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UK – EU Transition, and UK Civil Aviation Regulations

To access current UK civil aviation regulations, including AMC and GM, CAA regulatory documents, please use this link to UK Regulation. Please note, if you use information and guidance under the Headings below, the references to EU regulations or EU websites in our guidance will not be an accurate information or description of your obligations under UK law. These pages are undergoing reviews and updates.

This SAFER webpage is where the progress on Safety Recommendations (SRs) assigned to the CAA by the Air Accidents Investigation Branch (AAIB), the UK Airprox Board (UKAB) and other State Accident Investigation Authorities can be found.

To continuously learn and improve, we have reviewed how we deal with all aspects of our Safety Recommendation Management. As well as responding to SRs and acting where appropriate, our responses are independently evaluated and the through life management of the activity is now recorded and reported on centrally, providing assurance that we deliver on our commitments. Taking this one step further, we will analyse our responses and actions using bowtie methodology, ensuring that safety interventions are reflected in the bowtie Controls and that the bowties remain current.

Airprox Prefect(s) vs C208

Prefect Formation and Cessna 208 (Nr Langar)

Airprox Report No 2021121

Recommendation 2021121

Recommendation text

The MAA and CAA review conflicting Rules of the Air regulations with respect to formations of aircraft; specifically, Avoidance of Collisions within MAA RA2307 paragraph 9 and (UK) SERA.3210 Right-of-way.

Recommendation Response

The CAA accepts this safety recommendation from the UK Airprox Board (UKAB), and we note the Board’s conclusion that “each pilot was expecting the other to give way because each was operating to a different, and incompatible, regulation.”

Update Due

TBC

CAA Status

Open - Tracked Actions

Close Recommendation 2021121

Accident DJI Phanton 4 RTK

RPAS - No Registration (Newtongrange, Midlothian)

AAIB Bulletin: 6/2021 DJI Phantom 4 RTK AAIB-27058

Recommendation 2021-023

Recommendation text

It is recommended that the Civil Aviation Authority collate up to date information regarding the failure rates per flying hour for unmanned aircraft systems operating in the Recommendation text
Specific category, or previously under a CAA Permission for Commercial Operations, to facilitate effective risk assessments.

Recommendation Response

The CAA partially accepts this recommendation. Most flying hours accumulated by smaller commercial off-the-shelf UAS in the UK are carried out in the Open Category, which the CAA does not have visibility of. The CAA accepts that Open Category products like this will be used under an Operational Authorisation (OA) in the Specific Category. Regulation (EU) No. 2019/945 as retained (and amended in UK domestic law) under the European Union (Withdrawal) Act 2018 requires that the Secretary of State nominate a Market Surveillance Authority (MSA) that will have responsibility for ensuring that manufacturers adhere to appropriate standards.

Part of the remit under UK Reg (EU) 2019/945 is that the MSA will engage with the CAA on safety matters and help ensure that products are suitably safe for market and use in the UK. This coupled with the C-marking standards defined in the regulation will assist in ensuring that equipment used in the UK is of high quality, and the MSA will assist in ensuring that manufacturers continually improve their products.The collation of all flying hours across multiple product lines and manufacturers will not be feasible.

The collection of hours flown by type in the Specific Category is difficult due to the temporary nature of many applications. An Operational Authorisation is typically valid for a year, and there is no compulsion on the applicant to renew. This means that following the issue of the OA, unless Performance Based Oversight (PBO) principles means there is a requirement identified to audit or examine the applicant, the CAA may have no further contact with them. The provision of full logs is not currently a requirement under any existing legislation; only a confirmation of currency within the 3 months preceding the application or renewal.

Under UK Reg (EU) 2019/947, point UAS.SPEC.090, any holder of an Operational Authorisation must make any records available to the CAA on request. The CAA will examine whether the application and audit processes could be expanded to use this privilege to retain logs by aircraft type at the point of renewal or expiry of a Specific Cat OA.

Update Due

01/04/2022

CAA Status

Open - Tracked Actions

Close Recommendation 2021-023

Recommendation 2021-024

Recommendation text

It is recommended that, until an analysis of failure rates per flying hour has demonstrated an acceptable level of safety, the Civil Aviation Authority should consider prohibiting the overflight of uninvolved persons for those unmanned aircraft operating in the Specific category which rely solely upon their propulsion system for lift that would, following a failure of the propulsion system, impact the ground with a kinetic energy exceeding 80 Joules.

Recommendation Response

The ability to conduct a root cause analysis of the accident was frustrated by the rapid dispatch of the aircraft to the manufacturer for repair; important safety conclusions may have been missed. Neither Regulation (EU) No 376/2014 as retained (and amended in UK domestic law) under the European Union (Withdrawal) Act 2018, nor CAP722 specifically inform reporters that they should retain any material from the accident for potential investigations. The CAA will consider what advice should be added to a future draft of CAP722 regarding the preservation of evidence once suitable lines to take have been agreed with AAIB.

Overflight of people is permitted by regulation under UK Reg (EU) 2019/947. The CAA has not seen enough evidence that indicates that the prohibition of overflight of uninvolved people is a proportionate response to this accident. Authorisations to fly in congested areashave operating conditions and require a higher level of remote pilot competence to mitigate the safety risk it presents.

The CAA will conduct trend analysis of occurrence reporting and will release an appropriate message to the regulated community to reinforce good practice on how to reattach propellers and remind operators to conduct root cause analysis to close MORs.

Update Due

None

CAA Status

Closed

Close Recommendation 2021-024

Serious Incident G-LAWX

G-LAWX - Sikorsky S-92A (nr Shipston-on-Stour, Warwickshire)

AAIB Bulletin: 8/2021 G-LAWX AAIB-26196

Recommendation 2021-025

Recommendation text

It is recommended that the Civil Aviation Authority publish guidance on the meaning and intention of the phase of flight alleviations in UK SERA where detailed as “except for take-off and landing” to better enable pilots to plan and act on minimum height requirements for safe operations.

Recommendation Response

The CAA accepts this recommendation. A review of available guidance for the meaning and intention of the phase of flight alleviations in UK SERA (where detailed as “except for take-off and landing”) will be undertaken and if appropriate suitable guidance will be issued.

Update:10/02/2022

An internal working group consisting of Flight Operations policy specialists and helicopter Flight Operations Inspectors is planned to complete this review and confirm an action plan.

Update Due

July 2022

CAA Status

Open - Tracked Actions

Close Recommendation 2021-025

Recommendation 2021-027

Recommendation text

It is recommended that the Civil Aviation Authority encourage the development and deployment of Point-in-Space operations at landing sites.

Recommendation Response

The CAA accepts this recommendation. The CAA recognises safety and operational advantages are possible by developing Point-in-Space operations and will work with industry to encourage deployment through the Onshore Safety Leadership Group. However, the CAA is also cognisant that it is up to industry (operators and landing site owners) to identify most appropriate PINS applications, and that there is currently an industry cost burden in the development of such procedures which is an impediment to wider availability.

Update: 10/02/2022

Following consultation with industry, and internal discussions, we now have a better understanding of where the impediments to wider PinS adoption are. Meetings are planned in February 2022 between Flight Operations and Airspace Regulators to determine mechanisms to identify procedures that might be fast tracked due to minimal air space change requirements.

