But, back to the ops manual.
It is stupid, sorry CAA, but this makes no sense.
We are expected to write our own ops manual!
Why? Well, some aspects will be company specific - organisational structure, nominated staff, etc. Fair enough.
But a large chunk of it will be the same for every one-man operation, or the same for every small operation of a few staff. Some parts will be the same for everyone.
There are big chunks of it, like the emergency procedures, which surely must have well established best practice, and should be the same for everyone, or at least everyone with the same class of aircraft.
So why do I have to guess what risks there are and define what I think are the best emergency procedures, as someone that has, but definition, done no commercial flying yet?
Yes, the course had lots of information, but making me write the ops manual rather than just using a standard manual and making a few tweaks, is crazy.
One comment is that writing it, I have to think about it a lot, and that is good - but from what I can see it is the company that writes the ops manual and requests the PFAW (Permission for Aerial Works), and there seems to be no need for any of the pilots to have written it or have been involved in writing it. It could be written by our lawyer if we wanted to. So that argument falls flat on its face right there.
I would far rather have a standard small business operations manual, review and make a few changes, than have to write all this from scratch.
Oddly enough, our lawyer did say that he has much the same in setting up a law firm - they have to write their own manual as well - it must be a bit like having to construct your own light sabre?
Is it really a rule that we have to write our own (CAP722 seems to suggest so)?
Is that really in the best interests of safety?
P.S. First draft now done, 5th Jun. Once reviewed, we can book practical tests.
"It could be written by our lawyer" ...
ReplyDeleteWell, ask your lawyer what happens when you have an accident and the court then finds that you're operating outwith your own procedures (i.e. manual).
There's a case for writing the manual as permissively as possible.
Seriously though, your point is good: the procedures that are common to all operators should be regulatory, and only those that are operator-specific should be, well, operator-specific.
Indeed - the advise we had was make it as wide as we can in terms of pilot's discretion.
DeleteHave you thought of publicly releasing it as a "template" *under Creative Commons or similar) for others in the future to save them re=engineering the wheel?
DeleteYes, but CAP722 states it has to be "original work", which is just silly.
DeleteSo a similar thing happened when various flight training organisations had to convert from Registered Facilities (RFs) to full fat ATOs - in the end the industry organisations (e.g. AOPA etc) got together and put together a template manual that the CAA were happy with and places can now take and tweak.
ReplyDeletePerhaps you need something like an AOPA equivalent for drone flying who could take on things like this?
Manual:
ReplyDeleteIf In doubt, don't.
End of manual.
I work for a large company with shops everywhere, and as a shop manager recently had dumped upon me from a great height a pile of Health & Safety risk assessments that every shop apparently needs to have.
ReplyDeleteWe used to have a whole department who spoke H&S lingo, thus saving everyone else from the mental torture that it is.
For example, I have to complete a risk assessment on cellar hatches. My shop is a small unit, at street level, with one floor, no stairs, and definitely no cellar. We therefore do not have a cellar hatch, but simply writing 'Not Applicable' on the pre-made form is apparently not enough. I have to give specific threat details (i.e. what makes this shop different from every other shop, 99.9% of which also do not have cellars), and specify exactly what processess are in place to minimise this threat. I am so tempted to make up something utterly ludicrous to match, such as a daily procedure of listening to the floor for signs that someone might be constructing a cellar prior to opening each day, but if I put that sort of thing down, I actually have to ensure that it is done, and documented as done each and every day.
H&S procedures for stepladder use. Nope, not got one of those either. Procedure: Do not buy a stepladder.
H&S procedures for using stairs. Again, do not permit building work that involves the installation of stairs.
Ditto 'Heavy machinery', 'Gas safety' neither of which I can think of imminent danger from (although I do have a larger than average calculator, and my cashier occasionally likes a curry)
Wondering how long it is before I have to submit a risk assessment pertaining to the possibility of the outbreak of nuclear, biological or chemical warfare between two rival suppliers or customers.
If I have a manic day when I have too much creative energy, such a scenario could produce quite a epic H&S manual. Perhaps I should get it published (in the sci-fi section)
Was the response just that writing "not applicable" in respect of the cellar was insufficient, or that writing "no cellar on the premises" would also have not done the trick?
DeleteI can kind of understand that "not applicable" could mean "has a cellar, but no processes/controls", and that position would likely be unpalatable to an H&S womble, but a statement of why there are no controls would seem sensible enough?
FWIW, in similar situations, the HSE has been just fine with "N/A" as the *entire* risk assessment - e.g. when you have no hatches, N/A is good enough for your cellar hatch H&S policy.
DeleteYour H&S wombles may disagree, of course.
From a legal point of view the advantage of YOU writing a document is that courts by default resolve any resulting ambiguity AGAINST you, because you should have avoided the ambiguity if you cared.
ReplyDeleteIf you have (as most big companies do) a standard form contract and tell new hires "take it or leave it", then if ever they end up in court arguing about the contract a court will say since they had to put up with whatever text you chose you must put up with how their lawyers understand that text. If you didn't really mean what it says, why insist on those terms? So their lawyer may twist some little phrase in the contract to skewer you badly and you have no-one else to blame because you insisted on that contract.
I think likewise then, if your manual says something that's a bit vague, and then your people do something that ends you up in court and the court turns to the manual your opposition's lawyers will get to tell the court what THEY think the manual means. If you try to argue that the manual isn't clear enough they'll point out that's your fault not theirs.
Not sure that is the point, sorry.
DeleteFirstly, there is the issue of trying to make the manual as flexible and non prescriptive as we can - this is to ensure we are not accused of simply not following the manual, but that said, the manual does constantly point out that any pilot discretion is only where the pilot considers it safe, and that safety is paramount - so that is clear. Someone discarding safety does not get to say "the manual said I could do it" therefore.
My bigger concern here is the decisions we have to make in the manual, especially things like emergency procedures. Like, if another aircraft is approaching - what does the manual say to do. We have not done any commercial flying before, obviously, so we have to guess what scenarios (like that) may exist, and guess what action may be sensible to take. Even the ground school did not have a "right answer". However, surely, there are well established best practice answers for such things - yet we are not allowed to just copy those - the CAA say that the manual has to be all original work. I cannot see how my best guess (with no commercial experience) is the best for safety and better than a "standard" manual I could have been given by the CAA.
Basically, it sounds like the CAA is more concerned with buck passing and blame than with actually ensuring people operate safely. That, in my opinion, is the only conclusion I can draw from forcing every operator to make up their own manual like this.
The DIRTY DOZEN > NORMS, End of conversation, just do it, get on with it, stop complaining.
ReplyDelete