Picture this: A Part 139 inspector arrives at your airport. Your operations team runs daily runway checks without fail. Your maintenance crews know the FOD walk routine cold. The inspector asks for your documented risk assessment, your named FOD manager, and 90 days of trend analysis records. The room goes quiet.
That silence is the gap. A functioning FOD program and an auditable one are not the same thing. The FAA released an updated AC 150/5210-24A in February 2024. EASA has also formalized FOD control as a regulatory requirement for certified aerodromes. The bar has moved. Airport managers who rely on institutional habits instead of documented systems are increasingly exposed.
If you need a refresher on the underlying rules — inspection frequencies, training, and recordkeeping under §139.327 — start with our breakdown of what Part 139 self-inspection compliance really requires. This guide assumes those basics and focuses on the next step: the internal airport FOD program audit every safety director should run before external auditors do it for them.
What FAA Auditors Are Actually Checking
An audit isn’t about whether you sweep the runway. It’s about whether you can prove your program works. AC 150/5210-24A’s four-pillar model — prevention, detection, removal, and evaluation — is where inspectors start, and the fourth pillar is where most programs quietly fail. Teams cover prevention, detection, and removal well. Evaluation — the documented proof that data drives decisions — is the gap.
The stakes are sharper than many programs assume. For AIP- or PFC-funded airports, AC compliance is mandatory, not advisory, and grant recipients draw extra scrutiny. So when an inspector conducts an airport FOD program audit, they look for specific, retrievable evidence:
- A designated FOD program manager with documented authority and written responsibilities — not just an informal role someone holds
- Retrievable inspection records covering daily movement area checks, construction zone reviews, and post-event follow-ups
- A formal FOD risk assessment, particularly for SMS-required airports under Part 139 Subpart E
- Documented trend analysis showing that FOD occurrence data actually drove program changes
- Corrective action records with closure timelines for identified hazards
These are not obscure requirements. Nevertheless, they’re precisely where programs built on operational habit rather than documented systems tend to collapse under a formal review.
Where Most Airport FOD Programs Have Undetected Gaps
FOD costs the global aviation industry an estimated $4 billion per year in direct aircraft and engine damage. Delays, cancellations, and indirect operational costs push that figure to $22.7 billion annually, according to FAA cost-benefit analysis data. Despite those numbers, many programs haven’t run a formal review against current standards in years.
The most common gaps cluster in the same places. Documentation is usually the sharpest failure point: inspection logs exist, but they’re inconsistent, incomplete, or not centrally retrievable. Risk assessments are often absent or undocumented — someone knows where the high-risk zones are, but no one has committed it to paper. And many programs still run on the canceled 2010 AC rather than the February 2024 update.
Additionally, many airports have established solid aviation FOD prevention practices. Even so, they often lack formal training records or haven’t mapped FOD responsibilities across tenant organizations. Ground handlers, airlines, and maintenance contractors should each carry explicit, written obligations tied back to the airport’s program. Under the current FAA and EASA frameworks, that coordination gap is a compliance gap.
Why EASA Is Raising the Bar for Certified Aerodromes
For airports operating under EASA oversight, the regulatory picture has tightened considerably. ADR.OPS.B.016 now requires certified aerodromes to establish a formal FOD control programme. This programme must be documented in the aerodrome manual and fully integrated into SMS safety assurance processes.
Critically, EASA extends the compliance obligation beyond the aerodrome operator itself. Ground handling organisations must adhere to the FOD programme and train their personnel accordingly. Competent authority oversight will therefore examine both the programme document and verifiable evidence of cross-organization coordination. New EU Ground Handling Regulations, fully applicable by March 2028, make this even more concrete.
For U.S. airports with international operations, the convergence of FAA and EASA expectations signals where the industry is heading. Both regulators are moving toward structured, auditable programs — not informal practices that happen to produce good outcomes.
Running Your Internal Airport FOD Program Audit
An internal audit, run before external scrutiny, is the most cost-effective way to close gaps on your own terms. Here’s a practical framework.
- Document review against AC 150/5210-24A (2024). Compare your current program line-by-line against the February 2024 standard. Flag any sections referencing the 2010 version or missing the evaluation component.
- Inspection records pull. Retrieve 90 days of inspection logs. Check for consistency, completeness, and whether the team has separately documented post-event inspections versus routine checks.
- Risk assessment verification. Confirm a current, documented FOD risk assessment exists. For SMS airports, verify it integrates with your Safety Risk Management documentation.
- Trend analysis gap check. Review whether the team has actually used FOD occurrence data to identify hotspots, measure removal effectiveness, or adjust inspection frequency. Absence of this documentation ranks among the most commonly cited audit findings.
- Stakeholder responsibility mapping. Document the FOD obligations of every organization operating in your movement area — airlines, ground handlers, maintenance contractors, and construction crews.
Once gaps are identified, prioritize by audit risk. Ask which findings are most likely to generate a regulatory action — and which can close quickly. A well-documented FOD program structure makes both the audit and the remediation process significantly faster.
From Audit-Ready to Program-Strong
The airports that handle inspections best aren’t the ones with perfect programs. They’re the ones with programs that are well-documented, continuously evaluated, and clearly owned at every level. An audit, consequently, doesn’t have to be a compliance burden. Instead, it can be the forcing function that transforms a reactive FOD program into a measurable, defensible safety asset.
If your program needs an expert-led review against current FAA standards, FOD Control’s flightline assessment service can help. It delivers a structured evaluation of your airport’s FOD management practices against AC 150/5210-24A. Combined with operational capability like the FOD-Razor® friction sweeper, a documented program gives your airport both the removal performance and the compliance record that modern regulatory expectations require.
Key Takeaways
- FAA AC 150/5210-24A (February 2024) is the current standard — programs built on the 2010 version need updating now
- An airport FOD program audit examines four pillars: prevention, detection, removal, and evaluation — the evaluation layer is where most programs have undocumented gaps
- For AIP- and PFC-funded airports, AC 150/5210-24A compliance is mandatory, not advisory
- EASA ADR.OPS.B.016 requires certified aerodromes to maintain a formal, documented FOD control programme with SMS integration and verified ground handler coordination
- An internal audit run before regulatory scrutiny is the most cost-effective path to closing gaps and turning compliance pressure into program improvement
Ready to assess your airport’s FOD program against current FAA standards? Contact FOD Control to schedule a flightline assessment. Or download the free FOD Prevention Booklet to start your internal review today.
