New SFOC Application Process – Part 4 Compliant Operator

sfocIn order to use the Compliant Operator Application Process under the new SFOC procedures, one the of requirements is that the Operator is compliant.

The criteria for a compliant operator is outlined in Appendix D of the SI 623-001 document.

A large portion of the compliance for an operator builds on the processes and procedures that were part of the old SFOC application, in that operating and emergency procedures were defined and detailed and personnel were in place and properly trained for their role.  It is made more formal under the new process, and training records and manuals now must be maintained to a specific standard.

For training, the following is what must be maintained:

(d) Training
(i) Training Program
(A) The UAV operator shall establish and maintain a ground and flight training program that is designed to ensure that each person who receives training acquires the competence to perform their assigned duties.
(B) The UAV operator’s ground and flight training program shall be conducted in accordance with the Training Standard provided in paragraph (e) below and will include:
I. company indoctrination training;
II. upgrading training;
III. training in the specific work to be conducted; and
IV. initial and recurrent training, including
V. UAV type training,
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VI. procedures for passing piloting control from one control station or pilot to another,
VII. aircraft servicing and ground handling training,
VIII. emergency procedures training,
IX. training for personnel who are assigned to perform duties associated with the flight, and
X. any other training required to ensure a safe operation.
(C) The UAV operator shall:
I. include a detailed syllabus of its ground and flight training program in its operations manual; and
II. ensure that adequate facilities and qualified personnel are provided for its ground and flight training program.

(e) Training – Standard
(i) Company Indoctrination Training – This training is required for all persons assigned to the operation. Company indoctrination training shall include, as applicable ;
(A) Canadian Aviation Regulations and applicable standards;
(B) UAV SFOC and the conditions specified therein;
(C) company reporting relationships and communication procedures, including duties and responsibilities of crew members and the relationship of their duties to other crew members;
(D) flight planning and operating procedures including
I. operational preparation procedures related to reconnaissance of aerial work areas before low level flight operations; and
II. operational restrictions;
(E) fuelling procedures, including fuel contamination precautions;
(F) critical surface contamination and safety awareness program;
(G) use and status of the operations manual including maintenance release procedures and accident/incident reporting procedures;
(H) meteorological training appropriate to the area of operation;
(I) navigation procedures appropriate to the area of operation;
(J) carriage of external loads;
(K) operational control system; and
(L) weight and balance system.
(ii) Upgrading Training
(A) Upgrading training to PIC on a UAV type shall include:
(B) completion of applicable qualification training related to assigned duties; and
(C) completion of type training as PIC on the UAV type and a PIC competency check.
(iii) Ground Technical Type Training (Initial and Recurrent)
(A) This training shall ensure that each crew member is knowledgeable with respect to the systems of the UAV system and all normal, malfunction and emergency procedures, as applicable to their assigned duties. Ground technical type training programs shall include:
I. aircraft systems operation and limitations as contained in the UAV system operating manual, manual supplements, standard operating procedures;
II. use and operation of navigation and ancillary equipment;
III. equipment differences of UAV of the same type, as applicable;
IV. UAV performance and limitations;
V. weight and balance procedures; and
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VI. UAV servicing and ground handling procedures.
(iv) UAV Servicing and Ground Handling Training
(A) Training in UAV servicing and ground handling for each crew member, as applicable to their duties and applicable to the UAV type, shall include:
(B) fuelling/charging procedures:
I. types of fuel, oil and fluids used in the UAV;
II. correct fuelling procedures;
III. procedures for checking fuel, oil and fluids and securing of caps; and
IV. procedures for charging batteries.
(C) use and installation of protective covers; and
(D) procedures for operating in cold weather such as:
I. moving the UAV or other components of the UAV from a warm facility when precipitation or high humidity is present;
II. engine pre-heat procedures including proper use of related equipment; and
III. managing battery degradation.
(v) UAV Flight Training Program (Initial and Recurrent)
(A) The initial and recurrent flight training program shall ensure that each crew member is trained to competently perform the assigned duties including those relating to abnormal and emergency duties. Simulated malfunctions and failures shall only take place under operating conditions which do not jeopardize safety of flight. Flight training programs shall include, as applicable to the UAV system:
I. standard operating procedures for normal, abnormal and emergency operation of UAV systems and components;
II. use of check lists and pre-flight checks;
III. crew member co-ordination procedures;
IV. normal take-offs/launchs, circuits, approaches and landing/recovery including, as applicable, ground manoeuvring and hovering;
V. control station fire procedures, including smoke control;
VI. fire control and handling of hazardous materials;
VII. simulated engine and system malfunctions and failures including hydraulic and electrical systems;
VIII. simulated failure of navigation and communication equipment;
IX. stall (clean, take-off/launch and landing/recovery configuration) prevention and landing/recovery procedure;
X. autorotations and anti-torque system malfunctions, as applicable;
XI. rejected take-off/launch and landing/recovery procedures;
XII. use of performance information and performance calculation procedures;
XIII. simulated emergency descent;
XIV. collision avoidance techniques;
XV. operational procedures involving visual observers;
XVI. steep turns and flight characteristics;
XVII. briefings on recovery from turbulence and windshear; and
XVIII. flight manoeuvres used in specific operations.
(vi) Training and Qualification Records
(A) The UAV operator shall, for each person required to receive training, establish and maintain a record of:
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I. the person’s name and, where applicable, personnel permit/licence number,
II. if applicable, the person’s medical category and the expiry date of that category;
III. the dates on which the person, while in the UAV operator’s employ, successfully completed any training or competency checks; and
IV. information relating to any failure of the person, while in the UAV operator’s employ, to successfully complete any training or competency check or to obtain any qualification required herein.
(B) The UAV operator shall retain the records referred to in paragraphs (A) (III) and (IV) above, for at least three years.

