WHS-PRO-018 Drone Procedure

Intent

This Procedure outlines how James Cook University (JCU; the University) manages operations of drones, including Remotely Piloted Aircraft (RPA) and Model Aircraft (MA), to ensure activities are conducted safely and in compliance with all applicable rules, laws and regulations.

Scope

The Procedure applies to all JCU staff, students (including Higher Degree by Research candidates), involved in any JCU drone operations regardless of purpose, and regardless of the type, size or weight of the drone used. This Procedure also applies to external contractors engaged by JCU as Chief Pilot.

This Procedure covers private recreational drone activity conducted by JCU staff, students, or members of the public from JCU owned / leased land.

This Procedure does not apply to the Singapore or Brisbane campuses, or to JCU Controlled Entities.

Definitions

Except as otherwise specified in this procedure, the meaning of the terms used are as per the Work Health and Safety Policy or the Policy Glossary.

Acronyms

Table of Contents

1. Duty, Obligations and Responsibilities

2. Activities Requiring a ReOC (RPA Included Category)

3. Activities Not Requiring a ReOC

4. Recreational Drones Operated from JCU Land

5. Maintenance of Drones

6. Standard Operating Conditions (SOC)

7. Training and Licenses

8. CASA ARN

9. Insurance

10. Drug and Alcohol Management

11. Incident Reporting

12. Personal Information

Procedure

1. Duty, Obligations and Responsibilities

1.1 James Cook University

JCU has a duty to:

• ensure the health and safety of workers and others during all JCU drone operations; and
• ensure that all JCU drone operations comply with applicable rules, laws and regulations.

1.2 JCU staff and students, and visitors

JCU staff, students, visitors and volunteers must comply with this Procedure.

Visitors are not authorised to operate drones on JCU premises or for JCU-related purposes unless they are specifically engaged by JCU to do so (e.g. contractors).

1.3 Manager, Work Health and Safety (WHS)

The Manager, WHS is responsible for JCU-wide oversight of all drone operations. Specifically, the Manager, WHS is responsible for:

• maintaining the JCU Drone Register ensuring all listed drones are current;
• maintaining the JCU Pilot Register to ensure all listed Licensed Pilots and Accredited Operators have current licences/accreditations;
• ensuring all drones are included in the JCU aviation insurance policy via inclusion on the JCU Drone Register; and
• ensuring all Licensed Pilots and Accredited Operators are listed on JCU’s Pilot Register.

1.4 Chief Pilot

For certain types of drone operations, a Remote Operator Certificate (ReOC) is required. JCU does not hold a ReOC. Where a ReOC is required, JCU staff and students may operate drones under the direct control and supervision of an external contractor who holds a valid ReOC. All operations must be conducted in accordance with the contractor’s ReOC requirements.

The Chief Pilot, nominated and employed by the external contractor ReOC holder, is responsible for:

• ensuring that JCU’s RPA operations are conducted in compliance with the Civil Aviation Act 1988 (Cth) and the Civil Aviation Safety Regulation (CASR);
• reporting to the Civil Aviation Safety Authority (CASA) as well as other regulatory bodies as required.

1.5 Drone Operators (including Licenced Pilots, Accredited RPA Operators and Model Aircraft Operators)

All Drone Operators are responsible for:

• the safe flying of the drone;
• ensuring the drone is managed in accordance with this Procedure;
• complying with all applicable laws, rules, regulations and conditions required for that flight;
• carrying personal identification and, if applicable, CASA-issued Remote Pilot License (RePL) during operations;
• obtaining an individual Aviation Reference Number (ARN) (excluding micro-operations);
• ensuring drones are registered under the JCU ARN (excluding micro-operations);
• completing all training and licensing requirements relevant to the type of operation (i.e. RPA operator accreditation, RePL);
• keeping logbooks, insurance records and database entries up-to-date;
• conducting safe operations, from pre-flight checks through to shutdown and storage;
• ensuring currency of drone firmware and software;
• completing a risk assessment prior to and during JCU RPA operations to ensure control measures remain effective throughout the operation; and
• reporting defects as they occur and record the maintenance they have conducted on the drone.

