Overview of Airport Fueling Operations (2015)

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40 chapter six FUELING SAFETY PRACTICES In 1964, the CRC reviewed technical information on the safe handling and usage of aviation gasoline and jet fuel available at that time. The report concluded: “safety of fuel handling is more a function of equipment design, proper handling techniques, and rigorous precautions than of the particular fuel type employed” (Aviation Fuel Safety 1964). Safeguarding the entire fuel system from contaminants, flash point sparking, and leakage is an important aspect of the fueling industry. Built-in safety features, such as fuel level and leak monitoring systems, automatic fire suppression systems, and vehicle collision protections, are integral features of an airport fueling system. FUEL CHARACTERISTICS Jet fuel is a combustible liquid, whereas avgas is a volatile flammable liquid. Contaminated fuel results in underperforming or failed engines. Spilled fuel can contaminate the ground, water, and air. Fuel vapor can affect human health. Over-the-wing fueling exposes a worker to the vapors, and in the case of avgas, such vapors are easily ignited by static electricity. It is for these reasons that the industry takes utmost care and concern in the safe handling of fuel. Basic Properties of Aviation Fuels and Gasolines A review of training material developed for the industry generally includes information on the proper- ties and characteristics of fuel. A basic understanding helps to minimize or prevent injury, damage, or loss as a consequence of fuel use or misuse. Table 1 presents basic data about different fuel properties and characteristics; the data are taken from various material safety data sheets (MSDS). Specific oil company products can vary from the table listings. To be used in aviation, fuels must meet the stan- dards established by API, ASTM, IATA, JIG, or EI. For a more comprehensive description of the prop- erties and their fuel handling procedures, refer to ASTM’s Fuel Quality Control Procedures (2009). Clear and Bright When examined visually, industry standards call for jet fuel to appear clean and dry, clean and bright, or clear and bright. The standards identify clean fuel as one that lacks particles, silt or sediment, flakes, dye, rust, or solids. A bright fuel is one that visually sparkles and is not cloudy or hazy. Although no definition for the term “dry fuel” was found in the literature, “wet fuel” is described as any form of free water appearing as droplets or bulk water on the bottom of a white bucket or clinging to the sides (Standard for Jet Fuel Quality Control at Airports 2009). A dry fuel appears bright because of the absence of water. The bright distinction is made because a sample of fuel that is wholly water would appear clear but dull and not have a sparkle to it. Figure 23 shows different stages of jet fuel contami- nation from clear and bright (left) to opaque with excess water (right). The term “clear and bright” is used more commonly by the industry than the other terms. Accord- ing to ASTM D6986, the terms “clean and bright” and “clear and bright” have identical meaning. FAA AC 20-125 provides this distinction: Smaller amounts of entrained water can be detected by testing with a clean and dry clear glass bottle. If fuel is acceptably dry it will appear bright with a fluorescent appearance and will not be cloudy or hazy. The clear and dry bottle test is known as the ‘clean and bright’ test. The fuel is clean when it is clear and is bright when it is dry. (AC 20-125 1998)

