Nov. 25, 2020
Small UAS present risk factors that encompass both aviation and non-aviation hazards. While UAS are regulated as aircraft and must adhere to rules that govern safe operations in the airspace used by other aircraft, they are operated in ways and at locations that create challenges and risks over and above typical aircraft operations.
In broad terms, operators of UAS and users of UAS services should consider the risks presented by:
- The relatively low barrier to entry established by regulators and ease with which UAS can be purchased, creating the temptation for rapid adoption
- Flights often taking place in close proximity to people on the ground, property and critical infrastructure
- Use of aircraft that have not been certified by any entity other than the original equipment manufacturer (OEM)
- Concerns around privacy
Regulations and Access to Hardware
Regulations to govern the use of UAS have been in place in the United States and across the world since the mid-2010s. In general, regulators have attempted to control the areas and airspace where UAS may operate and the licensing for those operating or piloting them. In the U.S., the regulations restrict the overall weight of the aircraft and payload to 55 lbs. Rules also exist to limit hours of operation and require that the operator maintain visual line of sight to the aircraft at all times.
While regulations exist, the framework for broad adoption has been created and companies across numerous industry sectors have begun using their own UAS, as well as contracting external service providers.
The relatively low regulatory constraints for commercial drone users means that entities need to establish their own internal protocols to ensure a reasonable level of safety. There are considerable resources available to help establish solid, baseline risk management practices. Those preparing to use their own UAS or hire external support should take the time to assess the risks and put in place measures suited to their individual operations that go well beyond the minimum regulatory requirements in their jurisdiction.
In addition to the permissive regulatory framework for the operation of small UAS, it is also easy for entities to purchase aircraft and begin flying. While manufacturers of higher-end equipment generally provide advanced training and comprehensive after-sales support, less expensive, prosumer level UAS are generally less well supported. Furthermore, while many systems promise safety features to help prevent accidents, operators must exercise caution by preparing and planning for the potential failure of hardware, software or communication links.
Flights Taking Place in Proximity to People and Property on the Ground
Unlike traditional aircraft, small UAS are partly able to achieve their utility by operating close to the target of their mission. This applies whether the flight involves collecting data from a fixed asset such as an overhead power line or close up shots on a movie set.
Any set of operating procedures must contain provisions for maintaining additional operational safety in these situations and ensure emergency procedures are in place to protect people and property.
Risks Associated with Uncertified Aircraft
All onboard-piloted aircraft used around the world today have been through type certification, a rigorous initial design certification process by the FAA and other regulatory bodies. Each aircraft is issued an airworthiness certificate in which the aircraft must be operated and inspected in accordance with its original type design. The Type Certificate Data Sheet (TCDS) is published for each aircraft model approved by the FAA. This TCDS outlines specific information about the performance of the aircraft, type of fuel used and equipment that is approved to be installed on the aircraft. Furthermore, each aircraft is subject to required periodic maintenance and inspections. When accidents happen and are investigated, lessons are learned and regulators often change criteria for maintenance or inspection compliance, and may require an airworthiness directive be issued that requires mandatory compliance. This may lead to a change in equipment or design of the aircraft all helping to maintain a high standard of safety.
Small UAS in use today are not subjected to the same processes for design certification and associated maintenance and inspection requirements. As such, it is incumbent upon the individual operators to ensure that aircraft are properly maintained, parts are replaced at set intervals and routine inspections take place to make sure that all equipment is in good working order.
While many manufacturers provide assistance, the ultimate responsibility lies with the operator and their good judgement.
The safe and sustainable growth of small UAS use is dependent partly upon operators flying responsibly as well as safely. This involves being cautious and courteous around private property and public spaces. UAS are still considered new technology and draw attention from bystanders when they are flying. Operators should ensure that the neighborhood in which they are operating is aware of their presence and then maintain a sterile cockpit to avoid any unnecessary distractions.
Overview of Mitigation Measures
Safety mitigation measures will require adaptation depending upon individual business purpose and flight profile. That said, whether flights are taking place in a rural environment or in close proximity to people and property, the following items should be addressed, at a minimum, when building procedures for safe operation:
- Choice of hardware appropriate to the task
- Ways to ensure regulatory compliance at all times
- Processes for hiring and training operators for operational proficiency well beyond the requirements of minimums established by regulatory authorities
- Establishment of a proactive maintenance program
- Procedures to manage active crew operations, including effective communications
- Methods of respecting privacy minimizing nuisance to the public
- Emergency procedures
These principles apply equally to organizations operating their own aircraft, as well as to those hiring external drone services.
There is no shortage of support for establishing and maintaining an appropriately risk-managed UAS flight department. Invite help where needed. Drone companies and individual operators are professional aviators and should endeavor to approach each mission as if the CEO was a passenger.