Airport ramp damage and ground handling incidents remain a significant and costly category of loss within commercial aviation. Low speed collisions involving aircraft, airside vehicles and ground support equipment on the apron can give rise to substantial repair costs, operational disruption and, not infrequently, complex disputes as to legal liability. Against that background, on 27 March 2026, the UK Civil Aviation Authority (‘CAA’) launched a consultation on a proposed update to CAP 790, the guidance governing UK Airside Driving Permit (‘ADP’) schemes.
Ramp incidents: a persistent risk profile
Modern airport operations rely on specialised ground support vehicles and equipment to service, manoeuvre, and support aircraft during turnaround. Many of these vehicles have restricted sightlines, articulated arms, or elevated working platforms. Typically, they are operated in confined spaces around aircraft and in congested stand environments. In those conditions, driver competence, operational familiarity, and effective supervision are critical to reducing the risk of incidents arising, for example, due to misjudged clearance or unintended contact with aircraft fuselage or other equipment. According to the International Air Transport Association (‘IATA’), ground damage costs exceed US$4.5 billion annually and may rise to US$9.7 billion over the next 15 years in the absence of corrective measures.[1] A total of 29,608 aircraft damage events were reported under IATA’s Incident Damage Exchange (‘IDX’) programme by 188 operators between 2024 and 2025 in which the cause of damage was identified as passenger stairs, belt loaders or high-loaders.[2] Ramp damage is frequently the result of multiple contributory factors rather than a single act or omission. Common causal factors identified in incident investigations include poor distance judgement, inadequate vehicle specific training, communication failures between drivers and flight crew or headset operatives, and the gradual erosion of airside driving standards, over time. From an insurance and liability perspective, this risk profile is complicated further by the multi party nature of apron operations. Aircraft operators, ground handling agents, aerodrome operators, and equipment providers may all have some degree of involvement, giving rise to disputes over responsibility, contractual allocation of risk and the adequacy of safety oversight arrangements.
CAP 790: background and consultation context
CAP 790 (Civil Aviation Authority, CAP 790: Requirement for an Airside Driving Permit (ADP) Scheme) was issued on 29 February 2012 and remains at Version 1, with no amendment history or later revision dates recorded on the CAA publications website.[3] It applies, in broad terms, to most commercially operated airports, but not to smaller aerodromes operating solely under visual flight rules. Its stated objective is ‘to set out requirements for a scheme designed to minimise the risk of accidents and injury to individuals, and damage to aircraft and property, arising from the use of vehicles in airside areas’. [4] CAP publications are guidance documents, not primary or secondary legislation. However, they typically represent the view of the CAA in terms of industry best practice. The CAA formally opened its consultation on proposed amendments to CAP 790 on 27 March 2026, with the consultation closing on 8 May 2026.[5] Responses were invited from aerodrome operators, ground handling organisations, training providers, and other airside stakeholders, to ensure the revised ADP framework remains, “effective, proportionate and aligned with current operational practices and safety expectations’.[6]
The proposed amendments are set out in the CAA’s Citizen Space consultation materials, supported by a SkyWise alert.[7] The April 2026 draft reorganises existing material and introduces structural changes, with the result that it does not map directly onto CAP 790 Version 1. At this stage, the draft remains indicative only and has no formal status until a revised CAP 790 (Version 2) is published. It is against that background that the key features of the proposed amendments are considered in this article.
From administrative control to active risk management
The April 2026 draft introduces a series of substantive amendments which, taken together, strengthen and consolidate the ADP framework. In its consultation materials, the CAA has made clear that the objective is not to introduce a new regulatory regime, but rather to improve the operation and effectiveness of existing schemes. The proposed changes place less weight on the one off grant of an Airside Driving Permit. Instead, the draft focuses on the ongoing management of airside driving risk in practice.
Where automation sits in the framework
CAP 790 does not apply to autonomous or semi autonomous airside vehicles. That exclusion is deliberate: CAP 790 is concerned with risk arising from human-operated vehicles. The growing use of automated and semi-automated ground support vehicles raises a distinct set of issues around safety, assurance and accountability that falls outside the scope of CAP 790.