1.6 Drone managers

Any JCU staff member or student who manages a drone is responsible for its maintenance.

For RPA’s registered with ReOC providers, all maintenance requirements instructed by the ReOC provider must be followed. This applies to Included RPA operations only.

Maintenance Personnel are responsible for maintaining drones in accordance with section 5 of this Procedure.

1.7 Non-Controlling Observer

Non-Controlling Observers have the following responsibilities:

• provide assistance in emergencies if requested by the Licensed Pilot or Accredited RPA Operator (including first aid training if identified as required via the risk assessment);
• provide assistance to the Licensed Pilot or Accredited RPA Operator with observations of potential hazards both to the drone and the general public; and
• maintain knowledge of how to activate the drone’s failsafe mechanism.

1.8 JCU staff, students, or members of the public operating Private recreational drones from JCU owned/leased land

JCU staff, students, or members of the public must not operate a private drone for recreational purposes while physically standing on JCU-owned or leased land.

2. Activities Requiring a ReOC (RPA Included Category)

All RPA Included Category operations must be conducted in compliance with CASA Advisory Circular AC101-01: Remotely piloted aircraft systems – licensing and operations.

The following types of JCU activities using drones require a ReOC:

• commercial activities using a drone weighing over 2kg;
• commercial activities using a drone weighing under 2kg being operated outside of the SOC;
• non-commercial activities using a drone weighing over 7kg operated for education, training or research by JCU staff/students for JCU activity.

2.1 Options for conducting ReOC-required activities

As JCU does not hold a ReOC, there are two available options to proceed:

a. Engage a ReOC contractor to manage the work: JCU staff/student operate the drone under the contractor’s ReOC. Refer to 2.1.1 below for procedures.

b. Engage a ReOC contractor to conduct the work: The contractor supplies and operates their own drones. No JCU staff/students are involved in drone operation. Refer to the WHS Contractor Management Procedure for contractor engagement requirements.

2.1.1 Engaging a ReOC contractor

The JCU staff member or student engaging the contractor is responsible for:

a. Verification, including:

• verifying the contractor’s ReOC status via the CASA ReOC holder list.
• verifying the contractor’s ABN and company registration.

b. Ensuring the contractor holds the following insurance requirements:

• Public Liability: $20 million per occurrence
• Drone/RPA insurance: $20 million per occurrence (liability cover related to the use of the drone)
• Workers’ compensation (as required by law)
• Professional indemnity: $1 million per occurrence

(Insurance policy must include one automatic reinstatement provision)

Insurance documentation must be submitted to rpas@jcu.edu.au for review prior to engagement. Note: JCU does not have insurance for drone hulls, only liability cover. If drone has a high monetary value, the operator is responsible for discussing insurance directly with insurance@jcu.edu.au.

c. Contract and Procurement

All ReOC engagements must follow JCU’s procurement procedures:

• FMPM 711 – Procurement Procedure
• FMPM 712 – Engaging Individuals as Service Providers Procedure

A formal contract must be established.

d. JCU Register Requirements

Submit the following to rpas@jcu.edu.au:

• RPA type, weight, and registration numbers
• ReOC holder name and certificate number
• Chief Pilot details
• Copies of all relevant insurance documentation

e. JCU Liability

JCU insurance covers activities compliant with CASA regulations.

If the contractor breaches CASA requirements, their insurance will be liable for any incidents.

2.1.2 Riskware Field Trip Module

Off-campus drone operations managed by a ReOC Contractor must still have a field trip created in Riskware covering all aspects of the trip. However, the specific risks and details related to the drone operation itself, if fully managed by the ReOC Contractor, do not need to be included in the field trip module. Instead, the drone-related risk controls should be noted as: “Drone operation will be managed under (insert ReOC Contractor’s name).”

On-campus drone operations managed under a ReOC Contractor do not require a field trip submission.

3. Activities Not Requiring a ReOC

3.1 Education, Teaching or Research (Non-Commercial Use) up to 7kg under SOC

Drones weighing up to 7kg operated solely for education, teaching, or research purposes under SOC – not for financial gain or JCU promotional activities – do not require a ReOC.

