Ground Support Equipment Safety Inspection Program 2

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2 Safety Inspection Program 2 Figure 1 SFO Core Values

3 Safety Inspection Program 3 TABLE OF CONTENTS Executive Summary 5 Policy 5 Purpose 6 Program Description 8 GSE Safety Inspection Process 11 Vehicle Permit and QSP Equipment Maintenance Requirements 11 Audits and Inspections 12 Scheduled Periodic GSE Safety Audits 12 Random GSE Safety Inspections 12 Targeted Safety Inspections 12 Field Stops 13 Non-Compliant GSE Resolution Process 13 Scorecard 15 Violations 16 Fees and Fines 16 Individual Infractions 17 Citation Enforcement Process 18 Attachments 19

4 Safety Inspection Program 4 Table of Attachments: Attachment 1 SAO Registered Vehicle Permit Request Form Attachment 2 SAO-issued Registered Vehicle Ramp Access Permit Attachment 3 SAO Non-Registered Vehicle Request Form...21 Attachment 4 SAO-issued Non-Registered Vehicle Permit Attachment 5 SAO-issued Construction Access Permit Attachment 6 Auto Shop Vehicle/Equipment Inspection Checklist...23 Attachment 7 GSESIP Scorecard Attachment 8 Airport Citation Tracking System Form Table of Figures: Figure 1 SFO Core Values... 2 Figure 2 Scheduled GSE Audits Report as of September 11, Figure 3 Random GSE Inspections Report for CY 2012, 2013, 2014 as of September 11, Figure 4 GSESIP Stakeholders... 9 Figure 5 SFO Work Units GSESIP Responsibilities... 9 Figure 6 GSESIP Flowchart...14 Figure 7 Citation Enforcement Procedure...18

5 Safety Inspection Program 5 Executive Summary ALL WAYS SAFE The San Francisco International Airport (SFO) is pleased to introduce its Ground Support Equipment Safety Inspection Program (GSESIP), which enhances the former Vehicle Inspection Program as one of the key elements to demonstrate the commitment to its core value of Safety and Security is our First Priority. This program is governed by the Airport Rules and Regulations and exists to ensure the maintenance and safe operation of all Ground Support Equipment (GSE) operating on the Air Operations Area (AOA). The GSESIP embraces industry leading best practices and is applicable to employees of all airlines, domestic and international, and their contracted service providers, as authorized by their Aviation Support Services Permit. It includes compliance expectations, random and periodic auditing and procedure enforcement. The goal of the program is to increase overall safety awareness by eliminating preventable accidents and/or injuries related to driving and equipment maintenance. Each component of this program supports the framework necessary to ensure full compliance and build upon SFO s culture of safety. Policy Ground Support Equipment (GSE) on the Air Operations Area (AOA), whether such GSE is motorized or non-motorized, may be operated only with the permission of the Airport Director. Safe operation of GSE on the AOA is critical; drivers and vehicles shall comply with the Airport Rules & Regulations requirements. The GSESIP is annexed to the Airport Rules and Regulations as Appendix B. Any lease or permit authorizing the use of GSE on the AOA shall incorporate the GSESIP. Any GSE that fails an inspection is prohibited on the AOA, i.e. immediately suspended from service until the deficiency is corrected. Additionally, in general, the appearance of GSE must always be clean with the current permit and company markings clearly visible.

