Late last year, I posted that I was writing on another blog a complete series on an ISO31000 view of airport wildlife risk management. Well, that 7-part series is now complete and to view the whole series head over to my author page on New Airport Insider or you can read each post by clicking the individual links below.
The good folk over at the Australian Aviation Wildlife Hazard Group (AAWHG) have released their first Recommended Practice. It's still in draft form and comments are welcome. First off the block is a draft RP 3.2.1 - Firearm Safety. The document outlines a range of "shoulds" and is a great start, if not an end, for airport operators to get their own processes and procedures up to an industry standard - perhaps even, best practice.
I've been doing a bit of clearing of land at my airport to make way for a new fence. We've had to expand our borders to accommodate those new instrument approach procedures I mentioned a couple of weeks ago. Given that the airport is in "the bush", this meant knocking over a few trees to construct the new fence and make the new airside area completely manageable using tractors and mowers. So, we broke out the relatively cute D-6 dozer and set about clearing the new airport boundary and land.
This is probably my first real whinge post. But last week, I spent a good 9 hours on a Sunday in a training course that was a huge waste of time. And this was vital training - gun safety.
Airports are at the nexus of high visibility and idle time. We invite people to transit through our facilities. We provide windows for them to watch the action. We make them wait (hopefully not too long).
And how do they reward us?
By watching us at work. And sometimes, if you're unlucky, filming us at work...
Well, actually, his behaviour isn't really defensible, is it? ;)
This is me coming up for breath. I've been in the deep-end of airport operations for the last 10 months or so and I'm only just getting my head above water. I think (or at least hope) I've achieved a lot over the last couple of months but very little has been blog-worthy. However, over the last week or so, I've been swimming in that lovely little pool called Wildlife Hazard Management. And while I was re-writing my airport's Wildlife Hazard Management Plan, I stumbled across something I thought worthy of a share.
The Wild Side of Risk Assessment
The crux of my previous post was that the risk assessment of wildlife sits within the risk assessment of safety and that they may use different techniques. The SMS-level might use a standard risk matrix (or not) and the wildlife risk assessment might use a different technique such as the Paton bird risk assessment model.
The Risk Management Process
The two techniques are really just tools within the fairly standard risk management process. As the global standard puts it:
I think that some of this stuff most of us do well but there is a step we've been missing. It's that dark green one - evaluation.
Here is how I see most risk assessment processes going:
- We identify the risks - in this particular case bird species at or likely to be at the aerodrome
- We calculate a consequence and likelihood score for each species
- We assign each species to a risk category according to the model used
- We treat the risk - we think of stuff to do to address the identified risks
And all that sounds great but there is, to me, something missing. We might very well devise risk treatments that are sound and effective. We might even target those species that appear high up the list (let's call that, risk ranking, which doesn't appear in the standard). But how have we actually decided to do those things?
Well, good ol' ISO 31000 defines risk evaluation as:
(The) process of comparing the results of risk analysis with risk criteria to determine whether the risk and/or its magnitude is acceptable or tolerable
and notes that:
(It) assists in the decision about risk treatment
So what are risk criteria? Again, ISO 31000 says that risk criteria are:
terms of reference against which the significance of a risk is evaluated
Damn it ISO, buddy, you went a bit circular there. So what do I think the risk criteria are?
I look to the note above, they guide you in the decision making process. You set up parameters, before hand, that tell you what to do with risk assessed at the various levels you've set.
Here's an Example
I've just put together the risk assessment framework I intend to use at my airport. I'm basing it on Paton but extending it to land animals as well. I describe the calculation of consequence and likelihood and then outline (via a matrix :( ) the calculation of the final risk level.
I define what must be done for each risk category/level.
Even before I've looked out the door to see what birds I have at the airport. These requirements are now set in stone. It holds me to a standard and allows for variations in the real-world context, which will occur, to be managed in a consistent and almost predictable way.
This standard allows my bosses, my airlines and my team to know what is expected if we encounter a situation where a species is assessed as "extreme" or "very high" or "negligible".
And for me, those standards are:
Applying the Standard
Now, I go and look out the door. I, with the help of a qualified ornithologist or biologist, look at the environmental, operational and historical contexts and come up with a list of species. We score them and categorises them and then we have to do what the above table say we are going to do.
Any species assessed as "extreme" get their own plan (luckily none of them for me at this stage). Those at "very high" get general strategies that target them (for example, I will be implementing a short-grass policy to reduce my kite numbers) and so on.
As things change, I can also change my strategies with confidence as I have a standard to hold on to should I wish to drop strategies or introduce strategies.