Examples:

• A JCU researcher using drones to observe animals during a research project funded by the university where the aim is to support student learning.
• Academic staff teaching students drone operation during a field trip or coursework.

CASA classification:

• Flying a model aircraft up to 7kg for educational purposes at recognised educational institution is considered recreational use.

CASA requirements:

• Drones must be operated in accordance with CASA Advisory Circular AC101-03: Flying a model aircraft or drone for recreation or education.
• Compliance with SOC’s.

JCU requirements in addition to CASA requirements:

• Individual ARN
• RPA operator accreditation certificate
• Drone registration, insurance details and general mission plan must be submitted to rpas@jcu.edu.au prior to operation
• Field trip module completed for off campus activities (via Riskware)

3.2 RPA Excluded Category

RPA Excluded Category operations must be operated in accordance with CASA Advisory Circular AC101-01 Remotely piloted aircraft systems – licensing and operations.

3.2.1 Commercial use of Drones <2kg Under SOC

Examples:

• Filming to promote JCU courses or events
• Conducting paid research funded by a private entity to develop a product.

CASA Requirements:

• ARN
• Operator accreditation certificate
• Drone registration - submit details to rpas@jcu.edu.au
• Compliance with SOC’s

JCU requirements in addition to CASA requirements:

• Inclusion in JCU’s insurance register – submit details to rpas@jcu.edu.au and insurance@jcu.edu.au
• General mission plan submitted to rpas@jcu.edu.au
• Field trip module completed for off campus activities (via Riskware)

3.2.2 Non-commercial use of Drones weighing under 25kg, over JCU land (leased or owned) and under SOC.

Examples:

• Estate Directorate conducting a roof inspection; research or teaching practice over JCU land.
• Non-commercial activities over JCU owned or leased land.

CASA Classification:

• Landowner Excluded Category.
• Drones must be operated in accordance with CASA Advisory Circular AC101-01 Remotely piloted aircraft systems – licensing and operations.

CASA Requirements:

• Individual ARN
• Operator accreditation certificate
• Drone registration - submit details to rpas@jcu.edu.au
• Compliance with SOC’s

JCU requirements in addition to CASA requirements:

• Inclusion in JCU’s insurance register – submit details to rpas@jcu.edu.au and insurance@jcu.edu.au
• General mission plan submitted to rpas@jcu.edu.au
• Operations on/over JCU premises must have prior written approval. Permission and approval to fly over JCU premises must be sought by emailing rpas@jcu.edu.au
• Drones that are not owned by JCU must not be used over JCU premises and/or by JCU staff/students conducting JCU work/research/study.

3.2.3 Non-commercial use of Drones weighing over 25kg but not more than 150kg, over JCU land (leased or owned) and under SOC

Same requirements as section 3.2.2, plus:

• Operator must hold a Remote Pilot Licence (RePL) for the type and model of the drone. Contact rpas@jcu.edu.au to discuss RePL options.

3.3 Micro drone category

3.3.1 Commercial use of Drones weighing under 250g and under SOC

CASA Requirements:

• ARN
• Operator accreditation certificate
• Drone registration - submit details to rpas@jcu.edu.au
• Compliance with SOC’s

JCU requirements in addition to CASA requirements:

• Inclusion in JCU’s insurance register – submit details to rpas@jcu.edu.au and insurance@jcu.edu.au
• General mission plan submitted to rpas@jcu.edu.au
• Field trip module completed for off campus activities (via Riskware)

3.3.2 Non-commercial use of Drones weighing under 250g, operated for education, teaching and research, and under SOC

CASA Requirements:

• Follow CASA drone safety rules (i.e. SOC’s)

JCU requirements in addition to CASA requirements:

• Risk assessment and field trip submission for off-campus activities.

