Any ReOC holder who is considering growing their business to include BVLOS operations will be required to provide an emergency response plan (ERP) as part of any application to CASA. Although this may seem like an activity for the sake of compliance, it probably reflects that the size and scope of your operations are growing so that the need for a safety management system (SMS) is becoming apparent. An ERP is one of the fundamental components of an SMS. CASA’s SMS booklet 7 (SMS for small or non-complex organisations) states “An ERP is an integral part of your SMS and should facilitate the management of a hazardous event/accident and mitigate the impact on normal operations.” There are also good business reasons to have an ERP as the consequences of any incident can result in:
All of which will negatively affect the ability of your business to continue to operate.
The aim of any ERP is to ensure that the response to any incident should attempt to contain, control, or end the emergency. This means that reactive safety management is practised after a hazard has manifested itself and your operation has suffered risk related consequences. In the simplest of terms, your teams are responding to an event, which may be an accident, incident or irregularity.
The ERP you develop should not try and prescribe every action in such mind-numbing detail that the document is confusing and cumbersome for someone to follow. The goal of the ERP is to provide a resource that helps the team manage an adverse event but does not provide so much information that the team feels overwhelmed trying to enact an ERP so fail to manage the incident effectively. To put this into context CASA’s SMS booklet 2 (Safety policy and objectives) states “An ERP for a small, non-complex organisation may simply consist of a laminated lanyard card of current emergency contact numbers.”
The starting point for developing an ERP is to review your organisation’s foundation risk register or the risk register for a specific operation. The ERP is enacted when one of these risks occur and the control measures failed to prevent the hazard occurring. For example, you identified the hazard of a member of the public entering the operating area and being injured by the RPA, you had put in place your control measures of signage, marshalls, cones, barriers, etc but someone entered the area and was hit by the drone. Your risk assessment never removed the hazard only reduced the likelihood of it occurring to an acceptable level; the ERP is now enacted to manage the incident.
Next step is to identify the resources that are available to manage an incident from within and outside the business. These resources can then form part of the ERP. At this step you should consider the type of locations you are operating in: does it have good phone coverage, are there specific weather effects to consider, what access is there to medical and emergency services, etc.
You now have a set of risks/emergencies that will need to be managed when they occur and a defined set of resources available to do this. The ERP is now developed to define how the team responds, who they contact and what resources they will use or call upon. The ERP should be developed with the following flow in mind, not all will apply in every situation:
It is worth stating that common sense prevails when dealing with any emergency so all team members should bear the following in mind as they react to an emergency:
Now decide if the ERP is going to be an appendix to your operational library or a separate manual. This decision should be based on who needs access to the ERP; as placing it in operational documents is appropriate if all employees have an operational role but isn’t if non-operational personnel have responsibilities within the ERP.
You now have decided what is required so can now develop your ERP. Typical sections will be:
CASA has developed a checklist to help organisations to develop and implement their ERP
CASA SMS Booklet 2 ERP Checklist
So you have created an ERP but it is not an effective plan until everyone is trained and proficient in enacting it. You’ll need to hold a session with your staff to brief them on the ERP and its value. If they have not been part of its development use this as a peer review session so everyone’s input is considered so you get the best team plan. Refine it with a desktop exercise and finally do a live rehearsal; now everyone is trained. Document this training, decide on the frequency of future training and get everyone on board with another part of your safety culture.
You now have an ERP that you can take to customers and other operating locations that can be integrated with their ERP or adjusted to suit the conditions at the new location. It can be submitted as part of any application to a regulator to demonstrate that you are not just committed to managing risks but have a plan on how to deal with a hazard or emergency situation if one occurs. Finally, It demonstrates a commitment to safety, people’s welfare and a just culture.
The web is full of great resources on ERP’s almost to the extent that there are too many examples. The critical thing is to develop the appropriate ERP for your size of operation.
Should you need any assistance or guidance in developing an emergency response plan, BVLOS approval, EVLOS approval or need to discuss requirements to maximise the full potential of your RPAS program please do not hesitate to gain contact with Hover UAV.
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