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bbrownPWM's Blog

VPD Policy/Consequences

  • January 31, 2018
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Good Evening,

I am looking to expand and further develop our policies and procedures anytime there is a VPD occurrence on the airfield. I would like to hear what other airports are doing with regard to this type of incident and if you would be willing to share any of your procedures for response and action. Anything would be helpful. Thanks in advance!

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yanqui69,  The FAA has not issued a civil penalty (fine) for a V/PD in the past thrity years....fines and civil penalties are almost non-existant.  They will write you a very, very serious Letter of Correction and if you do it again, they will issue you another very, very stern Letter of Correction.....Grins,  Be Safe!

 

I'd definitely have the legal counsel be prepared for when one happens, because the airport might be able to challenge or mitigate fines levied by the FAA after a V/PD. Additionally, the legal counsel would be able to assist the airport recoup any fines levied by the FAA that may have been caused by a tenant.

The FAA will also want to know what actions the airport is going to take to prevent another similar situation V/PD from happening again and what actions the airport took against the violator. Training, record keeping, and progressive discipline are usually addressed. Good luck

Have an LOA with stakeholders addressing the requirement to report V/PDs immediately. Procedures should have a checklist to gather evidence such as driver and witness statements, transcripts of radio communications, recordings of the ATCT ASD-X or related software tools, immediate inspection of the affected area and vehicles, records of driver's training/certification, etc.. 

Familiarize yourself with JOs 8020.16A and 8020.11C Air Traffic Organization Aircraft Accident and Incident Notification, Investigation, and Reporting and to get an understand of what goes into the Report of Investigation (ROI). The FAA normally  has around 13 questions to ask about an RI/VP, but doesn't always request them, but it helps to be prepared.  

John,

 

That is very helpful! Thank you for taking the time to write! I am really trying to find a middle ground somewhere that supports our efforts to eliminate occurrences while also investing in our employees. It sounds like you have a very robust program. 

At MSP, we have an Ordinance which defines operating rules on the AOA, as well as penalties for violating those rules.  A runway incursion is normally a 30-day suspension of AOA driving priveliges.  We also have a non-punitive root cause analysis/process improvement program that we've developed called the MSP Runway Incursion Review Board.  We use the findings from this board, which was patterened after the NTSB's party process, to respond to the FAA's Letter of Investigation, which normally follows a V/PD.

   John Ostrom

You are absolutely right, sir. At present, this policy will be geared toward city employees and persons under contract for the city. I much prefer for tenants to sort out their own issues while the airport addresses safety concerns broadly through the ACM and Ramp Drivers Handbook. Thanks again for your input!

bbrownPMW, Yep, if it is through the ACM, you have some extra horsepower for airport employess, but need to be careful how the airport addresses the other tenants, FOB, etc.  It is much easier to implement a program utilizing the SIDA badge and driving authorization, for consequences of noncompliance than for the other tenants at the the airport  Be Safe!!

 

I like the NOV approach and have used it in the past at other airports along with fines. We have the ability to suspend and terminate through our ACM, but I believe the process could use some development. I appreciate your input!

We have a notice of violation system that includes issuance of fines for V/PDs, along with the ability to remove driving privileges and/or badge suspension/termination. 

Thank you, sir. I have already met with both legal and labor relations in an effort to facilitate this change. I believe we would benefit from an enhanced step-style disciplinary action procedure in addition to that which is in our ACM. Thank you for the insight! 

 

Just an FYI, please make certrain you coordinate any consequnces of non-compliance with your adminisitrative/airport operator management (legal).  Make sure the consequences are progressive and reasonable.  Re-training is not, I repeat, not a consequences of non-compliance.  Re-training should be in addition to the consequences....i.e.  suspend SIDA badge for a designated period of time and re-training. There are a number of ACs on the V/PDs you might want to review.  Be Safe!!! 

 

 

 

 

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