3.4 General Operational Requirements for all Non-ReOC Activities

Before commencing any flight, JCU accredited operator must complete the following:

3.4.1. General Mission Plan

For all non-ReOC activities (excluding micro <250g non-commercial activities), a General Mission Plan must be prepared by the JCU Accredited Operator. This plan should include:

• Information about the local area
• Identification of the local hazards
• Emergency procedures (e.g., RPA recovery)

For on-campus drone operations, the General Mission Plan must be submitted directly to Rpas@jcu.edu.au.

For off-campus drone operations, see 3.4.2.

3.4.2. Riskware Field Trip Module

Off-campus operations only:

• A field trip must be created in Riskware’s field trip module.
• The General Mission Plan must be attached within the field trip module as part of the submission.

3.4.3. Flight Location Assessment

It is the responsibility of the Drone Operator to download one of the CASA-approved drone safety apps to help decide where flights can take place.

3.4.4. On-Site Requirements

When arriving onsite to carry out a drone operation, the following shall be conducted by the Drone Operator:

• site familiarisation to identify hazards and launch/recovery areas (primary and emergency);
• a safety briefing to all personnel involved and spectating nearby;
• completion of a pre-flight checklist that is specific to the RPA being used (WHS-PRO-CHK-018a Pre-Flight Checklist for Non-ReOC operations);
• safely carry out the RPA operations as planned; and
• completion of a post-flight checklist that is specific to the RPA being used (WHS-PRO-CHK-018b Post-Flight Checklist for Non-ReOC operations).
• A test flight should be performed as part of the pre-start process to verify that all systems are functioning correctly following any updates.

All records are to be maintained by the Drone Operator in a readily accessible location for the life of the drone.

3.4.5. Post-Flight Requirements

On completion of a drone operation, the Drone Operator shall log the flight in a logbook. WHS-PRO-FORM-018c CASA Form 1483 – RPA Flying Hours Logbook.

Micro drones being used for non-commercial operations under SOC are excluded from this requirement.

4. Recreational Drones Operated from JCU Land

Private recreational drone activity conducted by JCU staff, students, or members of the public is not permitted while physically standing on JCU-owned or leased land. This includes the residential colleges and sports facilities.

JCU Security personnel are authorised to direct any individual operating a drone over JCU to cease operations immediately.

5. Maintenance of Drones

5.1 Drone Registered with ReOC Providers (Included RPA operations only):

• Drones registered with ReOC providers will follow all maintenance requirements instructed by the ReOC provider.
• The Drone Manager shall record and notify the ReOC provider Chief Maintenance Controller of all defects found during operation.

5.2 Drones Not Registered with a ReOC Provider:

• Must be registered with CASA under JCU’s ARN (excluding micro non-commercial drones)
• Must be maintained by designated JCU maintenance personnel or the Drone Manager.
• Drone maintenance must follow the manufacturer’s specifications.
• If a manufacturer does not provide details concerning the scheduling of maintenance, a schedule shall be developed based upon similar craft and best practice.
• JCU maintenance personnel will ensure maintenance schedules developed for a drone are followed and recorded.
• A copy of the maintenance schedule and inspection record should be kept with the drone.
• All components of a drone are subject to ongoing ‘on condition’ monitoring through the pre-flight and post-flight inspections to identify damage, wear, malfunction or unserviceability.
• Any defects found during these inspections will be recorded on a Defect and Maintenance Log.
• Components must be repaired or replaced where they show signs of unserviceability, abnormality or damage, unless the damage is insignificant to the operation of the drone (e.g., cosmetic damage).
• Drone software and firmware must be updated at regular intervals to ensure optimal performance and safety. The most effective way to maintain secure and reliable drone operating systems is to check for and install any available firmware or software updates as part of the pre-flight checks conducted before each use.
• Records of firmware or software updates will be documented in the maintenance log and include details of any test flights and version numbers relevant to the update.
• It is also the responsibility of the Drone Operator to maintain aircraft records that show:
  • time-in-service
  • maintenance history
  • any defects and abnormalities that affect operations
  • any incidents Riskware report numbers
  • any other useful information that may affect the safety of future flights with the drones.

Micro drones being used for non-commercial purposes are not required to maintain these records.

