Maintenance UAS/drones

    As set out in Implementing Regulation (EU) 2019/947, it is the responsibility of the UAS operator to maintain the UAS in a state suitable for safe operation, confirming that the UAS is in a position to perform the intended flight safely.

    The maintenance to be performed in the UAS will depend on the category in which the operation is being carried out.

    In ‘open’ category, maintenance shall be carried out by the operator using operator procedures based on the manufacturer’s manual(s).

    In the ‘specific’ category, maintenance will be carried out by the UAS operator following maintenance instructions and properly trained and qualified maintenance personnel. To do so, you must:

    • Develop maintenance instructions to keep the UAS in safe conditions of use, and include them in the operations manual. These instructions shall cover at least, where appropriate, the instructions and maintenance requirements laid down by the manufacturer.
    • Describe in the operations manual the minimum competence required of maintenance personnel, as well as their duties and responsibilities.
    • Keep and keep up-to-date a record of:
      • All relevant qualifications and training courses completed by maintenance staff for at least three years after those persons have ceased working with the organisation or have changed positions in the organisation.
      • Maintenance activities carried out in the UAS for a minimum of three years.
    • Establish and keep up-to-date a list of maintenance personnel employed by the operator to perform maintenance activities.

    In addition, depending on the risk obtained in the relevant operational risk assessment provided for in Article 11 of Implementing Regulation (EU) 2019/947, the maintenance of UAS may have additional requirements, such as:

    • To the maintenance instructions prepared by the UAS operator, a maintenance program and even an organisation’s maintenance manual will be added.
    • Qualified maintenance personnel would have to be authorised by the UAS operator to perform certain tasks, as well as receive maintenance training, which is recurrent and validated by a third party.

    Further information related to the operational risk assessment set out in Article 11 can be found at the following link:

    In the event that the UAS operator uses a standard scenario (STS), the UAS operator shall add to the above the additional requirements set out in the above scenarios.

    Maintenance requirements for the ‘certified’ category are in the process of being defined by EASA.

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