J.4_-_Safety_Directives.pdf
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SAFETY DIRECTIVES
APPROVED BY:
Don W. Campbell Director of Safety INL/A, Office of Aviation Patrick AFB, FL 32925
Effective: 1 May 2009 Proponent: DoS, INL/A Safety fernandezjm Typewritten Text fernandezjm Typewritten Text fernandezjm Typewritten Text fernandezjm Typewritten Text fernandezjm Typewritten Text fernandezjm Typewritten Text
ATTACHMENT J.4
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U.S. DEPARTMENT OF STATE
Bureau For International Narcotics and Law Enforcement, Office Of Aviation
SAFETY DIRECTIVES (1 May 2009)
TABLE OF CONTENTS
CHAPTER 1 – GENERAL INFORMATION
1-1 INTRODUCTION
1-2 RESPONSIBILITIES
1-3 DEVIATIONS AND VIOLATIONS
1-4 WAIVERS
1-5 SUGGESTED IMPROVEMENTS
1-6 REFERENCES
1-7 ABBREVIATIONS AND TERMS
1-8 RULES OF CONSTRUCTION AND DEFINITIONS
1-9 REGULATORY COMPLIANCE
CHAPTER 2 – SAFETY MANAGEMENT
2-1 SAFETY PLANS AND SAFETY SOPS
2.2 EMERGENCY ACTION PLANS
2.3 SAFETY AWARDS PROGRAM
2.4 RECORD KEEPING AND FILE SYSTEM
2.5 DOCUMENTING IDENTIFIED HAZARDS
2.6 REPORTING OF HAZARDS BY AN EMPLOYEE
2.7 TOXICOLOGY PROGRAM AND POST MISHAP TOXICOLOGY TESTING
CHAPTER 3 – SAFETY TRAINING
3-1 TRAINING
3-2 SAFETY MEETINGS
3-3 SAFETY STAND DOWN PROGRAM
3-4 DOCUMENTATION OF TRAINING
CHAPTER 4 – PROGRAM SAFETY COUNCIL
4-1 PURPOSE AND SCOPE OF THE COUNCIL
4-2 COUNCIL RESPONSIBILITIES
4-3 SAFETY COUNCIL MEMBERS
CHAPTER 5 – SAFETY INSPECTIONS AND SURVEYS
5-1 SAFETY INSPECTIONS
5-2 FACILITY SUPPORT EQUIPMENT
5-3 AVIATION RESOURCE MANAGEMENT SURVEY (ARMS)
CHAPTER 6 – ENVIRONMENTAL
6-1 HAZARDOUS MATERIALS
6-2 HAZARDOUS WASTE MANAGEMENT
6-3 SPILLS AND ENVIRONMENTAL MISHAPS
6-4 TRANSPORTING HAZARDOUS MATERIALS
CHAPTER 7 – REPORTING MISHAPS
7-1 PURPOSE
7-2 POLICY
7-3 WHAT TO REPORT
7-4 PROCEDURES
7-5 DETERMINING CAUSAL FACTORS FOR INL/A ACCIDENTS
7-6 ACCIDENT INVESTIGATION REPORTS
7-8 ACCIDENT INVESTIGATION BOARD APPOINTING AUTHORITY
7-9 SAFEGUARDING PRIVILEGED AND SENSITIVE INFORMATION
7-10 SAFEGUARDING ACCIDENT INFORMATION
7-11 SAFEGUARDING AND RELEASE OF ACCIDENT/INCIDENT INFORMATION AND
ACCIDENT/INCIDENT INVESTIGATION REPORTS
CHAPTER 8 – PROCEDURES FOR CLASSIFYING INL/A ACCIDENTS, INCIDENTS,
INJURIES, ILLNESSES, COSTS, RATES, AND PERSONNEL
8-1 OVERVIEW
8-2 TYPES OF REPORTABLE EVENTS
8-3 REPORTING TIME REQUIREMENTS
8-4 REPORTABLE OCCURRENCES NOT CONSTITUTING AN INL/A ACCIDENT
8-5 NON-REPORTABLE INJURIES AND ILLNESSES TO INL/A
8-6 OFFICE OF PRIMARY RESPONSIBILITY
8-7 REQUIRED FORMS FOR ALL REPORTABLE ACCIDENTS, INCIDENTS, OTHER MISHAP EVENTS ..
