Regulatoriske krav til droner

Ole Hammer

Senior Specialist, Approval Management

oh@force.dk

+45 25 40 82 08

https://forcetechnology.com/en/delta-services

2OH - 20171115

The regulatory environment

Your role in standardisation

Requirements besides the CE-mark

EU requirements of electromechanical products

Consider regulatory compliance from the start

Agenda

3OH - 20171115

What is a drone?Classification proposal from EASA, Technical Opinion — Operation of unmanned aircraft,

18.12.2015

NOTE! - All drones are machines and radios – unless fully covered EU by aircraft regulations

- At present not even the smallest drone is considered a toy by EU legislators

4OH - 20171115

EU Drone Conformity Requirements

Aircraft and

control system

Airworthiness approval functional safety cyber security

Pilot

Training and certification

Maintenance

Continuing airworthiness

Air traffic

Regulations

Liability & Insurance

Waste handling WEEE and batteries

Harmonised StandardsREACH

Phthalates, etc.

General Product Safety

Paraglider Emergency parachute

Packaging

CE-marking

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Drone standardization incomplete Existing standards cover drones Potential for drone specific standardization

Not applicable, however ……

5OH - 20171115

Igangværende projekter:

ISO/AWI 21384-1 Unmanned aircraft systems -- Part 1: General

specification

ISO/AWI 21384-2 Unmanned aircraft systems -- Part 2: Product

systems

ISO/AWI 21384-3 Unmanned aircraft systems -- Part 3: Operational

procedures

ISO/AWI 21895 Categorization and classification of civil unmanned

aircraft systems

Dansk Standard DS/S – 831

Udlaget er åbent for nye medlemer

6OH - 20171115

Pris 15.700,- eks moms for året 2018

SMV: 50% rabat

NGO: Gratis

Mulighed for rabataftale for brancheorganisationer

Etableret udvalg med kompetente fagfæller

Adgang til den europæiske arbejdsgruppe for droner

Indflydelse på alle standarder inden for droner

Forhåndsviden om krav og indhold i alle standarder for droner

2 danske arbejdsmøder pr. år, med status, debat og handling.

Dansk og internationalt netværk

Fri adgang til standarderne fra ISO TC20-SC16

Det danske standardiseringsudvalg

-produkter og services

7OH - 20171115

In EU the technical and operational aircraft requirements for UAS and

UAS pilots are regulated by national legislation in each member

country.

Quote from http://ec.europa.eu/transport/modes/air/uas_en:

“However, the absence of a clear regulatory framework at EU level does not

currently allow the creation of a truly European market for drone services

and aircraft, which limits the potential for jobs and growth creation in this

new sector of the economy.

In response to these challenges, the Commission has proposed, under the

2015 EU Aviation Strategy , to create a risk-based framework for all types

of drone operations.”

EASA activities and status:

– https://www.easa.europa.eu/easa-and-you/civil-drones-rpas

– Introduction of a regulatory framework for the operation of drones

EU Operational standards for UAS

8OH - 20171115

National regulatory requirements for UAS

Link: http://dronerules.eu

9OH - 20171115

Typically NOT covered in standard insurance packages, and can be hard to find!

Insurance coverage – Drone related liabilitieshttp://www.modelflyvning.dk/

10OH - 20171115

EU requirements for electromechanical products apply in addition to

the aviation requirements

Directive with harmonised standards are listed with links at:

– https://ec.europa.eu/growth/single-market/european-

standards/harmonised-standards_en

– A few of these directive do not have “CE” as their compliance mark

Waste related directives

– http://ec.europa.eu/environment/waste/weee/index_en.htm

– This page also provides links regarding the battery directive

Drone - an Arial and an Electromechanical

Product/system

11OH - 20171115

The enforced essential requirements are

– Health, RF exposure

– Safety

– EMC

– Effective use of spectrum by receivers and transmitters

– Indication of applicable radio restrictions in one or more EU member

states

– Configuration control including the SW version

RED may apply to all elements of an UAS

– By testing also non-radio elements as ancillary equipment.

• Equipment that is intended for connection to drone or pilot’s control unit

• E.g. a charger that connect to the drone rather than a detached battery.

RED, Radio Equipment Directive

12OH - 20171115

The enforced essential requirements are

– Mechanical Safety

• Including extra EMC immunity for functional safety aspects

• Test mode stopped – no unintended starting or mechanical movement

Compliance demonstrated by specified approach to risk identification and

implementation of adequate means of elimination or mitigation until it is

demonstrated that the product is safe under intended and foreseeable (mis)use

conditions.

– The directive has no specific standards for drones.

• Standards for products and systems with functional safety requirements

• The standard for weed cutters (buskrydder) may provide inspiration

regarding the protection necessary around drone propellers

Machinery Directive

13OH - 20171115

Batteries and battery packs are subject to transportation restrictions

depending on the size, technology and documented level of safety

approval.