6 Safety Inspection Program 6 Purpose For the purpose of the Ground Support Equipment Safety Inspection Program (GSESIP), GSE shall mean ground support equipment - motorized and non-motorized that operate on the Air Operations Area (AOA), essentially all permitted vehicles. Many accidents and injuries that occur on the AOA are the direct result of unsafe driving practices and/or inadequate equipment maintenance. The purpose of this GSESIP is to reduce these hazards and ensure that all ground support equipment operating on the airfield at all times is maintained in a safe and operational condition. The GSESIP formalizes and enhances the former Vehicle Inspection Program to focus on equipment safety and ensuring the safest possible work environment. The Airport conducts scheduled vehicle audits and random vehicle inspections that identify hazardous equipment that may be unserviceable and should not be operating on the AOA. Results of recent scheduled vehicle audits and random vehicle inspections show an alarming trend of increasingly unsafe GSE operating on the AOA. Scheduled vehicle audits include documentation review and mechanical inspection while random inspections include only a mechanical inspection. 160 Scheduled GSE Audits Report # Inspected # Passed # Failed Period: December 2013 to September 2014 Figure 2 Scheduled GSE Audits Report as of September 11, 2014

7 Safety Inspection Program Random GSE Inspections Report # Inspected # Passed # Failed Figure 3 Random GSE Inspections Report for CY 2012, 2013, 2014 as of September 11, 2014

8 Safety Inspection Program 8 Program Description The SFO Ground Support Equipment Safety Inspection Program (GSESIP) requires strict adherence to clearly defined safety standards for tenants and their service providers with ground service equipment. Any GSE deemed unsafe and/or non-compliant with established safety standards will be restricted from operating on the airfield. Existing fines and penalties for non-compliance will be strictly applied, and new fines and penalties will be implemented to ensure full compliance with the GSESIP. Governance for the GSESIP is found in the Airport Rules & Regulations, Airport Operating Permits, and Tenant Lease and Use Agreements. The Airport Quality Standards Program is a part of the Airport Rules & Regulations which was adopted by the Airport Commission to enhance safety and security at SFO and applies to any firm, which employs personnel involved in performing services that directly impact safety and/or security. The Program is necessary to ensure that all vehicles/equipment operating and around the AOA are mechanically sound and safe to promote the overall safety of the Airport Community. All tenants or permittees whose employees use or operate vehicles or equipment on the AOA must comply with the GSESIP. The GSESIP includes scheduled periodic physical inspections of ground support equipment and random inspections. The GSESIP is annexed to the Airport Rules and Regulations as Appendix B. Any lease, permit, or contract authorizing use of ground support equipment on the AOA shall incorporate the GSESIP. Failure to pass a safety inspection, as provided in the GSESIP, shall result in an assessment of a fine under Rule 14 of the Airport Rules and Regulations. The GSE owner shall comply with any Airport order to remove any GSE from service and shall not re-enter into service any such GSE until such time as the GSE is repaired and passes re-inspection. Any tenant, permittee, or contractor that tampers with a red tag on a GSE or interferes in any way with the impoundment of a GSE shall be subject to an additional fine under Rule 14. The GSESIP is a comprehensive ground equipment inspection program that includes several different components: documentation, mechanical inspections, compliance audits, and fees and fines for non-compliance. Six SFO work units play key roles collaborating and administering the program. These work units include: Airfield Operations, the Auto Shop, Employment Quality Standards, Aviation Management, Risk Management and the Security Access Office.

9 Safety Inspection Program 9 Risk Management Companies with GSE Security Access Office Figure 4 GSESIP Stakeholders Employment Quality Standards GSESIP Auto Shop Aviation Management Airfield Operations SFO Work Unit GSESIP Responsibilities Airfield Operations Supports scheduled audit inspections, random monthly and targeted GSE mechanical inspections. Conducts field stops. Issues admonishments and citations for violations of the Airport Rules & Regulations pertaining to the GSESIP. Auto Shop Performs all GSE mechanical inspections. Aviation Management Enforces GSE compliance within Lease and Use Agreements and Operating Permits. Employment Quality Standards (EQS) Coordinates scheduled periodic GSE audits per the Airport Quality Standards Program (QSP). Risk Management Conducts audits for equipment standards. Security Access Office (SAO) Issues vehicle permits Administers the Airport Infraction Management System which issues citation invoices and process citation payments. Figure 5 SFO Work Units GSESIP Responsibilities