Update Due

February 2023

CAA Status

Open - Tracked Actions

Close Recommendation 2021-027

Recommendation 2021-028

Recommendation text

It is recommended that the Civil Aviation Authority revise its guidance on helicopter flight in degraded visual conditions to include further information on managing the associated risks.

Recommendation Response

The CAA accepts this recommendation and will conduct a review of its current guidance on helicopter flight in degraded visual conditions with a view to providing enhanced information on the importance of the management of associated risks as exemplified through elements of this serious incident.

Update:10/02/2022

This is tied in with the working group evaluating SR 2021-032, and expected to deliver internal recommendations on revised guidance material.

Update Due

July 2022

CAA Status

Open - Tracked Actions

Close Recommendation 2021-028

Recommendation 2021-031

Recommendation text

It is recommended that the Civil Aviation Authority ensure that operators show clear evidence within their system for operational control as required by UK ORO.GEN.110 (c), of how the tasking process separates the customer from the flight crew.

Recommendation Response

The CAA accepts this recommendation. The CAA has conducted a Specific Objectives Check (SOC) relating to operational control as required by UK ORO.GEN.110 (c) and other associated AMC and GM materials, a number of observations have been raised with operators to address any shortcomings in their systems. As a result of this recommendation and the observations raised, the CAA is reviewing their guidance to operators. The CAA will also engage with relevant industry groups to promote awareness of, and compliance with, the relevant requirements.

Update: 10/02/2022

The CAA is currently working on both a short-and longer-term solution of addressing the risks associated with distraction and undue customer pressure to crew.

Whilst there is no regulatory requirement for the tasking process to separate the flight crew from the customer, Operator’s SMS should recognise this and as such should have mitigations in place to address it. The CAA will review the affected operators` management system and ensure that it is included where relevant and then appropriately mitigated.

This item has been raised with the relevant industry groups and the CAA will continue to promote awareness through these forums.

Update Due

October 2022

CAA Status

Open - Tracked Actions

Close Recommendation 2021-031

Recommendation 2021-032

Recommendation text

It is recommended that the Civil Aviation Authority assess the safety benefits and feasibility of Helicopter Flight Data Monitoring programmes for onshore helicopter operators conducting commercial operations or non-commercial complex operations and publish its findings.

Recommendation Response

The CAA partially accepts this recommendation. The CAA recognises the benefits of the principle of Flight Data Monitoring (FDM) and would encourage Onshore Operators to establish an appropriate programme as part of their Management System. However, the CAA is also conscious of the constraints and limitations placed upon small operators and the challenges they face but will work in close collaboration with the Onshore Leadership Group to progress the safety priorities published in CAP1864 (Onshore Helicopter Review Report) in Nov 2019 including the consideration for FDM for all commercial operations and non-commercial complex helicopter operations.  If it was so determined that FDM should be mandated for this sector then this would involve the development of a new Rule Making task which would include a full safety and cost benefit analysis that would necessarily involve public consultation and justification.

Update: 10/02/2022

This item has been raised informally with industry, but more work is required to understand the potential benefits for small fleet sizes (typical with this sector) and the types of operation conducted. External subject matter experts are being considered to assist with this project.

Update Due

July 2022

CAA Status

Open - Tracked Actions

Close Recommendation 2021-032

Serious Incident G-POWN

G-POWN - Airbus A321-211 (Gatwick Airport)

Aircraft Accident Report: 1/2021 G-POWN AAIB-26436

Recommendation 2021-022

Recommendation text

It is recommended that the Civil Aviation Authority (CAA), during future audits of CAA-approved Continued Airworthiness Management Organisations and Approved Maintenance Organisations, include a check that consideration has been given to the classification of biocide treatment of aircraft fuel systems as a critical maintenance task.

Recommendation Response

The Civil Aviation Authority (CAA), as part of its future audit oversight programme for Continued Airworthiness Management Organisations and Approved Maintenance Organisations, will review the use of critical maintenance task methods and procedures highlighting to organisations, including the classification of biocide treatment of aircraft as indicated within the AAIB Report. This will include the need to follow the guidance material as set out in GM M.A.402(h) or AMC2 145.A.48(b) for data sources used for the identification of critical maintenance tasks which includes accident reports.

As an additional mitigation the CAA will amend its guidance material on the creation and amendment of Aircraft Maintenance Programmes to include additional guidance on identification of critical maintenance tasks highlighting the above mentioned regulatory references and the need to place additional focus on Biocide treatment of aircraft.

As the regulatory framework within the UK is now separated from that of the EU, the CAA will also instigate a rulemaking task to amend the AMC as indicated in safety recommendation 2020-018 and 2020-019 for the UK legislation.

Update Due

December 2022

CAA Status

Open - Tracked Actions

Close Recommendation 2021-022

Serious Incident G-ZBKF

G-ZBKF

AAIB Bulletin: 5/2021 G-ZBKF AAIB-26975

Recommendation 2021-017

Recommendation text

It is recommended that the Civil Aviation Authority require that passenger seats in commercial air transport aircraft are designed to minimise the chance of portable electronic devices becoming crushed in mechanisms.

Recommendation Response

The Civil Aviation Authority (CAA), as part of its future audit oversight programme for Continued Airworthiness Management Organisations and Approved Maintenance Organisations, will review the use of critical maintenance task methods and procedures highlighting to organisations, including the classification of biocide treatment of aircraft as indicated within the AAIB Report. This will include the need to follow the guidance material as set out in GM M.A.402(h) or AMC2 145.A.48(b) for data sources used for the identification of critical maintenance tasks which includes accident reports.

The CAA partially accepts this recommendation and supports the Safety Action taken by EASA in regard to requesting the SAE International Seat Committee develop design standards and/or recommended practices in relation to the design of seats for commercial air transport aircraft to minimise the chance of portable electronic devices becoming crushed in mechanisms.

Evolution of  seat design standards will benefit from a global position and the CAA will work with the international regulatory community to review supporting evidence and global data that may support future amendments to global and UK Certification Specification and/or recommended practices.

Update: 31/01/2021

The CAA has continued to strengthen the UK State of Design capability recruiting Design Specialists who will be able to engage with other authorities and seek participation in the SAE International Seat Committee to the design of seats for commercial air transport aircraft and where appropriate to make recommendations to minimise the chance of portable electronic devices becoming crushed in mechanisms.

The evolution of seat design standards will only be effective when agreed on a global basis. The UK CAA will continue to work with other lead international regulatory authorities to review and support future amendments and updates to the Certification Specifications and /or recommended practices.

The CAA continue to monitor similar PED entrapment events through the requirements of CAA Regulation (EU) 376/2014(as retained and amended in UK domestic Law under the European Union withdrawal Act 2018) and through its engagement in the SAE committee. Currently the CAA do not envisage an immediate change to the Certification Specifications or Recommended Practices to aircraft seat design. We will continue to monitor progress and changes through the SAE working group

Update Due

September 2022

CAA Status

Open - Awaiting response

Close Recommendation 2021-017

Airprox RV9/Phenom

Vans RV9 & Embraer Phenom 100 (Turweston)

AIRPROX REPORT No 2020167

Recommendation 2020-167

Recommendation text

The CAA conducts a review to establish the reasons behind why many training airfields chose not to maintain their ATZ when the requirement to hold an aerodrome licence to conduct training activity was removed. Where whose reasons fall within the competency of the CAA - take appropriate action to mitigate against any increase in risk associated with the removal of the protection previously afforded to them (by an ATZ).

Recommendation Response

In responding to the recommendation, it is worth reviewing the background.

