Beyond Compliance: Building a World-Class SMS Training Program for Canadian RPAS Operations

By: Colonel (ret) Bernie Derbach, KR Droneworks, 15 December 2025

Introduction: The Shift to Safety Culture

In the rapidly evolving landscape of Canadian drone operations, checking boxes is no longer enough. Whether you are conducting basic VLOS inspections or preparing for complex BVLOS delivery routes, the difference between a grounded fleet and a successful mission often comes down to one thing: Safety Management Systems (SMS).

While Transport Canada’s Canadian Aviation Regulations (CARs) Part IX sets the baseline, the industry is moving toward higher standards driven by JARUS (Joint Authorities for Rule-making on Unmanned Systems) and ISO 21384-3.

This blog outlines a blueprint for a Canadian SMS Training Program that doesn't just meet regulations—it operationalizes safety excellence.

The "Why": Regulatory & Standards Alignment

Before diving into the curriculum, it is vital to understand the "Three-Legged Stool" of compliance that supports this program:

1. Transport Canada (CARs Part IX): While Part IX does not mandate a full enterprise-level SMS for every operator, Advisory Circular (AC) 901-002 and CAR 901.23 explicitly require procedures for emergency response, site surveys, and organizational oversight that mirror SMS principles [1][4].

   
   

2. JARUS SORA (Specific Operations Risk Assessment): For operators seeking Special Flight Operations Certificates (SFOC) for BVLOS, the SORA methodology requires an SMS to demonstrate the robustness of your Operational Safety Objectives (OSOs) [2].

   
   

3. ISO 21384-3 (Unmanned Aircraft Systems – Operational Procedures): The global standard for commercial drone operations requires a documented safety policy, risk management, and safety assurance processes [3].

The 4 Pillars of a Canadian RPAS SMS

Your training program must be built around the four internationally recognized pillars of SMS, adapted for the Canadian RPAS context.

Pillar 1: Safety Policy and Objectives

• The Accountable Executive: In Canada, safety starts at the top. The training must define who holds the ultimate financial and safety authority (the Accountable Executive).

• Non-Punitive Reporting: A cornerstone of Canadian aviation safety. Pilots must be trained that reporting errors will not result in punishment, provided there is no gross negligence or criminal intent.

  
  

Pillar 2: Safety Risk Management (SRM)

• Hazard Identification: Moving beyond "don't crash." Training pilots to identify subtle hazards (e.g., latent GPS signal interference, fatigue, organizational pressure).

• SORA Integration: Using the JARUS SORA methodology to assess Ground Risk Class (GRC) and Air Risk Class (ARC) before every complex mission.

  
  

Pillar 3: Safety Assurance

• Quality Assurance (QA) vs. Safety Assurance: Explaining the difference. QA asks, "Did we follow the procedure?" Safety Assurance asks, "Is the procedure actually safe?"

• Audits and Monitoring: How to conduct internal audits of flight logs and maintenance records (as required by CAR 901.48).

Pillar 4: Safety Promotion

• Training & Communication: The very blog you are reading is part of this pillar! It ensures competency and shares safety lessons across the team.

The Curriculum: Canadian RPAS SMS Training Modules

A compliant training program should be broken down into the following specific modules.

Module 1: Regulatory Framework & Responsibilities

• Objective: Understand the legal landscape.

• Content:

  • Overview of CARs Part IX and Standard 922.

  • The role of the Accountable Executive vs. the Safety Manager.

  • ISO 21384-3 requirements for commercial operators.

Module 2: Risk Management Workshop (SORA Focus)

• Objective: Practical application of risk assessment tools.

• Content:

  • BowTie Analysis: Visualizing threats and consequences.

  • SORA Methodology: Determining SAIL (Specific Assurance and Integrity Levels).

  • Emergency Response Planning (ERP): Drafting an ERP that satisfies CAR 901.23.

Module 3: Human Factors in RPAS

• Objective: Mitigating the "human element" of risk.

• Content:

  • The "Dirty Dozen" of aviation human factors adapted for remote pilots (e.g., complacency in automation).

  • Crew Resource Management (CRM) for Pilot-Observer communication.

  • Fatigue management for long-duration BVLOS shifts.

Module 4: Incident Reporting & Investigation

• Objective: Learning from mistakes.

• Content:

  • How to submit a report to the TSB (Transportation Safety Board) vs. internal reporting.

  • Root Cause Analysis (5 Whys technique).

  • Just Culture: Understanding the line between acceptable error and negligence.

Implementation Strategy

To implement this training program effectively:

1. Phased Rollout: Start with the Safety Policy module for leadership, then roll out Risk Management to pilots.

2. Documentation: All training must be documented in the pilot's personal file (IAW CAR 901.64) and the company's training records.

3. Recurrency: SMS training should not be "one and done." ISO standards recommend annual refreshers, especially as SORA guidelines evolve.

Conclusion

Adopting a Safety Management System is not just about satisfying Transport Canada or obtaining an ISO certification; it is about protecting your assets, your reputation, and the public. By integrating JARUS SORA methodologies and ISO standards into your training, you position your Canadian RPAS organization as a leader in global aviation safety.

Next Step: Review your current Operations Manual. Does it explicitly reference a Non-Punitive Reporting Policy? If not, draft one today—it is the first step toward a true Safety Culture.

RPOC Suite of Manuals

If you are struggling with writing your own SMS Manual or all of your RPOC Manuals for that matter, KR Droneworks has you covered with our Generic RPOC Suite of Manuals. Email us for details: kr.droneworks@gmail.com or check out our website: https://www.kr-droneworks.com/category/rpas-operators-certification-rpoc

References

1. Transport Canada. (2019). Advisory Circular (AC) No. 901-002: Guidance on the operation of remotely piloted aircraft systems (RPAS) in the specific environment. Link

2. JARUS. (2024). Specific Operations Risk Assessment (SORA) - Version 2.5. Joint Authorities for Rulemaking on Unmanned Systems. Link

3. ISO. (2023). ISO 21384-3:2023 Unmanned aircraft systems — Part 3: Operational procedures. International Organization for Standardization. Link

4. Transport Canada. (2024). Canadian Aviation Regulations (SOR/96-433). Part IX - Remotely Piloted Aircraft Systems. Link