Has your ops manual renewal been rejected?  Are you scratching your head wondering what the CAA are after?

Don’t worry – you aren’t alone. You are in a rapidly advancing industry – what was okay last year is not necessarily okay this year.

This article will help you to work through some of the common reasons for rejection to get you that renewal as quickly as possible.

So – you will have had an email from the CAA technical team identifying where your ops manual has gone wrong. They won’t give you the answers – rightly so – you need to be able to find the answers and understand where you fit into the big picture for yourself. If you have found this article unprompted then you are definitely on the right track.

So – the reasons for rejection:

  • READ THE FORM – If it says to fill out either section 1 OR section 2 then don’t fill out sections 1 AND 2.
  • Amendment record; your amendment record will change because you will update the year, staff, UAVs SOPs etc. When this happens you need to fill in the table in your amendment record, log what changes are made and then date. The CAA will reject any renewal with ‘Version 1’ on because it is clearly not Version 1. Ask yourself what this looks like from the CAA’s perspective – Renewal request comes through with no apparent changes and ‘Version 1’ still printed all over – it says the individual submitting has probably not looked at their manual since the last submission and has simply sent it back in again a year later. Is this a professional approach given that regulation and safety practices change continuously?
  • PFAW vs PFCO – PFAW went out years ago so, again, is the individual actually using the ops manual and keeping up to date with the industry in which they work?
  • MORS; by far the single biggest reason for rejection. With MORs/CAP382 you need to ask yourself two questions: WHAT? and HOW?
WHAT? What am I going to report? The CAA have made this straightforward because the list of mandatory occurrences for which a report MUST be filed is found here

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2015.163.01.0001.01.ENG

Look through this document but do not get bogged down. There are items which clearly do not apply to you such as:

Part 4 (9) – Any use of crew oxygen system by the crew

However there are items which definitely do apply such as:

Part 4 (11) – Crew fatigue impacting or potentially impacting their ability to perform safely their flight duties

You can see now that you have been provided with the means to work out what you   need to report. The next question is HOW?

HOW? How am I going to report it? The CAA have made this straightforward as well. It is all online and found here:

http://www.caa.co.uk/Our-work/Make-a-report-or-complaint/MOR/Mandatory-occurrence-reporting/

Go to the bottom where it says ‘Access the Reporting Portal’ and just follow through the various pages until you get to the form that you need to fill out in order to explain what happens it looks like this:

You don’t need to go any further than this until the day you need to actually submit a MORS. The point is, once you have got this far you will be in a position to know exactly how to submit a report and have the confidence to navigate the system.

So you have answered the WHAT and HOW questions – now you need to articulate it to the CAA. This is up to you to do because it is YOUR document. Look through the MORS section you already have and decide if you should take things out and how best to explain to the CAA how you will answer these two critical questions.

  • Publications List; This is relatively new and now needs to be a table whereas previously you will have generated a bullet list. Here is an example:

 

Document Title Date Version
CAP393 Air Navigation Order XXX V3.1

 

You need to web search each item you have listed in your publications list and you will be taken to a page that looks like this containing all of the information you need:

Now every year when you make your renewal the CAA can tell within seconds whether you are actually checking the source legislative documents directing your operations on a semi regular basis. It is the simplest gauge of your professionalism.

  • Articles 166/167; These were superseded years ago by articles 94 and 95.
  • Articles 240 and 241 of the Air Navigation Order. These are fairly new and weren’t particularly well publicised by the CAA – look them up, then articulate in your ops manual your compliance with them.

This concludes the list of areas where the CAA issue the most rejections during renewal. Ultimately it is your responsibility as an air user to ensure that you stay abreast of changes within aviation in order to operate as safely as possible – it becomes clear to the CAA at renewal time if you have done this or not; so don’t be that person.

If you have an issue with renewal which you absolutely do not understand then please contact me at opsman@rustuas.com and I will help where possible.

 

Fly Safe!
Daniel Alward-Smith – Chief Flying Instructor/Evaluator RUSTA