In April 2010, the Air Navigation Order (ANO) was amended to allow some forms of flying training activity to be undertaken at unlicensed aerodromes. This followed recommendations from the CAA's Light Aviation Airports Study Group (LAASG) - that was formed jointly with industry in 2005 - to consider changes to regulation specific to light aviation. Research conducted by the LAASG indicated that neither ICAO nor the then extant Joint Aviation Authority (JAA) requirements required flight training or testing for a licence, rating or certificate to be conducted from a certificated or licensed aerodrome. After analysing the available safety data, the LAASG concluded that there was no justifiable safety case to require flight training in light aeroplanes and light helicopters to be undertaken at a licensed aerodrome. Industry members of the LAASG cited the cost of maintaining an aerodrome licence as a disincentive to the flying training sector.

As a consequence of the LAASG's work, detailed proposals were developed by the Flying Training Sub-Group (FTSG) (comprising members of the CAA and industry representatives from the LAASG) to remove the requirement for flying training to be conducted at licensed aerodromes. These proposals were consulted upon and subsequently enacted through amendments to the ANO. This change prompted a number of aerodrome operators to opt to surrender their aerodrome licence, with evidence indicating that this was done in order to reduce costs.

To the first element of the UKAB's recommendation regarding the aerodrome traffic zone (ATZ), the 'Letter of Intent' to amend the ANO was published in February 2010. It specifically described the implications for an ATZ should an aerodrome choose to surrender their aerodrome licence, stating:

“Whilst there is an indirect link between a[n aerodrome] licence and the establishment or maintenance of an ATZ the primary driver is the level of air traffic service - air traffic control (ATC), aerodrome flight information service (AFIS) - or air/ground support established at an aerodrome. Unless supported by ATC or AFIS, an ATZ will be withdrawn on revocation of the aerodrome licence. Whereas a licensed aerodrome - with an associated ATZ - need only be served by a “means of two-way radio communication” (air/ground), an unlicensed aerodrome requires the support of an ATC or AFIS unit. The difference is associated with regulatory oversight. An unlicensed aerodrome and an unregulated 'service' (air/ground) would give the CAA no process to ensure that the airspace was being appropriately managed. In order to prevent such a situation an unlicensed aerodrome will need a minimum of AFIS for the establishment or maintenance of an ATZ to be considered. Promulgation of ATZs at aerodromes that are not licensed is not an issue. Such ATZs already exist (mainly in association with Government aerodromes) and are promulgated in the AIP at ENR 2.2.”

This text refers to long-standing CAA policy that the combination of “an unlicensed aerodrome and an unregulated aeronautical radio station” (i.e. providing an air/ground communications service (AGCS)) would result in an unacceptable lack of regulatory oversight aimed at ensuring that the airspace was being appropriately managed.

It is important to thus highlight that individual aerodrome operators chose whether to surrender their aerodrome licence, with many choosing to retain their licence. In those cases where aerodromes chose to surrender their licence, based on the evidence available, it appears that the decision was based, primarily, on the grounds of cost, and was made fully cognisant that a consequence of that decision would be the loss of the ATZ (where an air traffic service was not provided).

In terms of safety risk(s), one critical aspect of the changes to the ANO was the requirement for the commanders of aircraft, and the operators of aerodromes, being used for flying training to satisfy themselves that the aerodrome is safe for that purpose. In order to assist aircraft commanders and aerodrome operators in fulfilling this requirement, the CAA published CAP 793 'Safe Operating Practices at Unlicensed Aerodromes'.

CAP 793 states that “where flying training is taking place, additional safety margins should be considered”, emphasising the ANO Article 209 requirement. CAP 793 goes further, recommending that “adequate risk assessments are made and documented before flying training takes place”, and highlighting that “such documented risk assessments may be necessary to prove to the CAA and other authorities in the event of an accident or incident that an aircraft commander or aerodrome operator has had sufficient grounds to be satisfied that the aerodrome is safe for flying training”.

The CAA expects that such risk assessments would consider issues such as the nature of the flying operations at the aerodrome, the local airspace and its complexity and the need for the protection afforded by an ATZ in determining that the aerodrome is a safe environment for the conduct of flying training. We would also anticipate that those risk assessments are subject to ongoing review, in accordance with the aerodrome or aircraft operator's safety management systems, to ensure that the risks continue to be tolerable and mitigated to a level that is as low as reasonably practicable.

Whilst the CAA seeks to influence beyond our established Regulatory authority, for the purpose of this response, it is perhaps useful to describe the extent of that authority vis-a-vis aviation activities at unlicensed aerodromes. Our oversight teams have no regulatory remit for aerodrome oversight (with the exception of the storage and dispensing of fuel), nor are they resourced for routine oversight of the provision of AGCS. The General Aviation Unit (GAU) does undertake oversight of approved and declared training organisations (ATO and DTO respectively) at unlicensed aerodromes but their remit is limited.

ATOs are required to establish, implement and maintain a management system that includes the identification of aviation safety hazards entailed by the activities of the organisation, their evaluation and the management of associated risks, including taking actions to mitigate the risk and verify their effectiveness. Where the ATO operates from an unlicensed aerodrome, the GAU reminds them of their responsibilities under Article 209, which includes a specific assessment of the risk to circuit traffic in the absence of an ATZ.

Whilst the GAU reminds DTOs of their responsibilities under Article 209, there is no explicit requirement placed upon them to consider aviation safety hazards in the same way as for ATOs. A DTO is required to develop and establish a safety policy which ensures that the DTO's activities are carried out safely, and thus consider the hazards to their operations.

A review of our oversight intelligence indicates that:

  • whilst ATOs that operate from unlicensed aerodromes have identified airborne conflict in the aerodrome traffic circuit as a risk, those ATOs consider the risk to be tolerable. In some cases, the stated mitigation is that the aerodrome is depicted as a training aerodrome on the aeronautical chart(s);
  • where we have undertaken audits of DTOs at unlicensed aerodromes , some of those organisations had not considered the risk of airborne conflict in the aerodrome traffic circuit. They have been asked to consider this in discharging their responsibilities under Article 209 and Part-DTO. That said, we are aware that, following airprox 2018319, Hull Aero Club at Beverley contacted local military airfields to raise awareness of their location.

It is important to note that, where the operator of an unlicensed aerodrome believes that an ATZ may be a viable mitigation to perceived safety risk(s), the option to establish an ATZ remains open. Subject to the provision of an air traffic service (either ATC service or AFIS), unlicensed aerodromes may seek to establish a ATZ in accordance with CAA Policy on Aerodrome Traffic Zones (ATZ). This states that the establishment of an ATZ will be progressed as a Level 2C airspace change in accordance with CAP 1616.

On 23 October 2020, CAP 1886 “UK Approach to Recreational General Aviation Safety: An Independent Review” was published. This work, commissioned and funded by the Department for Transport, concluded that “the current safety level of recreational General Aviation in the UK is acceptable viewed in terms of its unavoidably greater risk than commercial aviation, the much higher risk acceptability of voluntary activities and in comparison, with other high-risk activities”. It went on to say that “Additional regulation is not justified and is unlikely to significantly improve safety”.

