The final component of a coherent safety argument is Processes – or more properly, the environment in which the activity takes place and how you manage it.
Each PfCO holder has an operations manual which defines the policies that underpin how you will operate and manage risk, although it typically isn’t detailed enough that each individual procedure is covered in real depth. In the context of a safety case, however, you will need to fully understand your operational environment, the hazards presented and what processes you will need to apply to bring the level of risk down to a level that can be considered As Low As Reasonably Practicable (ALARP).
This brings an inevitable ‘chicken and egg loop’. Specifically, to achieve a safety case, you need to demonstrate experience in operating in congested areas but the most optimal way to build this knowledge is possessing a safety case! It is a typical Catch 22 type paradox, which discourages many operators when they set out on the OSC path.
There is, however, a way forward. In your day to day operations with a standard PfCO, you will have encroached on congested areas at some stage, such that the limitations on your permission would have bordered on the operational limits of that flying task. In some cases, you would have had to be creative in developing a plan to fly the task whilst complying with the limitations, and sometimes accepting that there were elements of the project that, no matter the mitigations applied, you could not achieve safely. It is for latter that you are most probably seeking a safety case exemption, to unlock this last segment of work and meet clients expectations fully and, most importantly, safely. All of this experience builds your corporate operational knowledge and you should document it where you can – it may be useful to submit as evidence in the OSC application.
Focus on the extra procedures
To demonstrate that you understand how to safely manage your environment in a congested area, you will need to give extra focus to the policies and procedures in your Operations Manual. These should contain much more content and zero in on risk management, identifying where the gaps are in the context of flying in a congested area.
As part of this, you will need to become acquainted with a host of enhanced management concepts that are prevalent in congested areas such as advanced traffic management, augmented cordon procedures and a range of liaison and communication methods for imparting your intentions to members of the public. Additionally, if you intend to operate in areas with high-rise buildings it is useful to research how the operational environment will affect how you operate. The obvious component is how wind behaves in this environment so you can better understand the risks and incorporate that into your plan.
The best way to examine the way in which you would operate in a given congested area environment is to regularly place yourself in hypothetical scenarios in which you dynamically plan where you would launch and recover, how you would communicate with the public and what methods you would employ to manage a flying cordon. The only way to do this is to go out into your local town and workshop the problem in your head. Imagine you have been given a flying task in the local high street and then apply a logical approach to each planning factor. With practice, it starts to become second nature; indeed you may start to do this automatically even when not engaged in business activity!
Avoid taking shortcuts
As with the other components of a safety case, it will require you to immerse yourself in the subject and, I’m afraid, there is no shortcut in this case. Every piece of knowledge and experience you gain builds you into a more competent, safer operator, and in a competitive environment, this is an increasingly attractive attribute for potential clients.
For a congested area task, you will often need to provide a client with a Risk Assessment and Method Statement (RAMS) so that they can see how you propose to conduct the task and how you will mitigate risk. If you don’t immerse yourself in your procedures this will be evident in the plan you present to the client.
As a friend once said to me, ‘there are no shortcuts to any place worth going’. You should have that in your mind as you build your safety case.
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]