41 The goal of jet fuel transport and delivery is for jet fuel to conform to the latest revision of ASTM D1655, Standard Specification for Aviation Turbine Fuels, Jet A or Jet A-1 Kerosene Type. Two common means to quickly and easily check for the clear and bright characteristics are with a “white bucket” test, or with use of a clear glass jar. A white porcelain bucket is necessary for the proper detection of fuel color (Standard for Jet Fuel Quality Control at Airports 2009). Jet fuel has an appearance of no color (clear) to straw color. Kerosene-based fuels used for nonaviation purposes FIGURE 23 Different contamination levels of jet fuel. (Courtesy: Precision Filtration Products; used with permission.) Type of Fuel Jet-A Jet-A1 Jet-B JP-5 JP-8 Avgas100 Avgas 100LL Fuel basis Kerosene base Kerosene base Kerosene/ naphtha blend Kerosene base Kerosene base Gasoline Gasoline Use Commercial, narrow cut Commercial, cold climate Commercial/ military, wide cut, easy start US Navy/ US Coast Guard US Air Force High HP/ compression piston Low compression piston engines Additive SDA FSII, SDA SDA CI/FSII/SD A CI/FSII/SDA/ lubricants Antiknock/ antioxidant/ SDA Flash point 37.8°C/ 100°F >38°C/ 100°F 29°C/ -20°F 60°C/140°F 38°C/100°F -46°C/ -51°F 40°C/-40°F Autoignition temperature 210°C/ 410°F >220°C/ 428°F 246°C/ 475°F 246°C/ 475°F 210°C/ 410°F 440°C/ 824°F >250°C/ 482°F Lower/Upper flammability or explosion limits 0.6–4.7% (V) 1–6% (V) 0.7–7% (V) 0.7–5.0% (V) 1.0–6.6% (V) 1.4–7.6% (V) Vapor pressure 0.0077 psia <0.014 psia at 20°C/68°F 2.5 psia at 38°C/100°F <1 psia at 38°C/100°F 5.5–7.1 psi at 38°C/100°F >5.5 psia at 38°C/100°F Flame spread rate 100 fpm 100 fpm 100 fpm 100 fpm 100 fpm 700–800 fpm 700–800 fpm Boiling point/ boiling range 149°–300°C/ 300°–572°F 150°–300°C/ 302°–572°F 72°C/162°F 179°C/ 354°F 160°C/ 320°F 60°–170°C/ 140°–338°F 25°–170°C/ 77°–338°F Freezing point 40°C/ -40°F 47°C/ -53°F -65°C/ -85°F -46°C/ -51°F -58°C/ -72°F -58°C/-72°F Color Clear, light yellow Pale straw Clear Colorless Clear, white Green Clear, blue Adapted from Material Safety Data Sheets (MSDS) of various manufacturers. Use for illustrative purposes. fpm = feet per minute; HP = horsepower; psia = pounds per square inch absolute. TABLE 1 PROPERTIES AND CHARACTERISTICS OF VARIOUS AVIATION FUELS

42 have colored dyes that make cross-contamination more easily apparent. Avgas has a blue or green dye tint, depending on the grade. Additional quality control checks used in the industry include the use of water detection kits (because the human eye is not capable of detecting free water below approximately 30 parts per million) and API gravity testing (Refueling and Quality Control Procedures for Airport Service and Support Operations 2000). ASTM Manual 5, ASTM D3240, ASTM D1298, and ANSI/ASTM D287 provide further guidance on water detection, gravity, and other quality checks. The literature indicates the most common types of contaminants found in fuel are water, dirt, iron rust, scale, and sand. Other contaminants found include metal particles, dust, lint from filter material and rags, gasket pieces, and sludge from microbacteria. FIRE SAFETY ISSUES Of major concern to all involved in the operation of a fuel system is the potential for fire and explo- sion. A fire is the result of a heat source igniting a correct mixture of fuel and oxygen. The fire tetrahedron is a model for understanding the components needed for a fire; FAA efforts to prevent a fire are focused on eliminating one or more of the three components. It is difficult to eliminate oxygen or the use of fuel in aviation, so safety efforts are focused on reducing sources of heat or ignition (AC 150/2530-4B 2014). Sources of ignition can include lightning, open flame, electrical spark, static discharge, chemical reaction, or any heat source that can raise or ignite the fuel-air vapor mixture. It is for this reason that fuel trucks have sealed lights, wiring, and switches; no cigarette lighters; enclosed battery boxes; and other measures designed to eliminate a potential spark, ignition, or heat source. The distinction between jet fuel as a combustible liquid and avgas as a volatile flammable liq- uid lies in their flash points, or the point that a readily ignitable mixture of air and vapor exists. If a material has a flash point at or above 100°F, it is considered combustible. Flammable materials are those with flash points below 100°F and/or a vapor pressure not exceeding 40 pounds per square inch (psi). Jet fuel can have a flash point between 95°F and 140°F, making it either a flam- mable or combustible product, depending upon its product formulation. Avgas