Best Practices for Fuel Safety Inspection

Mike Schwanz
Published in: 

One of the challenges facing all but the smallest airports is ensuring compliance with FAA fuel safety regulations 14 CFR 139.321. Often, management tasks the Aircraft Rescue and Firefighting (ARFF) or Operations Department with performing quarterly audits of fueling agents to ensure that the specific requirements (listed in paragraphs b through h) are met. Such personnel, however, have other primary focuses and may not have experience with what should be included in a fueling safety audit and/or the proper tasks that should be performed to verify that safety devices or required items are operating correctly.


Project: Fuel Safety Audit Training

Locations: San Antonio (TX) Int'l Airport; Tallahassee (FL) Regional Airport

Consultant: Aviation Training Academy

Format: Onsite training in San Antonio; online courses for Tallahassee personnel

Sample Cost: Online class - $395/student; 2-day on-site course (classroom training, manuals & testing with live audit) - $5,000 + travel expenses (prices vary with number of students, location & session duration)

Benefits: Increased safety & readiness for annual FAA 139 audits

Some airports consequently contract outside specialists to train their auditors, making an investment in general safety, liability prevention and preparation for annual FAA inspections. Advisory Circular 150/5230-4B, available at, contains the latest list of FAA-approved trainers.

At San Antonio International Airport (SAT), fueling safety is the responsibility of the ARFF department. After its latest annual inspection in December 2012, the FAA suggested that the airport could benefit from additional training in how to inspect hazardous materials fueling systems.

"In an effort to expand our training, we went to an outside consultant, Aviation Training Academy," explains Fire Captain and ARFF Coordinator Georgia N. Rakowitz. The company conducted daylong, on-site sessions for three consecutive days to accommodate SAT's three different shifts. Instruction included both classroom presentations and hands-on training, and was scheduled in May, when most of the ARFF staff was present, notes Rakowitz.

"One of the main advantages we realized after the training was that our inspection forms will be redesigned so that all our inspectors will follow them easier," she relates. "The redesigned forms should add clarity to each step of the process, so there is less room for error." 

Online Approach

At the smaller Tallahassee Regional Airport (TLH), responsibility for fuel safety falls to the Operations Department, and the FAA strongly recommended that the agents in charge of its quarterly fuel inspections take fueling safety courses. Airport Operations Superintendent David Pollard chose operating agent David Smith to undergo training, because he previously worked several years at Million Air Tallahassee, the airport's primary fuel vendor, and already had an inherent knowledge of its fueling operations.

"The FAA wanted to ensure that whoever is doing the inspection is very knowledgeable," Smith says.

Because only two people on staff perform quarterly fuel inspections (Smith and fellow operations agent Haywood Kelly), Pollard also elected to take the fuel safety training. Like SAT, Pollard chose Aviation Training Academy to provide extra training; but he opted for online rather than on-site classes.

Pollard and Smith are each taking 16 hours of instruction via computer. "These online courses have been very useful," Smith reports, noting that each section of material is followed by a quiz and ultimately a final exam at the end. He considers the courses comprehensive enough to train new employees about fuel farm and equipment inspections - even those unfamiliar with aviation fueling practices.

"Now, when we observe Million Air Tallahassee fueling, we don't assume they are doing everything correctly. We can accurately evaluate them," Smith explains. "They are very good at checking fuel quality standards, inspecting tanks for leakage, etc. And if there is a problem, I am sure we will work it out. There are only five trucks in operation, and well more than 50,000 gallons in storage. We should be able to monitor it."

One of the courses, Preparing for a 14 CFR Part 139 Audit, is particularly timely for TLH. "Our next FAA inspection is coming up, so I am confident that if there are any problems, we will be able to work them out before the audit," says Smith. "The course actually walks you through an inspection of fuel farm facilities and refueling trucks. It gives auditors a very good idea of what an FAA inspector will be looking for, and provides a clear outline of NFPA 407 standards."

In addition to inspecting Million Air Tallahassee's fueling operations, THL also audits mobile refueling equipment that comes to the field with helicopter operators contracted by the U.S. Forest Service to help fight wildfires. Experience has taught Smith to have a copy of the NFPA 407 guidelines with him for such inspections.

"They bring their own fueling equipment with them," he notes. "Often, they are confused between DOT and FAA standards for placarding ... so we show them the regulations."

Common Mistakes

While TLH inspects fueling vehicles that support firefighting helicopters, other airports face their own field-specific challenges. Despite these differences, the staff at Aviation Training Academy has detected widespread mistakes that often transcend location.

Walter Chartrand, a company partner who has been training fueling agents for more than 30 years, highlights improper testing of braking procedures as one of the most common: "Mobile fuel trucks have a brake interlock," he explains. "When I remove the nozzle, the brakes are supposed to set, and the truck can't move up ... We show (auditors) how to do it properly."

Another big problem is complacency. "Fire extinguishers should be near the exit point, unobstructed, and in the path of the emergency fuel shutoff switch," Chartrand adds. "I have noticed that they are often hidden away out of sight, which is definitely a violation."

A third widespread error is improper inspection of the continuity bonding cables and connections to fuel trucks. Each fuel truck is required to have a bonding cable connected to the frame of the truck, with less than 25 ohms of electrical resistance. This is often neglected, he notes.

Overall, Chartrand advises airport executives to be proactive in evaluating fuel safety procedures: "It's imperative that you make sure your fuel auditors are properly trained for the quarterly inspections, so that when the FAA annual certification inspection is held, you will already be compliant."

Fuel Operations

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