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ARAC - ARFF Requirements Working Group. Airport Certification Issues Group Review of Final Report 14 CFR Part 139- Subpart D October 6, 2004. Airport Certification Issues Group.

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ARAC - ARFF Requirements Working Group

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ARAC - ARFF Requirements Working Group

Airport Certification Issues Group

Review of Final Report

14 CFR Part 139- Subpart D

October 6, 2004

Airport Certification Issues Group

  • Tasking:Review the existing ARFF Requirements in 14 CFR part 139, subpart D and identify requirements that should be added, modified, or deleted. This review shall include the current rule, other related FAA documents, and other recognized ARFF standards issued by other organizations. Federal Register / Volume 66, No 56 - March 22, 2001


  • As part of this project, ARAC should address the following issues:

    • Quantity of Agent & Number of Vehicles

    • Vehicle Response Times

    • Staffing Requirements

    • Airport ARFF IndexARAC Certification Issues - New Task - 3/14/01

ARFF Requirements Working Group

  • Members need not be ARAC members

  • Members appointed by the Working Group Chairpersons

  • Membership must be “balanced” with equal representation from opposing sides of the issues.

  • We also attempted to include airport geographic location and size to that balance.

ARFFRWG Members & Support

  • Ben Castellano - (FAA) ARAC Assistant Executive Director

  • Ian Redhead - (ACI) ARAC Assistant Chair, Airport Certification Issues Group

  • Jack Kreckie - (ARFFWG) Member/Co-Chair

  • Armen DerHohannesian (ADA-LLC) Member/Co-Chair

ARFFRWG Members & Support

  • Charles Burroughs (IAFF) Member

  • Mark Conroy (NFPA) Member

  • Tom Farrier (ATA) Member

  • Ken Gilliam FAA Representative

  • Don Hilderbrand (IAFC) Member

  • Captain Shannon Jipsen (IPA) Member

  • Kathy Lord-Jones (Aviation Cabin Safety Specialists Inc)

ARFFRWG Members & Support

  • Dawn Lucini (ACI-NA) Member

  • Les Omans (San Jose Fire Dept) Member

  • Bill Pahuta (Charlottesville Albermarle Airport, VA) Member

  • Brad Penrod (Pittsburgh Int.) Member

  • Pam Phillips (PANYNJ) Member

  • Captain Tom Phillips (ALPA) Member

ARFFRWG Members & Support

  • Jeff Vitti (Sacramento Fire Department)

  • Craig Williams (AAAE) Member

  • Keith Baggot (FAA R&D) Technical Support

Mission Statement

  • “To reasonably and responsibly recommend ARFF standards, which provide for the safety and welfare of the travelling public, the aviation community and emergency responders. Secondarily, to make recommendations to the ARAC Airport Certification Issues Group, as necessary to maximize the ARFF effectiveness of 14 CFR FAR Part 139.”

Work Plan

  • ARAC Working Groups are required to submit a “Work Plan” in compliance with FAA procedures described in “Operating Procedures for the ARAC” (Green Book).

  • The ARFFRWG “Work Plan” was submitted and approved in April of 2002. This approval served as our “Notice to Proceed”.

Historic Perspective

Task Groups

  • 139.303 - ARFF Staffing

    • Task Group Leader - Brad Penrod

    • Chuck Burroughs, Dawn Lucini, Bill Pahuta

  • 139.315 - ARFF Index Determination

    • Task Group Leader - Craig Williams

    • Shannon Jipsen, Tom Phillips, Jeff Vitti

Task Groups

  • 139.317 - Number of Vehicles, Quantities of Agent

    • Task Group Leader - Pam Phillips

    • Mark Conroy, Jack Kreckie, Les Omans

  • 139.319 - ARFF Response Times

    • Task Group Leader - Tom Farrier

    • Armen DerHohannesian, Don Hilderbrand, Kathy Lord Jones


  • Total of 12 formal meetings, followed by 3 conference call meetings of the ARFFRWG. These meetings were hosted by:

  • ACI-NA Washington, DC

  • AAAE Washington, DC

  • GOAA - Orlando ARFF


  • Pittsburgh International Airport

  • Boston-Logan International Airport

  • MWAA-Reagan National Airport

  • DFW International Airport

  • Phoenix Sky Harbor International Airport

    • Portions of these meetings were sponsored by, ALPA, ADA-LLC and the IPA.