easily produces adequate vapors to mix with air and can be ignited at temperatures warmer than -40°F. For this reason, caution with avgas is to be taken under any temperature condition because it is very volatile (will ignite easily). A primary safety concern for avgas and jet fuel storage, piping, transfer equipment, and vehicles is the possibility of static discharge or lightning igniting a fuel. Industry standards call for provisions to be made for the grounding and/or bonding of facilities and equipment, as per regulations, standards, fire code, or other design and operating requirements. Fuel moving through a fuel pipe or hose generates electrostatic potential. API 2003 provides information on acceptable flow rates given pipe size and other factors (Protection Against Ignitions Arising Out of Static Lightning and Stray Currents 2008). The slower the flow rate, the less the electrostatic potential. Bottom or single-point loading helps to reduce vapor generation. Over-the- wing fueling (splash filling) has bonding and flow rate requirements different from those of bottom or single-point loading. For low flow over-the-wing nozzles, having or maintaining a bond with the aircraft filler at the nozzle is a most effective practice. In either case, standards call for the fuel pump, cart, or truck to be bonded to the aircraft. When a fuel/air mixture is ignited, the speed with which the flame will spread across the pool of vapors is an indication of the fuel’s volatility. This is called flame spread rate. Jet fuel has a slow flame rate, such that if a pool of jet fuel is ignited at one end, a person can briskly walk away from the advancing flame. For avgas, if a pool is ignited at one end, it will propagate faster than a person can escape.

43 A number of tutorials exist on the web to familiarize employees with fire and explosion hazards and with combustible and flammable products. Available from FEMA is a report on the experiences of the Pittsburgh International Airport (PIT) with fuel-related emergencies and how to minimize or mitigate such emergencies (Eicher n.d.). HEALTH SAFETY ISSUES A number of health issues are involved with the handling of fuels. Information is best found on the MSDS for the product being used or through the Emergency Response Guidebook (2012). An MSDS identifies the specific safe handling procedures and health effects of exposure. A proper fuel handling training program normally addresses these safety issues. According to Occupational Safety and Health Administration (OSHA) and a review of MSDS, health can be affected by acute or chronic exposure to gasoline, diesel, and jet fuels. Avgas can cause skin and eye irritation. Inhaling its vapors can cause unconsciousness; ingestion into the lungs is harmful and can be fatal. Jet fuel is harmful or fatal if swallowed. Lung damage can occur from inhalation of the mist, and its fumes will irritate the skin, eyes, and respiratory tract. Consistent skin contact can result in cancer. OSHA guidance provides that eyewash facilities and deluge showers are to be available for use in the event of splashing or spraying of fuel on a person (Figure 24). A review of MSDS is commonly provided in any industry training material. Studies have shown neurotoxic effects of hydrocarbon exposures may lead to neurobehavioral consequences (Medical Management Guidelines for Gasoline 2014). A search of literature from the U.S. National Institute for Occupational Safety and Health (NIOSH) showed a number of studies have been completed on exposure to jet fuel and avgas during fueling operations. Although none of the NIOSH investigative reports found exposure to the effects of jet fuel beyond accept- able limits, they did find a hazard exposure to carbon monoxide (CO) as a result of a fuel handler’s exposure to refueler truck operation. During inclement weather, operators often sit inside idling fuel trucks to stay warm. CO exposure occurs as a result of the cabin’s closeness to the exhaust outlets (Millar 1984). FIGURE 24 Example of eye wash and water deluge system at a fuel loading area. (Courtesy: SMQ Airport Services.)

