OSO 17 – Remote crew is fit to operate
AMC1 Article 11 Annex E. Operational Safety Objective 17
CAA ORS9 Decision No. 46
OSO 17 – Remote crew is fit to operate
Level of integrity
| Criterion | Low (SAIL 1, 2) | Medium (SAIL 3, 4) | High (SAIL 5, 6) |
|---|---|---|---|
| Criterion | OSO17.L.I |
OSO17.L.I OSO17.M.I |
OSO17.L.I OSO17.M.I OSO17.H.I |
Level of assurance
| Criterion | Low (SAIL 1, 2) | Medium (SAIL 3, 4) | High (SAIL 5, 6) |
|---|---|---|---|
| Criterion | OSO17.L.A |
OSO17.L.A OSO17.M.A |
OSO17.L.A OSO17.M.A OSO17.H.A |
Low level of robustness (SAIL 1 and 2)
OSO17.L.I
(a) The Applicant must have a policy defining the criteria and the means for the remote crew to declare themselves fit before starting their duty and report themselves unfit, if required, during their shift.
(b) Where the certificate of remote pilot competence for any crew member requires a formal medical certificate, the applicant must have a procedure to periodically check its validity.
OSO17.L.A
(a) The Applicant must declare and provide evidence of compliance with the Integrity requirements. The detailed evidence of compliance may be assessed by the CAA.
AMC.OSO17.L.A
(a) A crew briefing including a record of an ‘IMSAFE’ check for all crew members is sufficient.
Medium level of robustness (SAIL 3 and 4)
Lower robustness level requirements to be complied with:
• OSO17.L.I
• OSO17.L.A
Additional requirements to be compiled with:
OSO17.M.I
(a) The maximum flight crew duty period and resting times for the remote crew must be defined by the applicant and adequate for the operation.
(b) The Operator defines requirements appropriate for the remote crew to operate the UAS.
OSO17.M.A
The Applicant must provide evidence of compliance with Integrity requirements which will be assessed by the CAA including:
(a) Remote crew duty, flight duty and the resting times policy is documented.
(b) Remote crew duty cycles are logged and cover at a minimum:
(1) when the remote crew member’s duty day commences,
(2) when the remote crew members are free from duties,
(3) resting times within the duty cycle.
AMC.OSO17.M.A
Annex E – AMC 1 Integrity and assurance levels for the Operational Safety Objectives (OSO) paragraph 1.5 provides further information about proposing a standard as an AMC.
High level of robustness (SAIL 5 and 6)
Lower robustness level requirements to be complied with:
• OSO17.L.A
• OSO17.M.A
• OSO17.M.I
Additional requirements to be compiled with:
OSO17.H.I
(a) The remote crew must be medically fit for their assigned duties.
(b) The applicant must have a Fatigue Risk Management System (FRMS) is in place to manage any escalation in duty/flight duty times.
OSO17.H.A
(a) The applicant must use a medical standard(s) considered adequate by the CAA and/or means of compliance acceptable to the CAA.
(b) The FRMS will be assessed by the CAA.
(c) The Applicant must provide evidence of compliance with the Integrity requirements, which will be assessed by the CAA. The CAA will validate continuing compliance through oversight.
GM1 Article 11 Annex E. Operational Safety Objective 17
CAA ORS9 Decision No. 46
GM.OSO17
For this assessment, the expression “fit to operate” should be interpreted as physically and mentally fit to perform duties and discharge responsibilities safely.
Fatigue and stress are contributory factors to human error. Therefore, to ensure vigilance is maintained at a satisfactory level of safety, consideration may be given to the following:
-
Remote Crew workload and duty times
-
Regular breaks
-
Rest periods
-
Handover/Take Over procedures
-
Personal Protective Equipment (PPE)
-
Workplace environment, including ergonomics of the workstation
GM.OSO17.L.I
The regulatory requirement is that remote pilots must not perform their duties under the influence of alcohol. [UAS.SPEC.060(1)(a)].
While no actual limits are specified, because of the more advanced nature of flying in the Specific category, and in particular the requirement to comply with the precise conditions of the operational authorisation, the limits prescribed for manned aviation in Railways and Transport Safety Act 2003 (RTSA 2003) Section 93 should be complied with.
| Level of Alcohol | All UK Nations |
|---|---|
| Micrograms per 100 millilitres of breath | 9 |
| Micrograms per 100 millilitres of blood | 20 |
| Micrograms per 100 millilitres of urine | 27 |
Personnel carrying out support functions that are directly related to the safe operation of the UA while in flight, such as unmanned aircraft observers, or airspace observers, should comply with the same limitations.
GM.OSO17.M.I
Fatigue and stress are contributory factors which are likely to increase the propensity for human error. Therefore, to ensure that vigilance is maintained at a satisfactory level in terms of safety, consideration should be given to the following:
-
Crew duty times
-
Regular breaks
-
Rest periods and opportunity for napping during circadian low periods
-
Health and Safety requirements
-
Handover/Take Over procedures
-
The crew responsibility and task/cognitive workload (including the potential for ‘boredom’)
-
Ability to mitigate the effects from non-work areas (e.g. financial pressure causing anxiety)
The work regime across the crew should take this into account. Where required, an effective Fatigue Reporting System should be implemented within the organisation to increase awareness of fatigue or stress risks and mitigate them accordingly.
Further information to support Fatigue Management approaches for safety relevant workers can be found in the ICAO Fatigue Management guidance material (Doc. 9966).