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Unmanned Aircraft Systems Operations for Offshore

Installations

Guidelines

Issue 2 December 2019

Unmanned Aircraft Systems Operations for Offshore Installations

Acknowledgments

In preparing and publishing this document, Oil & Gas UK gratefully acknowledges the contribution of members of the work group, namely:

• Colin Cheesewright - ConocoPhillips

• Stuart McGlynn - Cyberhawk

• Steve Moir - Texo

• Trevor Stapleton – OGUK

• Graham Wildgoose – OGUK

While every effort has been made to ensure the accuracy of the information contained in this publication, neither OGUK, nor any of its members will assume liability for any use made of this publication or the model agreement to which it relates.

All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, electronic, mechanical, photocopying, recording or otherwise, without prior written permission of the publishers.

Crown copyright material is reproduced with the permission of the Controller of Her Majesty’s Stationery Office.

Copyright © 2019 The UK Oil and Gas Industry Association Limited trading as Oil & Gas UK

ISBN: 1 903 004 73 2 PUBLISHED BY OIL & GAS UK

London Office:

6th Floor East, Portland House, Bressenden Place, London, SW1E 5BH Tel: 020 7802 2400 Fax: 020 7802 2401

Aberdeen Office:

Exchange 2, 3rd Floor, 62 Market Street, Aberdeen, AB11 5PJ Tel: 01224 577250 Fax: 01224 577251

[email protected]

www.oilandgasuk.co.uk

Contents

1.1 Introduction 8 1.2 Purpose 8 1.3 Scope 8

2 Planning and Procuring Service 10 2.1 Aviation Policy 10

2.1.1 Insurance Requirements 10 2.2 Scope of UAS Services 10 2.3 Defining Task Requirements and Work Scope 11

3 UAS Industry Guidelines Model 12 3.1 Interpreting the UAS Industry Guidelines Model 12 3.2 Quality Management System 13 3.3 Safety Management System 14

3.3.1 Just Culture 14 3.3.2 Incident Reporting 15 3.3.3 Management of Change 17 3.3.4 Safety Collaboration 17 3.3.5 Safety Plan 17

3.4 Operating Requirements and Procedures 19 3.4.1 Operations Management 19 3.4.2 Documentation 19 3.4.3 Operations Manual 20 3.4.4 Method Statement 20 3.4.5 Operating Procedures 20 3.4.6 Fatigue Management 21

3.5 Operating Safety Case 21 3.5.1 Standard Operating Limitations 21

3.6 Training, Assessment and Currency 22 3.6.1 Suitably Qualified and Experienced Personnel 22 3.6.2 CAA UAS Pilot Training Requirement 22 3.6.3 Training System 22 3.6.4 Industry Specific Training 23 3.6.5 Relevant Experience 25 3.6.6 Currency 25

3.7 Aircraft Systems and Airworthiness 26 3.7.1 System Requirements 26 3.7.2 New Technology 26 3.7.3 Maintenance 28 3.7.4 Equipment Control 28 3.7.5 Batteries 28

3.8 Task Specific Risk Assessment 29 3.8.1 Example Risks 30

3.9 UAS Team – Flight Execution 31 3.9.1 Crew Resources Management (CRM) 31


3.9.2 Flight Execution 32 3.9.3 Managing UAS Operations 32

3.10 UAS Team – Emergency Procedures 32 3.10.1 Emergency Scenarios 32 3.10.2 Procedures and Training 33 3.10.3 Emergency Response Plan 33

3.11 Aircraft Systems – Flight Recovery 33 3.11.1 Aircraft System 34

3.12 Using the UAS Industry Model 34

4 Managing UAS Operations 36 4.1 Auditing and Compliance Requirements 36 4.2 Roles and Responsibilities 36 4.3 Safety 37 4.4 Communication 38 4.5 Operations 38

4.5.1 UAS Service Provider – Non-aviation Training Requirements 38

4.5.2 Permit to Work 38 4.5.3 Minimum Crew 38 4.5.4 Equipment 39 4.5.5 Weather Conditions 40 4.5.6 Aviation Operations 41 4.5.7 Deconfliction with Maritime Activity 41

4.6 Flight operation 41 4.6.1 Pre-Flight 41 4.6.2 Launch and Recovery 42

4.7 Offshore Transportation and Accommodation 42

5 References 43


Glossary Definitions Airworthiness A condition in which the UAS (including the aircraft, airframe, engine,

propeller, accessories, appliances, and control station conforms to its type certificate, if applicable, and is in condition for safe operation.

Airworthiness Certification

A repeatable process that results in a documented decision that an aircraft system has been judged to be airworthy. It is intended to verify that the aircraft system can be safely maintained and safely operated by fleet pilots within its described and documented operational envelope.

ANO Air Navigation Order

BOSIET Basic Offshore Safety Induction and Emergency Training

BVLOS Beyond Visual Line of Sight

CAA Civil Aviation Authority

CAP Civil Aviation Publication

Congested Area Within aviation legislation (i.e. Air Navigation Order 2016) ‘congested area’ has a specific meaning which is “in relation to a city, town or settlement, means any area which is substantially used for residential, industrial, commercial or recreational purposes”. In the context of on and offshore UAS operations, working in a congested area should be determined on a case-by-case basis.

Deconfliction Reducing the risk of collision between aircraft by coordinating their movements

Experimental Certificate

A type of Special Airworthiness Certificate issued for the purposes of research and development, crew training, exhibition, and market survey. Commercial UAS operations cannot be conducted with an experimental certificate.

EU European Union

Flight Termination The intentional and deliberate process of performing controlled flight into terrain. Flight termination should be executed in the event that all other contingencies have been exhausted, and further flight of the aircraft cannot be safely achieved, or other potential hazards exist that require immediate discontinuation of flight.

Flyaway An interruption or loss of the control link, or when the pilot is unable to effect control of the aircraft and, as a result, the UAS is not operating in a predicable or planned manner.

GPS Global Positioning System

HAZID/HAZOP Hazard Identification/Hazard and Operability

HLO Helicopter Landing Officer

HSE Health and Safety Executive

IOGP International Association of Oil and Gas Producers

ISO International Standards Organisation


Glossary Definitions Lost Link The loss of command-and-control link contact with the remotely

piloted aircraft such that the remote pilot can no longer manage the aircraft’s flight.

MODU Mobile Offshore Drilling Unit

NQE National Qualified Entity

Observer A trained person who assists a UAS pilot in the duties associated with collision avoidance and navigational awareness through electronic or visual means. Collision avoidance includes, but is not limited to, avoidance of other traffic, clouds, obstructions, terrain and navigational awareness. A visual observer (VO) is a trained person who assists the UAS pilot by visual means in the duties associated with collision avoidance.

OIM Offshore Installation Manager

OPITO Offshore Petroleum Industry Training Organisation

OSC Operational Safety Case

Pilot Duty Period The period beginning when a flight crew member is required to report for duty with the intention of conducting a flight and ending when the aircraft is parked after the last flight. It includes the period of time before a flight or between flights that a pilot is working without an intervening rest period.

PIC Pilot in Command The person who has final authority and responsibility for the operation and safety of flight, has been designated as PIC before or during the flight, and holds the appropriate category, class, and type rating, if applicable, for the conduct of the flight. The responsibility and authority of the PIC apply to the UAS PIC. The UAS PIC position may rotate duties as necessary with equally qualified remote pilots. The individual designated as PIC may change during flight. NOTE: The PIC can only be the PIC for one aircraft at a time. The PIC should meet UAS guidance requirements for training, pilot licensing and medical requirements.

PTW Permit to Work

RAIM Receiver Autonomous Integrity Monitoring For aviation GPS applications. In order for a GPS receiver to perform a RAIM or fault detection function, a minimum of 5 satellites with satisfactory geometry must be visible to the GPS receiver.

SMS Safety Management System

Scheduled Maintenance (Routine)

The performance of maintenance tasks at prescribed intervals.

UA Unmanned Aircraft A device used or intended to be used for flight in the air that has no on-board pilot.


Glossary Definitions UAS Unmanned Aircraft System

A UA and its associated elements related to safe operations, which may include control stations (ground-, ship-, or air-based), control links, support equipment, payloads, flight termination systems, and launch/recovery equipment.

UKCS United Kingdom Continental Shelf

Unscheduled Maintenance (Non-routine)

The performance of maintenance tasks when mechanical irregularities occur.