44 Fuel system icing inhibitors (FSII) can be toxic if absorbed into the skin because of their affinity to join with water. FSII is not contained in Jet A, which is the prevalent fuel in the United States. However, there are certain jet aircraft engines that require FSII. For civilian aircraft needing an FSII, the agent normally is injected into the fuel tank along with the jet fuel to achieve proper atomization. Any spillage is to be immediately addressed according to the product’s MSDS. OSHA guidance is for fuel handlers and testers to use fuel-resistant gloves and approved protec- tive eyewear when fueling aircraft or testing fuel (Personal Protective Equipment 2003). If entering a confined space, such as a UST or AST, OSHA’s confined space entry regulations apply. In particular, nonstatic protective suits and respirators are to be worn, fuel vapors are to be purged from the tank, forced air provided, respiratory equipment used, and a spotter is to be positioned just outside of the tank to assist if needed (Figure 25). HUMAN FACTOR ISSUES Human factors are described by the FAA as a multidisciplinary effort to generate and compile infor- mation about human capabilities and limitations, and apply that information to equipment, systems, facilities, procedures, jobs, environments, training, staffing, and personnel management for safe, comfortable, and effective human performance (FAA Order 9550.8A 2005). The factors that affect humans and their work performance can be varied, as compiled from various human factor defini- tions. They can include the following: • workload, • fatigue, • shift work, • human error, • visibility, • user interface, • vigilance, • attention, • individual differences, • cognition, • learnability, • accessibility, • sensation, • data visualization, • aging, • stress, • situational awareness, • perception, • human performance, • usability, FIGURE 25 Equipment required for certified confined space fuel tank entry. (Courtesy: FAA Aviation Maintenance Technician Handbook—Airframe 2012.)

45 • control and display design, • motor control, • muscular strength, and • work in extreme weather conditions. From interviews with fueling operators and from the literature review, it was found that training on human factors is increasingly incorporated into the material for fueling operators. This is in con- junction with overall efforts by the airlines and trade organizations to reduce accidents and by the FAA to advance SMS processes into the airport and ground handling functions. A lack of vigilance and complacency are two factors of concern in the fueling industry. For instance, a required safety practice in place for the pumping of fuel is to have an enabling switch (a dead man’s switch) (NFPA 407 2012). In addition to a pump switch that activates the flow of fuel, the enabling switch is triggered to allow for continued operation. It requires the presence of a human operator to monitor the fueling activities. Should the employee become incapacitated or face an emergency, a release of the switch or a lack of a human response will shut off the fuel (Figure 26). For over-the-wing fueling operation, the switch can be integrated into the pump handle. For fuel transfer operations from a truck or hydrant system, the enabling switch can be a separate electrical or pneumatic switch. The problem of complacency can arise during transfer of fuel, especially for large volumes. As noted, the loading or unloading of fuel can be a lengthy process. During that time, the human opera- tor is to be doing nothing but monitor the transfer and clutch or press the enabling switch. For an A-380 aircraft with a capacity of 84,000 gallons, fueling through a hydrant system and double nozzles can take upward of 2 hours of monitoring time. It is easy for a lack of vigilance or com- placency to affect the human operator, especially if no incidents have occurred in recent memory. Operators have been known to attempt to defeat the need to hold the enabling switch by blocking or tying it off (Figure 27). To combat complacency or defeated safeguards, some switches require activation at certain intervals during the fueling process to ensure the operator remains attentive. Human factor problems with fueling are seen in accident reports in which an operator misfueled an aircraft with quantities other than what was expected, such as delivering the fuel in pounds, rather than in liters or gallons. One FBO operator in the study has painted “WE PUMP IN POUNDS” in large letters on its jet fuel truck. Employees are trained to verify pilot fuel order quantities and calculate proper conversion if necessary. Human factor issues can further be seen in a fuel-handler confusing a turbojet-powered aircraft that uses jet fuel with one that has a turbocharged piston engine that uses avgas. Misfueling will FIGURE 26 Example of employee monitoring mobile tank fill and operating an enabling switch. (Courtesy: S. Quilty, SMQ Airport Services.)