Given the limited oversight levers and the restricted latitude offered the CAA by the conclusion drawn in CAP 1886, the remaining course of action open to the CAA would be to review CAA policy vis-a-vis the notification of an ATZ at an unlicensed aerodrome where an air traffic service is not provided. As previously stated, the CAA's established position is that such an arrangement would not currently receive an acceptable level of regulatory oversight to ensure that the ATZ was being appropriately managed. Moreover, it is worth highlighting that a very course analysis of incident data, including the UKAB's own data, indicates that there may be underlying issues at such unlicensed sites that our current level of regulatory oversight is both unable to investigate and address. It should also be noted that the granting of an ATZ other than at a licensed (or certificated) aerodrome would (as a solution) generate multiple 'knock on' impacts.

Nevertheless, the CAA undertakes to review its position regarding what we would consider to be an acceptable level of regulatory oversight for the purposes of airspace management, and we will report back to the UKAB once that work is completed. Please accept this as our initial response to your recommendation.

Update Due

TBC

CAA Status

Open - Tracked Action

Close Recommendation 2020-167

Accident Alauda AS MkII

RPAS - No Registration (Goodwood Aerodrome)

AAIB Bulletin: 3/2021 Alauda Airspeeder Mk II AAIB-25876

Recommendation 2021-002

Recommendation text

It is recommended that the Civil Aviation Authority update Civil Aviation Publication 722; Unmanned Aircraft System Operations in UK Airspace - Guidance & Policy, to require detailed evaluation of any Unmanned Aircraft Systems that use onboard systems to mitigate risks with a Risk Severity Classifications of 'Major', 'Hazardous' or 'Catastrophic'.

Recommendation response

The CAA accepts this recommendation:
The RPASU has recruited an RPAS Technical Inspector with a specific background in airworthiness and avionics engineering, who has spent recent years working as an SMS and safety specialist for complex RPAS operations.  This allows the RPAS Sector Team (RPASST), who have responsibility for the assessment of Operating Safety Cases (OSCs), to deploy in-house airworthiness experience for the analysis of specific aircraft or systems.

A policy has been built and will be approved in the near future to trigger the involvement of other capability areas when in-house expertise is insufficient, calling on resources from the CAA's Cyber and Airworthiness capability teams.  The other capability teams will be consulted on 'triggers' that would result in their involvement being requested, so they are able to help inform if assistance is required.  If an onboard system is used to mitigate a risk originally classified as Major or above, the internal and external airworthiness experts will be specifically consulted.

Coincidentally with,  but not as a result of, the accident, the risk assessment  process  and  methodology was moved from its location as Appendices B, C and D of CAP 722, into its own, self-contained document entitled “CAP 722A - Unmanned Aircraft System Operations in UK Airspace - Operating Safety Cases”; This move took place in July 2019 and some elements of content were updated at the time.  As a result, this recommendation is interpreted to apply to CAP 722A rather than the 'parent' CAP 722 document. 

As a result of the introduction of the new UAS regulations, which became applicable on 31 December 2020, the CAA has been undertaking a wholesale update of CAP 722A to be published during Spring 2021.  The points relating to this recommendation will included in this update.

The new edition of CAP 722A will also include the Specific Operations Risk Assessment (SORA) methodology, affirming the CAA's aim to meet safety objectives to continue to mitigate these risks.

Update: 20/12/2021

A new series of publications to replace CAP722A is scheduled for publication in summer 2022. This will address all the above recommendations.

Update due

August 2022

CAA status

Open - Tracked Actions 

Close Recommendation 2021-002

Recommendation 2021-003

Recommendation text

It is recommended that the Civil Aviation Authority update Civil Aviation Publication 722, Unmanned Aircraft System Operations in UK Airspace - Guidance & Policy, to provide guidance on the planning, completion and documenting of Radio Frequency surveys to reduce the risk of Radio Frequency interference or signal loss when operating Unmanned Aircraft Systems.

Recommendation response

The CAA accepts this recommendation:

CAP 722A; Unmanned Aircraft Operations in UK Airspace - Operating Safety Cases; is the source document that provides guidance to applicants in the specific category on what should be included in an OSC that supports their application.  Guidance detailing possible methods to prove how robust a Command and Control (C2) link is will be provided and the potential efficacy of RF surveys will be highlighted, although the emphasis will be on the requirement for the applicant to prove and evidence a secure link. 

As noted in the response to SR2021-002 above. CAP 722A has replaced the text that was previously contained within CAP 722's Appendices B, C and D; as a result, this recommendation is interpreted to apply to CAP 722A rather than the 'parent' CAP 722 document.

As a result of the introduction of the new UAS regulations, which became applicable on 31 December 2020, the CAA has been undertaking a wholesale update of CAP 722A to be published during 2021.  The points relating to this recommendation will included in this update.

Update: 20/12/2021

A new series of publications to replace CAP722A is scheduled for publication in summer 2022. This will address all the above recommendations.

Update due

August 2022

CAA status

Open - Tracked Actions 

Close Recommendation 2021-003

Recommendation 2021-004

Recommendation text

It is recommended that the Civil Aviation Authority require Unmanned Aircraft System operators, that use unmanned aircraft which rely on a radio link to operate safety systems, to provide Radio Frequency survey reports to the Civil Aviation Authority for review, to ensure they are suitable and sufficient.

Recommendation response

The CAA partially accepts this recommendation:

Following the advice to be published in response to SR2020-003 above, any RF surveys or similar produced must be made available to the CAA on request. The new UAS Regulations include a requirement for any documentation to be made available to the CAA on request. 

If an RF survey has been stated as a mitigating factor to reduce the risk of a C2-related failure, or to support the use of an RF-enabled safety system as per this accident, then proof of example surveys will be required as part of the approval process.  Reference to RF surveys, methodology for conducting them, and their suitability as a safety mitigation has been added to the RPASST checklist for assessing audits.

For other typical cases, the RPASST have added to their renewal assessment audit checklist an opportunity to request examination of example RF survey reports to check compliance.

Update: 20/12/2021

If an Operator relies on a technical safety feature which requires RF triggering, following the incident that generated these recommendations, it is unlikely to be accepted. Only systems that fail safe or activate in the event of a loss of link would be considered as acceptable.
If a loss of RF link, or an inability to establish a link, would result in an unsafe condition, then a comprehensive approach to RF surveys would be required and would be assessed. The RPAS Sector Team are producing an appropriate policy. An initial internal action has been identified to liaise with a spectrum specialist in the CNS team at the CAA to understand what a good RF survey may look like.

The likelihood of this type of requirement appearing is considered very small given the lessons learned from the Alauda Airspeeder incident.

Update due

July 2022

CAA status

Open - Tracked Actions

Close Recommendation 2021-004

Recommendation 2021-005

Recommendation text

It is recommended that the Civil Aviation Authority update Civil Aviation Publication 722, Unmanned Aircraft System Operations in UK Airspace - Guidance & Policy, with guidance on how to define an Unmanned Aircraft System's operational and safety areas, using up-to-date maps, accurate trajectory analysis and human or automated safety system reaction times, to ensure a safe operation.

Recommendation response

The CAA accepts this recommendation:

The RPAS Policy Team (RPASPT) will introduce this in a future edition of either CAP 722 or one of its subordinate documents.

Reference is already made in CAP722A to aeronautical charts and the AIP, and it makes clear that 'non-established' sites require an assessment for suitability; however, it does not make clear what a 'non-established' site is, and therefore when a site assessment is not required. Furthermore, it does not make clear that any digital imagery (Google maps etc) used must be verified as being correct, and that site layouts (particularly aerodromes) may change, since digital imagery was captured.

