The reporter has raised a concern regarding Aerodrome Reporting Officers (AROs) interrupting aircraft maintenance activities while conducting security checks at [Location] aerodrome.
The reporter states that on multiple occasions aircraft maintenance engineers have been interrupted by AROs while conducting aircraft maintenance activities. The AROs have requested the maintenance engineers leave the airside area despite the engineers displaying a valid Aviation Security Identification Card (ASIC) on their shirt sleeve as required by ASIC holder display guidelines. The AROs have also remarked that the high visibility clothing worn by the engineers was not to standard.
The reporter acknowledges that ASIC security checks are required to be conducted by AROs at security-controlled aerodromes. However, the reporter is concerned about the potential consequences to aviation safety due to distraction caused by ARO security checks during times of aircraft maintenance activities.
[Aerodrome operator] is a certified aerodrome servicing Regular Public Transport (RPT) domestic, executive, emergency, general aviation (GA) and sport aviation operations. The airport is obligated to manage the airside areas in accordance with the requirements under the Aviation Transport Security Act 2004 and the Aviation Transport Security Regulations 2005.
[Aerodrome operator] is obligated under the Work Health and Safety Act 2011 to create and maintain a safe workplace for all workers, contractors, tenants, visitors and customers who use the aerodrome. The airport utilises an online information management system to report incidents and observations for aircraft safety, OH&S and security, and to monitor trends to identify potential hazards in the aerodrome environment.
[Aerodrome operator] develops safety bulletins and distributes these to aerodrome operators to communicate local procedures and policies relating to potential hazards and risks identified through monitoring and reporting. REF: Safety bulletin – High Visibility Garments Required Airside (date) (supplied to the ATSB and CASA).
On [date] a report was submitted regarding one of the regular users of the airport accessing the airside area after speaking with the Aerodrome Reporting Officer (ARO) on duty over the phone. The ARO asked if they have a valid Aviation Security Identification Card (ASIC) and are wearing high visibility clothing, to which the user answered yes to both questions. The ARO subsequently carried out a check-in of the maintenance engineers to discover they were non-compliant with the conditions of use of the aerodrome. The ARO was confronted with verbal abuse and threats. [Aerodrome operator] followed up in writing to the company Director citing all relevant documentation and regulations.
[Aerodrome operator] also placed the following conditions to ensure ongoing compliance with safety and security regulations:
- The operator immediately returns the key that had been provided, and
- Airside access can only be gained by calling the ARO who will conduct an inspection of ASIC and Personal Protective Equipment (PPE) prior to providing access.
This event also triggered a reissue of the safety bulletin and a focus on the use of appropriate PPE which was included into a campaign for Aviation Safety Week. Other users have been reminded of the use of appropriate PPE without any other issues or pushback. This is standard policy for a busy airport.
On [date] the same engineers accessed the aerodrome using a code given to them by a pilot. The access was gained without consent from [Aerodrome operator] representatives. The engineers refused to return the gate key they use for vehicle access stating it was back in the workshop.
[Aerodrome operator] again wrote to the Director of the business and followed up with phone calls and messages. At this point [Aerodrome operator] identified the group as a risk to safety and security and the breach reportable to the Department of Home Affairs (CISC) under our obligations to report security incidents. REF: Aviation Security Incident Reporting – Industry Guidance 2018 (supplied to the ATSB and CASA).
To manage the potential risk to safety and security, the ARO team were instructed to perform frequent ASIC checks in the GA area over the next few days. It should be noted that there was historical information regarding the same group of users allowing access to the airside areas to non-ASIC holders and underage persons. This information formed the basis of this decision.
[Aerodrome operator] was preparing to make a formal report to CISC and WorkSafe.
[Aerodrome operator] received an email from the Director on [date] confirming that all staff will wear appropriate PPE and does not expect this to be an issue again.
Subsequently [Aerodrome operator] received a call from the [position title] who had been the main contact onsite stating that the company will buy them all high visibility vests but to be patient while they sort it out. [Aerodrome operator] said they will provide additional surveillance support to manage the risk until they can get the correct PPE.
During the same conversation, the engineer challenged the activity of disrupting maintenance activities and the potential risk to aircraft safety. [Aerodrome operator] responded and dismissed this claim for two reasons:
1. An engineer should always take the necessary time needed to ensure that the task is completed to a suitable standard and appropriate checks are carried out. Time pressure is a risk to aircraft safety as is distraction. Individually they can be managed but the two together can be catastrophic.
2. The ARO on duty was acting to maintain a safe and secure environment as instructed by [Aerodrome operator] management and is justified in stopping activities that present a safety or security risk.
Based on the information [Aerodrome operator] was justified in ceasing the activities to conduct appropriate security and safety checks given the potential risks that were identified leading up to the incident.
The engineer expressed frustration at being held under extreme time pressure and should have the presence of mind to deal with all aspects of their role as an aviation professional including safety and security requirements rather that just trying to get the job done a quick as possible.
I would encourage ATSB to forward the de-identified incident report to CASA as discussed. There are some lessons that industry can learn from this incident.
Civil Aviation Safety Authority (CASA) does not consider the matter to be a direct safety concern for aerodrome operations within CASA oversight.
CASA rules under Part 139 do not stipulate:
- the carriage and display of Aviation Security Identification Cards (ASIC), or
- requirements for the visibility of personnel on the airside such as high visibility clothing.
Under Subpart 139.C of the Civil Aviation Safety Regulations, and the supporting Part 139 Manual of Standards (MOS), the aerodrome operator is required to maintain an Aerodrome Manual and follow the procedures therein.
Under the Part 139 MOS, this Aerodrome Manual must contain procedures for preventing the unauthorised entry onto the movement area (airside) including persons, vehicles, equipment, mobile plant or animals (including land-based wildlife) or other things that may endanger aircraft safety. These procedures must also address the control of airside access and monitoring of airside access control points and barriers, including fencing.
These requirements apply to all certified aerodromes, regardless of their status as a security-controlled airport under other transport security legislation. They do not stipulate the carriage and display of Aviation Security Identification Cards (ASIC), however. At security-controlled airports, the Aviation Transport Security Act 2004 and the Aviation Transport Security Regulations 2005 requirements apply instead.
Specific to [Aerodrome operator], the Aerodrome Manual states, 'As [Aerodrome operator] is a security-controlled aerodrome, persons in security restricted areas are required to display a valid Aviation Security Identification Card (ASIC) or a Visitor Identification Card (VIC) and be escorted by an ASIC holder. All persons not displaying a valid ASIC / VIC are to be challenged and escorted from the secure area'. It also states, '[Aerodrome operator] ensures that access is only permitted in accordance with the access control procedures in the Transport Security Plan (TSP)'. CASA does not oversight the Transport Security Plan and encourage the ATSB to refer the matter to the relevant agency (Department of Home Affairs, Cyber and Infrastructure Security Centre).
With regard to high visibility clothing, the Part 139 rules do not prescribe requirements for the visibility of personnel on the airside.
For applicable aerodromes above the respective trigger (either aircraft movement rates or passenger movement rates), a Safety Management System (SMS) or Risk Management Plan is required. If worker safety on the airside is identified within an applicable Safety Management System or Risk Management Plan, and if high visibility clothing is identified as a mitigation measure, CASA may issue a Safety Observation should a systems deficiency be otherwise be detected during surveillance activities.
CASA last undertook surveillance at [Aerodrome operator] in March 2023 at which time the SMS was under review. No Safety Observations were identified related to airside work or high visibility clothing.