Aviation Safety depends on Data
UAS operators not as likely to meet SMS process needs
Aviation Safety Reporting System will create useful numbers
It is great news that the FAA is permitting UAS operators to utilize the NASA Aviation Safety Reporting System.
Over the past 20 years, aviation safety has changed its perspective. Previously change came primarily AFTER a major accident (a practice that A. Mary Schiavo coined as “tombstone regulation”). Following the recommendations of ICAO, the FAA senior management instituted a state-of-art discipline entitled Safety Management Systems (SMS). This is a data-driven methodology that depends on massive amounts of information flowing from the operators on a real time basis. The numbers are then statistically analyzed to detect trends and provide insights as to risks. Instead of retrospective actions, SMS is prospective in designing preventative solutions.
The initial step in this new regime was the NASA ASRS process. The information is submitted confidentially—by filing the individual receives a level of assurance that the FAA will not take enforcement action. This non-punitive approach to all information that flows through SMS.
The application of SMS to UAS operators has been endorsed by several credible organizations:
- · ICAO Safety Management System (SMS) for UAS Operators
- · NBAA Introduction to UAS Safety Management Systems | NBAA
- Flight Safety Foundation Safety Management Systems For UAS Operations
- Unmanned Aircraft Safety Team Recommendations for using Safety Management Systems (SMS) in UAS Operations
The average, ordinary UAS operator should read these guides and, true to SMS flexibility, can adjust the parameters to an individuals’ drone flights. A self-designed Flight Risk Assessment Tool should provide a good regimen. If the amateur drone flyer makes an inadvertent error, filing the ASRS form (see below) would be appropriate.
The greatest potential for learning about these innovative vehicles is IMMENSE.
These syllabuses provide the basics, but more may be required to create a functional SMS for a business enterprise. Greater duty of care is expected of commercial drone operators. The demand to
- meet deadlines,
- weather problems,
- level of skill for the pilots,
- precision of flight paths,
- hazards posed by structures and other nearby objects,
- 24 hour schedules,
- people on the ground,
- the value of the cargo and/or mission
—all increase the need to accurately determine the risk and that is what SMS is made to calculate and uses hard data from past operations. The go/no go decisions will have greater credibility when explaining to a valued customer why the operation was cancelled. Equally, insurance companies will get greater comfort from SMS quantified, preflight assessments in case of an accident.
Using the handbooks mentioned above may not be adequate for a large company using drones for their businesses. A first effort to balance your operations against this safety matrix is likely a learning experience with a possibility of some poor choices with consequences. The Safety Culture that is the goal of this effort is not limited to the Drone Ops team; credibility gained from experience is essential to spread this awareness throughout an organization, especially where the UAS is ancillary to the primary business.
Use of OUTSIDE HELP (click on this link) may be needed, may insure that the Safety Culture (click on this link) is both omnipresent and permanent and will assure that the practices, policies and paperwork.
The FAA has extended the Aviation Safety Reporting Program (ASRP) to UAS operators, including the protections offered through National Aeronautics and Space Administration’s (NASA) Aviation Safety Reporting System (ASRS). NASA’s ASRS has a reporting form tailored to the UAS community↓. This will ensure that the safety data that is collected will result in actionable information for the entire aviation community.
What does this mean for you?
The FAA’s ASRP enables a non-punitive avenue for anonymous reporting. If you file a report with NASA’s ASRS, the FAA considers this to be evidence of a constructive attitude. Therefore, even if a finding of a violation is made, a civil penalty or certificate suspension will not be imposed as long as:
- The violation was inadvertent and not deliberate;
- The violation did not involve a criminal offense, accident, or action under 49 U.S.C. § 44709, which discloses a lack of qualification or competency, which is wholly excluded from this policy;
- The person has not been found in any prior FAA enforcement action to have committed a violation of 49 U.S.C. subtitle VII, or any regulation promulgated there for a period of 5 years prior to the date of occurrence; and
- The person proves that, within 10 days after the violation, or date when the person became aware or should have been aware of the violation, he or she completed and delivered or mailed a written report of the incident or occurrence to NASA.
ASRS captures confidential reports, analyzes the resulting aviation safety data, and disseminates vital information to the aviation community. This system is completely confidential, voluntary, and non-punitive. Anyone can use this reporting system, including bystanders.
For more information read AC 00-46F – Aviation Safety Reporting Program.
- UAS Safety Reporting from NASA’s ASRS
- NASA’s ASRS: https://asrs.arc.nasa.gov/
- Report Safety Issues
- FAA UAS Support Center
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