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 email@example.com for these templates or to find out when they will be available.
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;
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 Also, review your current record keeping requirements in you Ops Manual and Library to remove duplication or out-of-date forms.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:
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.
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