The complexity of non-compliant assets places a challenge on airport owners as they manage maintenance costs while providing a safe and attractive environment for passengers.
A non-compliance is an action or omission that does not comply with the requirements of the Civil Aviation Safety Authority (CASA) Manual of Standards (MOS) Part 139.
Opportunities for innovation may be identified through the review, monitoring or auditing processes, followed by the design and management of corrective actions. An airport owner’s ability to rapidly correct relevant non-compliance is essential to ensure passenger satisfaction and continued operational success.
This thinking paper outlines the common types of civilian airport non-compliances along with the practical processes for designing corrective actions and prioritising works.
The arrival of the COVID-19 pandemic confronted airports with two key questions; how to transition through the unprecedented situation, and how to plan for the future. Airports have a unique chance at the moment to consider their asset upgrade and maintenance programmes with reduced aircraft movements. But, as everyone knows, funding is tight, yet maintenance is essential.
An important factor moving forward is planning which critical projects to proceed with immediately, and which less critical projects to defer for future capital works.
To attempt to rectify all non-compliances has the potential to exceed reasonable budget estimates and make maintenance projects cost prohibitive. A long-term strategic plan for dealing with non-compliances can pragmatically prioritise works according to immediacy, risk impact and tolerance of a non-compliance.
As well as upgrade or maintenance works during this time, reduced passenger and aircraft movements also provide the opportunity to more easily undertake surveys, inspections or audits on airside assets.
Noting financial constraints during this period of limited international and domestic travel, regional airports, in particular, could apply for state or federal government funding to maintain assets.
Non-compliance management is managing non-compliances such that they are promptly identified, documented, evaluated/investigated, segregated and dispositioned as per the MOS 139.
Common civilian airport non-compliances are found along vertical geometry, longitudinal slopes, interconnecting taxiways, runway strip surfaces, and line marking. These generally come about from poor original design and/or construction, change in airfield operations or regulations, and wear-and-tear over time.
A closed-loop process ensures that best practices are consistently applied to support non-compliance corrective actions (Figure 1). Properly documented actions provide managers with important historical data, which may then be used to implement continual improvement plans and proactive actions and help in the capture and dissemination of operational intelligence related to these actions.
Non-compliances can be reactively identified by digital inspections or internal/external audits – or they can be proactively identified and rectified through innovative testing procedures and good internal processes, including newly developed digital means. Ensuring quality and safety is paramount in non-compliance corrective action planning and implementation.
When evaluating non-compliances, consideration of the potential impact of the problem in terms of its risk to airport operations and passengers must be determined, as well as any immediate actions required.
A pragmatic approach to prioritising upgrades and maintenance works will address non-compliances and the corrective actions required for individual assets.
A key part of the closed-loop process is determining and documenting the reasons why the non-compliance is a concern, and what impact it may have on airport operations and passengers. Typical concerns can include costs, functions, product quality, safety, reliability, and customer satisfaction.
Corrective actions promote:
An important part of the closed-loop process is documenting the rationale for the decisions around the non-compliance, and appropriate follow-up to validate the effectiveness of the actions (Figure 2).
This is not a ‘one-size-fits-all’ process, as assets react differently to non-stop usage and the condition of each asset can vary markedly between airports. Neither capital city nor regional airports are immune from non-compliance concerns, because of the similar nature of operations. The criticality levels rise at capital city airports due to the size of aircraft landing and taking-off, and the frequency of operations.
When designing and constructing a new facility, the requirement is to design assets that fully comply with MOS 139. However, for existing facilities with specific situations such as designing a maintenance asphalt overlay and, for example, a transverse grade, there can be circumstances where this cannot be reasonably rectified with a nominal thickness maintenance asphalt overlay.
There are situations where pre-existing grade non-compliances cannot be rectified with a 50-millimetre thick maintenance asphalt overlay on a taxiway or a 60-millimetre thick maintenance asphalt overlay on a runway.
Therefore, the approach would be to document the grade non-compliances that are pre-existing, and the resultant grades post the maintenance asphalt overlay, with the intention to demonstrate that the resultant finished surface levels are no worse than the existing situation, and in most cases are better than the existing situation. Coupled with the documentation of the non-compliances is the provision of advice on options and strategies to rectify the non-compliances.
With a pragmatic strategy to prioritise upgrades and maintenance, asset health is optimised and airside downtime is minimised.
For asset-intensive airports, identifying non-compliances and determining corrective actions can be aided by having asset history and condition data to help decision-making.
By implementing practices to capture and record asset data, owners can go beyond time-scheduled maintenance to condition-based actions. This enables the application of machine learning and data analytics to record non-compliances, corrective actions, and the tolerances of the asset over time in alignment with the MOS 139. Putting asset data to work provides a platform for identifying (and monitoring) the efficiency of non-compliant assets, full control over documentation of issues, together with real-time visibility and communication with CASA, and a solid plan for rectification.
Corrective actions can provide airport managers with not only the data they need to construct an effective long-term asset management plan, but also input for preventive actions from lessons learned reports and historical data.
Continuous improvement of the non-compliance identification, documentation, communication and rectification process will result in a more efficient system and enhanced benefits of a functioning non-compliance management system.
Effectively managing non-compliances and taking strategically-planned corrective actions is an integral part of airport operations and could result in fewer future omissions or reactive efforts.
By leveraging intelligence to maintain operations, the closed-loop approach to implementing systematic and consistent non-compliance identification, documentation and correction, can increase transparency, effectiveness and efficiency of assets for diverse, lively, and unimpeded airport business operations.
Matt Glenn has more than 20 years of comprehensive airport experience in the design, construction and maintenance of airport infrastructure in Australia and South East Asia. Matt’s approach is not to simply apply what has been done before, but rather to use his experience and apply his smarts and lessons learned to achieve the optimal outcome for a client's needs and the project.
Matt brings particular experience gained on Perth Airport, where he is providing ongoing specialist technical advice as a part of the team designing a new runway, and Defence market experience where he has designed multiple airfield upgrades for many of the airbases across Australia, as well as providing critical maintenance advice under a national airfield pavement maintenance programme. He has also been the Project Director and Technical Director for many runway and taxiway asphalt overlays at a range of capital city airports and airfields around Australia and Asia.
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