The drone industry is changing rapidly: innovative technologies are emerging; drone operations are evolving and new service providers such as Uncrewed Aircraft System Traffic Management Service Providers (UTMSPs) are establishing themselves.
With this rapid transformation comes new challenges. As drones become increasingly visible in our skies, it is crucial that we design, build, operate and manage this new ecosystem with safety at the forefront of our mind.
Developing and nurturing positive attitudes and behaviours towards safety within the drone ecosystem is essential to better identify, mitigate and manage risks as drones integrate with existing airspace users or structures.
A genuine culture of safety, will build trust amongst stakeholders, including the public, and local authorities, to other airspace users. This in turn will enable the drone industry to thrive within a mature aviation ecosystem, helping to normalise their presence and supporting increasingly complex and integrated operations.
This article builds on the previous articles developed by Ebeni, covering: an introduction to safety culture (Add link); defining what safety means and showcasing interdependencies with Safety Management Systems (SMS) (Add link) and highlighting the benefits of a positive safety culture (Add Link). These articles describe the current state of the drone industry in relation to safety culture and provide examples of how industry stakeholders could foster a positive culture within their organisations.
Safety Reporting and the Drone Industry
With safety reporting being a fundamental element of safety culture, a study was conducted by Ebeni on behalf of the UK CAA in 2022 [4], which reviewed drone safety reporting at the national level.
The CAA wanted to investigate whether there were low reporting rates within the industry and understand how they could remove or reduce barriers to occurrence reporting to enhance the safety of drone use.
The research consisted of a survey taken by drone operators, alongside desktop research and interviews with the CAA, industry stakeholders and other National Aviation Authorities.
- 31 interviews were conducted
- 32,000+ survey responses were collated and analysed
- 30 document / website reviews were completed
The fundamental takeaway from this study was that the number of drone safety reports should have been higher than was observed. One of the key discussion points of the study explored culture within the drone community, considering the CAA’s active promotion of just culture principles. Several factors were identified within the report [4], a few of which are discussed below:
1. “Drone users do not consider themselves aviators; primarily because they are not transporting passengers or cargo” [[4] Section 2.3]
Contrary to the survey findings, there are several use cases that appear to align with the aviator category, such as medical logistics, agricultural spraying and parcel deliveries, as they are load carrying operations.
Less-complex and lower-risk use cases, such as site inspections, surveys, and aerial photography, often operate with visual line of sight (VLOS). Both higher and lower risk use cases should be recognised as part of the aviation ecosystem and be required to meet aviation safety standards proportionate to their complexity/risk, for the following reasons:
Drones operate in the same airspace as those who comply with stringent safety standards. Whether it’s a commercial operation, private helicopter or general aviator, there are safety standards that need to be met, but this should be proportionate to their operation. There have been many drone-related Air Proximity Reports (AIRPROXs)[5] (shown in Figure 1) which indicates drones may need to meet higher standards of safety than at present.
A duty of care is owed to stakeholders on the ground. Drone operators, like all other airspace users, have a duty of care to those that are overflown. It is therefore important that the drone community has an accurate picture of the risks involved with their operations. Both mandatory and voluntary data reporting and analysis, including data pertaining to the system itself, is important to better mitigate and manage risk to the public.
These companies are naturally focussed on short cycles of development and investment to demonstrate the viability of their solutions. They may not have the time or funds to formally instil a positive culture within their organisation.
This being said, it is far easier for companies to build a positive safety culture from the outset than to change well-established behaviours, values and opinions towards safety. The effort required to take proportionate steps is something that can be developed early and internally, and brings benefits including better risk management, increased morale and productivity and harmonised safety behaviours throughout the business. The cost to the business is related to the resource (effort) required to develop and implement those proportionate steps. Read the remainder of the article for further details.
3. Drone operators come from various backgrounds, not all with extensive experience in aviation safety protocols.
Relationships with other industries
The drone industry is closely connected with many other sectors, such as construction, agriculture and rail. As a result, knowledge and experience within the drone community come from a wide range of backgrounds, which can make it challenging for some organisations to adapt to aviation safety principles. What is constant throughout many safety-critical industries, however, is the evolution of safety cultures and demonstration that a positive safety culture makes good business sense.
Proportionality in the Drone Industry
Irrespective of an organisations size and complexity, its safety culture and performance will not be fully optimised, and its operations may have unknown and unmitigated risks without:
- Trust, or reporting of hazards and occurrences and mitigating against future issues,
- Ensuring personnel and teams have the necessary tools (training, procedures, equipment and experience) to do their job.
Whatever measures are introduced to foster a positive culture, must be proportionate to the size and complexity of each organisation. A company with a small number of employees can still develop a positive culture. Consideration needs to be given to the number of times events, including near misses or hazards, are reported. For example, there may have been times where a pilot landed outside the designated landing zone or connected with a tree (no damage) and thought, ‘it’s ok, I won’t report that’. Other issues an organisation may be questioning include:
- Believing that it is not important for an organisation so small in size/ low in complexity to report issues
- That there will be too much paperwork
- That having 14 reporting bodies for the drone industry is too confusing
- Belief that they would be penalised by the regulator or insurer for openly and honestly reporting
- The belief that they would be blamed for openly and honestly reporting
This untapped data resource from proactive reporting, is key to safe and efficient operation, both now and in the future.
Culture is learned through observed and demonstrated behaviour and so for growing teams, a positive culture will help maintain the high standard of safety performance as an organisation brings in new members.
For those in larger organisations:
- Does the organisation know whether staff report safety events, hazards or observations?
- Does the organisation provide feedback to staff on reports that have been submitted?