The CAA will update CAP 722A to clarify these points and will ensure that these aspects are fully considered when assessing future risk assessments.

CAP 722A provides limited guidance in regard to the use of trajectory estimation when determining the emergency buffer zone around the flight volume. The CAA will update CAP 722A with further guidance on this, and the inclusion of reaction times where manual systems are involved. The updated CAP 722A also introduces the concept of operational volume, and emergency buffer, including factors to take into account when determining their size.  The operational volume is the area within which the RPAS operation is planned to be contained within, while the emergency buffer is an extension to this area that may be used, but only in the event of a failure.

Update: 20/12/2021

A new series of publications to replace CAP722A is scheduled for publication in summer 2022. This will address all the above recommendations.

Update due

August 2022

CAA status

Open - Tracked Actions 

Close Recommendation 2021-005

Recommendation 2021-006

Recommendation text

It is recommended that the Civil Aviation Authority update Civil Aviation Publication 722; Unmanned Aircraft System Operations in UK Airspace - Guidance & Policy, to require detailed evaluation of any Unmanned Aircraft Systems that use onboard systems to mitigate risks with a Risk Severity Classifications of 'Major', 'Hazardous' or 'Catastrophic'.”

Recommendation response

The CAA accepts this recommendation:

The existing guidance on RPAS safety systems is included in CAP 722A Section 2, para 1.13.  This will be expanded during the rewrite occurring in early 2021.  The safety improvement provided by multiple, layered safety systems will be emphased.  Examples of some typical mass-market systems such as ballistic recovery systems will be included.

Internal audit checklists referring to the technical volume of OSCs already required the auditor to assess whether any safety systems are appropriately installed and maintained. 

Examples of some typical mass-market systems such as ballistic recovery systems will be included.

Update: 20/12/2021

A new series of publications to replace CAP722A is scheduled for publication in summer 2022. This will address all the above recommendations.

Update due

August 2022

CAA status

Open - Tracked Actions 

Close Recommendation 2021-006

Recommendation 2021-007

Recommendation text

It is recommended that the Civil Aviation Authority introduce requirements to define a minimum standard for safety systems to be installed in Unmanned Aircraft Systems operating under an Operational Authorisation, to ensure adequate mitigation in the event of a malfunction.

Recommendation response

The CAA partially accepts this recommendation:

The current OSC methodology in CAP722A for managing risk already considers operational and technical mitigations in the event of any failure or hazard and assesses whether they are appropriate. Additionally, the RPASPT have pointed out that the CAA does not make regulations, this is the remit of DfT; their recommendation was that we consider the introduction of a policy that states we will adopt standards for UAS safety systems as they are developed and become available.

However, due to the very wide range of possible operations within the Specific category, the use of 'safety systems' per se will not be necessary for every operational authorisation.

As yet, no relevant minimum standards for the safety systems referred to in this recommendation have been defined; once the appropriate safety system standards have been are developed and become available, we will consider the introduction of an appropriate requirement where it is considered necessary.

Where the use of a safety system has been stated as a safety mitigating factor in a risk assessment, the minimum performance requirements of that safety system will be included as a condition of the resultant operational authorisation that is issued.

Update: 20/12/2021

Primary safety modes such as the use of lost link 'return to home' modes in system software are not yet subject to certification. Other systems such as ballistic recovery & parachute systems may adhere to standards such as ASTM F3322-18, but this is not mandatory and the number of available systems on the market that adhere to this is low.

The RPAS Sector Team have begun to request any evidence that any systems used on a UAS for safety purposes adhere to any standard and are building a library of relevant standards as cases begin to present them. This process is potentially complicated by the development of the Certified Category which may mandate standards for some systems, and the conflict between standards released by competing bodies such as EUROCAE, ASTM, ISO and BSI. Nevertheless, any standards that are produced and identified will be considered for inclusion in any guidance material.

The RPAS Sector Team already consider the robustness of any safety mitigation measure, in terms of its performance and integrity. All mitigations provided by technical systems are assessed to check:
• Performance relative to claimed reductions in severity
• Position and relevance in any bow ties or fault tree diagrams
• Integrity of function and assurance that the mitigation will function as claimed at all times or with an appropriate MTBF
• Its overall position within the Safety Risk Assurance Process, to understand how the applicant has formally assured the above, as well as how they selected the system as an appropriate mitigation.

As the Specific Category works on a case-by-case basis, every safety system is assessed individually for the use case described by the UAS Operator. Rather than a minimum performance requirement, each mitigation is checked to see if it achieves the claimed level of performance, and whether it can function as a mitigation as described.

Update due

January 2023

CAA status

Open - Tracked Actions

Close Recommendation 2021-007

Recommendation 2021-008

Recommendation text

It is recommended that the Civil Aviation Authority require Unmanned Aircraft System operations under an Operational Authorisation to be fitted with a data recording system which is capable of demonstrating: compliance with the Authorisation's conditions, safe operation and the logging of any failures which may affect the safe operation of the Unmanned Aircraft System.

Recommendation response

The CAA partially accepts this recommendation

The RPASST checklists for initial audits include a requirement to check whether an applicant can measure and maintain the limitations they are applying for. Where no direct metric (such as speed in m/s) is available, the authorisation will be written to reflect an example speed such as “a fast walking pace.”

Due to the very wide range of possible operations within the Specific category, for which an operational authorisation is required, and the wide range of RPAS types that may be used, it would not be practicable, nor indeed proportionate, to require a data recording system to be fitted in every case. It is for this reason that data recording is not mandated within the Specific category.

Most of the smaller RPAS types that are on the market, and presently fill the majority of the specific category operations we see in the UK, have the ability to log some forms of operational data within the system. But this is not generally a capability that can be activated, or subsequently installed, by the UAS operator. In addition, it is already a condition of all operational authorisations that records of all operations are maintained for audit purposes.

However, when considering the larger, more bespoke, RPAS types such as those that are similar to the subject of this accident, then it would be appropriate to require additional data recording capabilities to be included as the complexity of both the RPAS and the type of operation increases. This will be covered within the revised CAP 722A document.

Update: 20/12/2021

A new series of publications to replace CAP722A is scheduled for publication in summer 2022. This will address all the above recommendations.

Update due

August 2022

CAA status

Open - Tracked Actions 

Close Recommendation 2021-008

Recommendation 2021-009

Recommendation text

It is recommended that the Civil Aviation Authority specify the minimum requirements for the monitoring of Unmanned Aircraft System high-voltage stored energy devices, to ensure safety of operation.

Recommendation response

The CAA accepts this recommendation:

The policy will need to be developed and included in a future guidance document.  The new airworthiness-focused Inspector on the RPASST will help with current assessments of battery use, carriage and storage for applications, and any application with “self-made” (i.e. non-COTS) batteries will be exposed to extra scrutiny. 

In the meantime, an increased focus on this subject will be made during audits and any pre-authorisation assessment visits.

Update: 20/12/2021

A new series of publications to replace CAP722A is scheduled for publication in summer 2022. This will address all the above recommendations.

Update due

August 2022

CAA status

Open - Tracked Actions 

Close Recommendation 2021-009

Recommendation 2021-010

Recommendation text

It is recommended that the Civil Aviation Authority specify the minimum requirements for readily identifiable warnings and safety information on Unmanned Aircraft high-voltage stored energy devices to inform 3rd parties of the potential hazard.