VLOS Visual Line of Sight Unaided (corrective lenses and/or sunglasses exempted) visual contact between a PIC or a VO and a UA sufficient to maintain safe operational control of the aircraft, know its location, and be able to scan the airspace in which it is operating to see and avoid other air traffic or objects aloft or on the ground.

VMC Visual Meteorological Conditions

VO Visual Observer


1.1 Introduction

Unmanned Aircraft Systems (UAS) have the potential to offer significant safety and economic benefits to the Oil and Gas sector. UAS can be used to replace or enhance existing survey, inspection, maintenance and logistical solutions. In addition, advancements in sensor technology and data capture have improved data handling benefiting the oil & gas sector.

Unmanned aircraft vary considerably in size and weight and include both rotary and fixed wing variants. Their use can also vary from simple, low risk tasks to complex, high risk flights in close proximity to personnel and high value assets. Regardless of their size and the complexity of application it is essential that the risks associated with their use are understood, mitigated and the project is managed to the greatest extent possible.

1.2 Purpose

This document has been produced by OGUK in conjunction with key industry individuals and organisations to assist those with responsibilities for procuring, managing and operating UAS on and around oil and gas installations, to reduce the risks involved to as low as reasonably practicable during the entire project.

The intent of these guidelines is to encourage duty holders planning to utilise UAS to consider the entire operating and safety system, not just the air vehicle. Guidelines enable duty holders to have a greater understanding of the level of risk they are accepting and provide a tool to assist in making decisions regarding the use of UAS. The guidelines contained within this document are designed to provide a framework for the safe management/operation of UAS.

For UAS service providers this document aims to provide guidance on the main aspects of safe service provision in the oil & gas Industry both on and offshore. The term service provider also includes Duty Holders utilising their own personnel to operate UAS. Assessment of their industry training, task/environment specific experience, procedures and UAS should be exactly the same as for a dedicated service provider.

1.3 Scope

The UAS industry is developing rapidly with new equipment, applications and procedures being introduced at a rapid pace. An important element contributing to the safe growth of the industry is the introduction of standards and guidelines. Standards are important in that they set agreed levels of good practice or quality and help build trust. Guidelines also set out best practice and complement standards such as those produced by the British Standards Institute (BSI).

This document does not prescribe set standards for the use of UAS. Instead, the document is designed to provide guidance to Duty Holders and Service Providers on the safe operation of UAS with a mass of 20kg or less in the oil & gas industry.


This document does not provide guidance on the quality, security, and presentation of data that may be captured by UAS.


2 Planning and Procuring Service

2.1 Aviation Policy

Regulations governing the use of unmanned aircraft in the UK are contained within the Air Navigation Order (ANO) 2018. Guidance on the use of UAS in the UK is provided within Civil Air Publication 722: Unmanned Aircraft System Operations in UK Airspace (2015).

The guidelines provided in this document are designed to supplement the national regulations.

2.1.1 Insurance Requirements

Aviation insurance requirements for operators of unmanned aircraft in the European Union are set out in Regulation (EC) 785/2004 Article 2.

To operate on or in the vicinity of oil and gas installations a commercial UAS operator should be in possession of the following minimum insurance cover, valid for the period of the contract and underwritten by an insurance provider fully certified to do business in international financial markets.

• £10m third party public liability • £1m professional indemnity • £5m employers’ liability

2.2 Scope of UAS Services

This document deals principally with commercial UAS operations conducted on oil & gas infrastructure, including vessels, with the UAS having a maximum mass of 20 kg or less.

It is readily acknowledged by OGUK that as UAS technology advances, more sophisticated aerial platforms and task applications, such as non-destructive testing and logistics, will become more prominent, thus opening up the full potential for UAS support to the oil and gas industry.

Broadly speaking there are currently two main types of UAS operation conducted within oil and gas infrastructure:

a) Aerial Photography/Survey/Security/logistics - These operations typically involve flying in an open space away from structures. Examples of these would be taking overview photographs of a refinery or delivering equipment offshore.

b) Inspection Operations - these operations account for the majority of current UAS activities. This usually involves flying close to and even under structures in order to get detailed imagery or data of the asset.

On and offshore oil and gas infrastructure that can currently be accessed using UAS includes but is not limited to: flare towers and other elevated structures, flare booms, live flare tips, turbine generator exhausts, sulphur chimneys, cranes, drilling derricks, helideck support structures, under deck/splash zone, jacket structure/legs, risers/caissons, vessel hulls and tank internals.


2.3 Defining Task Requirements and Work Scope

From the outset, when specifying and procuring UAS services for work on oil and gas installations and vessels it is imperative that on and offshore management and UAS operating processes are fully understood.

Section 3 of this document sets out the key factors influencing risk and the safe operation of UAS for both duty holders and service providers. Section 4 addresses the requirements that should be considered by a Duty Holder for managing UAS within their domain.

In order for a Duty Holder to properly specify and procure UAS services it is essential to clearly set out what the UAS objectives are and, on completion of the tasking, the deliverables required 1 . This information should be used to inform the development of a detailed scope of work against which performance of the UAS services can be measured.

The scope of activity will depend largely on the following:

• Nature of the task (For example: close visual inspection, stand-off survey, logistics) • Scale of the task • Complexity of the operating environment • Proximity to other people, vehicles, vessels, and structures/buildings. This includes those under

control of the duty holder and those who are not. • Requirement for permissions and permits

Once the scope of the activity has been defined, service providers with the appropriate equipment, training and experience can be identified. Duty Holders should consider how they will assess potential service providers. The level of assessment should be proportionate to the level of risk involved and may require a formal audit. Potential service providers must have, as an absolute minimum, a Permission for Commercial Operations (PfCO) issued by the CAA. However, there are many factors to consider when selecting a service provider and these are addressed in the following section.

1 This may include specifying the resolution and/or accuracy of the data.


3 UAS Industry Guidelines Model

3.1 Interpreting the UAS Industry Guidelines Model

The UAS Industry Guidelines Model shown in Figure 2 provides an overview of the key factors that underpin the safe operation of UAS. The model identifies ten areas that contribute to safety; eight that help prevent an incident from occurring (Hazard Prevention) and two that help prevent an accident should an incident occur (Hazard Recovery). The more controls or ‘threat barriers’ that are present and the stronger they are the less likely a pre-existing hazard will lead to an incident. The same can be said for the Hazard Recovery or ‘harm barriers’ where robust emergency procedures and flight recovery systems will help prevent an incident, such as a loss of the control link, leading to an accident.

The first six threat barriers are those that contribute to the safe operation of all UAS tasks. The final two threat barriers along with the two harm barriers contribute to the safety of a specific task in a specific location. It is acknowledged that emergency procedures and flight recovery systems may be applicable across multiple scenarios. However, within the context of the model they are there to illustrate the tactical application when completing a specific task or recovering from an incident.

It is important to note that the strength of several barriers within the Hazard Prevention group are influenced by both the Duty Holder and Service Provider. Furthermore, interaction between the Duty Holder and Service Provider is crucial in order to gain the greatest safety benefit.

Figure 1: UAS Industry Guidelines Model


3.2 Quality Management System

The implementation of a robust Quality Management System (QMS) affects every aspect of an organization’s performance, including safety. A documented and structured approach to an organization’s processes and procedures helps to:

• Ensure compliance with regulations and standards • Provide quality services and achieve consistent results • Prevent mistakes • Create a cycle of improvement • Ensure employees and sub-contractors are provided with appropriate training • Set and monitor key performance indicators

When procuring UAS services, the existence of a QMS helps provide reassurance that an organization has attained a certain level of maturity in terms of its processes and procedures. It is recommended that Service Providers attain ISO 9001:2015 accreditation. In addition, Achilles FPAL is a recognised body for reporting and monitoring the quality of service providers within the Oil & Gas industry. Achilles FPAL membership is an integral part of the global oil and gas industry-wide initiative implementing a Supply Chain Code of Practice. This is endorsed by the Oil and Gas UK supply chain to measure best practice during the procurement process.

In the event a service provider does not have a formal QMS accreditation, Duty Holders should look for evidence of the following:

• Other external audits • Established internal auditing programme and other processes that contribute to continuous

improvement • Formal document control procedures • Establishment and monitoring of appropriate key performance indicators • Compliance with national aviation regulations • Formal training system and training records • Suitably qualified personnel

o Safety Manager o Maintenance Manager o Training Manager o UAS Pilot

• Maintenance Logs • Calibration Certificates (where applicable)


• Process for the review of procedures, safety, documents and issues

3.3 Safety Management System

A Safety Management System (SMS) provides a systematic approach to managing safety, including the necessary organisational structures, accountabilities, policies and procedures. An effective SMS requires planning, organising and communicating. Inherent within the SMS is a requirement for aviation safety management to be integrated into the day-to-day activities of the Duty Holder and Service Provider.

