Manual of Standards Overview

What is the MOS?

The Manual of Standards, commonly known as the ‘MOS’, is a legislative instrument that forms part of the greater body of legislation, CASR Part 101, which prescribes the rules around the use of unmanned aircrafts and rockets – most relevant to this article, drones and RPA.

Who does the MOS apply to?

The MOS is a190 pages long and addresses a number of areas within the drone ecosystem, including training provider requirements, operations in prescribed areas and Beyond-Visual-Line-Of-Sight (BVLOS) operations.

Most notably and applicable to commercial operators, Chapter 10 the MOS outlines a host of new record-keeping requirements for those operating in excluded and non-excluded categories, ranging from drone maintenance, flight hour tracking, operational logs and more.

What to expect in this summary?

The following summary goes into the record-keeping requirements for excluded and non-excluded operations. Our goal is for operators to have a better understanding of what the MOS is and some specific examples of how it is applied. 

Please note that this is only a summary and should not be viewed as a comprehensive legislative guide. For more detailed and specific information or advice, please contact the team at Sphere Drones.

10.03  Chief remote pilot records

Summary

This section outlines the record-keeping requirements the Chief Remote Pilot needs to meet in regards to the operations within their ReOC. There are 3 main types of records that must be kept, which are listed as follows;

1. Records that demonstrate the CRP is reasonably meeting the requirements under CASR 1998 101.342
   • maintaining a record of the qualifications held by each person operating RPA for the operator;
   • monitoring the operational standards and proficiency of each person operating RPA for the operator;
   • maintaining a complete and up-to-date reference library of operational documents required by CASA under subregulation 101.335(1) for the types of operations conducted by the operator.
   • These must be kept for at least 7 years after the day the record is made.
2. An operational record must be kept for every operation, including the following information
   • JSA (Job Safety Assessment)
   • A Risk Management plan if required.
   • NOTAMS (Notice To AirMen Submission), which means notifying alert pilots in the area to any potential safety hazards along the flight route.
   • These records must be kept for at least 7 years following the operation completion day.
3. For training that is delivered internally and is NOT RePL training, records must be kept, including;
   • Name, dates, nature and information of what was delivered.
   • These must be kept for 7 years following the training completion date.

10.04  RPAS operational release

Summary

An operational release, as compared with an operational log, can be viewed as a ‘pre-flight’ requirement and outlines a number of data points and information that needs to be captured and recorded prior to flight.

Information that is to be recorded (and kept for at least 7 years after the day the operation ends) includes;

• Nature and purpose of operation
• Identification information of the RPA (e.g. type, model, serial number).
• The dates and times of the operation.
• Launching and landing/recovery location.
• The height the operation is taking place and the maximum flying height as permitted by the regulation.
• The full name and ARN of any pilots involved in the operation.
• Name and duties of a non-RePL pilot involved in the operation.
• Whether the RPA is to be operated in VLOS, EVLOS, BVLOS
• Whether or not CASA has issued any instrument of approval, authorisation, direction, instruction, permission or exemption.
  • A copy of this instrument will suffice as a record of this.
• Certification that the RPA is serviceable for the purpose of the operation (either by the maintenance controller or someone who meets these requirements in 101.340)

The operation can’t commence until this has been submitted to the CRP and approved in writing.

10.05  RPAS operational log

Summary

In comparison to the operational release, an operational log is the post-flight record of what happened during the operation, as opposed to what was planned to occur in the operational release.

Information that is to be recorded (and kept for at least 7 years after the day the operation ends) includes;

• Nature and purpose of operation
• Identification information of the RPA (e.g. type, model, serial number).
• The dates and times of the operation.
• The place by specific location or cartesian coordinates, from which the RPA was
  • Launched and landed/recovered.
• The height the operation is taking place and the maximum flying height as permitted by the regulation.
• The full name and ARN of any pilots involved in the operation.
• Name and duties of a non-RePL pilot involved in the operation.
• Whether the RPA is to be operated in VLOS, EVLOS, BVLOS
  • BVLOS, specific flight route details by cartesian coordinates.
• Whether the RPA was serviceable by the end of the operation and nature of any unserviceability.

10.06 Remote pilot log — for flight time

Summary

This section refers to the accumulated flight time required to be kept by each pilot. This is relatively straight forward.

