Submitted:
16 October 2025
Posted:
17 October 2025
You are already at the latest version
Abstract
Keywords:
1. Introduction
1.1. Research Objective
2. Literature Review

| Source | Year | Scope | Measures | Bridges Part 139 + SMS? | Reason for fragmentation | Reference |
|---|---|---|---|---|---|---|
| FAA Final Rule: Airport SMS (14 CFR Part 139) | 2023 | U.S. airports (subset) | Mandates SMS, phased implementation | Not yet | Pre-2023 evidence mostly voluntary, no integrated outcomes dataset | [18] |
| FAA SMS site & AC150/5200-37A | 2023–2025 | Guidance for airports | Implementation guidance, FAQs, desk reference | No | Guidance focus, not outcomes evaluation | [18,19] |
| GAO-12-898 | 2012 | FAA enterprise | Recommends tracking SMS implementation and outcomes | No | FAA lacked systems to evaluate SMS effectiveness across units | [12] |
| GAO-14-516 | 2014 | FAA oversight planning | Calls for plan to oversee industry SMS | No | Uneven, non-generalizable data, need for guidance and training | [13] |
| GAO-20-642 | 2020 | FAA programs | Notes need for better SMS performance metrics | No | Shift to risk-based oversight complicates outcome measurement | [14] |
| DOT OIG ARFF oversight report | 2016 | Part 139 ARFF | Finds inconsistency in inspections and training oversight | No | Prescriptive stream had data quality issues, blocking linkage to SMS | [15] |
| ICAO Annex 19 and USOAP | 2013 | States worldwide | SSP and SMS requirements, State EI indicators | No (different level) | State-level indicators do not match FAA airport-level findings | [4,22] |
3. Materials and Methods
3.1. Dataset Selection
- FAA Part 139 inspection findings, which are publicly available through the FAA’s airport safety reporting system and document deficiencies identified during annual inspections [16].
- FAA Operations Network (OPSNET) data, which provides operational activity counts and is used to normalize inspection findings based on airport exposure, expressed as the number of operations per year [17]. OPSNET is the FAA’s Operations Network, the official database for air traffic operations and reportable delays; reportable delay denotes IFR delays of 15 minutes or more recorded by ATC facilities.
- ICAO Universal Safety Oversight Audit Programme (USOAP) Effective Implementation (EI) indicators, which quantify each State’s level of compliance with ICAO’s SMS requirements across the four foundational pillars of safety policy, risk management, safety assurance, and safety promotion [22].
- Bureau of Transportation Statistics (BTS) On-Time Performance Data, used to establish operational context and adjust for trafic exposure [1].
- National Oceanic and Atmospheric Administration (NOAA) Integrated Surface Database (ISD), which provides weather condition variables that may influence inspection finding rates [21].
3.2. Crosswalk Mapping
3.3. Analytical Procedures
- Descriptive analysis: Finding rates were calculated per 100,000 operations to identify baseline patterns and variation across airport classes.
- Gap analysis: A matrix comparison was constructed as part of the crosswalk framework (presented in Table 2) to highlight regulatory domains that are unique to either Part 139 or the ICAO SMS model.
- Regression modeling: Multivariate regression was used to test the association between ICAO Effective Implementation (EI) indicators, representing SMS maturity, and FAA inspection finding rates. The model controlled for traffic volume, airport size, and weather variability [9].
- Comparative assessment: Results from these analyses were synthesized to evaluate the relative advantages of each system, with prescriptive oversight emphasizing compliance assurance in high-risk areas and SMS providing adaptive strength through continuous monitoring and feedback.
3.4. Ethical Considerations