Clarifying roles and responsibilities
A notable feature of the draft is its clearer articulation of responsibility between aerodrome operators, employers, and drivers. Aerodrome operators are expected to exercise more active oversight of ADP arrangements, including the standards applied by third party training and assessment providers. Employers are expected to take clear responsibility for the competence and conduct of their personnel. Drivers themselves are reminded that holding an ADP carries personal responsibility as well as operational privilege. From a liability perspective, this is likely to be of material significance. Post incident disputes frequently turn on questions of control and supervision. Clarity as regards areas of responsibility may reduce the scope for ambiguity when assessing where responsibility lay and whether reasonable steps were taken to manage foreseeable risk.
Competence, training and revalidation
The consultation places renewed emphasis on competence as an ongoing requirement, rather than assessment at the point at which a permit is granted. The draft encourages a structured approach to refresher training and reassessment, particularly for drivers who operate infrequently, perform specialist tasks, or use complex ground support equipment. This reflects established patterns in ground damage claims, where incidents often involve experienced personnel operating beyond the limits of recent familiarity. From an underwriting perspective, how effectively an organisation maintains and reviews competence may serve as a useful indicator of risk.
Communication and human factors
Communication failures remain a recurrent contributory factor in ramp incidents. The proposed update clarifies expectations around radiotelephony competence and language proficiency where those skills are safety critical. In practical terms, this may influence liability assessments where miscommunication is said to have contributed to an incident, particularly in congested or time pressured operating environments.
Records, audit and evidential clarity
A further theme of the proposed update is the emphasis placed on record keeping and audit. The draft underscores the importance of maintaining comprehensive audit trails relating to training, authorisation, and revalidation, including where those functions are delivered through third party providers. For claims practitioners, this is likely to be welcome. Incomplete or poorly maintained records frequently complicate claim investigations and introduce evidential uncertainty. Improved documentation standards should make it easier to establish whether regulatory expectations have been met and, where they were not, where deficiencies lie.
Runway incursion prevention and GAPPRI alignment
The Global Action Plan for the Prevention of Runway Incursions (‘GAPPRI’) is an initiative led by the International Civil Aviation Organisation (‘ICAO’), aimed at reducing runway incursions through coordinated action on training, procedures, communications, and situational awareness.[8] The April 2026 draft embeds GAPPRI principles, explicitly. The proposed amendments promote entry onto runways facing oncoming traffic where practicable, improved visual checks prior to runway entry and enhanced awareness of the operational environment. The draft includes an expanded categorisation of common incursion types alongside clearer articulation of preventative measures. Taken together, the proposed changes reflect an increasing focus on runway risk.
Implications for insurers and claims practitioners
Although CAP 790 constitutes guidance rather than legislation, it carries significant weight as an expression of regulatory expectation. It is likely to inform how claims handlers, lawyers, courts, tribunals, and insurers assess reasonableness in the context of ramp incidents. For aviation underwriters, alignment by insureds with the revised CAA guidance may serve as a useful indicator when assessing exposure to ramp risk, particularly where there is a history of ground damage claims. For claims handlers, the updated framework is likely to sharpen scrutiny of competence management, supervision and record keeping when evaluating liability and recovery prospects.
What next?
The consultation closed on 8 May 2026. The output of the consultation will be taken into consideration by the CAA and a Comment Response Document (‘CRD’) will be published. The consultation materials do not specify a fixed implementation date for a revised CAP 790. The process may take several months, with final publication likely to be later in 2026.
Conclusion
The proposed updates to CAP 790 reflect a recognition that ramp incidents constitute a controllable risk. For legal and insurance practitioners, the consultation signals a re-setting of expectations rather than a wholesale change of approach. In its revised form, CAP 790 is likely to play an increasingly prominent role in shaping both safety outcomes on the ramp and the legal analysis of airport ground damage claims when incidents arise.
[1] International Air Transport Association, IATA Annual Safety Report – 2025.
[2] IATA, Incident Data Exchange (IDX) Summary Data 2024–2025 (IATA).
[3] Civil Aviation Authority, CAP 790: Requirement for an Airside Driving Permit (ADP) Scheme (CAA, 2012).
[4] Ibid
[5] Civil Aviation Authority, Consultation on Proposed Amendments to CAP 790 (CAA, 27 March 2026).
[6] Ibid.
[7] Civil Aviation Authority, Update to CAP 790 (Citizen Space, 2026) and Civil Aviation Authority, SkyWise Alert SW2026/090 (2 April 2026).
[8] International Civil Aviation Organization, Global Action Plan for the Prevention of Runway Incursions: Part I and II (ICAO, August 2024).