The Duty Holder should incorporate aviation activities into their own SMS to deal with aviation specific risks. Aviation hazards should be risk assessed and appropriate mitigation applied so that risks are reduced to as low as reasonably practicable (ALARP). This risk management process should not be completed in isolation as the risks and mitigation may well be dependent on the service provider. Also, the mitigation put in place may drive certain requirements from the Service Provider. Any mitigation required by the Duty Holder should be included within the Permit to Work.

3.3.1 Just Culture

An important factor enabling the successful implementation of a SMS is to attain a “just culture” reporting environment. An effective reporting culture depends on how Duty Holders and Service Providers handle blame and punishment.

Only a very small proportion of human actions that are unsafe are deliberate, such as reckless noncompliance, and as such deserve sanctions of appropriate severity. However, the implementation of a ‘no-blame’ culture is not the answer as it goes against the principle of appropriate, and proportionate sanctions. What is needed is a “just culture”, where an atmosphere of trust in which people are encouraged, even rewarded, for providing essential safety-related information but in which they are also clear about where the line must be drawn between acceptable and unacceptable behaviour.

There is a need to learn from accidents and incidents through safety investigation so as to take appropriate action to prevent the repetition of such events. In addition, it is important that even apparently minor occurrences are investigated, in order to prevent catalysts for major accidents. Safety analysis and investigation is a necessary and effective means of improving safety, by learning the appropriate lessons from safety occurrences and adopting preventative actions. Duty Holders should look for evidence of a ‘just culture’ within the Service Providers organisation.


3.3.2 Incident Reporting

The purpose of reporting UAS incidents and events and providing feedback to the industry is fundamental to evaluating and improving safety performance. Doing so will provide members of the OGUK UAS Technical Group (UASTG) including Duty Holders, UAS Service Providers, Original Equipment Manufacturers (OEMs) and regulators with an opportunity to share safety issues and highlight lessons learned as a result of any problems experienced during design, manufacture and operations.

This has been a routine process for offshore helicopter operations for many years and it has led to a much better understanding within the Aviation Safety Technical Group (ASTG), across all stakeholders, and many valuable lessons have been learned about a variety of aviation technical and operational safety related issues.

3.3.2.1 Air Accident Investigation Branch and Civil Aviation Authority Incident Reporting

Accidents and Serious Incidents must be reported to the Air Accident Investigation Branch (AAIB). An Accident is an occurrence associated with the operation of an unmanned aircraft which takes place between the time the aircraft is ready to move with the purpose of flight until such time it comes to rest at the end of the flight and the primary propulsion system is shut down, in which a person is fatally or seriously injured as a result of direct contact with any part of the aircraft, including parts which have become detached from the aircraft.

A Serious Incident is where there was a high probability of an accident associated with the operation of an unmanned aircraft. The difference between an accident and a serious incident lies only in the result.

All other occurrences must be reported under the CAA Mandatory Occurrence Reporting Scheme (MOR Scheme – details are contained in CAP 382). All occurrences related to UAS operations which are considered to have endangered, or might have endangered, any aircraft (including the subject unmanned aircraft) or any person or property, must be reported to the CAA via the MOR Scheme. This applies equally to all UAS categories, regardless of the aircraft's mass or certification state. Some examples of reportable incidents are:

• Loss of control/datalink – where that loss resulted in an event that was potentially prejudicial to the safety of other airspace users or third parties

• Close proximity to another aircraft where the distance between aircraft as well as their relative positions and speed were such that the safety of the aircraft involved may have been compromised. This is known as an AIRPROX.

• Significant navigation failures • Crew Resource Management (CRM) failures/confusion • Structural damage/heavy landings • Any incident that injures a third party

Accidents, serious incidents, and occurrences should be reported by the Service Provider. However, Duty Holders have a responsibility to ensure appropriate reporting mechanisms have been followed.


3.3.2.2 Health & Safety Executive Incident Reporting

Arrangements for reporting offshore incidents are jointly managed by the competent authority Health & Safety Executive (HSE) and The Department for Business, Energy and Industrial Strategy (BEIS) through the Offshore Safety Directive Regulator (OSDR). Incident reporting obligations under the new regime principally rests with the offshore installation owners and operators.

OSDR is responsible for the regulation of major safety and environmental accident hazards, and their consequences, in the offshore oil and gas sector. OSDR will coordinate the investigation of Reportable Incidents and Complaints, with decisions made at an early stage on a case by case basis as to which regulatory partner should lead, with aligned principles of enforcement covering safety and environment.

The offshore incident reporting process is driven by OSDR with reportable incidents and events notified in accordance with the OSDR ‘Notifying a Reportable Oil and Gas Incident’ (ROGI) Process Framework. Incidents should be reported as soon as possible but within 10 days at the absolute maximum.

Therefore, because all offshore UAS operating activities are authorised and controlled by the installation ‘Permit to Work’ system then legal responsibility for any UAS incident reporting falls to the installation Duty Holder.

Clearly, a service provider will need to assist the Duty Holder with completing the OSDR report forms in order to provide relevant information about the incident, personnel and equipment involved and procedures in place.

3.3.2.3 OGUK Incident Reporting

In addition to the regulatory reporting mechanisms above, safety benefit can be gained from sharing and investigating UAS incidents within the OGUK community.

The following processes mirror those in place for offshore helicopter operations:

• UAS Safety Alert • UAS Incident Reporting Procedures and Report Form • UAS Incident Database

UAS Safety Alert

Similar to helicopter operations, it is used to expedite lessons learned from incidents. The quickest and easiest way to disseminate this information is through an OGUK Safety Alert.

UAS Incident Reporting Procedures

All accidents, incidents, near misses and failures of safety controls should immediately be reported by the Service Provider to the Duty Holder and assistance given to notify the appropriate regulatory authorities (e.g. the Health & Safety Executive and CAA). Copies of official incident report forms should be sent to OGUK. In addition, Duty Holders and Service Providers are encouraged to report more minor incidents to OGUK so that learning and improvements can be made.


Incidents should be fully investigated by the Duty Holder and Service Provider in order that root-cause analyses can be conducted, and lessons identified, promulgated and implemented. Timely and accurate occurrence reporting is required across all UAS operations to: notify all relevant agencies of actual and potential hazards, initiate further investigation where appropriate and enable data capture and analysis. Robust and coherent reporting processes enable action to be initiated to prevent recurrence.

Incident reporting, analysis and lessons learned should be an integral part of a Duty Holders SMS and a review should be included in Duty Holder’s UAS operator auditing procedures.

UAS Incident Database

Using the annual data collected from helicopter operators and other official sources, OGUK have access to over 40 years of helicopter operations data. This data is routinely used to produce Section 10 – Offshore Helicopters - in the OGUK Annual Safety Reports.

Data that informs input to the Annual Report is made accessible in ‘sanitised’ form to the CAA and contributing companies.

OGUK will maintain a UAS incident database in order to identify trends and improve the safe operation of their use.

3.3.3 Management of Change

Duty Holders and Service Providers should have formal processes in place to manage aviation related changes effectively. This includes such things as:

• The introduction or modification of equipment • Change in operating procedures • Change in training methods • Change in work environment

The management of change process should evaluate the potential impacts of the proposed change in terms of existing risks and mitigation and also any new risks that may be introduced. The process should include the introduction of temporary changes as well as those that are more permanent.

3.3.4 Safety Collaboration

A full understanding of potential hazards can only be achieved through a joint safety management approach between the Duty Holder and the Service Provider. Both parties should share relevant aspects of their risk register and operating safety case in order to have a joint and integrated approach to safety management.

