Manufacturing, testing, and regulatory oversight of unmanned aerial vehicles

CASA response to the REPCON is as follows: 

Manufacturing Standards and Compliance

Remotely piloted aircraft system (RPAS) operational approvals are regulated based on an assessment of operational risk, except for operations classified under the excluded category of unmanned aerial systems (UAS). CASA recognises the Joint Authorities for Rulemaking on Unmanned Systems (JARUS) Specific Operational Risk Assessment (SORA) as the primary methodology for evaluating operational risk. This approach incorporates operational safety objectives (OSOs) related to design, manufacturing, and maintenance, ensuring an appropriate level of robustness for the RPAS. OSO #02 focuses on the manufacturer's competency and safeguards controlled, standardised quality in products. Compliance with this OSO ensures that risks related to manufacturing issues are effectively managed and mitigated.

Through the SORA process, the applicant determines the Safety Assurance and Integrity Level (SAIL) for the intended operation. Applicants are required to show compliance with less stringent requirements at lower SAILs, while higher SAIL levels impose stricter requirements that align more closely with those applying to conventional (type-certificated) aircraft. Depending on the SAIL level of the proposed operation, CASA may accept compliance declarations based on manufacturer-supplied information or conduct verification activities to confirm that technical OSOs meet the necessary levels of integrity and assurance. For high-risk operations, the methodology requires that supporting evidence is appropriately validated by the regulatory authority.

Australian-Specific Testing and Certification

RPAS operational approvals are regulated based on an assessment of operational risk, except for operations classified under the excluded category of RPAS. CASA accepts the JARUS SORA as the primary methodology for assessing operational risk. This methodology includes Operational Safety Objectives (OSOs). OSO #23 and OSO #24 focus on implementing measures to prevent failures arising from environmental conditions during operations. Applicants are required to demonstrate that the RPAS has been designed and qualified (tested) to handle adverse environmental conditions, commensurate with the requirements applying to the SAIL of the intended operation. Similarly, OSO #06 and OSO #13 outline the criteria that applicants must meet by evaluating the adequacy of the command, control, and communication link and external services supporting the operation. Applicants are required to consider the specific environmental and operational conditions applicable to their proposed operation. The level of integrity and assurance requirements can be reached from the JARUS website.

Regulatory Oversight and Enforcement

CASA has a suite of RPAS regulations that cover aviation safety matters for operations within Australia. CASA is mandated to conduct surveillance as a CASA function in accordance with The Civil Aviation Act 1988. As such, CASA conducts scheduled surveillance events and ad-hoc events throughout the course of each year. The primary surveillance focus for RPAS is on operators that generally conduct more complex activities such as beyond visual line-of-sight operations (BVLOS) and training. We also consider and conduct surveillance on other aerial work operators and operators within the sector that we oversee.

Incident Reporting and Investigation

The Australian Transport Safety Bureau (ATSB), a separate authority from CASA, is primarily responsible for conducting investigations consistent with the Transport Safety Investigation Act 2003. In addition, CASA may review events and consider what actions may be appropriate to prevent accident and incident reoccurrence. This activity includes surveillance and education, or counselling, or in other cases, CASA may seek to revoke the privileges of an authorisation holder. The RPAS industry is supported with regulations, guidance, and sample documents to assist operators, verified apps to aid operations, and guidance material. Safety promotion and education is a shared responsibility across the aviation safety community, and as such, CASA regularly contributes to aviation-related workshops, forums, and events that reinforce the aviation safety message.

For guidance about the ATSB and their investigation responsibilities, you should visit their website links:

• Aviation investigations | ATSB (RPAS investigations – search remotely piloted aircraft in sector field)
• Reporting requirements for RPA | ATSB 

I trust this provides clarity on CASA activity and commitment to maintaining the highest standards of aviation safety.

ATSB response to the REPCON is as follows:

Further to CASA's comments, please see below: 

Incident reporting

Type 1 Remotely Piloted Aircraft (RPA)s (defined in section 6 of the TSI Regulations and adopting CASR definitions) are included in Category B aircraft operations with the following reporting requirements:

Immediately reportable matters –

• aircraft accident;
• loss of separation standard between aircraft; and
• serious property damage incident (external).

Routine reportable matters –

• reportable serious aircraft incident;
• declaration of an emergency in relation to the aircraft; and
• aircraft incident (external). 

Type 2 RPAs are included in Category D aircraft options with the following reporting requirements: 

Immediately reportable matters (IRM) –

• aircraft accident – limited to fatal aircraft-related injuries or serious aircraft-related injuries; and
• serious property damage incident (external).

Routine reportable matters (RRM) –

• aircraft accident other than reportable as an IRM; and
• loss of a separation standard between aircraft. 

Further information on reporting requirements for RPAs can be found on the ATSB’s website.

The ATSB also considers all RPAs accidents for investigation under the TSI Act.