46 result in a damaged engine and poses a severe safety threat. EI 1597 (2006) provides a comprehen- sive set of procedures for addressing the many possible causes of misfueling. To enhance safety and reinforce training, two airports in the study posted their fuel loading and off-loading procedures at their respective transfer stations (Figure 28). ACCIDENT INFORMATION The review for this synthesis did not discover a public lesson-to-be-learned database of accident or incident reports. Although data are collected through insurance, oil companies, and profes- sional organizations, the data generally are retained within those organizations and not made freely FIGURE 27 Sign designed to deter an unsafe fuel loading practice. (Courtesy: S. Quilty, SMQ Airport Services.) FIGURE 28 Example of procedures to load and offload fuel posted at transfer station. (Courtesy: S. Quilty, SMQ Airport Services.)

47 available to the public. A report from the United Kingdom (Jones et al. 2000) also indicates that such information is scarce. Workplace accidents involving fueling accidents are reported to OSHA in the United States. Information on individual instances of worker injuries during fueling operations can be searched on OSHA’s website (www.osha.gov). Fuel tanker truck mishaps are reported to the U.S.DOT. As reported by the Flight Safety Foundation (FSF), only refueling incidents that result in severe aircraft damage or personnel injury appear to be reported (FSF Editorial Staff 2001). Minor incidents are often not reported because injuries related to refueling tend to be rare or there is no requirement to report the data. In the same report, FSF reviewed fueling-related fire occurrences from 1966 to 1998 worldwide and found only 15 reported cases. Yet, as FSF noted, each year thousands of fuel spillage events occur worldwide. As part of the 2013 FAA Design Challenge for Airports, one entry proposal reviewed a number of environmental spills at airports (Table 2). A loss prevention company in the United States compiles a list of the 100 largest losses in the hydrocarbon industry (The 100 Largest Losses 1972–2011 2012). Although many of the losses are not aviation related, brief summaries contained in the report have applicability to airport installations and provide insight into what can go wrong and lessons to be learned. PEI has an incident reporting function for its members that is published in the organization’s member safety letter. FAILURE MODES Two recent disruptive fuel fires that affected two large airports in the United States were fuel pump failures: Miami International Airport in 2011 and Boston Logan International Airport in 2013. A question is raised as to the prevalence of fuel pump failures that result in fires. A literature search did not find the frequency of fuel pump failures. Date Location Operation in Progress Gallons Spilled Incident Description 1/13/13 Tokyo, Japan Defueling 26 During the defueling operations of Boeing 787, a valve was found open on aircraft wing. Unknown clean-up measures. 1/8/13 Boston, Massachusetts Taxiing to runway 40 While the Boeing 787 was taxiing to the runway, a leak was discovered. Unknown cause and clean-up measures. 1/3/13 Marion, Ohio Truck refueling 2,500 While a fuel truck was refueling, the fuel overflowed and migrated into a creek. Unknown cause of overflow. Booms and vacuums used for cleanup. 1/12 Milwaukee, Wisconsin Pipeline fuel transport Unknown Fuel leaked from pipeline for 2 weeks and was discovered because of a strange odor. Booms installed in water for cleanup. 7/12 Fresno, California Fuel truck transporting fuel to aircraft 200 While a fuel truck was driving on tarmac, it overturned. Unknown cause for overturn and clean-up measures. 1/27/12 Chicago, Illinois Pipeline fuel transport 42,000 Pipeline burst and spilled fuel into a ditch. The Coast Guard and EPA were involved in the cleanup. 1999 Kirtland AFB, New Mexico Pipeline fuel transport 24 million Fuel coming up from underground at aircraft storage center. Monitoring for wells is being installed to determine contamination levels. Source: Bielefeldt et al. (2013). TABLE 2 SAMPLE ENVIRONMENTAL FUEL SPILL ACCIDENTS AT AIRPORTS

48 A 2000 United Kingdom Health and Safety Executive report on risk assessment in fueling opera- tions provides a list of global fueling accidents and is a good source for lessons to be learned and recommended actions to be taken (Jones et al. 2000). The accidents reported were a result of many varied actions or failures. Faulty shutoff valves at the tank or at the nozzle/hydrant were the most common causes of fuel spills. However, human error resulted in the largest amount of spillage. In the report, common failures during fueling operations included: • underwing couplings becoming detached from the aircraft; • nozzle quick disconnects separating; • vehicle impact damage to hydrant couplers; • failure of hydrant couplers as a result of incorrect reassembly after the couplers were modified; • hose ruptures; • failure of valve or poppet to close; and • accidental disconnection of a coupling after the failure of an interlock. Hydrant fueling operations pose a particular environmental risk because the frequency, volume, and pressures can result in large quantities of spillage or escaping high-pressure leaks are atomized quickly and