3.3.5 Safety Plan

A safety plan is an important operational document specific to oil and gas operations, including UAS operations. The purpose of the safety plan is for the Duty Holder to understand and approve the safety


and communications procedures that a UAS operations team will follow during the tasking. The safety plan should, as a minimum, contain the following details:

1. UAS specification and limits a) UAS technical specification b) UAS operating limitation and restrications

2. Pilot Limitations a) Weather limitations (if different from the UAS limitations)

b) Task limitations

3. Operation description including the scope of work(s) to be executed

a) Required equipment and personnel b) Permit to work system c) Airspace considerations d) Take-off and landing sites e) Airborne procedures including details of flight paths f) Communications protocol

4. Operations restricted access a) Restricted access to areas with hazardous atmospheres

identified and/or appropriate mitigation measures in place. b) Restricted access to areas of known or potential magnetic or

radio wave interference identified and/or appropriate mitigation measures in place

c) Overfly and security/privacy restrictions identified and mitigated for operations adjacent to 3rd party assets and people on and offshore

5. Emergency Response Plan a) Fire and gas alarms/release response procedures b) Blowdown/increased flare rate response procedures c) Emergency procedures for UAS operational upset conditions

6. Preventative Matters a) Prop/rotor failure b) Battery failure c) Loss of communications link

7. Loss of payload/dropped object risk 8. Resistance to magnetic disturbances 9. Logfile recording


3.4 Operating Requirements and Procedures

3.4.1 Operations Management

An essential safety element within the operations process is to ensure the right equipment and personnel are allocated to the task and operating environment. A process should be in place where the level of pilot competence is matched to the complexity of the task and the equipment selected is both fit for purpose and in a serviceable condition. A process for authorising appropriate personnel and equipment for each task should be in place. The authorising process may be enhanced through appropriate tracking of the following:

• Pilot experience • Pilot currency • Pilot training • Equipment serviceability states

Other procedures such as a formal out-brief and in-brief process help ensure all actions have been completed and add an additional layer of assurance.

3.4.2 Documentation

The operational team should carry sufficient documentation appropriate to the task. For example, the following documents would typically be available on site either in hard copy or electronically:

• Work Pack Containing o Risk Assessment & Method Statement o Work scope o Emergency contact details o Certificates of conformity (if applicable)

• Aviation permissions / exemptions / waivers (if applicable) • Permit to Work (if applicable) • Aircraft Logbook • Daily Flight Logs • Operations Manual • Aircraft flight manual


3.4.3 Operations Manual

The Service Provider should have a comprehensive Operations Manual in accordance with CAP 722 and signed by their accountable manager. Access to the Service Provider’s operations manual should be made available to the Duty Holder prior to and during the contract for UAS services. In particular, Duty Holders should look for evidence of the following:

• Aircraft Operating Limitations • Aircraft checklists • Emergency Procedures • Risk Assessment Procedure • Procedures for deconfliction from manned aircraft (and other drones) • Team composition (including the use of safety observer) • Incident Response Checklist • Safe Transport and Storage of Equipment • Containment of damaged batteries / equipment • Training and currency • Maintenance procedures

The Duty Holder should include the use of unmanned aircraft within their own operating procedures. In particular, procedures should be available for the following:

• Aviation Roles & Responsibilities • Communication Plan • Airspace Management • Deconfliction with other activities • Actions in the event of a drone crash • Incident Reporting Procedures • Transportation and Storage of Hazardous Goods • Identification and Management of Aviation Risks

3.4.4 Method Statement

Where survey or inspection services are to be provided, the Service Provider should have documented procedures (sometimes known as Collection Plans) covering the process for capturing the data. The collection plan will form the basis of the method statement that should be submitted and agreed with the Duty Holder prior to the flights commencing.

3.4.5 Operating Procedures

In addition to having defined operating procedures within operations manuals and collection plans it is important that they are subject to ongoing validation to ensure they remain fit for purpose. Furthermore, measures should be taken to ensure operational teams on site adhere to the procedures.


3.4.6 Fatigue Management

The Service Provider should have a fatigue management program for its operational personnel. It is recommended that the daily operating time for each pilot/payload operator/safety observer is limited to eight hours, and the continuous operating time for each task is limited to three hours.

3.5 Operating Safety Case

Service Providers operating within the standard CAA limitations with an aircraft mass up to 20kg are not necessarily required to have an Operating Safety Case (OSC). Regardless of the operating limitations in place, it is good practice for any Service Provider operating in hazardous areas to have a comprehensive OSC. An OSC is reviewed by the CAA and demonstrates that the Service Provider has a comprehensive understanding of their main operating risks and an appropriate risk mitigation strategy. In particular, the OSC should describe how procedures, training, equipment, and safety management systems contribute to the safe operation of their aircraft.

Service providers that require less restrictive operating limitations are required to have an OSC. This includes activities such as:

• Extended Visual Line of Sight (EVLOS) • Beyond Visual Line of Sight (BVLOS) • Reduced separation from people, vehicles and vessels not under direct control

3.5.1 Standard Operating Limitations

Service Providers with a standard Permission for Commercial Operations (PfCO) must operate within the following limitations2.

• Maximum 500m horizontal distance from the pilot • Maximum 400ft vertically • No operation of UAS within 50m of people, vessels, vehicles and property not under the direct

control of the pilot3 • Maintain UAS within visual line of sight

2 Full details of drone operating limitations are contained within the Air Navigation Order and the Operators Permission for

Commercial Operations. 3 During take-off and landing this may be reduced to 30m.


3.6 Training, Assessment and Currency

3.6.1 Suitably Qualified and Experienced Personnel

In order to integrate safely the use of UAS into the oil & gas environment it is important to ensure that all personnel, including sub-contractors, are suitably trained and experienced appropriate to their level of aviation exposure. Service Providers will generally be expected to manage and conduct their flying activities in a manner similar to established aviation industry practices. This includes promulgating the policies, practices and procedures required for UAS pilot and support team training, recurrent training, competence and currency requirements.

However, there are significant variations in training and operational experience across drone service providers. Duty Holders should consider what level of training is appropriate depending on the complexity of the task and operating environment.

3.6.2 CAA UAS Pilot Training Requirement

In order to operate a drone commercially pilots are required to complete theory training and pass a theory/practical assessment at a CAA approved National Qualified Entity (NQE). The subject areas and assessment criteria are set out in CAP 722. The training and assessment provided by an NQE is the minimum amount required.

There is no requirement for pilots to repeat the assessment in order to monitor currency nor is there any industry specific training within the syllabus. Therefore, service providers with no previous experience within the industry and/or with no industry specific training may lack the skills and knowledge necessary to operate safely in more complex environments. For those Service Providers with an Operating Safety Case, the CAA will require evidence that a pilot is suitably trained and current to operate in accordance with any exemptions.

3.6.3 Training System

Processes for UAS pilot selection, initial and recurrent type training, currency requirements, competence assessment and record keeping should be determined by the Service Provider and be embedded in the SMS. The Service Provider’s operations manual should have detailed UAS type training and recurrent training policies and adequate systems in place for undertaking periodic competency checks for each UAS pilot/crew member.


The Service Provider should also maintain up-to-date records of qualifications, training and competence assessments for each individual UAS pilot/crew member.

Training records and training manual should be made available for detailed examination by a competent aviation auditor appointed by the duty holder.

3.6.4 Industry Specific Training

Service Providers can vary significantly in terms of their training and experience and the Duty Holder should seek an appropriate level of training and experience proportionate to the complexity of the task and environment. Industry Specific Training is essential for those operating in complex, safety-critical environments and for those tasks that require a high level of airmanship and skill.

Currently there are two main groups of UAS operation that are carried out within the oil and gas industry:

Aerial photography/survey/security/logistics

These operations typically involve flying in more open spaces away from structures. An example of this would be taking overview photographs of a refinery or offshore platform. This task generally requires a lower level of skill than close inspection flying as the pilot will have more time and space to react to a system anomaly or failure or change in weather conditions. Nevertheless, the pilot should undertake additional training to ensure they have a comprehensive understanding of the potential hazards that may be present and how to mitigate the risks.

Inspection operations

This usually involves flying close to and even under structures in order to get detailed imagery or data of the asset. An example would be conducting a close visual inspection of a flare boom. Flying close to structures carries a potentially higher degree of risk as the pilot has less time to react to an unplanned event. There is also a higher probability of encountering turbulent air, the presence of explosive atmospheres and system anomalies caused by magnetic disturbance or loss of GPS. In addition to a comprehensive knowledge of the hazards present, pilots should have received additional practical training to ensure they are skilled at flying close to structures, without GPS assistance, and able to launch/recover to a confined space.

Industry Specific Training may be completed through a Service Provider’s internal training programme or via an external training provider.

