Introduction to CAP2555
The Civil Aviation Authority (CAA) has recently released a new guidance document, CAP2555. This crucial document provides policy and guidance for the operation of Unmanned Aircraft Systems (UAS) and Remotely Piloted Aircraft Systems (RPAS) in the Specific Category, specifically when carrying dangerous goods (DG). Although not a regulation, CAP2555 is designed to offer best practise guidance for the safe and efficient carriage of DG by air with a UAS/RPAS.
Scope of the Guidance
CAP2555 applies UAS/RPAS operators in the Specific Category who are seeking approval to carry DG. This guidance broadens the scope and content of CAP 2248 – Carriage of Dangerous Goods by Remotely Piloted Aircraft Systems (CAP 2248). CAA Innovation developed the latter to facilitate the carriage of UN3373, Biological Substances, Category B, during COVID relief efforts.
Principles for Safe Transport of Dangerous Goods
The document underscores that DG can be safely transported by air, provided certain principles were adopted and adhered to. These principles, which are embedded in the ICAO Doc-9284, Technical Instructions for the Safe Transport of Dangerous Goods (Technical Instructions), aim to facilitate the transport of articles and substances classified as DG. They ensure a level of safety such that, as long as all requirements are met, DG can be carried out without jeopardising the aircraft.
Definition of Dangerous Goods
Dangerous goods, as defined in the guidance, are articles or substances capable of posing a hazard to health, safety, property, or the environment. These are listed in the DG list in the Technical Instructions or classified according to the same document.
Addressing Multi-modal Transport
The guidance also touches on multi-modal transport. It highlights that the United Kingdom has adopted the United Nations system, ensuring compatibility between different modes of transport. This means a consignment can be carried by more than one transport mode without the need for intermediate reclassification and repacking.
Approval Process for Carrying Dangerous Goods
To secure approval for carrying DG in the Specific Category, operators must demonstrate that their intended operations do not pose a hazard to health, safety, property, or the environment. This involves a risk assessment process where operators identify the hazards and safety risks associated with foreseeable consequences and show that these have been mitigated to an acceptable level.
Operators are required to submit Application form SRG2807, along with proof of payment of the associated fee in accordance with Official Record Series 5 – Scheme of Charges for Air Operators and Police Operators. The form contains relevant information about the operator, the responsible persons for the application process, and outlines the information that the operator should submit with the application.
Dangerous Goods Procedures Manual
The CAA website offers a template with the recommended structure and content for a Dangerous Goods Procedures Manual, which all operators should adopt. The manual should include a policy statement for the safe carriage of DG, identify the person responsible for the DG approval and for continued compliance with the applicable regulations, and identify training needs for the operator’s staff and/or staff of other entities involved with activities related to the transport of DG.
Conclusion
In summary, the new guidance document CAP2555 marks a significant milestone in the regulation of UAS/RPAS operations, particularly concerning the carriage of dangerous goods. It provides clear and comprehensive guidance for operators, ensuring that dangerous goods can be transported safely and efficiently, while also safeguarding the health and safety of all parties involved.
You can find the operation manuals templates here:
