Now that you have established that an Operational Safety Case (OSC) would be of benefit to your organisation, the next stage is accepting that to build an effective safety case you need to comprehensively understand how you approach safety and determine what organisational safety culture is in place.
What is a Safety Case?
There are a number of definitions in the aviation industry but essentially, a safety case can be accurately described as ‘a coherent safety argument, underpinned by a body of evidence’. To build that argument and generate all of the evidence required, you need to understand how you currently tackle safety so that you can determine whether it is enough to achieve what you request on your OSC submission. One of the fundamental requirements of an OSC application is a Safety Assessment within Volume 3. This is a self-assessment process and the only effective way to faithfully represent this is by truly understanding the safety components in your operation, outlining where the weaknesses lie and how you go about addressing them.
The Safety Reality for PfCo Holders
Whilst it is not the case for all, it is a reality that for a number of PfCO holders, once initial issue is achieved, the subject of safety seems to become peripheral. Risk assessments are completed but not acted upon, reporting is not conducted because ‘well, nobody saw that’, and safety limits are relaxed because, ‘we are approved by the CAA right?’ In the day to day struggle to make a drone business work, this is a human condition that is perhaps understandable, however wrong it is.
Safety cannot be a peripheral activity in a drone operators day to day operations, it must be the core around which everything else revolves, not just a non-revenue generating function that must be performed in the background because that is what is expected. The pursuit of excellence in safety should be thought of as a business continuity activity, one that will reduce the chances of a catastrophic event which will bring the organisation to its knees and make you more resilient.
Conduct a Safety Audit
The only way to baseline your safety culture is to conduct an in-depth analysis on your organisation. This doesn’t need to be done independently, it can be done ‘in-house’, but you do need to be honest and document all of your findings. When operations allow, et aside a couple of days, find an appropriate space, include everyone in the company and leave no stone unturned.
Be prepared, because introspection of this nature often discovers some uncomfortable truths. They may not be intentional, but might simply have slipped simply because of the pace of commercial life. Look for patterns of behaviour which are obvious and some that are not. It might be that the safety procedures you implemented at the start of your operation have eroded gradually because of the pace of commercial activity or that a single compromise on a specific point may have turned into a systemic failure that built over a period of time.
In the audit, you will need to ask yourself some representative questions, such as:
- How diligent is your safety culture?
- Do we encourage a culture of safety throughout the organisation?
- Do we identify where safety issues may lie and address them through positive action?
- Do we document our safety management process as per the Operations Manual?
- Do we report incidents and accidents responsibly as per the Operations Manual?
- What are our key areas of improvement?
For some of those questions, the answer may seem unpalatable. For others, you are likely to discover areas which require only slight improvement but, whatever the outcome, you will need to accept the findings and implement change to rectify them before you submit an OSC. The CAA are both experienced and diligent in reviewing OSC submissions and consequently, understanding the safety culture of the applicant organisation. They will see through smoke and mirrors, so please don’t attempt to present a more comprehensive safety culture than that which exists currently in your organisation.
An audit will also generate a documented trail of self-examination, useful for the provision of evidence during the OSC application. This is critical for meeting the ‘Claim, Argument, Evidence’ methodology requirement referenced in CAP722. Over time, this is also useful to demonstrate an embedded and established SMS which is required for regulatory oversight.
Whatever your current understanding of safety, if you intend to build an OSC then you will need to immerse yourself in your safety culture. Prepare for a journey of enlightenment, because, as onerous as it may seem, this path will bring new strengths and capabilities to your organisation and make it more resilient over time. In a marketplace where potential clients can afford to be choosy, the new currency of ‘safety’ is becoming increasingly relevant.
In Part 3, we will start to look at each of the Safety Components in an OSC, the People, the Platform and the Processes.
ClearSky Consulting has successfully advised numerous clients in OSC generation in the UK. If you would like to explore what they have to offer in this respect then email: [email protected]