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GVC – Your Risk Assessment? Where Does It Come From?
Introduction
First of all, I must point out that I’m not a health and safety expert, and I haven’t taken the latest course on understanding risk.
As a UAS (drone) instructor, Piloting under many VLOS/OSC’s of many years, I’ve seen it all, many so-called Risk Assessments, if I were a drone pilot flying under those RAs, I would be asking questions.
Secondly, depending on how you produce your Operations Manual may differ from mine. Some RAE’s use the same template, others maybe completely different. But the understanding of how all the versions work I feel should be the same.
So, put the kettle on and grab some biscuits while you’re at it, as we may be some time.
What You Will Need
Next, grab the latest version of the UK CAA:
– CAP722H – PDRA Pre-Defined Risk Assessment
– CAP2606 – PDRA01 Operations Manual Template
– Your Operations Manual and your Risk Assessment. You’ll need these for reference.
There is a physical link to all of these documents, and I’ll show you that at the end if you haven’t worked it out beforehand.
Believe it or not, every time you fly your drone, you fly under CAP722H. It’s an interesting document at best, even your PDRA01 comes from it and to be quite frank, if you gave it to your client as your Risk Assessment (RA) , they would probably say, “Get off my land!” So, we need a document that, 1, they can understand, and 2, you can work with.
I would suggest we make a Risk Assessments (RA) pretty much every waking moment of our lives—walking down the stairs, crossing the road, even putting the kettle on—but we never document the event. If we did, we wouldn’t get anything done!
So, as we go through this, I would like you to remember one phrase: “Yes, your Honor.” This will help you focus your mind and force you to add detail. To put more meat on the bone.
I want you to imagine this scenario: you’re in court, it’s all gone wrong, and the judge in front of you asks, “Due diligence?”
If you fly your drone professionally under the GVC, you will have your Operations Manual, and that, I would say, is how you play with your train set. That document is your company’s intellectual property (IP), and in there, there is a section that covers the risk element of what we do.
In my OM, it’s Section 4: UAS Emergency Procedures. (In CAP2606 it fulls under section 2.16 Specific emergency procedures)
– 4.1 UAS Battery Failure
– 4.2 Transmitter Battery Failure
– 4.3 Motor Failure / Prop Failure
– 4.4 C2 Link Loss
– 4.5 Loss of GPS Signal
– 4.6 Malicious or Accidental Interference with Control Frequency
– 4.7 UAS Uncontrolled Flyaway
– 4.8 Pilot Incapacitation
– 4.9 Aircraft/Airspace Incursion
– 4.10 Public/Uninvolved Third-Party Incursion
– 4.11 Fire in the Air and on the Ground
– 4.12 Abnormal Environmental Conditions
Let’s create the Risk Assessment.
In the back of my OM, Appendix F is my Risk Assessment, this is the form I use, as its the form I’ve indicate with the CAA that I use.
Let’s now assume we are flying a DJI Mavic 3 Pro at 958g in an open field.
At the top, you’ll have:
1. Hazards
2. At Risk
3. Existing Control Measures
4. The Risk Matrix
– (4) Severity
– (5) Probability
– (6) Risk
7. Further Control Measures
– A second Risk Matrix with (4) Severity, (5) Probability, and (10) Risk
(2) At Risk, you’ll need to work that out yourself, as each site/location is different. You could be on a closed set, so it may be E – Employees and/or C – Client. You could be in the middle of a field with a footpath running through it, so it might be P – Public.
(3) Existing Control Measures – the key word here is EXISTING. Your OM – how you play with your train set – Existing. Under Section 4 again, copy and paste word for word the detail for each heading and place it in the Existing Control Measures column.
What it isn’t, is your interpretation of the hazard: “Yes, your Honor.”
Let’s now look at the Risk Matrix (4) (5) (6). Everyone must be on the same page here. Some factors can influence the outcome, such as age, experience, and maturity. When I was young, I’d happily skateboard down the road and climb trees. If I did that now, I’d probably break my arm!
Understanding what might happen
The pilot must know the weight of the drone and understand what 250g really means. The weight of the mass of the drone will affect the severity (4).
And I quote: “A drone that equates to a human impact of 80J of kinetic energy with a 30% probability of a fatality when striking a person’s unprotected head.” 80J is the threshold between less dangerous and more dangerous.
We see this today with cars on the road, According to analysis, in a 30 mph collision with a car, pedestrians have 6.8% chance of dying.
So, give your RA a title: DJI Mavic 3 Pro (958g). This will also help your client. When you say “drone,” they probably won’t know the difference between a DJI Inspire 3 at 4.3kg and a DJI Mini 4 Pro at 249g.
To help bring this point home, I use a lump of concrete that weighs 430g (I weighed it!). I place it in the hand of the pilot and ask whether it is heavier or lighter than the drone. Whatever answer they give, I run with it. There’s no right or wrong here.
Now, imagine that lump of concrete at 400 feet (120m) – our legal max height – and drop it. If it hit your car, would there be any damage? I would say YES! So, there would be an insurance claim with lots of red faces.