Recommendation response

The CAA accepts this recommendation

These minimum requirements will require development and consideration of the most appropriate location for this guidance, either within the technical chapter of CAP 722, or in a separate document.

In addition, this aspect would be required to be included within the risk assessment provided by the UAS operator and this will be covered within the revision to CAP 722A. An increased focus on this will be made during pre-authorisation assessments and, where appropriate, will be included as a condition of the operational authorisation.

Update: 20/12/2021

A new series of publications to replace CAP722A is scheduled for publication in summer 2022. This will address all the above recommendations.

Update due

August 2022

CAA status

Open - Tracked Actions 

Close Recommendation 2021-010

Recommendation 2021-011

Recommendation text

It is recommended that the Civil Aviation Authority ensure that operators of Unmanned Aircraft Systems have an effective Safety Management System in place prior to issuing an Operational Authorisation.

Recommendation response

The CAA partially accepts this recommendation

CAP 722 already covers elements of SMS that operators could use for best practice and to manage safety risks.

The regulation only states a requirement for an SMS for Light UAS Certificate (LUC)approval holders under Part C UAS.LUC.030 of the Implementing Regulations for UAS. Due to the very wide range of possible operations within the Specific category for which an operational authorisation is required, it would not be practicable, nor indeed proportionate, to require every UAS operator to have a safety management system in place.

The RPASST exercise a proportional, performance based approach to applications, and required that elements of an SMS such as functional reporting and investigation processes are included as the complexity of the RPAS and operation increase.

Update due

None

CAA status

Closed

Close Recommendation 2021-011

Recommendation 2021-012

Recommendation text

It is recommended that the Civil Aviation Authority, before issuing an Operational Authorisation to operate an Unmanned Aircraft System they have not previously had experience with, carry out a physical examination of the Unmanned Aircraft System to ensure that it is designed and built to suitable standards, and observe a test flight to confirm operation in accordance with the Operating Safety Case.

Recommendation response

The CAA partially accepts this recommendation:

When considering larger, more bespoke RPAS types such as the subject of this accident, then this is the approach that will be taken. However, in other cases, dependent on the type of operation that is being authorised, such an approach may prove to be impractical.

Where any features of design and construction have been included as mitigations in any risk assessment, then it would be appropriate for a pre-flight physical examination and an observation of an initial test flight to be conducted (bearing in mind that any test flight also requires an Operational Authorisation to be issued).

The RPASST will apply Performance Based Oversight (PBO) principles in order to target resource to risk. When a new platform is used that is likely to attract a high risk score, it will be prioritised for both physical direct inspection from an airworthiness Inspector and a flight test depending on the likely requirements. Even with COTS systems, the RPASST will use PBO to assess dynamically whether applications need a demonstration or test flight to show the requisite safety levels.

The RPASST also carry out sector-level reviews of risk metrics to help assess where PBO assets are best deployed.

Update due

None

CAA status

Closed

Close Recommendation 2021-012

Recommendation 2021-013

Recommendation text

It is recommended that the Civil Aviation Authority update Civil Aviation Publication 722, Unmanned Aircraft System Operations in UK Airspace - Guidance & Policy, to include reference to the consequences of not complying with the conditions of an Operational Authorisation to operate an Unmanned Aircraft System.

Recommendation response

The CAA accepts this recommendation

The Air Navigation (Amendment) Order 2020 (SI 2020/1555) introduced a number of new articles into the Air Navigation Order 2016. These create criminal offences, if the requirements of the UAS regulations that became applicable on 31 December 2020 are not complied with, along with the associated penalties.

This amendment was explained in guidance for UAS users within CAP 2013 (published 17 December 2020) and has been included in amendment 2021/01 to CAP 722 Chapter 4, Section 4.1.3 (March 2021).

Update due

None

CAA status

Closed

Close Recommendation 2021-013

Recommendation 2021-014

Recommendation text

It is recommended that the Civil Aviation Authority adopt appropriate design, production, maintenance and reliability standards for all Unmanned Aircraft Systems with aircraft capable of imparting over 80 joules of energy.

Recommendation response

The CAA partially accepts this recommendation

This is covered within the Delegated Regulation for Open Category UA and for the Specific Category work is ongoing within a number of standards bodies, including EUROCAE, ASTM and RTCA. The CAA will review standards as they become available and decide on the frameworks required to adopt these from a regulatory perspective.

Update: 20/12/2021

There is currently no standard of this type agreed upon and accepted by the CAA. While some generic standards that could be utilised have been generated, such as ASTM F2910-14 (Standard Specification for Design and Construction of a Small Unmanned Aircraft System), ASTM F3002-14a (Standard Specification for Design of the Command and Control System for Small Unmanned Aircraft System), and ASTM F2909-19 (Standard Specification for Continued Airworthiness of Lightweight Unmanned Aircraft Systems), the decision to accept these into UK use and relevant publications would need to be managed in concert with the CAA’s work on the development of the Certified Category.

In the Specific Category, procedures within the RPAS Sector Team have changed so that applicants are advised to demonstrate adherence to any relevant standards when able. No standards will be automatically accepted as proof of compliance with regulation, but conformance with any relevant standard shows a degree of safety assurance.

Update due

January 2023

CAA status

Open - Tracked Actions

Close Recommendation 2021-014

Accident G-SPAO

G-SPAO - EC135 T2+ (Glasgow)

AAIB Report: Aircraft Accident Report AAR 3/2015 - G-SPAO, 29 November 2013

Recommendation 2015-032

Recommendation text

It is recommended that the Civil Aviation Authority requires all helicopters operating under a Police Air Operators Certificate, and first issued with an individual Certificate of airworthiness before 1 January 2018, to be equipped with a recording capability that captures data, audio and images in crash-survivable memory. They should, as far as reasonably practicable, record at least the parameters specified in The Air Navigation Order, Schedule 4, Scale SS(1) or SS(3) as appropriate. They should be capable of recording at least the last two hours of (a) communications by the crew, including Police Observers carried in support of the helicopter's operation, and (b) images of the cockpit environment. The image recordings should have sufficient coverage, quality and frame rate characteristics to include actions by the crew, control selections and instrument displays that are not captured by the data recorder. The audio and image recorders should be capable of operating for at least 10 minutes after the loss of the normal electrical supply.

Recommendation response

The CAA accepts this recommendation and, subject to an impact assessment and liaison with the police operators, will require all helicopters operating under a Police Air Operators Certificate with a maximum take-off mass (MTOM) of more than 2,730 kg and first issued with an individual Certificate of Airworthiness before 1 January 2018, to be equipped with a recording capability that captures data, audio and flight deck images in crash-survivable memory. In order to put any change into effect, the CAA will need to amend General Exemption E4111 for the fitment of recorders to helicopters with a MTOM between 2,730 and 3,175 kg and the requirements for police helicopters with a MTOM greater than 3,175 kg. The CAA will work with the affected operators to agree a means of compliance for individual types in line with ICAO standards and recommended practices and ensure that appropriate protection provisions are afforded for image recordings. The CAA will also review, and amend as necessary, associated CAPs and CAA Specifications, for flight recorders. Introduction of amended requirements is expected to be completed by 3rd Quarter 2016.

Recommendation response update May 2021

The AAIB Safety Recommendations 2015-032 and 033 recommended that the CAA require certain helicopters operating under a Police Air operator Certificate to be fitted with flight recorders including cockpit image recorders (airborne image recorder (AIR)).  Additionally, SR 2015-034 recommended that the CAA consider requiring State aircraft not already covered by SR 2015-032 and 033 to be fitted with flight recorders, including cockpit image recorders.  

