What to Expect when You’re Inspected
The 2018 announcement that the CAA have begun to conduct inspections of licensed drone pilots has traditionally been something of a thorny issue amongst the pilot community.
The fact that even general information on the inspection process is conspicuous by its absence on the CAA website and a generalised fear of unannounced inspections by authority figures has combined to make this seem like a dark process designed to hunt down the slightest flaw and levy punishment against the unsuspecting pilot.
It’s refreshing therefore to speak to someone who has been through the process and come out the other side not only unscathed but feeling pretty positive about the whole experience.
In the interest of finding out more about what you can expect from an inspection and hopefully removing some of the darker rumours, we were delighted to speak to one of our DSR members. He uses drones as part of his overall photography and video business and he was happy to share his recent inspection experiences with us.
We have summarised our interview with the DSR Member below…
The Inspection Process
As you would imagine, the inspection was unannounced – “a simple knock at the door of the office one morning in April and a CAA gentleman announcing he was there to inspect the business, producing his official ID. Given that all drone pilots know that an inspection is possible, there was no need for me to question it although I’m sure there would have been a number to call if you needed further verification. Obviously, there was a quick moment of apprehension as there would be when any one arrives to examine your business process and procedures but obviously the inspector was made to feel welcome”.
“The first twenty minutes of the process was a reasonably formal and intense Q and A session addressing items in the Ops manual and how they applied to the business, with narrative being required and examples to be given.” Even though the CAA already have a copy of a pilot’s manual and the inspector was clearly familiar with its content, there was also an amount of time spent checking that the relevant paperwork was present and correct on site.
The drones themselves were also subject to a thorough inspection and the maintenance procedures were examined. Following this being completed, the next hour took on a more informal two-way discussion covering the drone industry, best practices, advice and feedback given. Of course, it’s likely that this would have been a very different scenario if the pilot wasn’t found to be up to date and in line with both legal and best industry practice, but he was (as you’d expect from a DSR member)!
Lots of pilots on the forums have wondered what the procedure would be to refuse or reschedule an inspection for any reason but as this was not necessary in our example, we can shed no light on this other than to say that with an organisation as necessarily procedure driven as the CAA, there is likely to be a process to follow which the inspector would no doubt explain if he or she were requested to.
All in all, the inspection was really seen as a positive thing although our pilot acknowledges that it might have been quite different if he hadn’t been certain that they had ‘99% of his ‘ducks in a row’. In fact, once the initial matters had been dealt with, he felt that it was an excellent opportunity to have a one on one discussion with an official at such a senior level in the CAA regarding the drone industry and how the authorities and pilots can work together to everyone’s benefit. It also had quite a validating effect in business terms to know that all the processes and procedures were put under the microscope and found to be working really effectively – a top notch endorsement from the horse’s mouth as it were.
He didn’t feel that there was a hidden agenda with the inspector and it wasn’t a case of trying to catch you out. It was in fact exactly what it should be – a chance for the CAA to take a look at your business and make sure that you really are following all the steps and processes that you have laid out in your operations manual, which of course is a condition of your PfCO being granted.
Familiarity with your operations manual is tested, and so it might catch out some operators who haven’t created their own but instead had someone write it on their behalf, and may not be so familiar or versed in it, but then isn’t that a good thing?
Submission of ops manuals that you haven’t authored may be a worrying practice for some which could potentially drag PfCO holders into disrepute if they don’t understand and abide by the working practices they’ve set out on paper. The drone industry is already facing the challenges posed by poor safety standards from unlicensed operators, if the licensed ones also start to have problems with compliance with the rules and regulations then surely the industry as a whole could really suffer.
As the pilot in question was just in the process of resubmitting all the documents required to renew their licence, the conversation naturally turned to issues that they were facing and the advice and guidance that they received contributed, he believes, to the renewal “sailing through with no queries or amendments.”
The Follow Up
In terms of follow up, there were 6 or so minor points that were identified during the meeting that could use a little attention and these were followed up with via email following the pilot’s enquiry a week or so after the inspection had taken place.
In fact, if there was one criticism that our pilot levied at the CAA during this whole process, it is that he would have liked a more “formalised follow up procedure with perhaps some certification of the inspection being passed when all of the issues had been addressed.” We don’t think it would be unreasonable for the CAA inspector to leave some kind if record of the visit and the points raised and discussed. A published document regarding compliance to inspection criteria would be a great conclusion to the process and proof and validation if it were required that the business is operating to the necessarily high standards.
Overall, the inspection process looks to be something of a positive chance for responsible UAV pilots to have a health check of their business. Although there can be a natural resistance to governing bodies when it comes to policing the standards that they set out, the CAA representative in this case was helpful and supportive – perhaps cementing the increasingly good relations between the organisation and drone pilots that has been building steadily over the last twelve months.
The DSR pilot in question said that “the experience gave him confidence in the ability of the CAA to have a two-way dialogue with pilots and that, if there were ever a need to contact them in the future, he would have faith in their commitment to supporting this fledgling industry.
We approached the CAA for comment on our article, and without reference to this specific visit/inspection, and had the following reply from Andrew Hamilton who is head of the UAV sector at the CAA…
Inspecting those we approve, or licence is a standard part of our oversight of the whole area of civil aviation that we regulate. So, introducing inspections for approved drone operators is no different to the way we’ve always treated the rest of aviation. Our teams visit major airlines, small private airfields, aircraft engineers, training schools and thousands of other companies and individuals every year. In each case we ask people to think of these as not just the regulator being satisfied that you meet the requirements, but also a chance for you to take advantage of time with us. What do you want to ask us or check? Perhaps you want advice on how to work up a safety case? It’s also a step in making approved drone use recognised as part of the commercial aviation industry. We’re encouraging approved operators to say to potential customers that they are approved by the CAA and that this does include inspections – providing your customers with more reason to use an approved operator. We absolutely understand that this is new for many operators, but we come into inspections with the same aim as you – to help make drone flying in the UK as safe as possible and for the industry to continue to expand.
Only in very rare circumstances would we look to do a spontaneous visit to an operator. I am very conscious that a lot of our operators could have another business so is quite likely that they would not be in if we turned up at the door. We will give notice that we will be visiting the operator for an oversight visit and outline the purpose of the visit and any documentation we would like to inspect. Where we get any information or intelligence to suggest an operator is operating outside of their permission or exemptions we would look to prioritise that visit.
Kind regards – Andrew Hamilton
Unmanned Aircraft Systems Sector Lead