And I think this is a good thing. Yes, you might get pinned in a corner and have to act in some cases but that is the point. You will be held accountable anyway and not setting a standard will not protect you if it all goes pear shaped - touch wood.
I long time ago I blogged about the risk posed by unexploded ordnance. Well, last week Schiphol Airport in the Netherlands had to deal with that very problem. [youtube=http://www.youtube.com/watch?v=xAxoc2oCZwg]
After a year away from airports, I couldn't stand it any longer. So, I'm back and this time I'm actually working for an airport operator. As such, I'll be swimming in airport stuff again and as I hit something interesting, I'll post it here. I'll also be posting a few projects I'm working on and a couple of handy hints and tips from time to time.
While I've been away from here, I have been blogging on general, perhaps esoteric, subjects at theregulatorslot.com. I've hit subjects like risk assessment, logical fallacies and culture. I'll be keeping that up over there as well as posting airport-related stuff here.
Oh, it's good to be back.
As you can no doubt tell, I haven't been blogging much over the last couple of months. The reason behind this is that I went and got myself a new job. Same place but a new role. I'm no longer an aerodrome inspector. Instead, I've moved into a much more strategic role in the Safety Systems Office at the Civil Aviation Safety Authority.
This new job has left few mental cycles left at the end of the day to put fingers to the keyboard. In addition to this, I'm back working with the whole industry and airports have had to take a bit of a backseat while I get my head around the more general issues facing the industry at the moment.
I am ready to get back into blogging but with my change in job comes a change in focus. I'm much more involved in regulation and risk management on an industry-wide basis now and I'd like to blog on these subjects.
Therefore, I've started a new blog over at The Regulator's Lot.
If you are interested in these subjects and aviation safety in general, please come on over and have a look.
Here's a friendly reminder that comments on the recently resealed draft advisory circular regarding hazardous materials handling must be in by 3 October 2011. Submissions to Matt Windebank by then will be duly regarded - after that date, not so much.
Here is another chance to have your say - this time it's a revision of the old CAAP 89I-1(2) to match the more modern CASR Part 139 and associated advisory circular format. Draft AC 139-12(0) - Handling of Hazardous Materials on an Aerodrome "provides guidance to Aerodrome Operators on aerodrome administration andoperating procedures for the handling of hazardous materials on the aerodrome" as required by CASR 139.095.
Send your comments to Matt Windebank by 3 October 2011.
The ATSB has posted, today, a discussion paper and set of draft regulations covering its confidential reporting system. You can have your say on the proposals with submissions accepted until the 16th December 2011. Comments, questions etc. can be sent to firstname.lastname@example.org. The discussion paper covers the 'no-blame' and 'just culture' approaches to reporting systems - no, they are not the same. These are concepts I'm very keen to research more, so stayed tuned - don't hold your breath though, its pretty hectic over here right now but I will try to post a few more things this week.
A couple of weeks ago a question came into the Aerodromes Inspectorate at work regarding the accuracy of airline scales at airports. In Australia, that's not necessarily an airport operator's responsibility and is not covered by our aerodrome regulations. Anyway, that's not the point of this post. This earlier event made me notice this story from the LA Times on the same topic, so I read with interest to see what other countries do. I couldn't exactly work out whether it was the airport or airlines responsibility but in Los Angeles at least, a government department comes in to give the scales the big tick of approval. But the angle of the story was what really stood out.
The journalist writing the story and the policy of the responsible bureau puts the emphasis of the process on money - basically the airline's attempts to charge the passenger for excess baggage. While that is by far the most apparent effect of these scales that is not why they are there.
Switching back to Australia now - an airline is required to have scales at an airport thanks to Civil Aviation Orders 82.3 and 82.5. The need for accurate weight calculations is spread across a range of other regulations. They are a safety device designed to provide the airline/pilot-in-command with an accurate weight of what is being thrown on to the aircraft. Why? Well, in the first instance if the aircraft is too heavy, it doesn't get off the ground and in the second instance, if weight is not distributed around the aircraft appropriately, it may be or become uncontrollable in flight. Accident databases have plenty of records of overloaded and out-of-balance aircraft accidents.
Back to the story - here is what is required when a scale is found to be inaccurate:
"If a scale is off by more than one-tenth of a pound in favor of the airline, bureau inspectors put the scale out of service until it is repaired. If a scale is off in favor of the passenger, it can still be used but must be repaired within 30 days, said Jeff Humphreys, deputy director of the bureau."