Training Content Prior to Onshore

Some example training objectives for onshore work are as follows:

Ground Training:

• Detailed systems training on aircraft type (GPS vulnerabilities, magnetic interference issues and flight system dependencies)

• Hazard awareness and risk management in complex industrial environments • Data collection techniques • Permit to Work system


Onshore Flight Training: • Flight skills assessments in confined areas and close to structures (including without the

availability of GPS)

Typically, eight hours ground instruction and two hours flight instruction (by a qualified UAS pilot instructor) culminating in an assessment of competence.

Newly graduated pilots should initially be supervised/mentored on-site by an experienced pilot instructor. Once this period of supervised work (e.g. a minimum of five hours logged flight time on the UAS type) a pilot should have gained sufficient experience in complex onshore environments to work without additional oversight.

Training Content Prior to Offshore

Ground Training:

• Minimum Industry Safety Training (MIST) • Basic offshore safety induction and emergency training (BOSIET) – industry mandated

(not included in the training times) • Dangerous Goods by Air Training 3day Packer and Shipper course (UK CAA mandated training

requirement) - (not included in the training times) • Advanced systems knowledge – flight systems theory

o GPS multipath o Accelerometer and gyro errors o Magnetic interference influence on flight systems o Electromagnetic interference effects o Local barometric pressure anomalies and effects o Autopilot control theory, Kalman filters and combination effects of sensor degradation o Offshore weather and sea influences o Additional hazard awareness and risk management in complex offshore environments o Advanced data collection techniques

Flight Training:

• Advanced flight skills – look-down scenarios, close to structures, all orientations • Operations in areas with magnetic interference • Operations under deck and lookdown scenarios including GPS denied areas • Close visual inspection operations at distances >50m from pilot position • Operating in induced turbulence and rotor streaming areas • Recovery from lost link, GPS drop out

Typically, eight hours ground instruction and 15 hours scenario-based flight instruction (by a qualified UAS Pilot Instructor) culminating in an assessment of competence. Pilots should initially be supervised/mentored offshore by an experienced pilot instructor. The period of supervised work should be a minimum of five hours logged flight time on the UAS type.

In addition to specialist internal training, industry specific training courses are also available from external training providers. The Engineering Construction Industry Training Board (ECITB) has produced


a specific Training Standard that includes operating within the oil and gas sector. This training covers such topics as:

a) Being aware of the relevant regulations pertaining to flying operations (e.g. CAA, EASA). b) Recognising the role Human Factors can play in inducing errors into Industrial Drone Operations. c) Identifying and selecting aircraft and payloads appropriate to the task and environment. d) Describe a range of factors that can affect aircraft control. e) Capture data to meet quality and General Data Protection Regulation requirements. f) Identify hazards and mitigate risks in a range of Industrial environments such as Oil and Gas

within Confined Spaces etc utilising the correct reporting procedures in the event of an incident. g) Create Pre deployment risk assessments. h) Perform commercial drone operations safely within Industrial environments.

Practical elements of the training include:

a) Basic to Skilled, which involves assessments of flying the drone and performing various manoeuvres in flight.

b) Advanced training involves flying of the drone within certain distances of a structure and holding at different heights all whilst being certain distance away and the entry into an enclosed space.

3.6.5 Relevant Experience

A Service Provider may have several hundred hours operating UAS. However, that experience may have been:

• Within non-complex environments • On tasks where the level of flying skill required is very different • On a different type of aircraft

Duty Holders should therefore look for evidence of relevant experience both in terms of the company and the pilot(s) that will be used. Operators without offshore experience may gain experience as a payload operator/safety observer before assuming the role of pilot in command.

3.6.6 Currency

In addition to relevant experience, Duty Holders should look for evidence of pilot currency both on the aircraft type and the nature of work being undertaken. Service Providers should specify currency requirements within their Training or Operations Manual and maintain records of assessments.

Service Providers should document requirements for periodic competency checks to ensure operational staff maintain standards and knowledge. These checks should include competence in the handling of typical emergency scenarios and failure modes.


3.7 Aircraft Systems and Airworthiness

There is a vast array of aircraft types on the market and new systems and updates are being introduced at an ever-increasing rate. It can therefore be challenging for Duty Holders to understand what impact the selection of a particular aircraft will have on their operation. Whilst the design of the aircraft is a factor, it is equally important that the aircraft and associated systems are maintained correctly and there is a system in place to ensure only serviceable equipment is taken on site.

3.7.1 System Requirements

Once an initial scope of work has been determined an important consideration is whether the performance of the aircraft and its associated systems are suitable for the task and environment. For example:

• The aircraft operate in the typical wind speeds encountered offshore • The aircraft and its associated systems are of a suitable size and weight to be transported (if

applicable). • The size of the aircraft is appropriate for take-off and landing in confined spaces (if applicable). • The aircraft resistant to magnetic interference • The aircraft and associated systems are intrinsically safe?4 • The materials of the aircraft and payload should be non-hazardous to the structure and the

operational environment during normal operations or in the instance of a malfunction or failure.

3.7.2 New Technology

Whilst service providers are often quick to adopt the latest technology, it may be prudent to specify a minimum time a product must have been on the market when it is being used in a high-risk area. A period of 6 months would normally allow sufficient time for any issues to be identified by the end user and be rectified by the manufacturer. Even aircraft from proven manufacturers can be prone to issues such as magnetic interference and GPS inaccuracies when used in an oil and gas environment and this may not become apparent until several months after release.

4 If the aircraft and associated systems are not intrinsically safe, then other mitigation should be in place in areas where there

is a spark risk.


Some service providers will have formal test and evaluation procedures for the introduction of new equipment which may speed up the introduction of new technology. Operators using bespoke UAS should provide evidence of test and evaluation and details of any safety systems.

3.7.2.1 Redundancy

An important consideration when selecting a suitable aircraft is the number of single points of failure. In the absence of formal airworthiness certification this is a useful indication of how resilient the aircraft is to various failures. The following are the key areas to consider with regard to the redundancy of components:

Flight Control System: A failure of a main component such as the Inertial Measurement Unit (IMU) may lead to a catastrophic failure. Some aircraft are fitted with dual or even triple redundant flight control systems. The aircraft should have multiple operational modes (e.g. GPS mode, height mode and manual mode) in the case of a malfunction or failure.

Navigation: Many operators rely on the use of GPS for such things as simplifying control of the aircraft, limiting operating areas (geofencing), and emergency recovery procedures. Redundancy of navigation systems such as GPS is therefore important.

Motors and Rotors: A failed motor or rotor in a single rotor or quad rotor aircraft would cause a catastrophic failure. Aircraft with six or more rotors can usually withstand the loss of at least one motor or rotor failure.

Control Link: A loss of a control link may lead to an aircraft initiating an automated flight mode. However, automated flight/recovery modes usually rely on the availability of GPS. A GPS signal may not always be present, particularly when flying between or underneath structures. It is therefore an advantage to have a redundant control link.

Power Supply: Aircraft with a mass of 20kg or less are usually powered by batteries. The failure of a battery would be catastrophic if the aircraft is fitted with just one. Some multi-battery systems cannot withstand the failure of one battery.

The availability of warning systems, both audible and visual, that notify the pilot of potential issues such as low battery voltage or degraded GPS signal is an added safety benefit. Some systems have inherent automated features that will, for example, return the aircraft to the ‘home’ position if the battery reaches a pre-determined level. However, such features should be considered as part of the risk assessment process as an automated manoeuvre to return home may introduce a new hazard when operating in close proximity to people and structures.

When assessing the level of redundancy of a UAS it is important to remember that not all tasks will necessarily require a high level of redundancy for all components. Lower risk flights such as aerial filming away from people and infrastructure may not require the same redundancy as flights in close proximity to people or valuable infrastructure. In addition to the level of redundancy, it is also worth considering what mitigation is in place should a catastrophic failure occur. Some examples are:

• Low weight • Frangible construction and materials • Protective guards or sphere around the aircraft


• Independent parachute recovery system • Auto recovery features

3.7.3 Maintenance

A service provider should have a planned schedule of servicing and preventative maintenance that meets or exceeds the manufacturer’s recommendation. Those completing the maintenance should be suitably qualified and experienced for the level of work they are undertaking. A list of those authorised to complete maintenance activities should be contained within the service provider’s documentation.

There should be a formal system in place to record faults and breakages and track when and how the issue was rectified. A formal process to flight-check an aircraft and associated systems following any form of maintenance, software change or incident should be followed.