The CAA conducted a focused consultation in 2016 with Police and SAR operators considering the various options for all the SRs and determined the way forward cognisant also of the feedback from industry. In response to SR 2015-034 specifically, it was decided not to pursue changes to State aeroplane equipment requirements but that it would be appropriate to align the requirements and meet the safety intent of the SRs for all State helicopters. The State SAR helicopters under contract with the UK Maritime Coastguard Agency (MCA) were already required to be equipped with FDR/CVR and therefore the alignment was limited to the fitment of airborne image recorders.

To implement the necessary requirements, the CAA issued Safety Directive 2016-006 detailing the type and level of equipment to be fitted to current and future helicopters operating as State aircraft.  CAA Specification 23 was also introduced to provide detailed information on the technical requirements for the equipment and fitting.  However, due to some difficulties experienced by the operators in procuring and fitting the equipment, the compliance dates had to be extended and SD 2018-002, now superseded by 2020-001, were issued.  The operators are now meeting the following equipment requirements mandated by the SD:

1. Helicopters with an individual Certificate of Airworthiness first issued before 1 January 2019 shall from 1 August 2021. 

(a) for those with a maximum take-off mass (MTOM) of more than 2,730 kg but not more than 3,175 kg, be fitted with a Class A airborne image recording system (AIRS) except those which have a Class C AIRS; or 

(b) for those with a MTOM more than 3,175 kg, be fitted with a Class A airborne image recorder (AIR). 

2. Helicopters with an individual Certificate of Airworthiness first issued on or after 1 January 2019 shall: 

(a) for those with a MTOM of more than 2,730 kg but not more than 3,175 kg, be fitted with a Class A AIRS; or 

(b) for those with a MTOM more than 3,175 kg, be fitted with a Class A AIR.

The CAA will incorporate these requirements into amendment of the scales of equipment for such operations in the Air Navigation Order at the next suitable opportunity.  Once done, this will provide for the SD to be revoked. 

Update: 19/05/2022

The CAA's response to this AAIB recommendation is currently being managed through the application of an Operational Directive: SD–2020/001. In due course an amendment will be made to the ANO. This may form part of a wider review of the ANO and the future regulatory framework in the UK.

Update due

May 2023

CAA status

Open - Tracked Actions

Close Recommendation 2015-032

Recommendation 2015-033

Recommendation text

It is recommended that the Civil Aviation Authority requires all helicopters operating under a Police Air Operators Certificate, and first issued with an individual Certificate of Airworthiness on or after 1 January 2018, to be fitted with flight recorders that record data, audio and images in crash-survivable memory. These should record at least the parameters specified in The Air Navigation Order, Schedule 4, Scale SS(1) or SS(3), as appropriate. They should be capable of recording at least the last two hours of (a) communications by the crew, including Police Observers carried in support of the helicopter's operation, and (b) cockpit image recordings. The image recordings should have sufficient coverage, quality and frame rate characteristics to include control selections and instrument displays that are not captured by the other data recorders. The audio and image recorders should be capable of operating for at least 10 minutes after the loss of the normal electrical supply.

Recommendation response

The CAA accepts this recommendation and, subject to an impact assessment and liaison with the police operators, will require all helicopters operating under a Police Air Operators Certificate and first issued with an individual Certificate of Airworthiness on or after 1 January 2018, to be equipped with a recording capability that captures data, audio and images in crash-survivable memory. To achieve this in the suggested timescale, the CAA will consider making a Direction to that effect but will also, as part of a wider review of the Air Navigation Order (ANO), prepare amendments to the flight recorder requirements that align with ICAO standards and recommended practices and European standards including the appropriate protection provisions for image recordings. The CAA would anticipate this change being addressed within the planned 2016 ANO amendment cycle.

Recommendation response update May 2021

The AAIB Safety Recommendations 2015-032 and 033 recommended that the CAA require certain helicopters operating under a Police Air operator Certificate to be fitted with flight recorders including cockpit image recorders (airborne image recorder (AIR)).  Additionally, SR 2015-034 recommended that the CAA consider requiring State aircraft not already covered by SR 2015-032 and 033 to be fitted with flight recorders, including cockpit image recorders.  

The CAA conducted a focused consultation in 2016 with Police and SAR operators considering the various options for all the SRs and determined the way forward cognisant also of the feedback from industry. In response to SR 2015-034 specifically, it was decided not to pursue changes to State aeroplane equipment requirements but that it would be appropriate to align the requirements and meet the safety intent of the SRs for all State helicopters. The State SAR helicopters under contract with the UK Maritime Coastguard Agency (MCA) were already required to be equipped with FDR/CVR and therefore the alignment was limited to the fitment of airborne image recorders.

To implement the necessary requirements, the CAA issued Safety Directive 2016-006 detailing the type and level of equipment to be fitted to current and future helicopters operating as State aircraft.  CAA Specification 23 was also introduced to provide detailed information on the technical requirements for the equipment and fitting.  However, due to some difficulties experienced by the operators in procuring and fitting the equipment, the compliance dates had to be extended and SD 2018-002, now superseded by 2020-001, were issued.  The operators are now meeting the following equipment requirements mandated by the SD:

1. Helicopters with an individual Certificate of Airworthiness first issued before 1 January 2019 shall from 1 August 2021. 

(a) for those with a maximum take-off mass (MTOM) of more than 2,730 kg but not more than 3,175 kg, be fitted with a Class A airborne image recording system (AIRS) except those which have a Class C AIRS; or 

(b) for those with a MTOM more than 3,175 kg, be fitted with a Class A airborne image recorder (AIR). 

2. Helicopters with an individual Certificate of Airworthiness first issued on or after 1 January 2019 shall: 

(a) for those with a MTOM of more than 2,730 kg but not more than 3,175 kg, be fitted with a Class A AIRS; or 

(b) for those with a MTOM more than 3,175 kg, be fitted with a Class A AIR.

The CAA will incorporate these requirements into amendment of the scales of equipment for such operations in the Air Navigation Order at the next suitable opportunity.  Once done, this will provide for the SD to be revoked. 

Update: 19/05/2022

The CAA's response to this AAIB recommendation is currently being managed through the application of an Operational Directive: SD–2020/001. In due course an amendment will be made to the ANO. This may form part of a wider review of the ANO and the future regulatory framework in the UK.

Update due

May 2023

CAA status

Open - Tracked Actions

Close Recommendation 2015-033

Recommendation 2015-034

Recommendation text

It is recommended that the Civil Aviation Authority considers applying the requirements of AAIB Safety Recommendation 2015‑032 and AAIB Safety Recommendation 2015-033 to State aircraft not already covered by these Safety Recommendations.

Recommendation response

The CAA accepts this recommendation and will consider whether the requirements of AAIB Safety Recommendation 2015-032 and AAIB Safety Recommendation 2015-033 should be applied to civil registered State aircraft not already covered by these Safety Recommendations and in particular the suitability of the introduction and/or retrofitting of image recorders. Due to their size, all current civil Search and Rescue helicopters are fitted with flight data recorders and cockpit voice recorders. The CAA anticipates determination of this issue by 3rd Quarter 2016.