are more susceptible to ignition. Although rare, the rupture of an underwing fuel hose can result in a spillage rate upward of 550 gpm, whereas the rate for a hydrant pipe or connection failure could be upward of 1,600 gpm (Ramp Operational Safety Procedures 2014). A major fuel tank fire at the Buncefield Oil Terminal in England was determined to be the result of failure of an AST’s high-level switch, coupled with a failure of the alarm system during the night- time hours, when only one person was on duty. The chain of events resulted in an overflow that was not detected. Weather conditions allowed for an unconfined vapor cloud explosion (UVCE). The accident significantly reduced jet fuel delivery to major airports in the United Kingdom (Buncefield Major Incident Investigation 2006). SAFETY MANAGEMENT SYSTEM AND HAZARD IDENTIFICATION An SMS is the formal, top-down, businesslike approach to managing safety risk. It includes systematic procedures, practices, and policies for the management of safety, including safety risk management, safety policy, safety assurance, and safety promotion (Advisory Circular 150/5200-37 2007). Research and interviews for this study found the use of SMS principles at airports to exist primar- ily at the larger organizations of into-plane fuel providers or FBO chains. Organizations that sought certification from third parties, such as those offered by IATA Safety Audit for Ground Operations (ISAGO), NATA Safety 1st, or International Standards Organization (ISO) quality management for fuel handling practices, were most likely to have an SMS or similar process in place. The FAA has issued a Notice of Proposed Rule Making (NPRM) to require Part 139-certificated airports adopt SMS principles as part of their airport certification manual (75 FR 76928 2010). Noncommercial or GA airports initially will be unaffected. A number of engineering tools can be applied to the identification of hazards in any industry and to the determination of failure causes. Known as hazard assessments (HA), failure mode and effects analysis (FMEA), fault tree analysis, and other terms, these analyses can be applied to the airport fuel system. Fault tree analysis is used to better assess and calculate the risk or cost benefit of a particular operation. When auditors were asked in interviews about whether an FBO, airline, or airport organization conducted such analyses, none indicated that they were involved in such assessments at their level. Examples of HA, FMEA, and fault tree analyses are shown in Appen- dices C through I. The 2000 United Kingdom report previously mentioned provides examples of various risk assessments and failure modes performed to illustrate the benefit of safety risk assessment (SRA) using the fault tree analysis and FMEA tools (Jones et al. 2000). The use of the tools focused on identifying what measures would reduce the frequency of a spill; what could reduce the size of the

49 spill; and what could reduce the possibility of ignition after a spill. An evaluation of the risk assess- ment tools in the report identified a significant proportion of the fuel spills at UK airports were caused by vehicles striking a hydrant during fueling. In determining the cause and risk, potential technical and SMS solutions were identified. For instance, under the category of hardware, solu- tions examined were to: • Increase the visibility of the hydrant through pavement marking cones or flags (Figure 29), • Provide a physical protective barrier, • Reduce the need for vehicle operations or backup in the area, and • Increase the reliability of the primary isolation system. Solutions examined as part of the overall SMS were to: • Raise awareness through training, • Improve supervision of fueling operations, • Increase the number of audits of fueling operations to ensure practices are followed, • Make provisions for use of second person for vehicle backups, and • Improve the location and identification of emergency shutoff switches to reduce reaction time to a spill response. INSPECTION Airports certificated under 14 CFR Part 139 have a regulatory requirement to perform inspections of fueling facilities at their airports, in particular to conduct regular daily inspections, continu- ous surveillance as necessary, and more detailed inspections every 3 months. AC 150/5200-18C provides guidance on the three types of inspection processes to occur. Part 139 also requires cer- tification from fueling agents on the airport as to the training records of individuals engaged in fueling operations. In AC 150/5200-18C, FAA cites NFPA guidelines as acceptable means of compliance for Part 139. A state, municipality, airport operator, or local fire jurisdiction may choose to have different standards. During an annual certification inspection, differences between the standards used at an airport may need to be discussed with the FAA inspector. In addition to NFPA, other standards exist, such as those of individual air carriers, local fire and building codes, and those of petroleum and fuel producers. Specific inspections of fuel facilities, vehicles, and equipment are to follow those outlined in any standards or operating manual adopted by the airport. Appendix J excerpts the fuel system inspection FIGURE 29 Marking and flag identification of fuel hydrant pit. (Courtesy: FAA.)