The following details the manual requirements that a compliant operator must maintain:

Manual Requirements
(a) Operations Manual
(i) The UAV operator shall establish and maintain an operations manual that meets the requirements of Section (b) below.
(b) Contents of Operations Manual
(i) The operations manual, which may be issued in separate parts corresponding to specific aspects of an operation, shall include the instructions and information necessary to enable the personnel concerned to perform their duties safely and shall contain the information required by the standards in Section (5)(a) below.
(ii) The operations manual shall be such that
(A) all parts of the manual are consistent and compatible in form and content;
(B) the manual can be readily amended;
(C) the manual contains an amendment control page and a list of the pages that are in effect; and
(D) the manual has the date of the last amendment to each page specified on that page.
(c) Distribution of Operations Manual
(i) The UAV operator shall provide a copy of the appropriate parts of its operations manual, including any amendments to those parts, to each of its crew members and to its ground operations and maintenance personnel.
(ii) Every person who has been provided with a copy of the appropriate parts of an operations manual pursuant to subsection (i) above, shall keep it up to date with the amendments provided and shall ensure that the appropriate parts are accessible when the person is performing assigned duties.
(d) Standard Operating Procedures
(i) The UAV operator shall, for each operation that is described in the operations manual, establish and maintain type-specific standard operating procedures that meet the standards described in Section (5)(b) below.
(ii) The UAV operator that has established standard operating procedures shall ensure that a copy of the standard operating procedures is available at the control station.

(5) Manuals – Standard
(a) Operations Manual Content – The operations manual shall include the following, as applicable to the operation:
(i) preamble related to use and authority of manual;
(ii) table of contents;
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(iii) amending procedures, amendment record sheet, distribution list and list of effective pages;
(iv) copy of the SFOC;
(v) flight authorization and flight preparation procedures;
(vi) retention period of flight operations documents;
(vii) dissemination procedures for operational information;
(viii) fuel/energy and oil requirements;
(ix) weight and balance system;
(x) accident/incident reporting procedures;
(xi) use of check lists;
(xii) maintenance discrepancy reporting and requirements on completion of flights;
(xiii) operating weather minima and applicable requirements;
(xiv) operations in hazardous conditions such as icing, thunderstorms, white-out, windshear;
(xv) operations conducted from control stations that are situated above 10,000 ft. ASL and associated oxygen requirements for crew members;
(xvi) performance limitations;
(xvii) securing of cargo;
(xviii) briefing procedures for persons other than crew members;
(xix) use of UAV operating instructions and standard operating procedures;
(xx) aircraft ice, frost and snow critical-surface contamination procedures;
(xxi) procedures for carriage of dangerous goods;
(xxii) fuelling procedures including:
(A) fuel contamination precautions;
(B) bonding requirements; and
(C) fuelling with engine running;
(xxiii) list of emergency and survival equipment, how to use the equipment and periodic inspection requirements;
(xxiv) emergency procedures for:
(A) command and control link;
(B) flight termination system;
(C) loss of visual contact;
(D) preparation for emergency landing/ditching;
(E) control station failures; and
(F) emergency control station evacuation;
(xxv) minimum crew members required and crew member qualifications;
(xxvi) flight time, flight duty time limitations and rest requirements;
(xxvii) training programs, including copy of company training and qualification record form(s);
(xxviii) operational support services and equipment;
(xxix) procedures related to operations including:
(A) carriage of external loads;
(B) low level flight precautions;
(C) towing precautions, pick-up and release procedures;
(D) external load procedures, including flight and ground crew signals and briefing procedures, steps to be taken before starting an external load operation, hazards of oscillating loads, low density loads and unfamiliar load configurations; and
(E) operational restrictions related to the operation.
(xxx) procedures to prevent and manage incidents of interference with UAV system command and control links; and
(xxxi) procedures to prevent and manage incidents of interference with a crew member.
(b) Standard Operating Procedures (SOPs)
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(i) The Standard Operating Procedures shall contain the following information. Where there are significant differences in equipment and procedures between the same type of UAV system operated, the SOP shall clearly indicate the UAV system it is applicable to.
(ii) Required information, if contained in another publication that is available at the control station during flight, need not be repeated in the SOP.
(iii) The SOP may form part of the operations manual.
(iv) The SOP shall contain the following as applicable to the specific UAV type.
(v) General
(A) table of contents;
(B) list of effective pages;
(C) amending procedure; and
(D) preamble.
(vi) Normal Procedures
I. assembly;
II. pre-flight tests;
III. weight and balance control requirements;
IV. take-off/launch, flight and recovery;
V. crew coordination such as standard briefings and calls and handovers;
VI. balked landing procedures;
VII. refuelling/battery charging or replacement; and
VIII. use of check lists.
(vii) Abnormal and Emergency Procedures
I. emergency landing/recovery;
II. equipment failure;
III. command and control link failure;
IV. loss of visual contact;
V. pilot incapacitation; and
VI. potential conflict with other aircraft.

These new documentation requirements will but a large workload on small operators, making it difficult for them to become compliant in a timely fashion as new documentation will need to be created in many cases.

In addition, to be a compliant operator there must also be a compliant pilot and compliant UAV.


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