Who audits the auditors?
It’s surely a fair question?
In this case, when I mention “auditors”, I’m not talking about the sometimes questionable antics of YouTubers with drones flying over industrial estates and police stations looking to capture an argument on camera.
No, I’m going higher. In fact, right to the top.
Edits:
“Pre-determined” changed to “pre-defined” in section Being Specific.
Being Specific
IN the UK, if you fly a larger drone for business (though possibly sometimes for fun), and frequent congested areas, then chances are you do so under an Operational Authorisation issued by the UK’s Civil Aviation Authority. The starting point for these authorisations is something called a Pre-Defined Risk Assessment no. 1 or PDRA01. Basically, PDRA01 outlines the conditions under which you can operate.
One of those conditions is that you must hold and maintain an Operations Manual. Because such a manual is subject to change, our dear regulator demands that the manual is kept under strict issue control. You will be expected to display the issue number of the manual on the front page. Here are the instructions from the CAA’s own template manual CAP 722A. Check against “Document version and date”.

CAP 722A Front page instructions
On the very next page, you are expected to insert an amendment record, detailing all amendments, when they were made, who by and details. You would naturally end this with the same version that is displayed on the front page.

CAP 722A Amendment table
Matchmaker, matchmaker…
It is no exaggeration to state that the shared service section of the CAA, the group that carries out the PDRA01 audits make it their mission in life to catch out any operators whose version numbers do not match between the front page and amendment table. They carefully scrutinise the headers and footers of those operators foolish enough to carry the issue numbers across to those page section too. Should you have failed to make all he numbers match, you will be required to correct the error forthwith.
Until recently, authorisations would not be issued until such an heinous crime had been accounted for.
Isn’t it ironic… don’t you think?
That the UK’s regulator issues a guidance document to those undergoing an audit containing a glaring example of exactly this problem. I like to call it the issue issue.
Where’s the evidence? Well, I was (very) recently sent a copy of the guidance document along with a request to help an operator out with advice about their audit. Always happy to oblige, I eagerly opened the attached guidance document from the CAA. What beautiful clarity was contained within its simple file name. “PDRA01 assessment guidance notes v1_1”.
It appears that they regulator has sensibly incorporated the current version number (1.1) within the file name.
Imagine my disappointment then, when I opened the file and gazed upon the front page.
Surely, I thought, the error lies only in the filename. Let’s take a gander at the amendment table.
It was at this point that all hope was lost. I held my head in my hands and wailed.
Even before I had started to review the document, which unsurprisingly contains a number of confusing statements that plainly contradict other CAA guidance documents, I knew all hope was lost.
The auditor had, in a now typical feat of gross silliness (apparently the word incompetence is frowned upon), managed to display an inability to keep track of possible one of its shortest and simplest documents.
Does it really matter?
I ask this question every time I find errors in CAA documents. I’m frankly fed up with it and I suspect so are they.
But it’s really down to the CAA and their lords and masters the Department for Transport. Personally, I feel the lack of care and attention reflects a sort of arrogance, particularly when coupled with demands for high standards of control by the “regulated community”.
The CAA is increasingly talking about increasing the professionalism of the industry.
Here’s a clear message from that industry.
With all due respect… you first.