Recommendation response update May 2021

The AAIB Safety Recommendations 2015-032 and 033 recommended that the CAA require certain helicopters operating under a Police Air operator Certificate to be fitted with flight recorders including cockpit image recorders (airborne image recorder (AIR)). Additionally, SR 2015-034 recommended that the CAA consider requiring State aircraft not already covered by SR 2015-032 and 033 to be fitted with flight recorders, including cockpit image recorders.

The CAA conducted a focused consultation in 2016 with Police and SAR operators considering the various options for all the SRs and determined the way forward cognisant also of the feedback from industry. In response to SR 2015-034 specifically, it was decided not to pursue changes to State aeroplane equipment requirements but that it would be appropriate to align the requirements and meet the safety intent of the SRs for all State helicopters. The State SAR helicopters under contract with the UK Maritime Coastguard Agency (MCA) were already required to be equipped with FDR/CVR and therefore the alignment was limited to the fitment of airborne image recorders.

To implement the necessary requirements, the CAA issued Safety Directive 2016-006 detailing the type and level of equipment to be fitted to current and future helicopters operating as State aircraft. CAA Specification 23 was also introduced to provide detailed information on the technical requirements for the equipment and fitting. However, due to some difficulties experienced by the operators in procuring and fitting the equipment, the compliance dates had to be extended and SD 2018-002, now superseded by 2020-001, were issued. The operators are now meeting the following equipment requirements mandated by the SD:

1. Helicopters with an individual Certificate of Airworthiness first issued before 1 January 2019 shall from 1 August 2021.

(a) for those with a maximum take-off mass (MTOM) of more than 2,730 kg but not more than 3,175 kg, be fitted with a Class A airborne image recording system (AIRS) except those which have a Class C AIRS; or

(b) for those with a MTOM more than 3,175 kg, be fitted with a Class A airborne image recorder (AIR).

2. Helicopters with an individual Certificate of Airworthiness first issued on or after 1 January 2019 shall:

(a) for those with a MTOM of more than 2,730 kg but not more than 3,175 kg, be fitted with a Class A AIRS; or

(b) for those with a MTOM more than 3,175 kg, be fitted with a Class A AIR.

The CAA will incorporate these requirements into amendment of the scales of equipment for such operations in the Air Navigation Order at the next suitable opportunity. Once done, this will provide for the SD to be revoked.

 

Update due

None

CAA status

Closed

Close Recommendation 2015-034

Accident N264DB

N264DB - Piper PA-46-310P Malibu (nr Guernsey)

AAIB Report: Piper PA-46-310P Malibu, N264DB, 21st January 2019

Recommendation 2020-005

Recommendation text

It is recommended that the Civil Aviation Authority ensure that the system in place to meet the requirements of EASA Part ARA.GEN.220 is effective in maintaining accurate and up-to-date records related to personnel licences, certificates and ratings.

Recommendation response

The Civil Aviation Authority accepts this Recommendation. A review of the current system is underway for ensuring licence records held by the Authority are updated following any changes related to personal licences, certificates and ratings to ensure the requirements of EASA Part ARA GEN.220 are met. We intend to complete this review by October 2020 with recommendations implemented by January 2021. Please note that this timeline may be affected by operational changes required as a result of COVID19 contingency plans.

In addition, the CAA has and continues to remind examiners of their responsibility to submit the required examination documentation to the Authority within 14 working days from the skill test, proficiency check or assessment of competence.

Recommendation update: 12/07/2021

The CAA has reviewed its processes for maintaining and updating records related to personnel licences, certificates and ratings. CAA are recruiting additional resources to maintain accurate and up to date individual records. The additional measure of assessing these documents will continue to ensure we always give the correct information. We believe this addresses the intent of the recommendation.

The “Aviation Licensing Discovery” activity will still be planned for a later date and should provide a more enhanced solution for personnel licensing. The CAA are currently focused on improving the quality of existing application forms by moving more forms from paper to online.

Update due

None

CAA status

Closed

Close Recommendation 2020-005

Recommendation 2020-008

Recommendation text

It is recommended that the Civil Aviation Authority require piston engine aircraft which may have a risk of carbon monoxide poisoning to have a CO detector with an active warning to alert pilots to the presence of elevated levels of carbon monoxide.

Recommendation response

"The Civil Aviation Authority does not currently accept this Recommendation, however we will revisit this position at the conclusion of our operational trial of carbon monoxide detectors.

We are considering what barriers in addition to good design and maintenance practice will be both effective in further minimising the likelihood of critical CO contamination in the UK GA fleet, whilst acknowledging that any such additional measures should be both practical and proportionate.

On 3 March 2020, we published a Safety Notice, CAA SN 2020/003, which highlights the potential benefits of carrying low cost available commercial/domestic active detectors, as well as conventionally installed, approved aviation units. We will further advertise this Safety Notice through communication to all pilots when the current restrictions on recreational flying due to COVID-19 are lifted, to reduce the risk of this announcement being overlooked. Importantly, the Safety Notice includes reference to a CAA-sponsored carriage trial of low-cost, widely available units which we see as facilitating informed decisions in the future regarding recommending (or possibly mandating) specific categories of devices. This trial will establish if there are any negative safety implications (such as loose article hazard or distraction) associated with the carriage of carbon monoxide detectors. However, given the implications of COVID-19 on the 2020 flying season and stakeholder events, the timing for this trial is currently under review.

Recommendation update: 12/07/2021

The CAA recognises the risk identified by the AAIB and is therefore conducting an operational trial of active CO detectors. The CAA will use the trial to assess the safety and practical implications of carrying active CO detectors onboard general aviation aircraft and expects to publish a report on the outcomes and findings of the trial in February 2022. The trial was originally scheduled to start in December 2020 but was delayed due to restrictions from COVID-19.

In the meantime, the CAA is taking the following steps:
SN-2020/003 has been updated (published April 30th 2021) to reflect the latest status of the CO detector trial and to reference the specific CO concentration check included in the Minimum Inspection Programme of UK Reg (EU) No 1321/2014 Annex Vb (Part-ML).
A Safety Sense Leaflet dedicated to carbon monoxide detection and prevention is being developed and will be published after the trial concludes to reflect the latest information and recommended practices. A further update will be provided when the trial report is published.

Update: 02/03/2022

The CAA is actively engaged in addressing the risks associated with carbon monoxide (CO) in general aviation (GA) and has undertaken several initiatives in this regard.

A CAA webpage dedicated to CO in GA was launched in July 2021 and contains useful information for pilots, including how to reduce the risk of CO poisoning as well as the benefits of carrying an active CO detector. The webpage also includes details of the various CO-related activities the CAA has undertaken and is regularly updated to ensure the information is relevant and accurate.

In July 2021, the CAA launched a survey of GA pilots to understand the extent to which active CO detectors are already used within UK GA and how these devices perform in the rugged GA environment. The survey attracted 600 respondents and the findings are available on the CAA CO webpage as an infographic

In addition, the CAA launched a 12-month operational trial of active CO detectors in September 2021 to assess the safety and practical implications of carrying active CO detectors onboard GA aircraft. It is hoped that the trial will also yield useful data on the extent to which carbon monoxide affects UK GA. Registered participants are asked to complete monthly surveys capturing their experience of flying with an active CO detector.

A report summarising the first three months of the trial is now available for download via the CAA CO webpage, and a copy is attached for your ease of reference.

A further update will be provided once the 12-month trial concludes.

Update due

December 2022

CAA status

Open - Tracked Actions

Close Recommendation 2020-008

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