8-8 NOTIFICATION OF ACCIDENTS, INJURIES AND ILLNESSES TO U.S. GOVERNMENT AGENCIES
OTHER THAN INL/A
8-9 SAFETY AND OCCUPATIONAL HEALTH PROGRAM INJURY/ILLNESS LOG
8-10 PERSONNEL CLASSIFICATIONS AND SPECIAL CASES
8-11 INJURY AND ACCIDENT RATES
CHAPTER 9 – RELEASE OR MOVEMENT OF AIRCRAFT / VEHICLES INVOLVED IN AN
ACCIDENT / INCIDENT
9-1 AIRCRAFT ACCIDENTS
9-2 AIRCRAFT INCIDENTS
9-3 AIRCRAFT ACCIDENTS/INCIDENTS WHICH BLOCK OR OBSTRUCT A RUNWAY OR PRIMARY
TAXIWAY
9-4 VEHICLE ACCIDENTS
APPENDIX A – REFERENCES
APPENDIX B – ABBREVIATIONS AND TERMS
APPENDIX C – ACCIDENT INVESTIGATION HANDBOOK ......................................................... I TABLE OF CONTENTS ................................................................................................................... I
GENERAL GUIDELINES
RESPONSIBILITIES
INITIAL ACTIONS
GENERAL
INITIAL ACTIONS CHECKLIST
WRECKAGE DISTRIBUTION DIAGRAM
GATHERING DATA
INVESTIGATION TEAM
WITNESS INTERVIEWS
SUGGESTED HUMAN FACTORS CHECKLIST
SUGGESTED MATERIEL FACTORS CHECKLIST
WRITING THE REPORT
INL/A ACCIDENT INVESTIGATION REPORT FORMAT
ADDITIONAL REPORT GUIDANCE
CONCLUSIONS
FINDINGS AND RECOMMENDATIONS
NON-AVIATION ACCIDENTS
NON-AVIATION ACCIDENT CONSIDERATIONS
PROCESSING OF ACCIDENT REPORTS
REVIEWS
PROCESSING ACCIDENT REPORTS
CHANGES TO ACCIDENT REPORTS AND REQUEST FOR EXTENSION
AIRCRAFT DIAGRAMS
C-208 C-27 C-27
UH-1
UH-60
OV-10
T-65
AT-802
SAFETY DIRECTIVES (1 May 2009)
CHAPTER 1 – General Information 1-1 Introduction This U.S. Department of State, INL/A directive is regulatory in nature and establishes procedures, policies, and personnel responsibilities for the protection and preservation of personnel and property against illness, injury and loss or damage to assets. Adherence to this document is mandatory for all Bureau for International Narcotics and Law Enforcement Affairs, Office of Aviation (INL/A) employees including U.S.G. civilian contractors, subcontractors, U.S. Military members and host nation members assigned to INL/A programs. This document supersedes any and all previous versions of the INL/A Safety Directives and Guidelines.
1-2 Responsibilities A. Director, INL/A
The Director, INL/A is the senior management official for all INL/A activities and exercises final authority on all matters pertaining to the operation, direction, and policy formulation of INL/A. This includes final waiver authority for this document.
B. Deputy Director, INL/A
The Deputy Director receives direct guidance from the Director, INL/A. The Deputy Director formulates and implements policies and procedures ensuring all INL/A operations are adequately resourced to provide optimum efficiency and safety. Functions and exercises the authority of Director in the absence of the Director, INL/A.
C. Director of Safety, INL/A
The Director of Safety, INL/A, provides contractor oversight on all aspects of the INL/A Aviation, Ground and Environmental Safety Program, to ensure compliance with all applicable regulatory Safety, Health, and Environmental (SHE) requirements. As a prerequisite before being officially designated the Director of Safety, the individual filling that position shall complete, or present evidence of completion, of an INL/A approved aviation safety course and accident investigation program. The Director of Safety, INL/A will:
1) Administer and direct an effective safety program to reduce the occurrence of accidents.
2) Act as principal adviser to the Director, INL/A on all safety matters.
3) Develop, coordinate, and disseminate INL/A safety program policy, direction, and guidance to the INL/A Air Wing and program contractors.
4) Monitor the INL/A safety program’s effectiveness.
5) Support the INL/A Director in developing specific plans and programs.
6) Collect and distribute accident data and statistics relating to injuries, occupational illnesses, and report damage related to INL/A operations.
7) Develop safety countermeasures to reduce accidents.
8) Investigate selected Air Wing accidents according to this directive.
9) Serve as the risk management advocate for INL/A and synchronize the risk management actions by Air Wing personnel.
10) Serve as the alternate waiver authority for this document.
D. Director of Operations, INL/A
The Director of Operations is responsible for:
1) Development and implementation of INL/A aviation policies in coordination with other INL/A functional staff members.
2) Oversight of INL/A operations, training, and aviation standardization.
3) Directing and coordinating aircraft deployments.
E. Director of Maintenance, INL/A
The Director of Maintenance is responsible for:
1) All maintenance and associated activities involving INL/A aircraft.
2) Development and implementation of INL/A aviation maintenance policies in coordination with other INL/A functional staff members.
3) Exercising oversight management of all contractor maintenance activities.
4) Ensuring the contractor follows approved and established maintenance polices to include those functions performed under Federal Aviation Administration (FAA) Repair Certificate authorizations.
F. Senior Aviation Advisors, INL/A
Senior Aviation Advisors (SAA) shall provide day-to-day oversight of contractor functional areas to include maintenance, logistics, quality control, safety, operations, standardization, Aviation Life Support Equipment (ALSE), and site administration. SAAs shall also provide day-to-day operational contractor guidance and direction as appropriate.
1-3 Deviations and Violations In an emergency, deviations from this document or from other INL/A Directives, U.S.
Federal Regulations, International Civil Aviation Organization (ICAO), host country regulations, and/or other regulatory requirements may occur. Any deviation or violation to this document shall be reported through the Senior Aviation Advisor, as appropriate, to the Director of Safety, INL/A within 48 hours. Willful violations of this directive or any regulation may be punishable under applicable policies, laws, and regulations.
1-4 Waivers Request for waivers to provisions of this publication shall be forwarded in writing to the Director of Safety, INL/A for approval. Waivers requiring immediate approval may be requested and approved telephonically; however, a follow-up written request must be made within 48 hours of the telephonic approval.
1-5 Suggested Improvements Users of this document should send comments and suggestions to:
Director, DoS INL/A
ATTN: Director of Safety, INL/A
1038 South Patrick Drive
Hangar 985
Patrick AFB, FL 32925-3516
1-6 References
Appendix A is a listing of official publications cited within this document.
1-7 Abbreviations and Terms Definitions of all abbreviations and terms used throughout this document are included in Appendix B.
1-8 Rules of Construction and Definitions A. “Will,” “must,” and “shall”” are used to indicate a mandatory requirement.