Interactive Research Sessions

  • Orlando International Airport ARFF

  • Pittsburgh International Airport ARFF

  • Boston-Logan International Airport ARFF

Informational Briefings

  • Derivation of airport revenue / funding alternatives and administrative approach to operational & maintenance issues.

  • NTSB perspective of aviation safety

  • History & background of aircraft extinguishing agents.

  • NFPA 403 - NFPA 1710


  • Final Report

  • Meeting Minutes

  • Related Recommendations, outside the context of Part 139

  • Draft Advisory Circular - ARFF Staffing Task Analysis

  • Bibliography

ARAC Process

  • The recommendations to satisfy the tasking by ARAC, were submitted to Ian Redhead, Chairman of the Issues Group 2/14/04

  • The Airport Certification Issues Group will review the document to determine if the task has been satisfied.

  • If approved, the Issues Group submits the document to the full ARAC Committee.


  • 68% of this document is devoted to the Preamble.

  • The Preamble serves as a foundation for discussion of background information and data. Subsequently this research effort was used to assist in the development of regulatory language, the objective of which was to satisfy the task assigned by ARAC.

139.303 - ARFF Personnel

  • Preamble - There was NO reference to minimum ARFF staffing required by Index in the original 139 document.

    • Role of ARFF Personnel

    • Sufficient Personnel

      • ARFF Training was moved from .319 to .303

139.303 Regulatory Language

  • Consensus

    • The Working Group reached “General Consensus” on the use of a Staffing Analysis to evaluate ARFF Staffing Levels.

    • There were 2 opinions on how best to determine the minimum required level to perform those tasks identified within the specified time objectives.

Option 1-Minimum ARFF Staffing & Staffing Task Analysis

Cat 1 - 3 *

Cat 4 - 3 personnel - A

Cat 5 - 6 personnel - A

Cat 6 - 9 personnel - B

Cat 7 - 12 personnel - C

Cat 8 - 12 personnel - D

Cat 9 - 15 personnel - E

Cat 10 - 15 personnel

139.303 Regulatory Language

139.303 Regulatory Language

  • Option 1 - Additionally, a Staffing Task Analysis will be performed to determine additional staffing requirements. The analysis is based on a worst case accident/incident. The analysis shall be supported by a risk assessment which examines risk to aircraft occupants.

139.303 Regulatory Language

  • Option 1 - .303 includes items to be used to determine the basic contents of the staffing task analysis.

  • A DRAFT Advisory Circular, “ARFF Staffing Task Analysis” was developed (and submitted) by the task group as suggested guidance for conducting a task analysis.

139.303 Regulatory Language

  • Option 2 - A staffing task analysis is the sole method used to determine minimum ARFF personnel required.

Description / Airport

ARFF Category

Response Criteria

Aircraft Operations

Operational Hours

ARFF Services Structure

Level of Personnel

Level of Supervisors

ARFF Competence

Extraneous Duties of ARFF Services

Alerting Systems

ARFF Vehicles

Extinguishing Agents

Special Equipment

139.303 Regulatory LanguageItems Used to Determine Contents of Staffing Analysis

139.303 Regulatory LanguageItems Used to Determine Contents of Staffing Analysis

  • Medical Facilities

  • Pre-Determined Attendance

  • Other ARFF Staffing Sources

  • Incident Task Analysis

139.303 Regulatory LanguageStaffing Task Analysis

  • Results shall be recorded with the following information

    • Time Objectives, Starts with initial response time, ends with all required tasks initiated.

    • Listing of all tasks & Priorities

    • Resources, Personnel & Equipment required for each task

    • Comments, Explanatory Information

139.303 Regulatory LanguageStaffing Task Analysis

  • In either Option 1 or 2, each Certificated Airport’s Staffing Analysis Will Be Subject to the Approval of the FAA and Shall Be Included in the Airport’s Certification Manual.

139.303 Training (relocated from .319)

  • All ARFF personnel shall be properly trained to perform their duties. Such personnel shall be trained PRIOR to performance of Rescue & Firefighting duties. The Training curriculum shall include initial and recurrent training in at least the following areas:

139.303 Training

  • Practical ARFF Driving Operations

  • SCBA

  • Evidence Preservation

  • Incident Command

139.303 Training

  • All ARFF Personnel shall participate in recurrent training on at least a monthly basis. All required topics shall be addressed at least every 12 months.