So if the scale over-reads by 45 grams its instantly out of service - good, not extra baggage tax! But if it under-reads by any amount (no limit stated) the airline has 30 days to fix it, really? So overloading an aircraft is okay but overcharging passengers is not okay?
I see this type of thing a lot. People doing something which appears to be correct but on closer examination it's for the wrong reason. It is very important to ensure that what you do is for the right reasons because over time, the wrong reasons might mean something is missed or worse, your actions contribute to an accident.
An example from my recent experience goes like this:
An airport operator was not providing an aerodrome works safety officer for minor works (slashing, etc.). They got pulled up by transport security officials because at the same time they weren't providing the appropriate security escort. The airport operator's solution was to provide staff with the appropriate security card to supervise the works and lucky for me, those people were all trained works safety officers.
But what happens when someone working for that operator gets an appropriate security card but not the required works safety officer training?
If the operator is not doing the right things for the right reasons, they could easily end up with an unqualified person supervising aerodrome works with no understanding of the risks they are meant to be controlling. They might not even have the right equipment (e.g. an airband radio) because the procedure has morphed into a security role and safety has been forgotten.
Killing two birds with one stone is fine, but make sure you remember to kill 'em both all the time*
Something to consider when you do your next aerodrome manual review, right?
* I am not condoning violence towards animals - even though I'm under siege from swooping magpies at the moment.
Last week I blogged about the ACRP's new synthesis report on bird control techniques and on that very day, Airport International News reported on deterrent grass developed in New Zealand. This new grass is still being tested in NZ so its no wonder it didn't make it into the ACRP's report. The grass itself is bred with a fungus component designed to make the birds that eat it sick. Over time, the birds will move on and thus reduce the risk of bird strikes on the airport. My initial concerns regarding non-herbivorous birds were somewhat answered on the product's actual website where it stated that the same effect occurred in insects. I'm assuming the same for mammals (both as food-sources and hazards) - anyone know the answer?
It's an awesome idea and I can't wait to see some data from further trials. However, I think the article overstates the impact of a single risk control measure on the wide ranging problem of wildlife strikes. The problem of land side and off-airport attractants or even woodlands, swamps etc. still remains.
I'd love to hear more about how the product works. For me, it seems that the birds (maybe not individually but at least each population) must first consume the grass before it deters them. Therefore, every bird population must first visit the airport before they decide not to come back. I don't know enough about bird behaviour, society, learning etc. to pass judgement on that.
PS - I wonder if it will work out where I was last week?
* should I trademark that?
I know plenty of airport people who really don't care about aircraft. For me, it's the thing that sets our sector of the industry apart from the rest. A large portion of the airport industry, in Australia, are not in the aviation industry by choice. They are a council providing civic services of which one is the airport or they operate a mine or tourist venture which requires the airport in a support role. They come with little or no aviation experience, skills or knowledge and many would sooner gush over CAT's latest front-end loader than the new ATR 72 flying around Queensland. For those engineers, works supervisors and general road-works warriors out there, here is a cool new video of trucks, asphalt, men and some more trucks as they overlay one of Melbourne Airport's runways. Enjoy :).
Aerodrome Technical Inspection (ATI) Inspector Qualification & Experience Validation Form Very few aerodromes I visit take the time to make sure the person or persons who carry out their aerodrome technical inspections meet the qualification and experience requirements laid out in CASR 139.240.
Operations under a safety management system typically demand a higher level of assurance than has existed in the past. You can't rely on tradition or past conduct - you have to examine and re-examine your decisions regularly - its part of the safety assurance, change management and continuous improvement components of a good safety management system.
To assist with making the assessment of a potential ATI Inspector, I've put together this simple form to show how a conscientious aerodrome operator might record such an assessment. The process involves the aerodrome operator seeking evidence (degrees, resumés, references) from the inspector and then either accepting or rejecting this evidence based on the regulatory requirements.
Please feel free to take this form, change it, incorporate it into your manual (or not). Whatever you do, please do something and make sure its recorded. We auditors are a cynical bunch, for us - if it ain't recorded, it didn't happen.
"One of the things we've learned is that one of the few ways to mitigate the bird problem is to not put anything near an airport runway that's likely to attract birds"
Capt. Chesley "Sully" Sullenberger discussing the plan to build a garbage transfer station less than a half-mile from LaGuardia Airport.
For the full story and video go over to the un-embeddable cbsnews.com.
I caught this story on the web last week. According to the
press release (eh, I mean) article, aircraft are falling apart during take-off and landing and the frontline of defence, airport safety officers, are prone to error. Enter the saviour – FOD radar.