3.7.4 Equipment Control

In addition to robust maintenance procedures, processes should be in place to ensure equipment is returned in a serviceable condition and only serviceable equipment can be taken on site.

3.7.5 Batteries

Batteries used for powering the UAS propulsion/rotor systems (including electronic speed control), flight control systems (e.g. receivers, transmitters, servos and flight management) and load platform components (e.g. cameras) vary greatly in type, capacity and operating characteristics.

The batteries used in UAS will be susceptible to:

• Impact damage • Incorrect charging • Incorrect storage • Ambient temperature • Payload weight • Wind strength

It is therefore imperative that the service provider Operations Manual fully details all the battery types used (e.g. LiPo, NiMH, Li-ion, Alkaline) and the associated safety instructions/precautions for battery management, charging and discharging, packing and carriage by air and sea and battery disposal.

Healthy and fully functioning batteries are integral to ensuring the safe and efficient operation of an UAS and completing the assigned tasks in a timely manner. To ensure this, UAS service providers should have a battery management system in place that as a minimum should include the following key areas:

• Battery Inventory – To ensure sufficient batteries are available for the assigned task and to provide accountability for all batteries transported to and used at the work site.

• Battery Charging - Lithium polymer (LiPo) batteries should be handled and managed with great care to ensure they remain undamaged and properly protected during charging and discharging cycles and cell testing. During charging, discharging and cell testing LiPo batteries


should be placed in a robust fire-proof enclosure to contain any fire condition that may potentially arise (i.e. due to shorting between cells).

• Battery Health Checks – specific checks (depending on battery type) are carried out to ensure that batteries are in a suitable condition and retain the requisite charge to complete the task safely. Any battery that does not reach the minimum standards or shows signs of being faulty should be removed from the battery line immediately, quarantined and recorded on the inventory. Internal resistance and/or documented flight times provide a useful guide to battery condition as opposed to specifying a ‘shelf life’.

• Battery use – specific maximum flight times should be detailed in operating procedures and levels set that flights must be curtailed to permit sufficient time to recover the aircraft.

• Modification - batteries should not be modified in any way that changes the OEM specifications. Original battery wiring should not be spliced, nor should cut-off or monitoring devices be installed in the battery circuit.

• On no account should damaged or faulty batteries be transported by air.

• Battery Disposal – Damaged or underperforming batteries should be removed from the battery line, quarantined and noted on the task inventory.

If a battery is damaged or is found faulty whilst on an offshore installation it should be brought to the attention of the OIM and signed over to the person on the installation responsible for managing disposal of hazardous waste from the installation. The installation will have procedures in place for hazardous waste disposal and these batteries should be fully discharged and brought ashore (by sea) and disposed of by a registered waste collection company compliant with Environment Agency guidelines. The number of times a battery has been charged and discharged should be recorded.

3.8 Task Specific Risk Assessment

A risk assessment is an essential part of the duty holder’s and service providers planning for UAS operations on or about an oil and gas installation.


Service Providers must complete a detailed risk assessment that covers all flights associated with the scope of work. In addition, there should be a documented method statement describing how the flight profiles will achieve the desired task. The risk assessment and method statement should be made available to the Duty Holder in advance of the flights taking place. As with the overall Safety Management System, the task specific risk assessment should be a joint process where the Duty Holder and Service Provider ensure that all risks have been identified and emergency procedures agreed. The duty holder must ensure that any mitigation is compatible with existing safety measures.

A thorough knowledge of the operating environment is essential in order to identify the relevant hazards and also ensure appropriate mitigation is in place. Guidance on potential hazards should be covered within the operator’s training programme and the method for completing risk assessments detailed in their Operations Manual.

To ensure consistency of risk assessments, a standard template (company standard) should be completed for each specific UAS operation. There should be a regular cycle of ‘action and review’ for any operational risk assessment, in addition to the template itself.

Hazard identification and risk assessments (e.g. using methodologies such as bowties) should be jointly completed by the Duty Holder and Service Provider prior to work commencing on an oil and gas installation. The work should be accomplished with involvement/participation of all assigned UAS team members (e.g. lead remote pilot and the manager in charge of field operations) and UAS operations management oversight to approve and sign off the UAS risk assessment.

During the risk assessment and HAZID/HAZOP the main risks of the specific task (taking into account the ongoing activity on the installation) should be identified and either eliminated or controlled, as appropriate. Additionally, hazards associated with the design and operation of the UAS airframe and payload should also be identified and either eliminated or controlled, as appropriate. For example, UAS motors, electrical and electronic equipment that are not intrinsically safe.

On sites with high aircraft activity (for example central hub platforms servicing multiple satellite NUIs) or during shutdown/major projects where there could be multiple work parties in close proximity, an additional visual observer or “standby man” assigned from the installation staff, may be required to assist the UAS team to safely manage the worksite.

Normally, the basic minimum UAS crew composition will be two persons and the need for an additional visual observer should be identified at the risk assessment stage although more often, a third person will not be required.

All task risk assessment documents should be reviewed and approved by the offshore Duty Holder task management representative(s), (e.g. offshore installation manager (OIM) and/or delegate).

3.8.1 Example Risks

There is a spectrum of risks that may be present around an oil and gas installation and it is not feasible to produce a list covering all scenarios in these guidelines. However, the following are some important areas to consider:

• Explosion Risks in Hazardous Areas


• Dropped Object Risks • Collision Risks

o Manned aircraft o Unmanned aircraft o Birds o Structures o People o Vessels

• Loss Link • Control signal interference • Degraded GPS signal

o Impact on control o Impact on emergency procedures

3.9 UAS Team – Flight Execution

Whilst the execution of the flight itself will be completed by the service provider, interaction with the duty holder is essential. This is in order to maintain awareness of a full risk picture across the site and establish clear roles and responsibilities.

3.9.1 Crew Resources Management (CRM)

An essential element of any successful flight execution is effective CRM. CRM is the effective use of all available resources for personnel to assure a safe and efficient operation, reducing error, avoiding stress and increasing efficiency.

CRM is concerned not so much with the knowledge and skills required to operate a UAS but rather with the interpersonal skills needed to manage the flight. In this context, skills are defined as the processes used for gaining and maintaining situational awareness, for solving problems and for taking decisions. Interpersonal skills are regarded as communications and a range of behavioural activities associated with teamwork.

Main components that contribute to effective CRM:

• Communication (Barriers and efficiency) • Leadership (Defined roles and responsibilities) • Decision Making (Shared risk management and problem solving)


• Situational Awareness (How to achieve, maintain, and recover) • Workload Management (Priorities, delegation) • Cross Checking (Team approach to using checklists)

3.9.2 Flight Execution

Checklists

The use of checklists is an important factor in the safe execution of flight operations. Checklists help to ensure essential elements of pre-flight, flight, post-flight, and emergency responses are not missed.

Method Statement

The method statement details the process by which any flight operations will be conducted. The method statement should be approved by the Duty Holder prior to the first flight taking place.

Collection Plan

A collection plan is sometimes used to add detail to the specific flight profiles mentioned in the method statement. The collection plan may contain details such as minimum distances from infrastructure, aircraft positioning, and payload selection/settings.

Noise and Distraction

Operations offshore are often noisy and distracting and therefore consideration should be given to how noise and any possible distractions can be minimized.

3.9.3 Managing UAS Operations

Details of managing UAS operations offshore are contained in Section 4.

3.10 UAS Team – Emergency Procedures

3.10.1 Emergency Scenarios

The following are the key emergency scenarios that should be considered:

• Loss of aircraft control • Pilot incapacitation


• Air incursion • Ground incursion

3.10.2 Procedures and Training

Should an incident occur it is essential that the pilot in command and any support staff are able to react quickly and effectively in order to prevent an accident. In order for this to happen the following should be in place:

• Service provider has documented emergency procedures for each specific aircraft type • Emergency procedures have been validated • Emergency procedures are contained within the aircraft checklists and these are immediately

available to operational personnel • Roles and responsibilities, including those of the duty holder, in the event of an emergency are

defined and understood • Emergency procedures are briefed to relevant personnel on site, including selection of

alternative landing areas. • All relevant personnel are trained in the emergency procedures • All relevant personnel receive recurrent training/testing in emergency procedures

Should a loss of control occur, it is essential that the pilot in command is able to operate the aircraft in all available flight modes. This may require a high level of competency in either manual or height hold/altitude modes. Such skills may be required without warning and in a challenging offshore environment, hence the importance placed on recurrent training and testing.