B. “Should” is used to indicate that non-compliance is authorized when reasonable justification exists.
C. “May” is used to state authority or permission to perform the act specified.
D. “Includes” means “includes but is not limited to.”
E. “And/or” is used to indicate either “and” or “or.”
F. Words that impart the singular include the plural.
G. Words that impart the plural include the singular.
1-9 Regulatory Compliance A. When operating within the Continental United States (CONUS), all personnel will adhere to all Federal, state, and local safety and health regulations, including the Occupational Safety and Health Act (OSHA).
B. In OCONUS locations all personnel shall make every attempt to comply with appropriate OSHA and EPA regulation or the host nation laws/regulations, whichever laws/regulations are more stringent. Infractions shall be reported in writing through the country SAA to Director of Safety, INL/A.
C. Program personnel shall comply with applicable environmental laws and regulations; operating policies and directives outlined in Executive Order 12114 of January 4, 1979, “Environmental Effects Abroad of Major Federal Actions.”
SAFETY DIRECTIVES (1 May 2009)
CHAPTER 2 – Safety Management 2-1 Safety Plans and Safety SOPs Each organization shall maintain a safety program and develop Safety Plans/SOPs as necessary to ensure compliance with this Directive at all levels and in all operating locations. The Plans/SOPs shall include policies, rules, and techniques required to implement provisions of this INL/A Safety Directive as well as to promote safety awareness and facilitate the safety and health of all personnel assigned to INL/A programs. Copies of all contractor generated Safety Plans/SOPs will be forwarded through the Contractor's primary Safety Office located at PSD to the Director of Safety, INL/A for USG review and approval prior to implementation.
2.2 Emergency Action Plans
Each organization shall develop and maintain a well developed, comprehensive, and standardized Emergency Action Plan (EAP) which provides well defined procedures necessary to protect personnel and U.S.G. assets in the event of an emergency. EAPs shall be tailored for each CONUS and OCONUS operational site/FOL and will:
A. Address both aviation and ground potential mishaps.
B. Be clearly written and provide step by step procedures to follow in case of emergency.
C. Focus on organized rescue of personnel, protection of property, preservation of the mishap scene, and notification of appropriate personnel.
D. Facilitate coordination with airfield management, local emergency response agencies, site management, and compliance with host nation operational directives and regulations.
E. Address procedures for both fixed-site and temporary field site locations.
F. Include necessary emergency and immediate action steps and contact numbers for response agencies.
G. Be rehearsed and reviewed for administrative accuracy at least quarterly. A written After Action Report (AAR) will be completed for each rehearsal, briefed to site personnel and retained on file for 2 years. Coordinate rehearsal of plans with local emergency response agencies, if participation of local agencies is not possible note on After Action Report (AAR).
2.3 Safety Awards Program
Each organization operating under the INL/A program will establish an active safety awards program to recognize employees who make positive contributions to safety awareness.
2.4 Record Keeping and File System
Safety Management will develop and maintain a standardized hard copy filing system which will be used at each country location. The filing system will be used to file those documents which are required to be maintained in support of the INL/A program. The file system shall be standardized throughout the INL/A program and shall be maintained for a period of not less than 2 years.
2.5 Documenting Identified Hazards
Each organization shall maintain a current “HAZLOG” which captures all identified safety hazards and risks. As a minimum, Safety Management shall record in the HAZLOG identified risks for all MOBs and FOLs. The HAZLOG will be standardized and shall be reviewed at least quarterly as to the status of the hazard. All high risk hazards shall be reviewed monthly until the risk has been eliminated or mitigated to an acceptable level.
Each country site location shall be responsible for monitoring their functional areas of responsibility. As a minimum, the HAZLOG shall include the following:
• Hazard site (country, MOB, FOL and actual physical location)
• Point of contact
• Initial risk level
• Mitigation efforts
• Residual risk level
2.6 Reporting of Hazards by an Employee
A. All employees shall report to management any actual or potential condition that can cause injury, illness, death of personnel; damage to or loss of equipment/property; or mission degradation. This includes conditions, procedures, and practices directly related to the work environment which creates a potential for producing occupational injuries or illness and/or the loss of or damage to property or assets.
B. To facilitate the reporting of hazards the Contractor’s Safety Management shall establish, maintain, and promote a methodology and written procedures for non-punitive and anonymous reporting procedures of hazards by employees.
2.7 Toxicology Program and Post Mishap Toxicology Testing
A. The investigation of accidents and incidents is necessary to determine the cause of the mishap and to obtain engineering data, provide trend information, protect the rights of the individuals involved, and assist in the prevention of similar accidents or incidents. To facilitate a proper and complete investigation of mishaps the following procedures will be utilized to determine if and when an employee is required to provide toxicology samples for testing:
1) In the event of an operating aircraft accident or incident involving structural damage to the aircraft, a fatality, or injury to personnel, alcohol and drug testing for the flight crews shall be mandatory. See paragraphs 2.7 (B), (C) and (D). Intent for flight is not necessary. Examples: Major aircraft accident with or without injuries/fatalities; minor aircraft mishap such as a hard landing or blade strike causing damage to the aircraft or injury to personnel.
2) In the event of an aircraft flight violation where a crewmember may be responsible for the violation. Intent for flight may not be necessary. Accident Investigating Authority, SAA, or the Country Site Manager has the authority to order alcohol and drug testing in accordance with paragraph 2.7 (B) (C) and
(D) of this document. Examples: Crew failing to follow ATC clearance, unauthorized flight maneuvers, crew actions causes other aircraft to deviate from their course, and/or failing to follow proper FAA/ICAO flight procedures.
3) In the event of an aircraft incident where there is damage to private property or USG assets as a result of that flight and where the flight crew may be responsible. Accident Investigating Authority, SAA, or Country Site Manager has the authority to order alcohol and drug testing in accordance with paragraph 2.7 (B) (C) and (D) of this document. Examples: Hover mishaps where there is damage to property as a result of flight crews hovering their aircraft too close to unsecured equipment or other aircraft; flight crews not being aware of what is behind their aircraft during engine starts, run-up, and/or high-power operations and as a result there is damage to property or injury to personnel.