The accumulated flight time must outline;

• Drone related information included type, model and serial number.
• Date, location and duration of each individual flight
• Separate and accumulated flight times for different operational conditions, including night ops, VLOS, EVLOS, BVLOS.
• Flight times in simulated operations (basically flight simulator or related).
• This must all be kept for 7 years after the last time the RPA is operated by the operator.

10.07 RPAS technical log

Summary

This section references the requirements for the maintenance of the RPA and the associated records that are to be kept. This is very much an ‘Asset’ focused section, grouping all relevant information on the drone and its operational record. This must be kept for at least 7 years after the last time the RPA is operated by the operator.

 

The information required on the record includes;

• RPA Type, model, SN.
• SN in any previous configuration.
• Max and min take-off weights of the RPA.
• Total flight time
• Individual in-service time for engines, motors, rotors and propellers (RPA >25kg)
• The maintenance schedule (RPA >2kg)
• The maintenance taken out on the RPA included in accordance with documentation and procedures (RPA >2kg)
• The date or operational time of the next maintenance action.
• The results of any defective equipment that has been serviced (RPA >2kg).
• Certification by the relevant maintenance controller that this has all been completed.

There is also information here about best practice when transferring when ownership of the RPA changes or when this information is requested by someone (e.g. new owner, CASA, other).

10.08 Records of qualification and competency

Summary

This section refers to the record-keeping of information relevant to people involved in RPA operation.

The RPA operator must;

• Create a record of the person obtaining a qualification or competency
• Provide a copy of this to the person before they perform any related duties or responsibilities.
• Keep the record for 7 years after their employment finishes with the operator.
• This could apply to staff involved in the operation including observers, ground handlers or staff involved in safety.

EXCLUDED RPA

10.10 RPAS operational log

Summary

This section outlines the requirement for excluded RPA, both small (sub-2kg) and medium (sub-25kg).

Regarding the operational log, a record for each operation should be kept to include;

1. Nature and purposes
2. Specific location and the maximum flight height
3. RPA type (e.g. multirotor), model (e.g. DJI Phantom 4 Pro) and SN
4. Remote pilot station (i.e. the ground-station and/or remote controller) for the operation
5. Date and time of the operation
6. The name and ARN of the remote pilot 
7. Whether the drone was serviceable after the final flight and the nature of the unserviceability.
8. Logs must be kept for 3 years for excluded RPA.

Differences between this and the non-excluded is;

• Logs only need to be kept for 3 years, not 7.
• Non-RePL pilots do not have to be disclosed.
• Do not need to specifically identify take-off and landing locations.
• Instruments, flying conditions (e.g. BVLOS, EVLOS etc) do not need to be disclosed as these are only attainable to those who hold ReOC.

10.11 Remote pilot log — for flight time

Summary

This section of the MOS only applies when operating a ‘medium excluded RPA’, which is defined as between 25-100kg gross take-off weight.

The remote pilot must record accumulated flight time on medium excluded RPA that they operate, disclosing;

• RPA type, model, serial number
• The date, location and duration of each flight.

This information must be kept for 3 years from the last day the RPA is flown by the operator.

10.12 RPAS technical log

This section of the MOS only applies when operating a ‘medium excluded RPA’, which is defined as between 25-100kg gross take-off weight.

Summary

This section references the requirements for the maintenance of the RPA and the associated records that are to be kept. This is very much an ‘Asset’ focused section, grouping all relevant information on the drone and its operational record. This must be kept for at least 7 years after the last time the RPA is operated by the operator.

• The information required on the record includes;
• RPA Type, model, SN.
• SN in any previous configuration.
• Max and min take-off weights of the RPA.
• Total flight time
• Individual in-service times for engines, motors, rotors and propellers;
• The date or operational time of the next maintenance action.
• Any maintenance that has been performed on the RPA
• The results of any defective equipment that has been serviced (>2kg).
• Certification by the relevant maintenance controller that this has all been completed in line with manufacturer requirements 

There is also information here about best practice when transferring when ownership of the RPA changes or when this information is requested by someone (e.g. new owner, CASA, other).

The technical log must be kept for a period of 7 years after the last time the RPA is operated.

If you are interested in reading further into the official legislation, you can view it on CASA’s website.