10 Safety Inspection Program 10 The GSESIP takes a four-prong approach to ensure GSE operating on the AOA are mechanically safe with scheduled periodic audits, random safety inspections, targeted safety inspections, and field stops. 1. Scheduled periodic safety audits are conducted annually by the Employment Quality Standards (EQS) work section with Risk Management, the Auto Shop, and Airfield Operations. 2. Random (unannounced) safety inspections are conducted every other week by Airfield Operations and the Auto Shop at select AOA locations. 3. Targeted safety inspections are conducted by EQS, Airfield Operations and the Auto Shop. 4. Field stops are conducted by Airfield Operations. The GSESIP seeks to enhance safety by increasing the frequency of mechanical inspections and getting a statistically significant sample size by equipment type that represents the fleet size thus the bi-weekly events for scheduled periodic safety audits and random safety inspections, e.g. one week scheduled audits will be performed followed by random inspections the next then back to scheduled audits, etc. EQS analyzes and reports on audit and inspection findings and is the record-keeper for the audit and inspection documents. EQS provides a monthly report to the Deputy Airport Director of Operations & Security to report out at the monthly ITOC and A4A meetings.

11 Safety Inspection Program 11 GSE Safety Inspection Process Vehicle Permit and QSP Equipment Maintenance Requirements Companies with GSE must obtain a vehicle permit for each piece of GSE before operating equipment on the AOA from the Airport Security Access Office (SAO) as well as comply with the Equipment Standards section of the QSP. All (existing and new) GSE must be permitted by the SAO prior to operating on the AOA. All GSE on the AOA require either a ramp or vehicle permit. Ramp Access permits are issued for vehicles licensed by the California Department of Motor Vehicles and drive on and off the AOA. Vehicle Permits are issued to GSE that do not leave the AOA and are permitted as non-registered. Vehicle Permits do not have an expiration date. The permit decal is applied for permanent identification on the GSE. Samples of the vehicle permit forms and permits are in the Attachments section of this program. The Equipment Standards section of the QSP requires GSE companies to: Have a preventative maintenance program that includes: o Periodic safety inspection schedules for each type of GSE; o Procedures for taking mechanically unsound GSE out of service ; o Daily User Check Program for each type of GSE that includes provisions for inspection of: tires, head, tail and brake lights, horn, parking brake, handrails and guards, walk-around fluid leak check. Maintain all GSE maintenance records for a minimum of 24 months. Provide annually to the Airport Security Access Office a total GSE inventory listing. Be subject to audit. Be subject to the Vehicle Impound Program as defined in the Airport Rules & Regulations.

12 Safety Inspection Program 12 Audits and Inspections Scheduled Periodic GSE Safety Audits Scheduled periodic audits are coordinated by the Employment Quality Standards (EQS) work section that monitors the Airport Quality Standards Program (QSP). EQS coordinates the work with Risk Management, the Auto Shop and Airfield Operations. Scheduled periodic audits are conducted for all GSE companies each year where a statistically significant sample by equipment type representing the fleet size is randomly selected for inspection. The audit starts when EQS requests GSE companies submit a list of their GSE inventory (motorized and non-motorized) to EQS. EQS forwards the inventory list to Risk Management to select a statistically significant sample by equipment type to represent the fleet size for mechanical inspections by the Auto Shop. Auto Shop performs the mechanical inspections and submits the results to EQS. Airfield Operations issues admonishments as required. EQS produces the scorecard for the GSE company within two business days of the inspection date. EQS notifies GSE companies if re-inspection is required, which does not require a re-inspection fee payment if completed within 30 calendar days of the original inspection date, sends with request to pay re-inspection fee if not completed within 30 days of the original inspection date at the SAO before re-inspection by the Auto Shop, and sends non-compliance letters with the recommended fine after 60 days, see figure for GSESIP Process. Random GSE Safety Inspections Random GSE safety inspections are conducted by Airfield Operations and the Auto Shop biweekly at various AOA locations. Reports are submitted to the EQS for analysis, reporting and recordkeeping. EQS notifies companies with GSE if re-inspection is required, sends with request to pay re-inspection fee at the SAO before re-inspection by the Auto Shop, and sends non-compliance letters with the recommended fine after 60 days. Targeted Safety Inspections Targeted safety inspections will be performed as-needed based on industry trends, issues with companies or specific discrepancies.

