Manual of Standards (MOS)

101 RECORD KEEPING FOR REOC HOLDERS

The holidays are upon us and as our thoughts turn from work to family, and we prepare to spend time with the most important people in our lives, a little niggle in the back of our minds wonders if we have forgotten anything. Most will be wondering what will 2020 bring and what do I need to do? Well, I am never one to look into the future and make New’s Year’s Eve predictions but there are a few things we know will be happening in the drone regulatory landscape. The main one will be that the Manual of Standards (MOS) 101 will come into effect on 5 Apr 2020, so it seemed appropriate that as this deadline approaches we should discuss how prepared we all are for the new record keeping requirements. 

At Hover UAV we use a paperless operations application, AVCRM, so we have contacted them to see how their preparation for the Manual of Standards (MOS) 101 transition is going. They will be updating AVCRM to conform with MOS 101 next year and plan to do a release very close to the change over date. That way AVCRM ensure that they have all of the current information, hence, AVCRM are working to a timeframe of sometime around March. Sounds great if you are using a digital solution such as this but what if you are not? What are the things you need to start thinking about? Well, you have to read MOS 101 Chapter 10. However, we have summarised the main changes for a ReOC holder conducting RPAS operations. In the MOS 101 explanatory statement, it was stated that “CASA will provide the certified RPA operator industry with some suitable templates to assist in compliance with record-keeping and notification requirements” so it is worth contacting CASA rpas@casa.gov.au for these templates or to find out when they will be available. 

CHANGES THAT WILL COME INTO FORCE AS OF 5TH OF APRIL 2020:

Firstly all required records now have to be kept for 7 years, so do you have a system to do this that is appropriate for your operations? 

Secondly not every ReOC holder has to keep the same records; 

1. single-person ReOC holders are not required to complete the “Operational release” since by definition they would be directing themselves.
2. The record keeping requirements for <2kg RPA operations are reduced for both the operational release and technical logs. 

Thirdly, update all your documents with how you are going to comply with the MOS 101 requirements. It is not just a case of adding revised forms but you need to revise everyone’s duty statements so that it is clear who is responsible for completing each record and who can approve what operations. Also, review your current record keeping requirements in you Ops Manual and Library to remove duplication or out-of-date forms.

The following records are now required to be kept:

1. Chief Remote Pilot (CRP) records: These need to demonstrate that the CRP is completing their duties as detailed in CASR101.342. The CRP has to set up record keeping IAW MOS101 which when combined with their duties as part of the Operations Manual means not much additional work is required.
   1. 1 CRP needs to conduct and record the completion of the annual review of the ReOC manuals to demonstrate that the Operations Manual and Procedures Library are up to date. 1.2 In addition to the operational release, which now has to be provided to the remote pilot (RP) in writing prior to the RPA operation, the CRP must ensure they keep a copy of the following if they were completed for the operation:
      1. JSA – always
      2. Risk assessment – depends how risk is managed by the ReOC holder
      3. NAIPS, NOTAM or AIS brief – nearly always
      4. Flight plan
      5. Cargo or payload requiring special or unusual handling
      1.3 Record of any internal training (date, names, what it was and outcome). This appears to go together with the records of qualification and competency (MOS101 10.8). We recommend that if your internal training provides any sort of skill to an employee (ie EVLOS Class 1 Observer) you record this in the relevant persons training folder and provide them a statement of what they have achieved and when. 
2. RPAS Operational Release is a new requirement for many operators, particularly as it has to be provided to the RP in writing prior to the operation commencing. Each operator has to simply make a form in which they record the RPAS operational release information as set out in MOS101 10.04 and we would suggest combine it with the operational log MOS101 10.05 so one form is available to record what was planned and approved versus what was flown and achieved. Also attach a map of the route planned versus flown if operating EVLOS or BVLOS. You will also need to update your Ops Man with who can approve the operational release as CASA has stated “approved RPAS operational release means the RPA operational release approved in writing by the certified RPA operator or the chief remote pilot”. 
3. Remote pilot log, for those with a manned aviation background sounds a lot like a pilots logbook. The operator’s responsibility is to ensure that the RPs are correctly logging hours so the CRP needs to be checking this IAW a procedure documented in the operator’s operational library. This needs to include simulated hours and by type (night, EVLOS, BVLOS, VLOS)
4. RPAS Technical Log is simply keeping records to show that RPA is airworthy, the maintenance controller is responsible for the majority of these requirements but RPs responsibilities also need to be considered. The requirements differ for less than and greater than 2kg; in particular, that for greater than 2kg the operator is required to keep records:
   1. for individual motors and propellers, 
   2. maintenance schedule 
   3. maintenance carried out
   4. rectification carried out

The operator is also now required to provide a copy of the log to the new owner of the RPA on request; so if trying to sell an RPA provide the log as part of the sale information and if buying a second hand RPA ask for the log. 

Remember these are not the only changes that come into effect on 5 April 2020 as the requirements for operations around controlled and non-controlled aerodromes are also changing. We all have about 90 days after the holidays to get our documents and procedures MOS 101 compliant so I hope this has provided some timely advice on what is required. Don’t hesitate to contact Hover UAV if you need assistance in deciphering these regulations or aligning your documents and procedures with MOS101. Should you require any assistance in implementing these changes please do not hesitate to contact Hover UAV to discuss these regulatory changes.