Now let’s up the ante. Again, place the lump of concrete at 400 feet and drop it. It lands on someone’s head. Would it kill them? I would say YES! Why? Because it’s over 250g (DJI Mavic 3 Pro = 958g).
What it isn’t, is their interpretation of what they may think will happen. Terms like “might”, “should”, “maybe” or “could” are too grey. Your RA is black and white – it’s either YES or NO.
On the back of my RA, I have a Risk Matrix. Under the Severity column, a 4 fits the bill for the DJI Mavic 3 Pro: Major Injury, Single Fatality, Critical Loss of Process/Damage to Property. So, 4 would go into the Severity column (4).
That said, it can be a 5 – Multiple Fatalities in the case of an Airprox. There aren’t many aircraft with bird-proof windscreens, and your drone, I would say, would go straight through.
Working out Probability
How do we work out probability/Likelihood? There’s no maths or equation to be added. If I said it’s 1 Extremely Unlikely and always 1, how would you feel?
It’s 1 because of CAP722 (our guidance), which comes from the UK CAA. This must be treated as a GREEN document. If it was anything other than green, the UK CAA would not let us as an industry fly in UK airspace.
It’s 1 because, as a GVC pilot, you have gone through the GVC course, and undertaken a theory exam and practical flight test. The RAE (Recognised Assessment Entity) will give the recordation to the CAA, who will then in turn issue the authorisation (PDRA01) from (CAP722H).
So, even in the worst outcome, a 5 – Multiple Fatalities, Catastrophic Loss of Business – you will still be GREEN (I’m thinking of an Airprox again here).
Again, why? This isn’t a tick box exercise, under Section 4, UAS Emergency Procedures in your OM is now your training and SOPs (Standard Operating Procedures). Plus (and I would suggest you get the crew around the table and go through each one in turn and fly them at least once a month) that way, you’ll keep current and add time flown to your logbook. A win-win.
Further Control Measures
So, what about Further Control Measures? As it stands, we are green, so further control measures can stay blank.
As the pilot, you are responsible for the crew. Occasionally, I work over or close to water, so the hazard is drowning. Who is at risk? The crew. You will mention in your briefing the risk of getting too close to the edge, don’t go through that gate, etc. Your briefing is an existing control measure.
But the risk of working close to or on the water is NOT in your OM, so the severity will be 4 (a single fatality) and 2 (remote possibility), making the risk now 8 (yellow). A further control measure is now needed to mitigate the risk, and the obvious one when working around water is to wear a life jacket. You will also find that working on a boat will require some form of induction beforehand, just like working on a building site.
Again, the severity stays the same at 4, someone may still drown, but the probability has come down to 1 because of the Further Control Measures.
What to Do Next?
Using this method, you can easily create an RA for all of your drones listed in your OM. The only thing that will differ is the Risk Matrix, as the size, mass, and overall speed of each drone is different. For example, my DJI Inspire 2 scores a 5 for Severity in every Hazard, as it weighs 4.3kg, but the DJI Mini 4 Pro scores a 3 in Severity, as it weighs only 250g.
I’m not writing the RA out every time I plan a job—the basics are already there. I just go into the folder, pull out the RA for that drone, and add anything that is needed as a Hazard for that specific site.
I don’t usually mention trees, to be honest. I prefer flying as close as I can to the trees as it looks great in the edit. But that said, if the tree is important to the client, I would add it.
I hope now you can see the link between CAP722H, your OM, and your RA.
What you have now are documents to work with: Training, SOPs, and currency—all rolled into one. There could now also be a cultural shift within your organisation/company in terms of understanding Risk.
If you work for a company and the Accountable Manager is your boss, you’ll need to get them on board too, as they will be beside you in the dock, “Your Honor.”
You’ll need to set aside time to practice and train—currency is now the key with the CAA, and it all needs to be documented and available as evidence if the CAA asks for it.
What’s more, you now have a document to give to your client, along with proof of insurance. If they ask for proof of currency (GVC), these are the three documents I send to my clients.
Up to this point, we’ve been working with and inside CAP722, which is very much our guidance. The last thing I want to bring your attention to is:
Article 241: A person must not recklessly or negligently cause or permit an aircraft to endanger any person or property.
This is very much the law, and this Act is what you’ll be going to prison for—not the fact that your drone was over 400ft at the time of…
One last thing to mission here, remember your RA is a aviation risk assessment and should be treated as such, I’m not interested in slips and trips and COVID. Your RA fits into the over all RA for the site. The Project Manager should have Slips and Trips to help cover you while your on site.
The Electrician working onsite won’t have – what to do if the drone pilot trips over my cable while flying, that’s for sure.
Think safety and happy landings.
Useful links and bed time reading-
Evaluation of the drone-human collision consequences
https://www.sciencedirect.com/science/article/pii/S2405844022029656
UKCAA CAP2606-PDRA01 Operations Manual Template
https://www.caa.co.uk/our-work/publications/documents/content/cap2606 [...]