4) In the event of a weapon firing incident (including accidental discharge) which causes damage to USG assets, damage to private property, or which causes injury to personnel or results in a fatality. Accident Investigating Authority, SAA, or Country Site Manager has the authority to order alcohol and drug testing in accordance with paragraph 2.7 (B) (C) and (D) of this document.
Examples: Weapon discharges as a result of gunners not following procedures or weapon techs improper handling of the weapon system while clearing the weapon and the weapon fires causing an injury and damage to an aircraft, personnel or other property.
5) In the event of a motor vehicle accident causing injury to personnel, damage to private property or damage to USG assets. Based on the severity of the damage, the Accident Investigating Authority, SAA, or Country Site Manager has the authority to order alcohol and drug testing in accordance with paragraph 2.7 (C) and (D) of this document. A blood alcohol level of 0.08 shall be used as the maximum limit for vehicle mishaps. The driver shall always be tested anytime there is a serious injury or fatality. Accident Investigating Authority or Country Site Manager has the authority to order drug testing in accordance with paragraph 2.7 (B) (C) and (D) of this document. Examples: An employee is involved in a vehicle accident where the employee is charged with the accident or contributed to the cause of the accident.
6) Improper use of equipment causing injury or significant damage to assets.
Accident Investigating Authority, SAA, or Country Site Manager has authority as to order alcohol and drug testing in accordance with paragraph 2.7 (C) and
(D) of this document. A blood alcohol level of 0.08 shall be used as the maximum limit for these types of mishaps. Examples: An employee failed to follow procedures during the movement of equipment while using a powered industrial truck (forklift) causing damage to equipment, cargo, facilities or injury to personnel.
7) Improper supervision of personnel resulting in an injury to personnel or serious damage to equipment or anytime any employee intentionally and/or knowingly violates procedures, directives, or regulations. Accident Investigating Authority, SAA, or Country Site Manager has authority as to when drug testing would be required in accordance with paragraph 2.7 (B)
(C) and (D) of this document. A blood alcohol level of 0.08 shall be used as the maximum limit for this type of mishaps. Example: An employee and/or supervisor fails to follow procedures during the towing and ground movement of an aircraft where the aircraft make contact with another object causing damage to the aircraft, other assets, or injury to personnel.
8) Intentionally committing an unsafe act or intentional causing harm to personnel or material assets. Accident Investigating Authority, SAA, or Country Site Manager has the authority as to when drug testing would be required in accordance with paragraph 2.7 (B) (C) and (D) of this document.
A blood alcohol level of 0.08 shall be used as the maximum limit for this type of mishaps. Example: Violence in the workplace, threats, or altercation causing physical or mental harm to others. Deliberate damage to property.
9) Whenever an employee is believed to have reported for duty while under the influence of alcohol or drugs. SAA, senior on site manager, or Country Site Manager has the authority as to when drug testing would be required. A blood alcohol level of 0.08 shall be used as the maximum limit for this type of mishaps. Example: Employee reports for work smelling of alcohol where it is believed by his supervisor and department manager (second opinion) the employee is under the influence. Under the influence may include: alcohol or drugs including prescription, over the counter, and illegal drugs.
B. For the purpose of alcohol and drug use and testing, all personnel acting as an aircraft crewmember shall comply with 14 CFR Part 91.17 (a) and Part 121 (appendices I and J). These regulations describe when an employer is required to conduct and when an employee must submit to post-accident drug and/or alcohol testing. For all aircraft related mishaps an alcohol limit of 0.04 shall be used as the maximum blood alcohol level. No person may act or attempt to act as a crewmember of an INL/A aircraft—
1) Within 12 hours (INL/A requirement supersedes the FAA requirement of 8 hours) after the consumption of any alcoholic beverage;
2) While under the influence of alcohol;
3) While using any drug that affects the person's faculties in any way contrary to safety; or
4) While having an alcohol concentration of 0.04 or greater in a blood or breath specimen. Alcohol concentration means grams of alcohol per deciliter of blood or grams of alcohol per 210 liters of breath.
Except in an emergency, no pilot of an aircraft may allow a person who appears to be intoxicated or who demonstrates by manner or physical indications that the individual is under the influence of drugs (except a medical patient under proper care) to be carried in that aircraft.
C. Post-accident drug and/or alcohol test shall be conducted as follows:
1) As soon as practicable following an accident, each employer must test each surviving employees for the presence of marijuana, cocaine, opiates, phencyclidine (PCP), and amphetamines, or a metabolite of those drugs in the employee's system, and for alcohol, if that employee's performance either contributed to the accident or cannot be completely discounted as a contributing factor to the accident.
2) For post-accident drug testing, the employee must be tested as soon as possible but not later than 32 hours after the accident.
3) For post-accident alcohol testing, the employee must be tested as soon as possible but cannot exceed 8 hours from time of accident. If a test is not administered within 2 hours following the accident, the employer must prepare and maintain on file a record stating the reasons the test was not promptly administered. If a test is not administered within 8 hours following the accident, the employer must cease attempts to administer an alcohol test and must prepare and maintain the same record.
4) The decision not to administer a test must be based on the employer's determination, using the best information available at the time of the determination that the employee's performance could not have contributed to the accident.
D. An employee who is subject to post-accident testing shall remain readily available for such testing or may be deemed by the employer to have refused to submit to testing. Nothing in this section shall be construed to require the delay of necessary medical attention for injured people following an accident or to prohibit an employee from leaving the scene of an accident for the period necessary to obtain assistance in responding to the accident or to obtain necessary emergency medical care.