- Are organisations only seeing the ‘tip of the iceberg’ in relation to hazards and near misses?
- Is the organisation openly demonstrating a fair and ‘just’ culture?
As organisations grow and increase in complexity, accountabilities and responsibilities need to be clear, and risk management needs to be effective. There needs to be feedback mechanisms and education arrangements to ensure safety messages can be communicated effectively between teams. Nonetheless, proportionality is key! It is crucial that organisations have a framework in place which enables them to establish processes and build safety awareness as the company expands and/or intends to conduct more complex operations.
The foundations of a safety culture framework
The Civil Aviation Authority’s guidance document CAP 722 [6] guides drone operations within UK airspace. While not explicitly mandating a safety culture, it lays the foundation for developing a safety culture focussed on positive safety practices within the drone community by promoting risk awareness, crew competence, and proactive safety planning.
This is achieved through several key attributes:
- Risk-Based Approach: CAP 722 [6] Emphasises a risk-based approach to drone operations. This inherently requires a safety-conscious mindset within organisations, which should be further exploited to develop a positive safety culture.
This could be achieved through:
- Developing internal occurrence reporting processes that feed into the risk assessment process, including a confidential reporting scheme (if the organisation is large enough)
- Creating a communications channel to share lessons learnt and successes.
- Conducting internal reviews of why occurrences have taken place and learn from errors.
- Receiving updates from external reporting systems to look at lessons learnt from within the industry.
- Crew Competence: Ensure that operators possess the necessary knowledge, skills, and qualifications to handle their drones in a safe and responsible manner. Ensure that the organisation provides the necessary toolkit (equipment, processes and procedures, training, support) so that they can conduct their role safely and efficiently.
This could be achieved through:
- Creating an atmosphere where staff are motivated to report occurrences, and highlighting when things (people, processes, equipment etc) are not working well, which will help to better understand what support (elements of the toolkit) the team might need.
- Providing training (proportionate to the organisation’s management system) on safety and safety culture will also help.
- Operational Risk Assessment (ORA): CAP 722 [6] requires drone operators to outline a comprehensive plan for managing the risks associated with their specific operations. The process of developing and maintaining an ORA through safety planning aligns with the principles of a safety culture.
This could be achieved through:
- Developing a safety policy (requirement within the Operations Manual) which is relevant for the company, demonstrating how those accountable and responsible for safety, at all levels of the organisation, will behave.
- Documenting how the organisation continues to manage risk and changes within its business.
- Occurrence Reporting: CAP722 [6] emphasises the requirement to report certain accidents, serious incidents, and other mandatory occurrences. This focus on safety reporting allows for valuable learning from past mistakes and fosters continuous improvement in safety practices.
This could be achieved through:
An internal voluntary and confidential reporting scheme, which could be developed to further identify potential safety issues before they lead to an incident.
1 The CAA has implemented UK SORA, which allows operators to conduct ORAs using SORA to comply with UK UAS Regulations. The Online SORA Platform allows operators to submit their application through a digital portal.
- Safety Management System: CAP 722 [6] explicitly refers to the CAA’s CAP 795 [7]. guidance on SMS. Whilst there are no direct references within this document to drones, this guidance does highlight that safety culture is a crucial element for an effective SMS. It emphasises a fair and balanced approach to incident investigation, protecting those who report safety concerns, ensuring employees are trained and educated and finally making sure that the organisation can effectively manage change. Within CAP722 [6] there is a requirement for a safety policy and risk assessment process, whereby accountabilities and responsibilities must also be identified.
In summary, whilst CAP 722 [6] does not directly mention safety culture, change management, promotion or education, (which are all key factors when developing and enhancing a positive culture) it does outline the minimum level required for safe operations that companies should endeavour to meet or surpass.
Developing a positive safety culture
So how can a Drone industry organisation develop a positive safety culture? There are some practical steps that can be applied to help organisations develop and improve:
Summary
Developing and nurturing positive attitudes and behaviours towards safety across the drone ecosystem is essential to the success of the sector and the organisations operating within it.
Promoting a positive safety culture, will help build trust amongst stakeholder groups, including the public, local authorities, and other airspace users. This is key to enabling the drone industry to thrive within a mature aviation ecosystem, to normalise their presence and to support both high and low SAIL operations.
Experience from other industries and sectors has demonstrated the need for a positive safety culture. As mentioned in our own SMS Article [1] (Published November 2023), a proportionate SMS, which considers the size and complexity of your business, is crucial to the success of gaining operational approvals and realising your further investments. An SMS can only be effective if you have the foundations of a positive safety culture within your organisation to support it.
In essence, CAP 722 [16] helps with the foundations for developing a culture focussed on positive safety practices within the drone community by promoting risk awareness, crew competence, and proactive safety planning. Whilst it does not directly stipulate that organisations should have a positive safety culture, it defines key elements that can be built upon to achieve a safety-first environment for operations in the aviation ecosystem. Notwithstanding, there are gaps in relation to a just and fair culture, effective change management, and promotion and education (key factors when developing and enhancing a positive culture); however, CAP722 [16] outlines the minimum level required for safe operations that companies should endeavour to meet or surpass.
References
- [1] Safety Management Systems for Sustainable Growth | Ebeni
- [2] http://jarus-rpas.org/publications/
- [3] CAP 382 – The Mandatory Occurrence Reporting Scheme (skybrary.aero)
- [4] CAP 2356 – CAA RPAS Safety Reporting Project. Discovery study report
- [5] Historical Airprox trends | UK Airprox Board
- [6] Unmanned Aircraft System Operations in UK Airspace – Guidance (caa.co.uk)
- [7] CAP 795 Safety Management Systems – Guidance to Organisations