3.10.3 Emergency Response Plan

Should an accident occur, the Duty Holder and Service Provider should have a comprehensive emergency response plan in order to minimise the impact. The Service Provider’s emergency response plan should be detailed within their Operations Manual.

The UAS Team should be equipped with any equipment that may be necessary in the event of an emergency. For example, containment of damaged batteries and specific handling instructions and equipment that may be required for some composite materials when the integrity of the composite is compromised.

3.11 Aircraft Systems – Flight Recovery


3.11.1 Aircraft System

Should an incident occur, some UAS are fitted with recovery features that may be initiated manually and/or automatically. Such systems are useful in preventing an incident, such as a loss of control link, from developing into an accident.

Some example recovery features are as follows:

Return-to-home

This is typically available as a manual intervention and an automated recovery feature. The automated recovery may be initiated in circumstances such as a loss of the control link or when the aircraft battery has reached a critical level.

Some return to home functions are more sophisticated than others where they can be set to return to an alternative location, climb to a pre-determined height before returning, or use obstacle avoidance technology. These types of features should be considered as part of the risk assessment and how appropriate the mitigation is for the specific environment.

One limitation with the majority of return-to-home features is the reliance on a GPS signal. As a GPS signal may be weak or unavailable around offshore platforms it is prudent to consider the impact on emergency procedures during the risk assessment process. The option for the pilot to recover an aircraft without GPS may therefore be desirable.

Consideration should be given to the impact of operating from vessels on emergency procedures such as ‘return-to-home’ as some systems use the take-off location as the recovery point and the vessel may well have moved during the flight.

Parachute

Should a catastrophic failure occur, parachute systems offer an additional layer of safety should an incident occur. Such systems may be linked to aircraft flight control systems or have independent sensors that will deploy the parachute should a loss of control be detected. Other systems rely on manual initiation. There are pros and cons to each type depending on the environment they are used in.

3.12 Using the UAS Industry Model

The sections above amplify what contributes to the availability and strength of each barrier in the model. This should enable Duty Holders to make informed decisions about the level of risk they are prepared to accept.

The complexity of UAS tasks and number of hazards in a given location vary considerably. The challenge for Duty Holders is to seek an acceptable and proportionate level of safety appropriate to the task and environment. For example, a non-complex survey task of a surface pipeline in a rural area may not necessarily require a service provider with comprehensive industry training and experience using an unmanned aircraft that has few, if any, single points of failure. However, many oil and gas assets are located in high-risk, challenging environments and the nature of the task may require flight in close proximity to structures and personnel. In this case, the Duty Holder may look for all barriers in the model


to be present with strong performance indicators in each. This includes the performance of the Duty Holder and Service Provider and, where appropriate, the interaction between them.


4 Managing UAS Operations

This section provides an overview of the key issues to be taken into account by Duty Holders when supervising aviation contractors during ongoing support operations.

4.1 Auditing and Compliance Requirements

Duty holders should undertake a detailed audit of a prospective UAS service provider and any sub-contractors prior to contracting the company to undertake UAS operations.

Audits can be undertaken at the invitation to tender stage or periodically (e.g. annually), in a manner similar to that used for auditing offshore helicopter operators.

The aviation elements of the audit should be completed by a suitably qualified and experienced person. A useful basis for completing the audit is set out in the Oil & Gas UK Management of Aviation Standards and Guidelines.

Auditing of data capture, interpretation and reporting requirements are out with these guidelines and should be addressed by duty holders as part of company maintenance and inspection standards and guidelines.

4.2 Roles and Responsibilities

The Duty Holder must define any task requirements, work scope and the deliverables required. Roles and responsibilities of both parties must be defined including supervision of flying activities such a integration with other airspace users. Any operating limitations, from the Duty Holder’s perspective, should be specified.

Management Roles and Responsibilities

The OIM or master is responsible for all activities undertaken on an oil and gas installation/MODU/vessel. This includes ensuring that all conflicting/simultaneous UAS operations have been properly risk assessed, robust procedures are in place and trained and competent personnel are assigned to manage the UAS activities.

Day to day delegated responsibilities will normally include:

The installation maintenance manager (or an alternate nominated responsible person) providing a single point of contact to manage all UAS team activities on and around the installation.

The helicopter landing officer (HLO) (or an alternate nominated responsible person) will normally act as the UAS team communication link and, if required, additional visual observer for flight operations on and around the installation.

The radio operator is responsible for ensuring deconfliction between UAS operations and other airborne/seaborne activities.


The installation/vessel/MODU will appoint a nominated person as a single point of contact to manage the permit to work (PTW) system on behalf of the UAS team (in the event the UAS team have not done a company specific PTW course).

UAS Manager and Flight Team Roles and Responsibilities

All of the UAS activities should be overseen remotely by an operations manager or project manager who supports the UAS team with Duty Holder liaison, assignment preparation, operations and assignment post operations duties.

Normal UAS Team composition at the work site should be comprised of the following:

• Remote Pilot (nominated as pilot in command (PIC)) – Accountable for the safe conduct of all aspects of the UAS flight.

• Payload Operator / Safety Observer / Inspection engineer (As required) – Responsible for assisting the pilot with see-and-avoid responsibilities when operating within VLOS.

4.3 Safety

Once on board the offshore installation the UAS operations team should receive a full and detailed platform safety briefing.

Duty Holder’s Role in Managing Aviation Risk

The Duty Holder is responsible for assessing, mitigating and accepting that any risk within their area of responsibility is controlled to ALARP. Contracted aviation falls within this requirement, so it is essential that the Duty Holder has an understanding of the hazards associated with operating UAS and how the risks are mitigated to a satisfactory level.

Task Specific Risk Assessment

The Service Provider must complete a detailed risk assessment prior to operating a UAS. The risk assessment should be shared with the Duty Holder to ensure all hazards have been identified and that any mitigation is agreeable to both parties.

Once on site, the Service Provider must update the risk assessment with any additional hazards that may not have been apparent during the initial assessment. A joint safety brief covering the key safety points, emergency procedures and flight profiles should take place prior to the first flight.

PPE

All personnel must wear the PPE specified for the operating area plus any required for the specific task. The Service Provider shall wear high visibility clothing that clearly identifies them as the UAS team. VR goggles should not be worn at any time when operating externally.


4.4 Communication

Clear lines of communication must be established between all personnel impacted by the UAS activity. Communication between the Service Provider and installation/asset supervisory personnel should be established as part of the pre-task requirements and should be adhered to at all times throughout the UAS operations.

In noisy environments the UAS team must ensure that communication between the flight team can be effectively made without the risk of missed instructions or misunderstandings. This may require the use of headsets.

Actions in the event of a communication failure, such as between the UAS team and the radio operator, must be established.

If amendments to agreed flight profiles or procedures are required, this must be communicated to the payload operator/safety observer who will inform the pilot when it is safe to do so.

4.5 Operations

4.5.1 UAS Service Provider – Non-aviation Training Requirements

Prior to proceeding offshore all members of the UAS operations team should undergo training/screening and be in possession of valid and up to date certificates for the following:

• BOSIET • HUET including CAT A, CA-EBS • Offshore medical

4.5.2 Permit to Work

PTW requirements for undertaking UAS operations on an offshore oil and gas installation will be conducted using the duty holder ‘in place’ permit to work procedures for the asset. These PTW procedures will normally be administered under the close scrutiny of the OIM or a designated alternate.

Prior to undertaking on-board UAS operations, at least one member of the UAS operations team should have attended a formal permit to work training course (e.g. OPITO). In addition, the UAS operations team should nominate a competent person to act as the PTW focal point for the task and be responsible for ensuring that PTW compliance is maintained throughout the on-board UAS operations.

4.5.3 Minimum Crew

For the purposes of oil and gas surveys and inspections using UAS, the Service Provider should deploy, at all times, a minimum crew composition of two persons forming the ‘UAS team’ plus one observer provided by the duty holder. The UAS team must be qualified and current for the equipment used, the type of task, and operating environment.


A newly qualified pilot with less than 25 hours industrial inspection flight experience on airframe type should not routinely be considered as competent to work in an offshore environment. Payload operators must have a minimum of 15 hours experience of operating in industrial environments. Those with previous offshore experience may be able to transition to offshore UAS operations more quickly.