Okay, that's a cruel, exaggerated (mis)representation.
I will admit that Foreign Object Debris (FOD) is a very real problem for aviation and airports, in particular. Skybrary puts the yearly cost at $4 billion per year (including wildlife) and the list of FOD-induced crashes is often headlined by the 2000 Concorde disaster.
It's the mis-characterisation of runway inspections that gets to me as it seems that the article is trying to paint the following picture:
The first correction I want to make to the characterisation will actually make runway inspections sound worse. In Australia and under ICAO Annex 14, inspections are not required six-hourly but only once or twice a day. Well, at least once or twice a day. It's that "at least" which makes all the difference because at busy airports the expectation is that inspections are carried out more regularly based on the airport operator's assessment of the risk they are trying to mitigate.
Airport operators, in most jurisdictions now, are required to have a safety management system - a big component of which is risk management. Below is another picture and this time, I've had a go at identifying the causes of FOD. Carrying out this type of exercise gives the airport operator a better understanding of the risk posed by FOD and the numerous options for control available to them.
Now its time to throw in a few more controls and treatments. The light green boxes in the picture below are preventative measures designed to stop FOD from being on the runway during aircraft operations. I've never actually seen all of these in described within the single risk scenario but they all contribute in their own way with varying levels of success. Remember, no single risk treatment is 100% effective (except maybe abstinence!). So multiple, in-line defences or defences-in-depth are essential.
The more interesting risk treatments, since it was the characterisation of runway inspections that got my goat in the beginning, are shown in light blue. These "as required" runway inspections are extremely important, maybe even more important than the standard regular inspections because they are specifically triggered when the risk is greater. Let's start with the bottom one and work our way up:
Rubbish + Wind = Bad - This inspection is actually already mandated in Australia. CASR 139.225 (3) (a) requires an aerodrome serviceability inspection be carried out after a gale. Following such events, it is reasonable to expect that stuff has been moved around and that some of that stuff might be on the runway. To combat this hazard, the scenario includes a rubbish control program (preventative) and an "as required" inspection (mitigative).
Engines that Blow, Suck - On narrow runways where outboard engines overhang the shoulder or even the strip, FOD from these areas may be blown on to the runway for subsequent aircraft to encounter. Again, the above scenario includes a preventative measure, erosion resistant surfaces, and another "as required" inspections as a mitigative measure.
Risk Control Gone Bad - Generally works are designed to make things better but as any good risk manager knows, sometimes controls become hazards themselves. In this case, FOD resulting from runway works is a very real problem. Tools are one of the big offenders, so the scenario includes a tool tracking procedure and the now familiar "as required" inspection to back it up.
Dodgy Bros. Airline - In some parts of the world, aircraft might have a tendency to fall apart or drop things. I'm going to put my hand up here and say that I've contributed to this one. Once upon a time, I left my fuel tank dipstick ( a cut-off broom handle) on my wing following my pre-flight inspection. Luckily it didn't do any harm as it fell off in the aircraft's assigned parking position but it highlights the point that some operations may have a higher likelihood of dropping presents on your movement area (in my case, low hour private pilots!). Other than banning such operations, I'm not sure what preventative measures there are but inspections after operations by known "dodgy" aircraft couldn't hurt.
Susceptible Aircraft - Critical aircraft operating at the edges of safety (maybe something like the Concorde) demand more attention. I don't think it unreasonable for runway inspections to be carried out before these aircraft operate.
I'll admit that inspections aren't perfect. A 2,000 metre long, 30m wide runway is 60,000 square metres - a lot of area to cover and a 3km x 45m is even bigger! Throw into the mix time pressures and poor weather and yes, effectiveness goes down. But using risk management to understand the complete (or at least wider) FOD picture helps to comprehend the risk and the controls already in place to deal or help deal with the problem. It also helps to make a sound purchasing decision when considering new equipment.
Don't get me wrong, FOD radar and detection equipment has a place and overtime, I'm sure its use will filter down to little ol' Australia. I, for one, will welcome its introduction as long as its considered within the total risk picture including an analysis of what new hazards are introduced by the new equipment.
You can use Google Earth to really explore the OLS in all its (fairly accurate) 3D glory. Check out pictures below for established infringements. The gateway bridges also make for a good indication of the location of the OLS around the airport. Brisbane residents could even calculate the maximum height of their renovations.
And a long time before this, I also drew an exaggerated vertical scale version of a code 3 non-instrument OLS over a remote aerodrome in Western Australia.