A first-hand look at the CAA’s PfCO Audit Process
When the CAA invited Eyeup Aerial Solutions to road-test their latest process, I have to say I was flattered. After all, this reflects a high level of trust in what is only a small, part-time operation typical of many others. However, when I found out that the process in question was their revised audit system I realised it wouldn’t just be a case of, “what do you think of this then?”
It wasn’t made much easier when Head of UAV, Andy Hamilton said, “don’t worry – think of it as a trial…” Not what you want to hear from an ex-policeman! However, I am confident in Eyeup’s systems and saw it as a great opportunity to measure them against CAA’s expectations and look for improvement measures. I may even get a blog out of it too!
Rolling back the clock a few months to before Christmas, PfCO holders may remember the furore as CAA took on a number of auditors. Forum threads criticised the regulator for dropping in unannounced on PfCO holders and expecting to be welcomed in for a thorough inspection of flight logs and manuals. The CAA picked up on the harsh words of the community and decided to revise their procedures.
Now they are rolling out audits in a more considered way.
Hunting in packs
Being a test, the audit I received was slightly different to the completed process but not in any significant way. I was audited by one member of the team though I understand that two will be more common – so don’t be alarmed if they’re hunting in packs if they come to visit you.
Initial contact won’t be a knock on the door in the dead of night but an email inviting you to arrange a date. I was given a choice a couple of weeks ahead and was even able to organise it around my full-time job with the visit arranged for an evening.
I didn’t receive an email in advance letting me know the outline of the audit as you will but I had enough of an idea from my initial discussions about the process to know what was coming. Did I do a quick run thorough my paperwork the day before to ensure it was all in place? Of course I did. I also thought it worthwhile ensuring my hardware was close to hand and easy to view as this would be covered too.
So, what do they want to see? Well, the auditor will be following an agenda but will expect to be able to ask about any aspect of your operations and management systems which may impact safety.
On arrival my auditor, the ever-professional Sudip PunGarbuja, explained the process and warned me of the possible consequences in the event of non-compliance. Issues raised during the audit reflect the perceived risk to safe operations:
- Comments – effectively continual improvement items identified during the audit
- Level 2 – Corrective actions not impacting safety to be corrected within an agreed period, around 6 months or so
- Level 1 – The biggie…those items that could compromise safe operations and requiring immediate attention within the next 21 days.
Be warned… if your operations are so sloppy that you warrant a few Level 1’s then stand by, because CAA have the power to suspend or revoke your PfCO. It’s not something they want to do and they will try to educate rather than take a punitive line but their first responsibility is safety.
So what do the CAA want to see?
Well, it could depend on what’s going on in the world of regulations. Eyeup’s audit took place on the 28 February so the upcoming changes to legislation announced by CAP1763 were discussed. Had my manual been updated yet? No, but it was planned to be done by the 13 March. Was I aware of the changes and how they may impact operations? We advertise ourselves as professionals so this all goes with the territory. When the ANO or any other relevant regulation or guideline changes then get used to catching up with it. CAA’s Skywise App is a great aid to this as you can turn on drone-related email alerts.
Your Operations Manual is the key to your business. So, CAA want to know how you manage your document, which version are you working to? Is it the version CAA have in their records? If not, why not?
There will be a check of your basic documentation. Insurance policy, training logs, flight logs, examples of pre and site-surveys. As another operator found recently, CAA would like to see a good level of detail on items such as batteries to see that you have systems in place to manage usage and cycling. This isn’t an exhaustive list and you can work on the basis that if it’s in your manual then it’s fair game.
Having looked at your procedures, the auditor needs to know if you follow them. Do you have the records to provide evidence of this? Where and how are those records maintained? At this point you will probably have to provide a couple of examples and these will be judged against what you say you do in your manual… fair enough.
Then to the hanger (in my case a converted wardrobe. Are the airframes in good condition, well stored and looked after? What about your batteries? If you claim to keep them securely in metal cases then those batteries need to be in…guess what?!
More and MOR!
One area the CAA is extremely keen to see improvement on is MOR reporting. This is key to allowing them to spot patterns in failure modes and send out safety notices and alerts. Is there a risk of your airframe being taken out of commission on some jobs for a while because of this? Yes there is. But do you want to be the next operator whose M210 drops from the sky, possibly causing an injury but certainly ruining your day.
This is one area where I am as guilty as anybody, having suffered a crash in dense woodland caused by a software glitch during battery run-down. I can argue that this is something I would never do in a congested area – and will never repeat in woodland – so there would never be a risk to anybody else but CAA’s view is that I should have seriously considered a report. Next time (please don’t let there be a next time) I will be making one in the knowledge that it may help another operator. Fortunately, I had produced a detailed contemporaneous report (I did it at the time) in accordance with my OM and was able to provide a copy of this to Sudip as a partial penance.
Once the audit was complete, I was told that I would receive a report within 20 days. It did take the full 20 days but I think the CAA have had a very busy March with regulatory changes and further potential Brexit fuelled shenanigans to come. Apparently Sudip was very impressed with Eyeup’s operations so I am pleased to report that we are still cleared to operate UAVs commercially in UK airspace.
Possibly even better news to the industry is that the CAA seem to have now got an audit system that is “fit for purpose” and able to cope with the often “messy” diaries of the average PfCO-holder.
If you need help with your own operations manual updates, especially in the rapidly changing regulatory environment, or you want to take the step up in operations and gain exceptions to standard clearances then click on one choices below.
Or you can find the CAAs blog, where they explain the reasoning behind the audit process here ow.ly/brQY50osRmY
