Making sound standards for ground operations

Aviation safety starts on the ground, yet the domain of airport ground operations remains a ‘self-regulated’ field in aviation. The ground services staff, who control key safety parameters of the aircraft turnaround, often experience inconsistent and sometimes poor training standards while functioning within a web of disharmonised and often vague or contradicting operating procedures and rules. It is unsurprising therefore that aircraft ground damages remain a problematic area of concern. Although the reliability of ground handling accident statistics is questionable due to under-reporting, the Flight Safety Foundation has estimated that one ramp accident/incident occurs in every 1,000 departures worldwide with an injury rate of nine per 1,000 departures each year. We can perhaps acquire a more comprehensive picture by delving into the reports of aviation insurance companies, where all ground accident claims end up. In the 2014 Allianz report, ground handling accidents ranked third in terms of both the number of claims received and their total value, and accounted for 18% of all its aviation insurance claims. 

Systemic perils

The systemic pathogenies frequently encountered in the ground handling business around the world comprise the following:

• Subpar selection criteria and inadequate or improper training of ground services staff
• Inconsistent implementation or non-compliance with standard operating procedures
• Lack of on-site supervision
• Shortage of manpower
• Ineffective internal quality control and safety oversight from ground service providers
• Unsatisfactory maintenance and serviceability of ground support equipment
• Deficient apron supervision and control from aerodrome operators
• An unjust corporate culture, where employees may even be negatively incentivised
• Limited managerial commitment and accountability
• Incoherent communication and collaboration among key stakeholders.

Although some of these issues have the potential to raise the probability of human error by up to eleven-fold on their own, when combined this likelihood increases exponentially.

Formulating a GSP Regulatory Framework

The industry has put a significant amount of effort toward harmonising ground servicing around the world, yet airlines are still reluctant to give up their own procedures and protocols. The implementation of the ISAGO programme may still fall short of attaining the required confidence level in the industry, compared to that of the IOSA programme. Moreover, many decision-makers may regrettably seek operational ’compromises’ if something that isn’t prescribed by a regulation translates to additional costs or capital investments. Hence, the need to ensure high and consistent standards in ground operations and further safeguard the systematic oversight of the national aviation authorities, implies the forging of a formal regulatory framework. Such a system can be founded on five normative pillars:

1. Establishing the regulatory requirements and process for the certification of ground service providers
2. Defining the governing framework for awarding a license to ground services staff relevant to its job function(s)
3. Delineating the practical and theoretical training specifications for all ground service functions, including training material, classroom or OJT hours and assessment criteria
4. Outlining the requirements for the approval of training organisations that deliver courses on ground services
5. Developing and implementing a compliance oversight system encompassing tactical audits and inspections.

Implementing GSP Certification

In 2016 the General Authority of Civil Aviation (GACA) of Saudi Arabia was the first to introduce a formal certification framework for ground service providers and the licensing of their personnel. It comprises a set of documents of more than 200 pages including the core regulations, advisory circulars, internal manuals, checklists and related forms. The benefits of the new regulatory framework are seen as three-fold:

• Enhancing ground operations safety at all aerodromes by establishing systematic compliance oversight against the new regulatory requirements
• Setting a level playing field for new entrants to compete with incumbent service providers in view of the opening of the ground handling market and the undergoing airport expansion projects and privatisation
• Elevating the quality and level of service provided to passengers and airlines.

A year and a half after the introduction of the new regulations, the close collaboration and commitment of all associated stakeholders resulted in the reduction of aircraft ground damages by more than 65%. Swissport was the first ground service provider certified to operate at three international airports, followed by the national Saudi Ground Services (SGS) at Jeddah airport in 2017. Another 20 ground service providers from different disciplines are in the process of certification including cargo, fuel and catering companies.

GACAR Part 151 – Ground Service Providers

The new regulatory framework for the certification of ground service providers defines 11 ground service categories and 30 subcategories, while additional activities may be authorised if it is deemed in the interests of safety, or enhances the quality and comprehensiveness of the services offered at an airport. The technical and operational standards use as baseline the ground work carried out by the industry – and, more specifically, the IATA’s AHM, IGOM, CHM, ISAGO and DGR, the JIG (Joint Inspection Group) standards for into-plane fuelling services, airport depots and hydrants, as well as the IFSA (International Flight Services Association) specifications and World Health Organization’s guidelines for hygiene, sanitation and food safety for inflight catering services. Some of the important regulatory insights include the following:

• Certified organisations nominate key ‘postholders’ responsible for the three critical domains of ground operations, training and quality assurance. The post-holders have to be accepted by the aviation authority, enhancing the degree of accountability and allowing the regulator to directly assess the qualifications, knowledge and competence of such key personnel. The responsibilities of managerial, supervisory, safety, internal audit, and training personnel are also framed.
• Duty period limitations for operational staff are addressed for the first time. It is stipulated that no person may be scheduled to perform duties for more than 10 hours within 24 consecutive hours, while a minimum rest period of eight hours is observed. This can alleviate the excessive work hours of ground staff that has a direct impact on aviation safety, due to the induced fatigue on employees and the training hours frequently lost under such circumstances.
• The service life of ground support equipment is limited to 15 years, which is on average double the depreciation period used for heavy equipment. As the condition of equipment is always a function of its utilisation, granting extension of the service life is on the provision that the party concerned conducts a risk assessment for the ground support equipment in question. Furthermore, maintenance organisations need to obtain the acceptance of the aviation authority prior to engaging in contracts with ground service providers.
• A dependable quality assurance system is considered the core of a safe and wellfunctioning organisation. The content of the corresponding quality assurance manual, the set-up of the quality organisation, and the responsibilities of the associated personnel are outlined. Non-certified organisations may serve as subcontractors only under stringent conditions, operating under the quality system of the certified ground service provider. Submission of safety reports and statistics is also introduced to address the under-reporting of occurrences.
• The application for certification involves the submission of six prerequisites, including the five principal manuals of: ground operations, training, quality assurance, safety management and emergency planning, which have to be reviewed and accepted by the authority. The ground service provider certificate includes the operational specifications for the organisation, i.e. the privileges awarded, and is initially valid for one year.

GACAR Part 68 – Ground Services Personnel

The regulatory framework regarding ground personnel requires all staff working for service providers to obtain a ‘work permit’. With a total of 13 specific job functions defined, some of the significant elements encompass the following:

• Training records are submitted for acceptance to the aviation authority to ensure that the applicant has undergone the training modules foreseen. The relevant certificates must be issued by a training organisation that is acceptable to the regulator.
• The organisation has to assume accountability for assessing the competence of its employees and explicitly attest to their eligibility to perform their functions before releasing them to duty.
• The ICAO Level 3 English proficiency requirement is introduced for all staff that have direct contact with cockpit crew.

GACA is also working with key stakeholders on the standardisation of ground services training requirements and assessment criteria. This comprises the course topics and content, the minimum duration for both the theoretical and practical elements, and the length of practice under supervision.

The dynamic nature of aviation suggests that any framework established is continually reviewed and expanded. There is still much to be done to ensure the successful integration and implementation of the new regulations, which are currently undergoing their third revision. Greater attention to ground operations standards and their implementation translates into enhanced aviation safety across the board.