6. Standard Operating Conditions (SOC)

6.1 The drone is to be operated:

• by visual line of sight (VLOS) only - close enough to see, maintain orientation and achieve accurate flight and tracking;
• no higher than 120 m (400 feet) above ground level;
• during daylight hours only.

6.2 The drone must not be operated:

• any closer than 30m from people not associated with the flight (i.e. any person who is not charged with duties essential to the safe operation of a remotely piloted aircraft);
• in a prohibited area or restricted area as defined by a CASA-verified drone safety app;
• over populous areas;
• within 5.5km (3 NM) of a controlled aerodrome with an operating control tower;
• in the area of a public safety operation without the approval of a person in charge of the operation.

6.3 Only 1 drone flown per operator at any one time.

6.4 For clarification on any of these points refer to CASA.

7. Training and Licenses

7.1 Remotely Piloted Aircraft Operator’s Certificate (RePL)

For those JCU drone operations that require a Licensed Pilot, the Chief Pilot authorises the Licensed Pilot to carry out a JCU RPA operation.

A Licensed Pilot will report to an externally contracted Chief Pilot and regulatory bodies as required.

To obtain a RePL, JCU staff and students should first contact an externally contracted ReOC provider. The relevant JCU staff member or student will be contacted by the ReOC provider’s Chief Pilot to commence the licensing process. The Licensed Pilot may be required to complete additional licensing and training as directed by the ReOC Provider.

Each Licensed Pilot will be qualified on a class of RPAs. Any changes will need to be approved and CASA will issue the relevant Remotely Operated Aircraft Pilot License to reflect new RPA types and weights class that may be operated by the Licensed Pilot. After the CASA updates are confirmed, the license will be updated.

7.2 Operator accreditation

RPA operator accreditation is completed online through the myCASA portal, and involves viewing a short safety video, reading the educational material and successfully completing an online quiz to test knowledge of the standard RPA operating conditions and RPA safety rules.

Accreditation is free and is valid for three years.

Individuals who hold a RePL are not required to hold operator accreditation.

Accredited Operators must be 16 years or older.

8. CASA ARN

An ARN is a unique identifier issued by CASA for aviation activities in Australia. There are two types of ARN – Individual and Organisation.

8.1 Individual ARN

Each JCU staff member and student conducting drone operations will require an individual ARN to complete operator accreditation or RePL.

JCU-owned drones must not be registered under an individual’s ARN. Drones must be registered through the JCU ARN (refer 8.2 below).

An ARN application for an individual can be made through the CASA website. The applicant will need to provide CASA with proof of identity. Details of acceptable identity documents are available on the CASA website.

8.2 Organisation ARN

JCU’s ARN is managed by WHS Unit.

As JCU does not hold a ReOC, the ARN is only used to register JCU-owned drones. To register a JCU-owned drone with CASA send the drone details to rpas@jcu.edu.au.

9. Insurance

9.1 RePL and Accredited RPA Operators Coverage

All Accredited RPA Operators and Licensed Pilots must be listed on JCU Pilot Register to be included in JCU’s Remotely Piloted Aircraft System (RPAS) insurance policy before conducting any drone operations.

This requirement excludes non-commercial operations using drones under 250 grams.

9.2 Drone Coverage

All drones and associated equipment operated by the Licensed Pilot/Accredited RPA Operator must be listed on JCU’s Remotely Piloted Aircraft System insurance policy before they can be flown. The Drone Operator is responsible for contacting JCU insurance@jcu.edu.au to discuss and arrange insurance coverage.

9.3 Registration, confirmation and annual renewal

Pilots/RPA Operators and aircraft information must be updated annually by February each year. The previous year’s pilot and aircraft listings will be removed from the insurance cover and will require the Pilot/RPA Operator to contact rpas@jcu.edu.au and insurance@jcu.edu.au to arrange cover. Insurance cover is only in place once confirmation has been received.

10. Drug and Alcohol Management

Drug and alcohol testing may occur at any time by CASA or the ReOC Provider in accordance with their safety management systems.

Pilots/RPA Operators should make themselves familiar with their rights and obligations under the CASA regulations. Information on random drug and alcohol testing can be found on the CASA website under Safety Management.