13 Safety Inspection Program 13 Field Stops Once GSE is permitted to operate on the AOA, Airfield Operations may make field stops on GSE for a safety check that are general visual inspections. These inspections focus on items from the Vehicle Equipment Inspection Checklist. If an Airport Safety Officer (ASO) finds a GSE safety deficiency, the ASO will issue an admonishment requiring the GSE owner correct the deficiency. Non-Compliant GSE Resolution Process If GSE fails the safety inspection, it will be Red-tagged. The Auto Shop will apply an Out of Service tag that is easily visible to the GSE. The tag will remain on the GSE until it passes reinspection and is removed by the Auto Shop. Should the vehicle be stopped on the Airfield before this re-inspection is completed, the vehicle will be impounded and the Airport may impose the impound fees plus fines and/or the termination of any and all agreements with the Airport. If the Auto Shop finds a GSE safety deficiency, then EQS sends a courtesy notice and the company has 30 days to correct the deficiency. If the GSE safety deficiency has not been corrected within 30 days, then EQS sends a notice to the company notifying them that they must pay a $25 re-inspection fee at the SAO and present the receipt and the GSE to the Auto Shop for re-inspection. If the GSE safety deficiency has not be corrected within 60 days, then EQS sends a letter of non-compliance to the company notifying it that it will be assessed $200 per GSE per day until the deficiency is corrected.

14 Safety Inspection Program 14 Figure 6 GSESIP Flowchart

15 Safety Inspection Program 15 Scorecard GSE companies safety performance is graded according to the percentage of equipment passing inspection. A sample Scorecard is in the Attachments section of this program document.

16 Safety Inspection Program 16 Violations Permitees, leasees and contractors shall be responsible for the safe operation of GSE by their employees and/or agents. Any citation issued to an individual GSE driver or operator for violation of the Airport Rules and Regulations shall also be issued to the employer. The employer shall be responsible for its operator s compliance with any citation listed below. The administrative penalties below shall be in addition to any fine assessed under Rule 14 of the Airport Rules and Regulations; the permittee, tenant or contractor shall be solely responsible for any cost associated with a citation under Section 4.8. Fees and Fines RULE/ SECTION DESCRIPTION OF VIOLATION FINE CATEGORY AIRFIELD SAFETY AND SECURITY 4.8(A) GSE AOA vehicle driver operations A 4.8(B) GSE AOA vehicle requirements E 4.8(E) Failed GSESIP Inspection C 4.8(E) Tampering/Interfering with a GSESIP Red Tag or Impoundment E FINE CATEGORY FIRST OFFENSE SECOND OFFENSE THIRD OFFENSE A $50 $75 $100 B $100 $150 $250 C $250 $500 $750 D $750 $1,000 $1,250 E $1,000 $2,000 $3,000