SAFETY DIRECTIVES (1 May 2009)
CHAPTER 3 – Safety Training 3-1 Training Each organization shall regularly schedule safety training to emphasize particular elements of the Safety Program. In most cases, Site Safety Specialists or Section Supervisors should accomplish the safety training. Safety managers will regularly oversee the training program and ensure the training has been conducted properly and documented.
3-2 Safety Meetings Safety meetings can vary in both scope and complexity, and may cover recent incidents, employee feedback, or any other safety awareness topic.
A. Each organization shall ensure safety training briefings are conducted weekly at all sites and will cover ground safety-related issues. Attendance is mandatory for all available personnel.
B. Organizational aviation safety training will be conducted monthly for all aircrew personnel. Attendance is mandatory for all available personnel.
3-3 Safety Stand Down Program Safety Stand-Downs are used to increase safety awareness of all Air Wing personnel.
This awareness involves knowing the role people play in maintaining a safe organization and understanding the risks involved. Safety Stand-Downs will be conducted at all sites at least semi-annually. SAAs, Site Managers, and Host Nation Commanders will make every attempt to include as many employees as possible in this training. Exceptions will be made only to meet critical mission requirements as determined by the SAA.
3-4 Documentation of Training Safety managers will maintain summaries of all safety meetings, safety stand downs, and training for two years. The summary will include the topic(s) covered and a personnel attendance roster. Records of required safety training meetings will be forwarded to the Director of Safety, INL/A through the safety management chain.
SAFETY DIRECTIVES (1 May 2009)
CHAPTER 4 – Program Safety Council 4-1 Purpose and Scope of the Council A Safety Council shall be established that provides a formal forum allowing open discussion and opportunity for the resolution of Safety concerns and issues for all organizations supporting the INL/A mission. The Safety Council shall be held quarterly and shall convene separately from the Flight Standardization Committee. A special Safety Council may be called at anytime by the Director of Safety, INL/A to discuss special or high risk issues.
The Safety Council has the authority to assign tasks and suspense dates to either an individual and/or to an Office of Primary Responsibility (OPR). The primary purpose of the Safety Council is to identify safety concerns, provide solutions, and disseminate safety information.
4-2 Council Responsibilities Site management at each main operating base shall:
A. Establish a proactive Safety Council process which addresses each of the following areas and ensure U.S.G. regulatory compliance:
1) Aviation Safety
2) Ground Safety
3) Environmental Compliance
B. Designate members of the safety Council in writing and ensure all members are formally notified of their duties, roles, and responsibilities.
C. OCONUS locations should make every effort to convene their Safety Councils by the second month of each quarter.
D. Council Chairmen are responsible to ensure that Council minutes are completed and forwarded within 30 days from the meeting date. Routing shall be through the contractor’s Program Safety Office to the Director of Safety, INL/A. A copy of the most recent minutes shall be posted on safety bulletin boards at each operating location. File copies shall be maintained for two years.
4-3 Safety Council Members A. CONUS Council Members
1) U.S.G., INL/A – Director of Safety (Council Chairperson)
2) Contractor – Director of Safety (Recorder / Council Co-Chairperson)
3) Contractor – Deputy Director of Safety (Co-Recorder)
4) U.S.G., INL/A – Director of Operations
5) Contractor – Director of Operations
6) Contractor – Ground Safety and Environmental Manager
7) U.S.G., INL/A – Chief of Flight Standardization
8) Contractor – Chief of Flight Standardization
9) Contractor – Fixed and Rotary Wing Chief Pilots
10) Contractor – Director of Maintenance
11) U.S.G., INL/A – Director of Maintenance
12) Contractor – Director of Logistics
13) U.S.G., INL/A – Director of Logistics
14) Contractor – Quality Control Manager
15) U.S.G., INL/A – Quality Control Manager
16) Other personnel as directed by the Council chairperson
B. OCONUS Council Members
1) U.S.G., INL/A – Senior Aviation Advisor or designated INL/A representative
(Chairperson)
2) Contractor – Site Manager (Co-Chairperson)
3) Host Nation Senior Leader ( Co-Chairperson)
4) U.S.G., INL/A – Aviation Safety Representative
5) Contractor – Site Safety Manager (recorder)
6) U.S.G., INL/A – Aviation Advisor for both fixed and rotary wing SPs as appropriate
7) Contractor – Fixed and/or Rotary Wing SPs
8) Contractor – NRCM – FI/SI
9) U.S.G., INL/A – Aviation Advisor ME or MP
10) Contractor – ME or MP
11) Contractor – Maintenance Manager
12) U.S.G., INL/A – Maintenance Manager
13) Contractor – Logistics Manager
14) U.S.G., INL/A – Logistics Manager
15) Contractor – Quality Control Manager
16) U.S.G., INL/A – Quality Control Manager
17) Other personnel as directed by the Council chairperson
SAFETY DIRECTIVES (1 May 2009)
CHAPTER 5 – Safety Inspections and Surveys 5-1 Safety Inspections
A. Safety Management shall develop a comprehensive aviation, ground and environmental self-inspection checklist system which will be used as a measuring tool to assess safety practices in the workplace and determine regulatory compliance.
B. Site safety personnel will conduct bi-monthly safety inspections at all sites and maintain inspection records on site for 2 years.
5-2 Facility Support Equipment All facility/site support equipment such as overhead hoist, fire extinguishers, first aid kits, eye wash stations, etc. will be inspected in accordance with applicable NFPA/OSHA regulation.
A. Fire Extinguishers: Safety Management will establish a fire extinguisher policy addressing placement, inspection and servicing. Only approved portable fire extinguishers shall be used. All fire extinguishers shall be inspected monthly and date and PID or initials entered on the inspection tag. Fire extinguishers will be utilized in accordance with 29 CFR, Section 1910.157.