  • All ARFF Personnel shall be trained to and maintain certification in the U.S. Department of Transportation’s First Responder: National Standard Curriculum

139.315 – ARFF Index Determination


  • Harmonizing w/ICAO Airport Categorization

  • Aircraft Width + Fire Protection

  • Air Cargo Aircraft

  • ARFF Index Remission

139.315 – ARFF Index Determination


  • Full Consensus on harmonization with ICAO’s Categorization

  • No Consensus regarding Remission although a majority favored eliminating it.

139.315 – ARFF Index Determination


  • Category Determination - Largest Air Carrier Serving the Airport.

  • Proposed Airport Categories (Table 2)



Recommended Categories


Length (ft.)

*indicates up to but not including.

Width up to

but not










































Table 2 Airport Categories

139.317 ARFF Equipment & Agents

  • Agents - Preamble

    • Primary Agent, 3% or 6% AFFF Mil Spec Foam #MIL F-24385, QPL Listed

    • Complementary Agents, Potassium Bicarbonate or Potassium Bicarbomate Dry Chemical.

    • Clean Steaming Agents currently approved are Halotron and Halon 1211

139.317 Quantity of Agents

  • Consensus: Unanimous agreement that the current quantities were not appropriate for current times.

  • A majority of the WG agreed that NFPA quantities were appropriate while a dissenting opinion concluded that ICAO quantities with the 1000 gallons added back were appropriate.

139.317 Quantity of Agents

  • There was also full consensus by the WG that the additional hazards of the ever increasing second level passenger deck of the B-747 have been neglected over the years.

Table 3 – Minimum Extinguishing Agent Quantities and Discharge RatesNote: Categories 1-3 fall outside the applicability of this Part. (* = GA)

139.317 ARFF Equipment & Agents

  • ARFF Vehicles - Preamble

    • Number of Vehicles - Tactical considerations

    • Capacity with regard to agent, personnel, equipment.

    • Equipment loading / performance issues

    • Vehicles out of service / maintenance, repairs, damage.

139.317 ARFF Equipment & Agents

  • Rescue & Fire-Fighting Vehicles Consensus

    • The majority of the ARFFRWG felt that the NFPA recommended number of vehicle were appropriate; a minority felt that ICAO number of trucks required were appropriate.

    • The number of trucks required is directly related to required agent quantities as well as to enhance operational flexibility.

139.317 ARFF Equipment & Agents

  • Rescue & Fire-Fighting Vehicles

    • Minimum Required ARFF Vehicles per Category Described in Table 4

      • Maintaining Minimum Number of Vehicles: Numbers of vehicles in Table 4 shall be met at all times with the ability to have the largest vehicle Out of Service.

      • All foam producing vehicles to be tested at least semi-annually, Complimentary Systems Annually.

Table 4 – Minimum Required ARFF Vehicles per Airport CategoryNote: Categories 1-3 fall outside the applicability of this Part.

139.319 – Operational Requirements


  • ARFF response times

  • Pre-positioning of ARFF Equipment

  • ARFF response location

  • Protective Clothing + Personal Equipment

139.319 – Operational Requirements


  • Full Consensus for Pre-positioning of ARFF vehicles

  • General Consensus for Response time and location

  • No Consensus for Protective Clothing + Personal Equipment – majority for using NFPA standards

139.319 – Operational Requirements


  • Response Requirements for timed drills

  • Pre-positioning of ARFF Vehicles

  • Response Time Objectives

  • Protective Clothing + Personal Equipment

139.325 - Airport Emergency Plan

  • Change-Hold a full scale emergency plan exercise at least every 2 years.

  • Additional sections required to address new age threats.

    • WMD-NBC Threats

    • Security Threat Level Changes / Modified from Radiological Incidents

139.325 - Airport Emergency Plan

  • Consensus: There was no consensus on the issue. The majority felt that the “full scale emergency exercise” should be harmonized with ICAO and NFPA, which require full scale exercises every 2 years.

  • The minority held that changing the requirement to every 2 years poses a financial and organizational burden on the airport as well as other resources that play a part in a full scale emergency response.

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