17 Safety Inspection Program 17 Individual Infractions Individuals granted access to the AOA or other secure areas of Airport property may be subject to an Admonishment or Citation for driver/operator or security violation. The charging officer may issue a verbal or written Admonishment which shall be considered a warning and shall not include any fine or training requirement. A written Admonishment shall be recorded as a First Offense as described in the table below. If the charging officer issues a written Admonishment or a Citation for an individual infraction, the Airport will notify the employer/tenant, permittee or contractor and may assess against the employer the appropriate fine and any other charge under the lease, permit or contract in addition to any individual fine and/or fee assessed against the individual. Any training required shall be designated by the Airport. The individual employee shall remain responsible for any training or training fee or fine assessed, as follows: RULE/ SECTION DESCRIPTION OFFENSE RESULT First Offense/ Written Admonishment Warning to driver/operator 4.8(A) GSE driver/operator violations First Offense/Citation Second Offense (within 12 months of First Offense) Two-hour training class Driver/operator s AOA security access badge and driving privileges suspended for the day the employee attends the training Driver/operator pays the training class fee Driver/operator pays the Category A (First Offense) fine Two-hour training class Driver s AOA security access badge and driving privileges immediately suspended for three consecutive days (a 72-hour period) following Citation Driver/operator pays the training class fee Driver/operator pays the Category A (Second Offense) fine Permittee pays permit charge for a violation of the Rules and Regulations Third Offense (within 12 months of First Offense) Driver/operator permanently loses driving privileges

18 Safety Inspection Program 18 Citation Enforcement Process Airport Safety Officers (ASO) and Airport Duty Management (ADM) may issue citations for unsafe GSE and unsafe GSE operations pursuant to the Airport Rules & Regulations. The ASO or ADM produces a copy for the violator and submits a copy to the SAO. The SAO s a notification to the Authorized Signatory for the GSE company. If the citation is paid within 30 days then the citation is closed out. If the citation is not paid, then the SAO contacts Aviation Management. Aviation Management then issues a letter to the GSE company invoking Paragraph 9.6 of the GSE company s Operating Permit, allowing for a draw down on their deposit. Airport Safety Officer issues Citation Security Access Office - s Notification and Invoice - Payment Net 30 Permit Holder Pays Yes, paid within 30 days Closes Citation No After 30 days Aviation Management Issues Letter to the Permit Holder invoking Permit Paragraph 9.6 Figure 7 Citation Enforcement Procedure

19 Safety Inspection Program 19 Attachments Attachment 1 SAO Registered Vehicle Permit Request Form

20 Safety Inspection Program 20 Attachment 2 SAO-issued Registered Vehicle Ramp Access Permit

21 Safety Inspection Program 21 Attachment 3 SAO Non-Registered Vehicle Request Form

22 Safety Inspection Program 22 Attachment 4 SAO-issued Non-Registered Vehicle Permit Attachment 5 SAO-issued Construction Access Permit

23 Safety Inspection Program 23 Company Name Driver Name AOA Badge Vehicle/Equipment Inspection Checklist Pass Fail Citation Vehicle/Equipment Type Company Vehicle/Equipment Number Date Time Mileage or Hour Meter Location SFO Permit SFIA Rules/Reg 4.8(B)(6) PASS FAIL N/A PASS FAIL N/A LIGHTS BODY A Headlights A Doors B Tail Lights B Hood C Brake Lights C Seats Secured D Reverse Lights D Bumper E Signal Lights E Hitch F Hazard Lights notes: G Lens notes: FLUIDS LEAKS A Engine Oil TIRES B Transmission Oil A Uneven Wear C Coolant Front Left D Fuel Front Right E Hydraulic Oil Rear Left F Lavatory Fluid Rear Right notes: B Nail/Damage C Pressure notes: LIFTING PLATFORM A Hydraulic Cylinder B Rollers STEERING/SUSPENSION C Locking Mechanism A Noise notes: notes: EXHAUST SYSTEM A Smoking/Fumes B Rattling/Loose notes: SAFETY DEVICES A Interlocks notes: COMMENTS BRAKES A Operational B Park Brake notes: Inspecting Mechanic: White Employer Pink Operations Yellow Suspense File Blue Recipient Airfield Safety Officer: Attachment 6 Auto Shop Vehicle/Equipment Inspection Checklist

24 Safety Inspection Program 24 Attachment 7 GSESIP Scorecard

25 Safety Inspection Program 25 Attachment 8 Airport Citation Tracking System Form