B. Emergency Eyewash and Shower Units: Safety Management will establish an emergency shower and eyewash policy. Emergency shower and eyewash units will be placed in work areas where the eyes or body of any person may be exposed to injurious corrosive materials. Emergency shower and eyewash units will be inspected monthly and date and PID or initials entered on the inspection tag
C. First Aid Kits: Safety Management will establish a policy on the utilization of first aid kits to meet program requirements. First aid kits will be inspected monthly and date and PID or initials entered on the inspection tag.
5-3 Aviation Resource Management Survey (ARMS) INL/A will conduct an Aviation Resource Management Survey (ARMS) for each site on a periodic basis. The goal is to conduct an ARMS inspection on a 12 to 18 month cycle.
The INL/A Arms Checklist will be used as the basic document for conducting the ARMS inspection.
SAFETY DIRECTIVES (1 May 2009)
CHAPTER 6 – Environmental 6-1 Hazardous Materials Safety Management will develop and implement a comprehensive Hazardous Material (HAZMAT) Program, which will be included in the Air Wing Safety Plan. The plan will be administered by Logistics personnel and monitored by site safety managers to ensure regulatory compliance.
6-2 Hazardous Waste Management Safety Management will develop and implement a comprehensive Hazardous Waste Management PLAN which meets federal and state requirements. Each site should develop a Supplemental PLAN which addresses laws and regulations dictated by host nation authority as they apply to INL/A. OCONUS sites may use the PSD Supplemental Hazardous Waste Management SOP as guidance in the development of their local supplemental SOP.
6-3 Spills and Environmental Mishaps To ensure a rapid response to environmental incidents, Safety Management shall ensure that a well developed emergency spill response plan is available at all locations.
The spill response plan will detail the quantity, location, and make-up of spill response kits and spill response teams. The plan shall also make provisions for spill response training. All spills of hazardous materials in excess of five gallons shall be reported to the INL/A, Director of Safety through the Air Wing Safety Department. The spill response plan should be included as part of the EAP.
6-4 Transporting Hazardous Materials All hazardous materials shall be processed, packaged, labeled correctly, and transported in accordance with either 49 CFR, PART 172; U.S. Department of Transportation, 14 CFRs (Federal Aviation Regulations), International Civil Aviation Organization (ICAO), International Air Transportation Association (IATA), U.S. Air Force Manual 24-204, Host Nation Laws, or whichever regulation is appropriate for the agency transporting the hazardous material.
A. Unauthorized or improper shipment of hazardous materials is not authorized.
B. Personnel who handle hazardous materials for shipment shall be formally trained.
C. Transportation of non-compatible materials is not authorized.
D. All hazardous materials shipped on INL/A aircraft shall meet the same transportation requirements as stated above in the main paragraph to provide for passenger/crew safety and prevent damage to aircraft.
E. Whenever hazardous materials are shipped on INL/A aircraft the hazardous cargo shall be identified on the cargo manifest, a copy of the MSDS for each type of hazardous material shall be given to the Pilot in Command or Load Master, and the Mission Briefer shall brief the Pilot in Command about the hazardous materials being placed on his aircraft. A comment shall be made on the Mission Brief Sheet that the Pilot in Command was briefed about the hazardous materials. A copy of the MSDS shall be attached to the Mission Brief Sheet as part of that day’s flight record.
F. The Director of Operations, INL/A has the authority to approve exceptions or waivers to this chapter on a case-by-case basis in consultation with the Director of Safety, INL/A. Conditions of the approval must be annotated and signed by the Mission Briefer on the Mission Brief Sheet for the aircraft in which the waiver has been granted. A copy of the waiver shall be attached and maintained with the mission brief sheet. Under exigent circumstances SAA’s may also approve a waiver for the shipment of hazardous materials on a case-by-case basis. Both the SAA and Country Site Manager shall ensure all appropriate actions have been taken to mitigate risks or minimize risks to their lowest level prior to the start of the mission. The SAA and Country Site Manager shall ensure that the Director of Safety, INL/A and the Safety Management’s Director of Safety have been notified of the waiver. Written notification shall be made within 10 calendar days to the Director of Safety, INL/A through the Safety Management’s Director of Safety.
SAFETY DIRECTIVES (1 May 2009)
CHAPTER 7 – Reporting Mishaps 7-1 Purpose This chapter defines procedures and responsibilities for the initial notification, investigating, reporting, and submitting of reports for INL/A accidents and incidents. For the purposes of this document, an INL/A mishap is defined as an unplanned event, or series of events, that results in injury/illness to either Air Wing or non-Air Wing personnel, and/or damage to U.S.G. or non-U.S.G. property as a direct result of INL/A operations. In addition, all aircraft related mishaps, other incidents (over $2,500 damage to U.S.G. property), a fatality, serious injury, or lost workday by personnel, the U.S.G.
will be notified within 2 hours of discovery and a CIR submitted within 24 hours.
7-2 Policy It is the policy of INL/A to prevent accidents before they occur. Effective accident prevention programs will be instituted to identify hazards and to prevent accidents. All INL/A accidents will be investigated, reported, and analyzed in accordance with the requirements of this directive. The primary purpose of investigating and reporting INL/A accidents is accident prevention.
7-3 What to Report A list of reportable events are found in Chapter 8, paragraph 8-2 of this document.
7-4 Procedures A. In the event of an accident or incident, the primary concern is the health and safety of those personnel involved. This includes those personnel actually involved in the mishap and those involved in the rescue, emergency response, and investigation.
B. Secondly, Air Wing assets must be protected. It is essential that all personnel understand what may be required of them in the event they witness or respond to a mishap. For a detailed list of responsibilities see Appendix C of this document. Overview of responsibilities include but not limited to:
1) The EAP should be initiated immediately after any accident, incident, personnel injury, or property damage to ensure proper actions have been taken.