UAS Observer

To assure safe operations, the UAS team and aircraft should be visually observed by a responsible person familiar to the asset and its operational safety requirements. The observer should be the radio link between the UAS team and the asset to assure agreed process is being followed against the pre-determined safety plan and correct actions are taken in event of an asset incident (call to muster, etc.) during UAS operations.

The observer must be allowed to see the UAS without being immersed in a virtual world which precludes them from spotting other hazards (e.g. remote video terminals first-person view operations). Therefore, the use of video goggles is not acceptable while performing observer duties.

4.5.4 Equipment

4.5.4.1 Dangerous Goods

There may be a requirement to transport batteries to an offshore oil and gas installation via air freight. If so, the batteries must be packaged and transported as per the IATA Dangerous Goods Regulations relevant to the specific battery type. Appropriate information and instructions should be highlighted on a material safety data sheet that is specific to the battery.

It should be noted that in addition to complying with Dangerous Goods by Air Regulations for battery transport by air to an offshore installation, UAS operators should be fully conversant with the HCA certificate associated with offshore platforms. Where an HCA certificate states "no dangerous goods by air to this platform" this rule should be complied with at all times.

Lithium ion cells and batteries must be offered for transport at a state of charge not to exceed 30% of their rated design capacity. Cells and/or batteries at a state of charge greater than 30% of their rated capacity may only be shipped with the approval of the State of Origin and the State of the Operator under the written conditions established by those authorities5.

4.5.4.2 Storage and Maintenance of UAS Equipment Offshore

Whilst UAS equipment is located on an offshore installation secure storage should be allocated. It is essential that equipment is protected from unauthorised modification, interference, or handling. Failure to do so could compromise the safe operation of the system. This includes storage and charging of batteries.

Routine maintenance of the equipment should be authorised and supervised by designated duty holder staff, in particular for the safe storage and charging of batteries.

5 http://www.iata.org/whatwedo/cargo/dgr/Documents/lithium-battery-guidance-document-2016-en.pdf


4.5.4.3 Battery Handling

Batteries should be stored and recharged in fire-proof containers

Damaged batteries should be removed from operation and disposed of in accordance as per hazardous materials on site.

4.5.5 Weather Conditions

4.5.5.1 Visual Conditions for Operations

Service Providers should have documented operating limitations, including the conditions required for VLOS. It is important that the meteorological conditions provide sufficient visibility to enable the aircraft to be in visual contact at all times. In addition, there must be sufficient visibility to identity any air incursions in ample time to take evasive action. This principle is valid for both day and night operations.

Where night time operations are required on the exterior of an installation, a specific UAS OSC must be obtained and approved by the UK CAA and asset duty holder(s) aviation safety department.

UAS operations in confined spaces such as tanks and voids should be subject to special consideration, risk assessment and rigorous work permit controls. Visual conditions in these cases will be dependent on the provision of sufficient artificial lighting to allow good visual references to be obtained to ensure that proper UAS control can be maintained throughout the flight duration.

4.5.5.2 Wind

The duty holder adverse weather policy is the controlling factor for all offshore installation operations. This includes UAS flights.

UAS generally operate well below the set limits of an installation adverse weather policy so the UAS operational envelope should specify the wind limits for the type of UAS in use and the type of operations being conducted.

Due to the extreme weather conditions encountered offshore on the UKCS, a UAS should ideally be capable of being operated safely in wind speeds gusting up to 25 knots in order to offer a practical operational envelope.

If the weather forecast shows that wind conditions are anticipated to be outside of the UAS operating limits at some stage during the flying task, the remote pilot should land the UAS 30 minutes prior to the forecasted change.

4.5.5.3 Precipitation

Rain and moisture can affect some exposed parts of the UAS and its payload but, additionally, it potentially degrades the quality of the imagery that may be captured. This is an important consideration for the UAS operator when selecting the UAS system (e.g. airframe and payload) for the specified task and should be fully considered in the Risk Assessment and Method Statement.


4.5.6 Aviation Operations

4.5.6.1 Airspace Management

Routine UAS operations on offshore assets will normally be deconflicted from manned aircraft by time. The UAS operating team is responsible for ensuring that operations cease with the UAS ‘on-deck’ and helideck cleared at least 30 minutes prior to any scheduled helicopter arrival. The helideck should be checked by the Helicopter Landing Officer (HLO) prior to manned flying.

There must be clear lines of communication to notify the UAS team of any planned and unplanned flights to the asset. Furthermore, the UAS team must have a clear line of communication to report any emergency situation such as a loss of the control link.

Prior to planned UAS operations on an installation, the installation/asset supervisory personnel should ensure the daily report includes that UAS operations are being conducted and the times these operations are scheduled to take place. Helicopter operators and flight crews must be made aware of UAS activities during the flight planning phase for scheduled helicopter flights to the installation.

Concurrent operations between manned and unmanned aircraft are feasible provided all aviation users have situational awareness of each other and the activities have been fully risk assessed.

4.5.6.2 Deconfliction with Concurrent Activities

Prior to undertaking any UAS activities on or around the oil and gas installation/plant, the UAS operations team, assisted by the duty holder, should obtain full and detailed information about the installation/MODU/vessel to generally familiarise themselves with the layout, topography, processes and hazardous areas. Focus should be on ensuring that the planned UAS operations can be safely managed without interference, such as from moving cranes, or jeopardising other on-board operations. Operations from vessels should include information on any anticipated movement in order to understand the hazards that may be present at different times and any impact on emergency procedures.

4.5.7 Deconfliction with Maritime Activity

Procedures should be in place to ensure that adequate deconfliction with surface vessels servicing the installation, is effectively achieved.

Standby and other vessels working in close proximity to the installation (e.g. supply vessels, etc.) should be made aware of ongoing UAS operations by the radio operator and a listening watch maintained.

4.6 Flight operation

4.6.1 Pre-Flight

The UAS flight team should conduct a pre-operations briefing for each day’s activities that details, as a minimum:

• Review of the emergency escape/evacuation plan


• Planned flight schedule • Designated take off/landing area(s) • Weather forecast including motion conditions for MODUs/vessels • Intended areas of UAS activity • Potential installation operating effects on the UAS programme such as:

o Turbulence o Thermal effects from turbine exhausts o Areas of potential radio-frequency/magnetic interference o GPS denied areas

• Actions in the event of a UAS emergency • Confirm correct PPE in place

Any party should have the authority to immediately abort the operation at any time if deemed necessary.

4.6.2 Launch and Recovery

Offshore installations are, by their nature, often congested with limited options for launch and recovery of the UAS. The size of the UAS should be considered when planning an operation offshore; with smaller UAS (< 7Kg) typically being more favourable for tight and congested areas.

In certain circumstances where there is not enough space to launch and recover the UAS on the ground (e.g. helideck), hand launch recovery can be considered; this however should only be done by competent personnel trained in the technique when all other available options have been discounted and a suitable hand launch and recovery procedure is in place. This should not be considered a safe option for larger UAS systems (>7kg).

UAS launch and recovery requirements/conditions/limitations should be detailed in the Service Provider’s operations manual or may be imposed by the duty holder’s safety plan/permit to work system.

4.7 Offshore Transportation and Accommodation

Authorisation and arrangements for transporting to and accommodating members of the UAS operations team on an offshore installation is the responsibility of the duty holder.

Prior to UAS operations team members proceeding offshore, the UAS onshore management should ensure that all personnel comply fully with medical and safety and survival training requirements and are in possession of the appropriate certificates.

UAS equipment authorised for transportation to an offshore location should be packed, manifested and despatched in accordance with the duty holder and UAS company cargo handling procedures.

Equipment classified as dangerous goods should be transported in accordance with IATA regulations for air cargo, and International Maritime Dangerous Goods regulations for marine cargo transfers.


5 References

Air Navigation Order (ANO) 2016

CAA Information Notice IN-2016/073 – Small Unmanned Aircraft – ANO 2016

CAA CAP 722 - Unmanned Aircraft System Operations in UK Airspace – Guidance, Seventh Edition Amendment 2019/03 4 September 2019

CAA SRG 1320 – Application for Operation of a Small Unmanned Aircraft

IOGP Guidelines - Unmanned Aerial Systems Guidelines February 2015


OGUK Guidelines Member companies dedicate specialist resources and technical expertise in developing these guidelines with Oil & Gas UK with a commitment to work together, continually reviewing and improving the performance of all offshore operations. Guidelines are free for our members and can be purchased by non-members.

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