Article 16 Reporting Clarification

[leccyflyer]

2 hours ago, Frank Skilbeck said:

Just read it, it states we must report flying over 400ft, I thought association members had an exemption from this? Or do the CAA just want to know how often association members model aircraft fly over 400ft?

That's not what it says. It say you must report any occurrence of a serious incident whilst flying above 400ft -or within 50m of uninvolved persons.

[Andy Symons - BMFA]

3 hours ago, PeterF said:

But that does not really have any clarification as far as I can tell, it really just lists out the article 16 authorisation requirements and some definitions and provides a web based tool for deciding if / what reporting is required. Some clarification examples would be good.

The problem with clarification examples is there are so many variables at play they are more likely to muddy the waters, which if you just work your way through the web based tool are perfectly clear.

Just for information, we worked with the AAIB to produce the reporting tool and they are more than happy with it.

It is too easy to overthink theses things.

[Martin Harris - Moderator]

I've just checked the "incident" today where I scraped my finger on an APC prop as I was loading my car - no blood involved but I winced slightly - and the pre-reporting tool confirmed that this didn't need to be reported.

 

Yes - a silly example but this would have given the same result had I broken a prop on a Hurricane nosing over, lost a wheel on a landing run or overshot and landed in the adjacent field - the answers given would have been identical.  As far as I can see, this tool will filter incidents which contain grey areas and makes the process extremely straightforward.

 

Well done BMFA.

[Gary Manuel]

47 minutes ago, Andy Symons - BMFA said:

It is too easy to overthink theses things.

 

Definitely!

 

The new guidance avoids the cross references to the crazy reporting of everyday incidents such as dead-sticks, broken props etc in CAP722 and allows us to just think about the sort of more serious incidents that make sense to be reportable. As it stands now, it feels like we are only being asked to report incidents that should be reported.

 

Now that these reporting criteria are at the right level, they are more likely to be complied with by the membership. Previously I suspect that the majority would have been ignored. Job done!

Edited April 1, 2021 by Gary Manuel

[Gary Manuel]

7 minutes ago, Martin Harris - Moderator said:

I've just checked the "incident" today where I scraped my finger on an APC prop as I was loading my car - no blood involved but I winced slightly - and the pre-reporting tool confirmed that this didn't need to be reported.

 

Yes - a silly example but this would have given the same result had I broken a prop on a Hurricane nosing over, lost a wheel on a landing run or overshot and landed in the adjacent field - the answers given would have been identical.  As far as I can see, this tool will filter incidents which contain grey areas and makes the process extremely straightforward.

 

Well done BMFA.

Ah, but don't forget that the pre-reporting tool itself wouldn't have complied with the criteria in CAP722. The tool and the BMFA guidance together make make things clearer and FAR more workable.

 

Yes - Well done BMFA / CAA / AAIB for a pragmatic solution.

[MattyB]

Hmmm... This is undoubtedly better, but there is still plenty of woolly language to my eyes. To clarify my understanding as per the updated BMFA guidance...

 

• Minor (and probably major?) injuries sustained in the pits due to ground handling issues (props injuring fingers, burns from a hot engine etc) are not reportable because they did not occur “...between the time the aircraft is about to take off until it comes to rest at the end of the flight with its propulsion system shut down”, correct?
• Have the CAA/AAIB given guidance on what they consider to be a “high probability that the occurrence could have led to someone being fatally or seriously injured”? For instance if a model loses control and crashes in a designated flight area where no uninvolved person or model flyer is or should be located, that is presumably not reportable?

 

Yes, I get that not every use case can be listed and there will always be grey ones you could think up. We know the examples above will be hotly discussed at clubs around the country though, so would benefit from some additional detail/context. Another similar area would be the definition of BVLOS - if someone crashes into the hedge on the edge of our strip when landing or behind a fence due to a depth perception issue with no uninvolved people within the 15m Art 16 distance presumably that is not reportable?

 

Edited April 2, 2021 by MattyB

[Martin Harris - Moderator]

I think common sense has to be used here - and yes, I know that it isn't a defence in law. 

 

Let's say that in your scenario, the model crashes behind a hedge into what you knew to be an agricultural field which should be empty unless a tractor was working in it.  You go to retrieve it and other than a few slightly alarmed pigeons, nobody is in sight and no damage has been caused to the field.  You can fairly state that there was no endangerment to persons or property and you were able to monitor the flight to a split second before losing sight of the model.

 

Alternatively, you arrive to find a concerned boyfriend comforting his swooning girlfriend amidst the wreckage of their picnic which has been deranged by your wayward Wot 4 - happily they were canoodling in the standing corn several feet from the impact while trespassing on the land.  This is obviously reportable as would be the case if anyone were within a reasonable distance at the time of impact or the crash site was the playground of the local infant school. 

 

In essence, if there was a perceivable risk, go through the reporting process but if you honestly believe that nobody was put in any danger then it doesn't require any action. It's rather similar to the old conundrum of whether a falling tree in a deserted forest makes any noise...  With an infinite variety of circumstances possible, I can't see how any hard and fast definitions could be possible and any legal judgement would hinge on whether you took reasonable actions in deciding whether to file a report - did you feel lucky there was nobody near or would it have come as a shock that somebody was?.

 

If you carried the logic that something might have happened if circumstances had been different to extremes, surely every flight by a model or full sized aircraft could potentially endanger someone!

[Frank Skilbeck]

Just a thought but maybe a smart phone BMFA reporting app would be useful, something you can do at the field. Then if the incident should be reported it can provide contact details and instructions etc.

[GrumpyGnome]

The reporting form is just a web page so can already be accessed and used on a smart phone........

 

GG

[Cuban8]

The issue as I see it is whether or not the actions of a model cause actual or potential injury/risk to an uninvolved person. Naturally, that would include risking full sized aviation. If you chop your fingers off in your own prop, or if at your club you clout your mate 'round the ears with your  dumb thumbed ground looping Acrowot, why would any further bureaucracy other than that to do with your club's local procedures and BMFA insurance, should it apply, be required? What good would it do over and above reviewing local  existing club rules and procedures?

Fly-aways OOS with R/C have always been relatively uncommon with decent gear produced within the last forty years or so,  and with very modern equipment, failsafe, geofencing, return to home and so on will become even rarer. The reporting facility is in place but I doubt whether it'll be needed very much by model flyers considering our history of safe operating and so few serious incidents.

Edited April 2, 2021 by Cuban8

[GrumpyGnome]

Seems sensible outcome - thanks BMFA!

[maurice northcott]

Yes Grumpy Gnome, spot on.

 

I have spent some time over 2 days reading and digesting the BMFA writings regarding this subject.

 

To be honest, I found it far more simple than others in various places were making it. Well done BMFA and Thank You for your time and your efforts.

 

[MattyB]

One additional observation... The reporting wizard is exclusively focussed on reporting under the Article 16 authorisation, but many of us also fly under CAP 722 at other times / in other locations. @Andy Symons - BMFA, could the wizard be updated to meet that use case too? Many thanks.

Edited April 6, 2021 by MattyB

[Andy Symons - BMFA]

21 hours ago, MattyB said:

One additional observation... The reporting wizard is exclusively focussed on reporting under the Article 16 authorisation, but many of us also fly under CAP 722 at other times / in other locations. @Andy Symons - BMFA, could the wizard be updated to meet that use case too? Many thanks.

A distinct possibility yes.

[MattyB]

On 07/04/2021 at 14:15, Andy Symons - BMFA said:

A distinct possibility yes.

 

Thanks Andy, much appreciated. We have already integrated use of the reporting wizard into our Club Code of Practice...