2) Every effort shall be made to assist survivors, remove any victims, protect the wreckage from further damage, and protect the public.
3) The DoS Director of Safety, INL/A will be notified telephonically within two (2) hours of an incident involving serious personal injury, fatality, safety of flight or structural damage to an aircraft.
4) An initial Consolidated Incident Report (CIR) shall be submitted to the U.S.G.
within 24 hours.
5) In the event of an accident, site management will initiate and maintain a mishap log of events. The mishap log will be provided to personnel investigating the mishap on arrival.
6) Site Management must ensure the mishap site is tactically secure. This depends on threat level and may require the use of local law enforcement or military agencies.
7) As soon as possible witnesses shall be identified, segregated, and their statements recorded.
8) First Air Wing responders must not interfere with emergency service personnel or equipment. Safety First! Anyone approaching an aircraft mishap must use extreme caution. Approach upwind if possible and avoid any smoke, fumes, munitions, or other hazardous cargo which may be on the aircraft.
9) Site safety personnel will immediately proceed to the mishap scene to initiate preliminary mishap investigation procedures. See Appendix C “Accident Investigation Handbook.”
10) Accident site safety briefings shall be given by a Safety Representative or Site Manager anytime there is a threat of hazardous materials, unexploded ordinance, fire, and/or exposed body fluids/parts (blood born pathogens).
Briefing shall include the type of required Personal Protective Equipment (PPE) personnel will wear. Also discuss wind direction, emergency actions, possible hostile threat, personnel responsibilities, and possible support which may be needed.
11) Safety personnel or Senior Air Wing personnel will secure/preserve the accident or mishap scene, secure critical documentation, take photos, and collect witness statements.
12) The Director, INL/A or a designated representative will determine which accidents will be investigated by an appointed INL/A Accident Investigation Board.
7-5 Determining Causal Factors for INL/A Accidents A. The purpose of determining the causal factors of an accident is to help determine principle elements accountable for the mishap and to facilitate accident prevention. The primary causes for an accident will be classified as Human, Material or Environmental. The final CIR will identify a primary causal factor in the report.
B. Accidents involving INL/A equipment loaned or leased by INL/A to a non-INL/A organization for maintenance, repair, test, contract training, contract bailment, or experimental projects will not be charged to INL/A if the non-INL/A organization that has operational control of the equipment has assumed the risk of loss (in writing).
7-6 Accident Investigation Reports Accident investigation reports are limited use reports and will not be used to initiate a collateral investigation or for Loss, Damaged or Destroyed (LDD) determination.
Collateral/LDD investigations are administrative investigations. Accident reports are restricted use, internal communications of INL/A whose SOLE purpose is prevention of subsequent Air Wing accidents. Accident reports are required for all mishaps as outlined in paragraph 8-2 of this document. See explanations below.
A. Since much of the mishap information is available only from persons directly or indirectly involved in the accident, a means must be provided to establish frank and open exchange of such information without fear of recrimination or other adverse action.
B. Personnel who provide information to accident investigators in this category under a promise of confidentiality may be assured that INL/A will use its best efforts to honor the promise and will not voluntarily disclose this information to outside parties.
C. In addition to flight accidents and fratricide/friendly fire accidents, other Limited Use Safety Accident Investigation Reports will be used for accidents involving other complex systems, equipment, or military-unique items, or equipment/operations/exercises when the determination of causal factors is vital to safety and the security of assets and personnel.
D. The following restrictions are imposed on the handling of accident / incident investigation reports:
1) Reports shall not be used as evidence or to obtain evidence for disciplinary action, in determining the misconduct or duty status of any personnel, before any evaluation board, or to determine liability in administrative claims for or against the Government.
2) During mishap investigations, witnesses may be given the option of making their statement under a promise of confidentiality if they are unwilling to make a complete statement without such a promise and the investigation board believes it is necessary to obtain a statement from a witness.
3) To the extent permissible under the law, these reports shall not be released in their entirety to the public or any federal agency outside of DoS, INL/A.
Notwithstanding, the restrictions on the use and release of these reports in their entirety, purely factual material, including information such as date, time, location, type system, weather, maps, and transcripts of air traffic communications, may be released as required by law or pursuant to court order, or upon specific authorization of the Director, INL/A. Non-releasable portions of these reports include findings, recommendations, aircraft technical data, analysis of the accident board, and confidential witness interviews. To facilitate the separation of this material, INL/A shall structure the reports so that releasable, non-privileged material is easily identifiable and retrievable.
7-7 Other Investigations and Reports The accident investigation has priority over any other investigation. Designated safety personnel will not conduct, review, evaluate, assist with or otherwise participate in other investigations convened to determine individual culpability. Similarly, other personnel serving as accident board members or as a sole investigation authority will not conduct, review, evaluate, assist with or otherwise participate in other investigations convened to determine individual culpability for the mishap in which those personnel conducted the accident or incident investigation.
7-8 Accident Investigation Board Appointing Authority A. The Director, INL/A is the final authority for all accident investigations and is responsible for appointing accident investigation boards. All mishaps involving fatalities, permanent disabilities, or total aircraft loss will be investigated by an accident investigation authority. If available, FAA or NTSB personnel will act as a board member of an appointed INL/A accident investigation board.
B. Accident investigation authority is defined as
1) An individual who is authorized to conduct INL/A mishap investigations based on their assigned job descriptions or…
2) A group of selected individuals appointed by the Director of INL/A. This group of appointed individuals is referred to as the Accident Investigation Board. Both investigation authorities have the sole purpose of determining the cause of the mishap.