As a guide, drugs or alcohol should not be consumed 8 hours prior to or during any period of planning or executing JCU RPA operations. Pilots/RPA Operators must be fit for duty and free from the influence of any substance that may impair performance.

11. Incident Reporting

11.1 In the event of any incident, the Pilot/RPA Operator must report the incident by contacting:

• 000/112 if anyone is injured;
• local air traffic controllers;
• Chief Pilot and/or Manager, WHS; and
• any additional parties identified during the Pre-Flight Risk Assessment.

Pilot/RPA Operator must also:

• document and photograph all aspects of the incident immediately;
• assist with investigation of the incident if required, and ensure processes and documentation are amended to incorporate recommendations from the investigation; and
• follow the additional requirements outlined in the WHS-PRO-005 Incident and Hazard Management Procedure.

11.2 Incidents and accidents involving RPA operations may also be reportable to the Australian Transport Safety Bureau (ATSB). The ATSB require immediately reportable and routine reportable matters to be reported as soon as is reasonably practicable. The Manager, WHS, in consultation with the Operator of the RPA is responsible for reporting the incident to ATSB. Details on how to make a report about an incident or accident can be found on the ATSB website.

11.2.1 Immediately reportable matters

An immediately reportable matter is a serious drone-related safety matter including accidents involving death, serious injury or significant damage to the RPA.

Immediately reportable matters may include:

• where a person is seriously injured by an RPA;
• a collision with another aircraft (including another RPA);
• where the RPA has been seriously damaged;
• other matters where it may be necessary for the ATSB to attend the operational area immediately to collect evidence for safety analysis.

The ATSB must be contacted by phone as soon as reasonably practicable, with a follow up written report submitted within 72 hours.

11.2.2 Routinely reportable matters

A routinely reportable matter is a drone-related event that did not have a serious outcome and does not require an immediate report, but could have impacted the safety of aviation.

Routinely reportable matters may include:

• a non-serious injury to a person;
• a near miss with another aircraft (including another RPA);
• an issue controlling the RPA such as a loss of control;
• non-serious damage to the RPA; or,
• other matters where aviation safety could be enhanced by the ATSB collecting the incident data.

A written report should be submitted within 72 hours.

11.3. Unsafe operation of drones is managed in accordance with JCU Staff Code of Conduct or Student Code of Conduct processes.

12. Personal Information

JCU staff and students should note that their personal information may be supplied to a ReOC provider as part of the approval process contained in this Procedure and will be done so in accordance with JCU’s Information Privacy Policy and relevant legislation.

JCU staff and students should be aware that personal information of third parties may be collected while undertaking JCU drone operations, for example, taking photographs of individuals.

If JCU staff and students are concerned about the use of any video footage or photographs they have taken as a result of carrying out a JCU drone operation, they should contact the Manager, WHS in the first instance for further advice prior to use of any such footage or photograph.

Related policy instruments

FMPM 711 Procurement Procedure

Legal Services, Claims and Litigation Assistance Policy

Information Privacy Policy

JCU Pilot Register

JCU RPA Register

Staff Code of Conduct

Student Code of Conduct

WHS-PRO-002 WHS Risk Management Procedure

WHS-PRO-005 Incident and Hazard Management Procedure

WHS-PRO-015 Field Trip Procedure

Work Health and Safety Act 2011 (Qld)

Work Health and Safety Regulation 2011 (Qld)

The Civil Aviation Act 1988 (Cth)

The Civil Aviation Safety Regulation 1988 (Cth)

Transport Safety Investigation Regulations 2021 (Cth)

Related forms and registers

Appendix 1 Drone Types Quick Reference Guide

WHS-PRO-CHK-018a Pre-Flight Checklist for <2kg SOC

WHS-PRO-CHK-018b Post-Flight Checklist for <2kg SOC

WHS-PRO-FORM-018c CASA Form 1483 – RPA Flying Hours Logbook

Administration

NOTE:  Printed copies of this procedure are uncontrolled, and currency can only be assured at the time of printing.

Approval Details

Revision History