Temperature ranges, charging, operation, storage

Mechanical robustness, LiPo – invisible damage after impact

Charge and discharge controls are essential for battery life and

continued safety – Battery management/balancing circuitry

Warning of damaged, defective or worn out cells in a battery pack will

prevent or reduce the probability of a safety incident.

Drones may be comparable to segboards in stressing the batteries

Critical componets e.g.

Battery Pack Safety Considerations

14OH - 20171115

Contents of a typical approval project

Specify Implement Document

Begin Finish

Conformity Requirement

Specification

Tests & Assessments Technical Construction File

Performing the tests and

assessments specified in the CRS

- In-house or via third party labs

Compiling (accredited) test reports

Project management for third party

labs and internal testing

Maintenance service: CRS & TCF still updated?

Guidance on requirements for contents of

the technical file

Folder structure and descriptions for each

entry in the technical file

Templates for specific entries, such as an

EU Declaration of Conformity or a US

agent letter

Advising requirements for products labels

and user- / service manuals

Obtaining Notified Body Opinions, Grants,

safety marks, certifications…

Review of technical data for completion of

the technical file

Description of product and intended use

Description of markets and conformity

assessment procedures

Applicable directives, rule parts, standards

Conformity strategy; product family

synergies, inheriting modular approvals

Test plan

Applicable tests, pass limits,

frequency & temp ranges,…

Performance criteria, test setups

15OH - 20171115

Ole Hammer

Senior Specialist, Approval Management

oh@force.dk

+45 25 40 82 08

https://forcetechnology.com/en/delta-services

Spørgsmål ?

16OH - 20171115

ISO UAS Standard System - Structure

17OH - 20171115

18OH - 20171115

The Danish Regulatorhttps://www.trafikstyrelsen.dk/DA/Luftfart.aspx

19OH - 20171115

Any importer, re-brander or manufacturer of EEE is most likely a

“producer” and will need to register by joining a producer compliance

scheme. Compliance schemes typically differ by country. For Denmark

details are found at www.dpa-system.dk. For other EU countries:

http://ec.europa.eu/environment/waste/weee/pdf/contacts_ms_weee.p

df

Products under the WEEE or the Battery directive must bear the

WEEE symbol.

Waste handling

20OH - 20171115

REACH

– Some drones may contain or consume a reportable substance

Packaging

– Use recyclable packaging when practicable

General Product Safety

– Applicable to consumer goods, when no other directive imposes safety

requirements

– Listed for inspiration regarding features like a safety landing parachute.

Directives where compliance is not indicated

by the CE-mark

21OH - 20171115

Apply when part of the intended user group is below 14 year of age.

Not applicable for drones when children cannot be certified as drone

pilots

At some point in the future the toy lobby may convince the EU

commission that some drone can be classified as toys

One or more standards will be required to define a toy drone and how

to test and/or assess that it is safe under all imaginable

circumstances.

Toy Safety

22OH - 20171115

This directive is concerned with effective use of the energy resources

For UAS equipment the current ECO requirements may only cover the

standby consumption of the charger, < 0.5 W

Be aware that the ECO directive includes requirements, which get

stricter with time.

ECO directive

23OH - 20171115

At present drones are not called out in the scope of this directive.

It is strongly recommended to take guidance from this directive in

minimizing drone noise emissions.

Noise is a likely cause of complaints regarding drone activity in an

area.

Noise

24OH - 20171115

The intended use of some drones may include areas where dust or

gasses can be ignited.

Firefighter prefer ATEX equipment as smoke gases under some

conditions are explosive or ignitable substances are present at the

scene of an accident.

Flying in mines or at petrochemical plants are other examples.

ATEX

25OH - 20171115

This directive apply to virtually all electrical or electronic products and

including professional equipment.

The relative content of the regulated substance is measured in the

smallest discernible homogenous layer/area on or within a part.

– E.g. the surface treatment of a screw to prevent corrosion

RoHS

Reduction of Hazardous Substances

26OH - 20171115

The electrical safety aspect for the UAV is covered firstly by the

machinery directive and secondly be RED.

The electrical safety of the pilot’s control unit is covered by RED

LVD applies to items within the UAS that has no radio and presents no

mechanical risk e.g. a battery charger

LVD

27OH - 20171115

The EMC aspects for the UAV are covered by RED and the

machinery directive in combination as each directive adds specific

performance criteria to be observed.

– Performance criteria must be defined for each functional safety feature

and primary function.

– A functional safety related performance criteria can include a defined

safe state that the UAV or UAS can enter sufficiently fast for the system

to remain safe and thus pass the test.

The EMC aspects of the pilot’s control unit is covered by RED or as

above if it plays a role in a functional safety scenario.

The EMC directive applies to items within the UAS that has no radio

and presents no mechanical risk e.g. a battery charger.

EMC