C. The Director, INL/A will:
1) Appoint the president and other members of the board based on professional experience, duty assignment, and needs of the U.S.G. Other individuals may be designated as technical advisers (non-voting) to enhance the investigation and reporting of the accident.
a) The primary purpose of inviting advisors to participate in an accident investigation is to assist the Board in developing a complete and accurate factual record of the accident. It also helps responsible safety officials to have immediate access to facts regarding the accident/incident that may facilitate prompt preventive and/or corrective action.
b) Participation as a party; however, is a privilege – not a right – and conveys no right to information or participation.
2) Request support from outside the Air Wing when needed or required tasks are beyond the Air Wing’s capability.
3) Give priority to accident investigation and reporting duties to ensure prompt completion of accident reports. Ensure adequate clerical and administrative support is available to assist in the rapid completion of accident investigations.
4) Ensure that no member of the board has a personal interest in the outcome of the accident investigation.
D. Where practical, a representative from INL/A will accompany the Accident Investigation Board as a member. Any mishap, regardless of the severity, shall be investigated by an authorized investigating authority. Those mishaps which the Director, INL/A believes that may serious enough to warrant a formal investigation will be investigated by a formal accident investigation board. Host nation personnel should be included in the investigations as appropriate.
7-9 Safeguarding Privileged and Sensitive Information Privileged safety information includes statements, reports or testimony given to a safety investigator or board. The findings, evaluations, analyses, opinions, conclusions, recommendations and other indicia of the deliberative processes of a safety investigator, safety investigation boards, endorsers and reviewers are also privileged safety information.
7-10 Safeguarding Accident Information A. All accident related documents, photographs, and technical data shall be considered proprietary to the U.S.G., sensitive in nature, and shall be secured at all times.
B. In the event of an aircraft mishap requiring an investigation, all related documents shall be immediately secured and promptly surrendered to an Air Wing Safety Representative or an Accident Investigation Board Member.
C. Prior to surrendering the aircraft log book to the Air Wing Safety Representative or an Accident Investigation Board Member, an entry will be entered in the aircraft’s logbook on Form 2408 -13 by Quality Control stating that the aircraft was involved in an accident/incident and all aircraft records have been secured and surrendered to the investigating authority. An entry shall be made stating that the aircraft is restricted from maintenance activity until release by the Accident Board President; the Director of Safety, INL/A or his designated representative.
D. QC shall ensure the same 2408-13 logbook entries are made in AWIS. Once the appropriate entries have been made, all AWIS records shall be secured and not released until approved by the president of the accident board or the Director of Safety, INL/A or his designated representative.
7-11 Safeguarding and Release of Accident/Incident Information and Accident/Incident Investigation Reports
A. Good judgment and common sense must prevail in safeguarding sensitive information. This restriction is necessary to prevent undue anxiety to family members, co-workers, and other concerned parties by releasing misinformation.
Additionally, this restriction is necessary to prevent the release of information, accurate or otherwise, to the media or other unauthorized personnel.
B. Accident investigation reports are official documents and are internal to INL/A.
Their SOLE purpose is the prevention of subsequent Air Wing accidents and incidents. Since much of the information available can only come from persons directly or indirectly involved in the accident or incident, a means must be provided to establish a frank and open exchange of such information without fear of recrimination or other adverse action.
C. All information provided to accident investigators shall be considered privileged and sensitive information and is only releasable subject to previsions of the
Freedom of Information Act (FOIA) or in compliance with a judicial decree.
Therefore:
1) AT NO TIME SHALL ANY PERSON DISSEMINATE, RELEASE, OR
CAUSE TO BE RELEASED ANY INFORMATION INCLUDING
PHOTOGRAPHS, STATEMENTS, OR TECHNICAL DATA, REGARDING
AN INL/A ACCIDENT OR INCIDENT TO ANYONE, WITHOUT EXPRESS
WRITTEN PERMISSION FROM THE DIRECTOR, INL/A.
2) THE ACCIDENT INVESTIGATION AUTHORITY; DIRECTOR OF SAFETY,
INL/A; AND SENIOR SAFETY MANAGEMENT HAVE THE AUTHORITY
TO REQUEST, COLLECT, AND SECURE ALL INFORMATION,
INCLUDING PHOTOGRAPHS, STATEMENTS, OR ANY TECHNICAL
DATA REGARDING ACCIDENTS AND INCIDENTS FOR THE PURPOSE
OF CONDUCTING MISHAP INVESTIGATIONS.
3) ALL ACCIDENT OR INCIDENT INFORMATION, INCLUDING
PHOTOGRAPHS, STATEMENTS, OR ANY TECHNICAL DATA WHICH IS
COLLECTED EXTERNAL TO AN ACCIDENT OR INCIDENT
INVESTIGATION AUTHORITIES DATA SHALL BE IMMEDIATELY
SURRENDERED TO CONTRACTOR’S SAFETY DEPARTMENT OR THE
DIRECTOR OF SAFETY, INL/A.
4) NO INFORMATION WILL BE DISCUSSED ON A TELEPHONE, RADIO OR
ANY OTHER MEANS OF TRANSMITTAL BY ANYONE FOR ANY
PURPOSE, UNLESS SPECIFICALLY CALLED FOR IN THE EMERGENCY
ACTION PLAN, THIS DOCUMENT, OR SPECIFICALLY AUTHORIZED BY
THE DIRECTOR, INL/A.
5) AT NO TIME SHALL ANYONE RELEASE THE NAMES OF THOSE
PERSONNEL INVOLVED IN AN ACCIDENT OR INCIDENT UNLESS
SPECIFICALLY AUTHORIZED BY THE DIRECTOR OF, INL/A.
NOTE
Failure to comply with any portion of paragraphs 7-8, 7-9, or 7-10…
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