Multiple sections of the Part 101 Manual of Standards cover the obligations for the nominated Director / CEO of a RPA Operators Certificate.

In the Part 101 Manual of Standards instrument, the Director / CEO role is not mentioned directly. It is implied by referring to the “Certified RPA Operator” in the document. The exact meaning of “Certified RPA Operator” can be found in regulation 101.335 of the Civil Aviation Safety Regulations 1998 which refers to the nominated person.

The main issues the Director / CEO should be across in the document are as follows.

1. Data Integrity

From Section 10.01 – Definitions, the Manual of Standards requires several things in regards to maintain the integrity of electronic records.

record includes an electronic record but only when:

(a) the electronic record is created in a form that makes the record unalterable after the record has been made; and
(b) if an erroneous electronic record is created — the correction of the electronic record is in the form of an electronic record which identifies the error and corrects it.

This clearly means any electronic system used to record RPAS operations must be highly sophisticated to prevent tampering while also creating an audit trail for compliance.

2. Data Retention

On top the requirement to maintain data integrity there are also multiple requirements to keep all records for 7 years. These are outlined below.

Section 10.03 (2) The certified RPA operator must keep the following records for the period stated for the record:

(a) chief remote pilot’s duties records — for at least 7 years after the day the record is made;
(b) RPA operational record — for at least 7 years after the day the operation ends;
(c) RePL training course records — for at least 7 years after the day the course ends.

Section 10.04 (3) The certified RPA operator must keep the RPA operational release for at least 7 years after the day the operation ends.

Section 10.05 (3) The certified RPA operator must ensure that the remote pilot operational log for an RPA operation is kept until the day that is at least 7 years after the last time the RPA is operated by the operator.

Section 10.06 (3) The certified RPA operator must ensure that the remote pilot log for an RPA operation is kept until the day that is at least 7 years after the last time the RPA is operated by the operator.

Section 10.07 (2) The certified RPA operator must keep the RPA technical log until the day that is at least 7 years after the last time the RPA is operated by the operator.

Section 10.08 (2) (c) keep the record for at least 7 years after the day the person ceases to be employed by the operator.

The need to retain this information for 7 years is considerable and will require a system for ensuring all records remain in a form that can be easily accessible and secure.

3. Timeliness

Furthermore for Section 10.07 additional requirements are added for the timeliness of compiling and distributing the RPAS Technical Log,

(3) Within the period of 7 years after the last time the RPA is operated by the certified RPA operator, he or she must, as soon as practicable, provide a copy of the RPA technical log to CASA upon written request.

(4) Within the period of 7 years after the last time the RPA is operated by the certified RPA operator, he or she must, as soon as practicable, provide a copy of the RPA technical log to a person who:

(a) makes a written request for the log; and
(b) provides reasonable evidence that he or she is the new operator of the RPA; and
(c) provides payment for preparation and provision of the log, based on a reasonable cost recovery for such preparation and provision.

Note: The complete technical history of an RPAS is of vital importance to the safety of future RPA operations by the new certified RPA operator.

CASA has placed an extremely high important on the integrity of this log being accurate and compete as can be seen above and having the tools which can produce the required reports at short notice are vital.

4. Oversight Obligations

Part 101 Manual of Standards also explicitly states how the Director / CEO must ensure the respective people in the organisation are maintaining their obligations.

Section 10.03 – (1) A certified RPA operator must ensure that its chief remote pilot keeps the following records:….

Section 10.05 (1) The certified RPA operator must ensure that the remote pilot in command of an RPA flight maintains an operational record (the RPAS operational log)…..

Section 10.06 (1) The certified RPA operator must ensure that each of the operator’s remote pilots keeps a remote pilot log to record his or her accumulated flight time operating RPA.

Section 10.07 (1) The certified RPA operator must ensure that 1 of the following:

(a) the operator’s maintenance controller (if any);
(b) a person within the meaning of subparagraph 101.340 (1) (c) (ii) of CASR;
keeps a record (the RPAS technical log)…..

Section 10.08 (2) The certified RPA operator must:

(a) make a record (the record) of the person obtaining the qualification or competency; and
(b) provide a copy of the record to the person before the person exercises any privileges attributable to the qualification or competency; and……

Using purely paper based systems it will very difficult for the Director / CEO to maintain visibility and oversight of all activities. Therefore, the use of an electronic system will be extremely important going forward.

5. Summary

In summary we can see how the Part 101 Manual of Standards requires the nominated Director / CEO to maintain the system to not provide data integrity but also data retention, timeliness to provide information to others and confidence that all members of the organisation are fulfilling their obligations under the Manual of Standards.

We have built the FlyFreely platform to handle all of the requirements of the Part 101 Manual of Standards to give Directors / CEO’s peace of mind that their organisation is meeting their obligations.

This and other key features relevant to Directors and CEO’s are detailed in our Part 101 MOS Compliance Guide. Fill in this form to obtain your copy today.