Could Your UAS Operation Benefit From an SMS?
It was probably almost a decade ago I found myself at one of the many aviation industry’s tradeshows, but this one was different. There was a vendor selling these things that had four rotors, very bright flashy lights, a camera dangling from the bottom, and referred to as a “drone”. I remember finding it odd that a vendor would be selling these things - which I thought of more as a toy - at a convention for operators with the big business aviation iron. There could not possibly be a pragmatic application for drones in an industry run by airplanes and helicopters, or so I thought.
Fast forward five years and I found myself engulfed in a feasibility study for the International Business Aviation Council to determine if a new unmanned aircraft systems (UAS) standard should be developed and published due to the rising proliferation of these aircraft in airspace systems around the globe. Fast forward to today and we are witnessing the explosion of unmanned aircraft systems in a myriad of applications and industries. Unlike 10 years ago, I see UAS as a great tool to fill a critical gap in an organization’s aerial needs. These platforms provide solutions when the alternatives are cost prohibitive, high-risk, or will require more time. However, while this industry is evolving rapidly with new uses seemingly emerging every single day, regulations to protect operations, equipment and the public have been slow to keep up. Add to that the difficulty in developing regulatory controls for the myriad of different contexts in which unmanned aerial systems are used today. Organizations, therefore, need to be innovative in developing appropriate risk controls to protect not only their assets but the public image of this new segment. Implementing a safety management system to proactively identify and mitigate risk can help the organization develop sound operating policies and procedures to provide a level of safety that has come to be expected in the aviation industry.
The rapid growth of the UAS industry has been nothing short of breathtaking. The International Civil Aviation Organization (ICAO) segments UAS’s into basically three categories: remotely-piloted aircraft systems (RPAS), autonomous aircraft systems, and a hybrid of both. Today, we see applications across the three categories from a search and rescue team flying a drone to locate a missing person to much-needed medicine being delivered to remote hospitals via a fully autonomous aircraft. To understand how we have moved from a few vendors trying to sell the UAS idea a decade ago to the vast applications today; and how this growth is sustained and can even accelerate, it is helpful to consider the diffusion of innovation curve (below).
This curve describes how an innovation is adopted into a given population. The innovators represent about 2.5% of the population and these are the risk-takers and trailblazers. These might have been the ones strapping a package to a drone with duct tape to see if package delivery was a viable option. The early adopters represent 13.5% of a given population and describe the industry leaders who see an opportunity for change and build upon innovator’s work. We saw this with early companies offering deliveries in some areas using UAS, some first responder units using these platforms to aid in emergencies, and companies utilizing UAS’s in inspection roles. The early majority represents 34% of a given population and describe those that are not part of leading change but do adopt innovation before the average person. This is where I think we are today. We see more organizations in a given business segment utilizing UAS and learning application uses from the early adopters in that industry. The late majority and laggards are those that are still skeptical of UAS applications, and I can’t help but feel we will see use in this late majority within the next 5 years.
When I did the study for IBAC five years ago, the research suggested that UAS application was still in the early adopter phase. Now, five years later it appears we are crashing into the early majority and accelerating very quickly towards the late majority. With this, I suspect we will see not only more novel UAS applications arise, but also current applications become more mainstream. However, as stated above, with this rapid acceleration in scope and applications, it is very difficult for the regulators to keep up in developing controls to protect organizational resources and the public. At this rate, it might even be a challenge for more agile institutions such as AUVSI, AAM, and IBAC to provide relevant industry standards as guidance. Therefore, operators should also look inward and through their efforts in safety management work to develop controls to reduce the risk of operations to an acceptable level.
The beauty of safety management is an organization can evaluate hazards and associated risk in the context in which they operate. This means the organization can create controls that make sense for what they do. This is done through a safety management system, which is implemented into an organization to broadly bring risk under organizational control. Safety management systems are becoming a mainstay in other aviation segments such as airline, airport, business aviation, maintenance, and manufacturing operations. While the FAA has not yet mandated SMS outside of airline operations, other segments have been proactive to implement SMS voluntarily. This is in large part due to the benefits of SMS including risk awareness and control. SMS regulations in UAS operations may be on the horizon - possibly a very distant horizon - but nonetheless sometime in the future. The need for safety management systems in the UAS industry has already been suggested in ICAO’s Manual on Remotely Piloted Aircraft Systems (RPAS), Doc. 10019. Adopting an SMS now can greatly help organizations understand and control risk in operations.
The SMS uses a data-driven and policy-backed approach to help ensure risk is reduced to an acceptable level. I think a key point in the SMS is that frontline data and information is crucial for the identification of operating hazards in the context of operations. In other words, the frontline operators, and the information they provide, are critical to the organization understanding the risks associated with their operations rather than the generalized risk of a prototypical UAS operator. The SMS provides processes for identifying hazards in context and assessing the associated risk both proactively and reactively. In other words, the SMS provides the tools to help determine problems before they happen and determine what went wrong if something does happen to help ensure it won’t repeat. When a hazard is identified and the risk assessed, controls can be developed to mitigate the risk and then deployed into operations. A safety management system then has provisions to monitor these controls to ensure they are performing as designed and are effective. Data is used to determine the effectiveness of the controls and, if needed, to drive the organization.
It is through an SMS that the UAS operator can develop appropriate risk controls that will provide the requisite protection without hindering operations.
So, by this point, I know you all are thinking “where can I get me one of these SMS’s?” If only it were as easy as throwing one in your Amazon cart! The safety management system must be implemented into the organization and integrated with operational policies and processes. It does take time and effort, I won’t lie about that, but the benefits outweigh the effort. However, before we go full throttle into implementation, we need to really understand SMS and the associated processes. A good place to learn about SMS is ICAO’s Doc. 9859 4th Ed. There may be a cost for this manual depending on where you look, but it provides a very encompassing and in-depth discourse on SMS and the safety management principles that make it up. Another source that provides a good overview of SMS principles is the FAA’s AC120-92. It is less “heady” than the ICAO document but provides a lot of the same information with a bit of an FAA twist.
These publications provide guidance on how to implement SMS including example implementation plans, but it is important to start the information flowing from the start. In fact, ICAO recommends the establishment of hazard and event reporting straight away so the organizations can get a sense of risk early Finally, the gathering of information early will also provide insight into risk controls already in place to help determine if they are still applicable or need to be updated.
The UAS industry is growing at a staggering pace. Considering the diffusion of innovation, this industry appears to be accelerating through the early majority. More organizations are adopting UAS for novel applications in which traditional aircraft are incapable or not financially viable. Considering how fast this industry is evolving, it is difficult for regulators to keep up in providing protective controls. Implementing an SMS can help UAS operators understand risk in their context and develop protective controls without hindering productivity. Collectively, SMS implementation can help the UAS industry continue to grow with the appropriate protection.