18% on a weekly basis, an additional 12% use them on a monthly basis, and a further 6% use FOD walks annually. Based on survey responses, a daily FOD walk may only include a ramp area, whereas monthly or annual FOD walks may involve closing a runway. Combined these responses sug- gest that 62% of participating airports utilize FOD walks on at least an annual basis. Although not a new concept, FOD walks are becoming a more common method of thoroughly inspecting pavement for debris at airports. With a foundation in the military, FOD walks have been relied on for decades on U.S. aircraft carriers to ensure that a flight deck is free of foreign objects. Indeed, the decks of U.S. aircraft carriers are walked by personnel at least twice daily (McCreary 2010). Although these walks may require closure of pavement, they allow an airport to utilize the assistance of numerous airport employees to thoroughly scan yllaunnA ylhtnoM ylkeeW yliaD dohteM Human/Visual (not including FOD walks) 89% 6% 0% 0% Human/Visual (including FOD walks) 26% 18% 12% 6% Continuous Surveillance Using Technology/Equipment 6% 0% 0% 0% Periodic Surveillance Using Technology/Equipment 4% 4% 0% 0% Our Airport Does Not Inspect for FOD 0% 0% 0% 0% Note: Participants were asked to select all that apply. Thus, percentages may not equal 100% across categories of methods or frequency of inspection. TABLE 1 FOD INSPECTION METHODS

an entire length of pavement (typically a runway) for any foreign objects in a relaxed setting (i.e., with no aircraft on final approach). A FOD walk is a good way to estimate what has been missed during FOD inspections. Although an airport may hold a FOD walk only once each year, these events can create an esprit de corps among participants. FOD walks, and their use in promotion, are discussed in detail in chapter seven. 18 weekly basis). An in-depth discussion of these various systems is presented in chapter three. When asked about the frequency of runway closures for non-routine FOD inspection or removal, more than half of respondents (52%) indicated they did not close runways for non-routine FOD inspection removal. This finding supports the need for the 2009 Cert Alert (09-06) that was issued to airports advocating the closure of runways, if necessary, to prevent operations until debris are removed. The findings indicated, however, that almost 30% are forced to close a runway one or more times each month. At Whiteman Air Force Base in Missouri, FOD walks are con- ducted every Tuesday and Thursday. With several multi- billion dollar aircraft operating from Whiteman Air Force Base, including 20 B-2 Stealth Bombers, FOD walks are seen as integral to ensuring flight safety. Because of around-the- clock operations, crew chiefs, maintainers, and other person- nel working on the Whiteman flightline all assume responsi- bility for eliminating FOD to keep aircraft and personnel safe. “FOD is and will always be a dilemma, but it is absolutely one that we keep to a minimum by performing these walks and ensuring we collect even the smallest bits of FOD,” explains Technical Sergeant Kenneth Prenger, 131st Bomb Wing crew chief. Whiteman has discovered that even sweeper trucks may miss some debris; therefore, Airmen and civilian personnel working on the flightline participate in regular FOD walks by lining up side-by-side and walking across the aircraft ramp. According to Whiteman statistics, 363.1 pounds of FOD was collected at the end of the first quarter of 2010. “FOD prevention is everyone’s responsibility,” Sergeant Kelly explains. “We are all one team. If anyone sees FOD, it’s their job to ensure it gets picked up”. (Source: Holston 2010, paragraph 12). It appears that only 6% of participating airports use any continuous surveillance technology or equipment for detect- ing FOD, whereas 4% use technology or equipment for peri- odic surveillance on a daily basis (and an additional 4% on a Although almost one-third of participating airports indi- cated they are forced to close a runway once or more per month as a result of FOD, airports are typically hesitant to close runways (even for a short time) for this purpose. Even though a closure for FOD would often be in the best interest of safety, ATC and the airlines may not support closures of active runways, especially with no advance notice. For this reason, in 2009, the FAA issued a Cert Alert (No. 09-06) indicating that the FAA’s Office of Safety and Standards had been made aware of “instances where some airports have failed to take immediate and positive action following a report of FOD (on or near the runway) from flight crews” (FAA 2009b, paragraph 2). As a result, the Cert Alert reminds airport operators to develop procedures for “affecting immediate runway closures in the presence of certain types of FOD, such as large pieces of metal, large aggregate, large concrete spalling pieces, and any other materials likely to pose a high risk for operators” (FAA 2009b, paragraph 3). To effectively accomplish this, airports may enter into a Letter of Agreement or Memo- randum of Understanding with ATC to effect closure when circumstances dictate (Appendix H). (Source: FAA 2009b).