4. Results
4.1. Descriptive Statistics
4.2. Crosswalk Matrix: Part 139 vs ICAO SMS

4.3. Crosswalk Comparison Results
4.4. Regression and Statistical Findings
| Variable | Coefficient (β) | Standard Error | p-value | Interpretation |
|---|---|---|---|---|
| SMS Implementation (ICAO EI Score) | –0.245 | 0.072 | <0.01 | Higher SMS adoption is associated with fewer FAA inspection deficiencies |
| Airport Size (Class I vs Regional) | –0.180 | 0.065 | <0.05 | Larger airports show lower deficiency rates, controlling for exposure |
| Traffic Exposure (Operations per year, log) | 0.092 | 0.041 | <0.05 | Higher traffic correlates with more recorded deficiencies |
| Weather Conditions (Severe days/year) | 0.051 | 0.028 | 0.07 | Marginally significant; adverse weather increases deficiency likelihood |
| Constant | 1.320 | 0.410 | <0.01 | Baseline deficiency rate when predictors are at zero |

4.5. Summary of Key Results
5. Discussion
6. Proposed Framework
6.1. Core Principles of the Hybrid Framework
- Prescriptive Baseline Controls:
- 2.
- Performance-Based Enhancements:
- 3.
- Data-Driven Integration:
- 4.
- Organizational Safety Culture:
6.2. Framework Structure

- Layer 1: Prescriptive Oversight (Part 139)
- Layer 2: Performance-Based Oversight (ICAO SMS)
6.3. Decision Matrix for Application
- Runway pavement condition → Prescriptive
- Wildlife hazard management → Hybrid (inspection + predictive modeling)
- Fatigue risk management → Performance-based
6.4. Policy Implications
7. Conclusions
8. Patents
Author Contributions
Funding
Data Availability Statement
Acknowledgments
Conflicts of Interest
Abbreviations
| FAA | Federal Aviation Administration |
| ICAO | International Civil Aviation Organization |
| SMS | Safety Management System |
| ARFF | Aircraft Rescue and Firefighting |
| OPSNET | Operations Network |
| BTS | Bureau of Transportation Statistics |
| NOAA | National Oceanic and Atmospheric Administration |
| USOAP | Universal Safety Oversight Audit Programme |
| SSP | State Safety Programme |
| EI | Effective Implementation |
| IFR | Instrument Flight Rules |
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| Part 139 Checklist Element | ICAO SMS Pillar Alignment | Overlap / Strengths | Unique to Part 139 | Unique to ICAO SMS | Identified Gaps |
|---|---|---|---|---|---|
| ARFF readiness (staffing, training, equipment) | Safety Policy / Safety Assurance | Strong compliance oversight ensures readiness | Mandatory staffing and equipment levels | Promotion of safety culture and continuous competency training | Limited focus on safety promotion beyond compliance |
| Wildlife hazard management | Risk Management / Safety Assurance | Structured inspection and corrective action | Detailed programmatic requirements | Hazard identification and predictive assessment | Limited predictive analytics and reliance on observed deficiencies |
| Training requirements (Operations, Maintenance, ARFF) | Safety Promotion | Ensures baseline training compliance | Prescribed minimum training | Emphasis on safety culture and proactive promotion | Absence of focus on safety culture or behavioral change. |
| Emergency planning (drills, coordination) | Safety Policy / Risk Management | Coordination and readiness checks | Mandatory full-scale drills | Integration into SMS hazard-identification cycles. | Reactive orientation, not predictive hazard assessment. |
| Hazard Domain | Recommended Oversight Approach | Rationale |
|---|---|---|
| Runway pavement condition | Prescriptive | Requires strict compliance with technical standards (e.g., friction, surface integrity). |
| Wildlife hazard management | Hybrid | Combines on-site inspections with predictive modeling of wildlife activity patterns. |
| Fatigue risk management | Performance-based | Best addressed through continuous monitoring, reporting systems, and organizational safety culture. |
| ARFF readiness | Prescriptive | High-consequence hazard requiring mandatory staffing, equipment, and training. |
| Training and safety promotion | Performance-based | Focus on culture, proactive initiatives, and continuous improvement. |
| Emergency planning & drills | Hybrid | Mandated drills supported by SMS cycles of hazard identification and evaluation. |
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