50 criteria from the FAA. In general, some industry practices for inspection of fuel systems include the following: • Daily – general cleanliness and conditions of grounds – filter and tank sumps – differential pressure at full flow – enabling switch operation – grounding rods, reels, cables, and clamps – fire extinguishers. • Monthly – Millipore testing – grounding cable continuity (continuity test) – bottom loader fuel strainer – signs and placards – floating suction cables – fire extinguishers. • Quarterly – emergency shutdown system – water defense and foam system – tank high-level controls and alarms. • Yearly – storage tank interior – differential pressure gauge – filter elements – filter separator heaters – tank vents – cathodic protection – pump line filters – water defense and foam systems. • Periodic – maintenance of all equipment – manufacturer recommendations. The focus of Part 139 inspections is on safety in fueling operations and not on quality control. There is no federal regulatory mandate for private companies to perform fuel quality assessments. However, the consequences of not providing proper fuel quality are understood in the industry because the out- come can have catastrophic consequences. Safety of operations, corporate responsibility, legal liabil- ity, customer expectations, and good business practice dictate the requirement to diligently monitor, inspect, and test fueling operations. It is for this reason that the airlines first formed a committee to identify fuel standards, resulting in ATA 103. According to a well-known industry fueling expert, the key to safe fueling is knowing what to look for, in both quality control and operations, and understanding what you see (“TOP 5 Fuel Quality Issues You Need to be Aware of” 2005). The author states, “You have to look for things out of the ordi- nary and understand their importance.” The top five problem areas identified were: (1) inadequate or poorly organized fuel quality control records and documentation, (2) irregular or inadequate inspec- tion or audit, (3) improper storage of fuel quality devices, (4) inadequate or poor signage and marking, and (5) haphazard white bucket testing and daily sumping. This has implications for training and also for the quality of those who inspect. Research seeking to identify a centralized database of fuel facility inspection results was not successful. Information culled from articles published in trade journals and interviews highlights a wide range of problems or issues (Crotty 2007). Interviews conducted with several NATA Safety 1st ground handling auditors support the list of problems cited previously at FBOs across the country.

51 RECORD KEEPING Documenting fuel deliveries, inspections, and tests is a standard of any quality control program. Record keeping allows for the determination of a change in a process, demonstrates compliance with regulations, acts as a check against claims by others, and serves as historical record of the business. ATA 103, NATA Safety 1st, and the branded fuel suppliers provide forms for recording all aspects of fueling operations. Several of the forms are reproduced in Appendices L through S. In the words of one airport operator, the role of the airport inspector is to “trust but verify.” Verify- ing fueling agent records is one industry practice the FAA supports to ensure safe fueling operations. The airport inspector is verifying that the fueling agent is doing what the agent is supposed to do according to the operating manual, industry specifications, and airport or local government require- ments. Based on the literature and interviews with auditors, the absence of written records for many fuel-related procedures included the following (Crotty 2007): • filter changes, • hose replacement, • tank and equipment inspection, • fuel receipts and settling time, • ground and bonding cable resistance checks, • gauge calibration, and • personnel training.