Now that you thought about operational safety cases and audited your operation and have an understanding of the safety culture that exists within it, you will need to look at the components included in building a safety case.
The 3 safety components are People, Platform and Processes and in this 3rd article in the series, we will look at People, the human component in the safety argument.
It is natural to assume that people simply means the remote pilots in the operation, specifically those whose experience will help to mitigate any identified flying risk. That is correct, but it also encompasses support staff, such as a nominated Safety Manager (if there is one), the Accountable Manager and any observers who may contribute to operations in the form of cordon control. Indeed, when it comes to safety, everyone in the organisation has a part to play so don’t assume that because an individual does not participate in flying that they do not, even indirectly, contribute to the overall safety effect.
The ‘Human Capital’ in your business is arguably its most important commodity and also the one which requires the most amount of nurturing. In the emerging drone sector, it is currently difficult to ‘buy’ knowledge in the form of hiring a drone professional who may offer the sort of flying experience that would be beneficial for an OSC application. Most PfCO holders would not be in a position to do so anyway, so the only real option is to develop organically.
Knowledge, Skills and Attributes
Organic development, of course, takes time and effort and consequently, has an attached cost, but you can start this process now, with some simple steps. The People component focuses on the Knowledge Skills and Attributes (KSA) of an individual such that you can demonstrate they have sufficient proficiency and experience to operate the drone safely in flight and within the safety parameters for a given congested areas site. Beyond the normal NQE Ground School process and the pre-course experience an individual might have in radio control flying or military drone operations, there is little post qualification Continuous Professional Development (CPD) that is tailored for remote pilots. However, it is possible to develop this in-house with established intermediate and advanced flying training programmes (both theoretical and practical) and other industry specific learning programmes. For instance, if you intend to operate in the construction sector you will need a Construction Skills Certification Scheme (CSCS) card for access to sites and for many projects and clients, this type of accreditation may be a mandatory requirement. Each accreditation gained adds a little to an individuals overall KSA so, look for these courses in every industry sector and commit to achieving these accreditations where time and resources permit.
When it comes to organic training, the important point is to conduct your training activity as defined in your Operations Manual (OM) Volume 1 and document everything you do. Often, training is loosely defined in a particular OM paragraph but is then very rarely conducted for a number of operational and commercial reasons. It may seem unimportant but for an OSC it is a key point to demonstrate that you are investing and developing in the KSA of your staff.
Training needs to be a series of overlapping events building on both the individual and organisational capability, should be conducted routinely and records produced every time. Don’t go through the motions in this respect; although training may seem like peripheral activity, over time it instills layers of operational and cultural resilience which is beneficial for everything that you do, not just operations in congested areas.
Focus on good communications, strong procedural skills, close inspection flying in both GPS and Attitude mode, and actions in the event of an emergency. Look at the environment encountered in built up areas and structure the training to meet that challenge, ensuring that a thread of safety runs through all of the activity. Find a way to include everyone in the business if you can, because you never know when someone who is in a support role may contribute positively from a safety perspective. Even if this means putting a support member through an SUA familiarity day on an annual basis, they will have a better context for that support if they know what the end effect is.
As these skills accrue, you will build a bank of evidence that is critical for the ‘Claim, Argument, Evidence’ methodology required in the Volume 3 – Safety Argument element of the OSC submission. For the people component, this requires patience and dedication. It takes time but it is time well spent.
Developing people might seem counter-intuitive, after all, they could just leave and take their skills elsewhere. In business circles it is often said, ‘What if we train them and they leave?’, to which an appropriate response might be, ‘what if we don’t and they stay?’
People are the indispensable core at the centre of any coherent safety argument, so what are you doing to invest and develop them for the benefit of your business and ultimately, to achieve a congested area exemption?