Beyond the Visual: Implementing LOSA in High-Stakes Canadian RPAS Operations
- krdroneworks
- 3 hours ago
- 7 min read
By: Colonel (ret) Bernie Derbach, KR Droneworks Academy, 13 March 2026
(NOTE: Check below on how to receive your FREE copy of our RPAS LOSA Observation Checklist
The Canadian Remotely Piloted Aircraft Systems (RPAS) sector is currently navigating its most significant evolution since the introduction of the 2019 regulations. As we push the boundaries of "Level 1 Complex" operations, Beyond Visual Line of Sight (BVLOS), Search and Rescue (SAR), and wildfire suppression ("Hot Spot" firefighting), the margin for error has evaporated.
While Flight Data Monitoring (FDM) tells us what happened—the altitude deviation, the battery spike, or the lost link event—it rarely explains why. To bridge this gap, the RPAS industry is looking toward a proven gold standard from manned aviation: the Line Operations Safety Audit (LOSA).
Based on the frameworks established by Robert (Bob) Baron, PhD, and the methodologies used by The Aviation Consulting Group, this article explores how LOSA can be adapted from the cockpit of a Boeing 787 to the ground control station (GCS) of a complex RPAS operation in the Canadian wilderness.
What is LOSA? The Proactive Safety Sentinel
As Dr. Baron notes, LOSA is a proactive, formal process where expert observers collect real-time data on environmental conditions, operational complexity, and human performance. It is not an inspection or a "checkride." It is a diagnostic tool.
In a LOSA, a trained observer (often a peer pilot) sits in the "jumpseat"—or, in our case, stands behind the RPAS Pilot-in-Command (PIC) and Payload Operator—to record how the crew manages threats and errors during a normal mission.
The Core Pillars of LOSA
Jumpseat Observations: Real-time data collection during normal operations.
Anonymous and Confidential: Data is de-identified to ensure the crew feels safe being observed.
Non-Punitive: Management cannot use LOSA data to discipline individuals.
Trusted Data Collection: The focus is on systemic trends, not individual "gotchas."
Applying LOSA to Canadian RPAS Contexts
Canada’s geography and regulatory environment present unique challenges. Applying LOSA to specific high-complexity missions requires a nuanced approach.
1. Level 1 Complex and BVLOS Operations
In BVLOS operations, the pilot is detached from the aircraft’s physical environment. The "threats" are often invisible: latency in the C2 link, shifting signal-to-noise ratios, or unexpected non-cooperative aircraft entering the operational volume.
A LOSA observer in a BVLOS GCS focuses on Information Management.
The Threat: An unexpected weather front moving into the recovery zone.
The Error: The crew failing to cross-check METAR updates during the cruise phase.
The Mitigation: LOSA identifies if the GCS layout or the lack of a standardized "weather check" call-out contributed to the oversight.
2. RPAS Search and Rescue (SAR)
SAR operations are defined by high cognitive load and "mission creep." Crews are often operating in "Save-a-Life" mode, which can lead to intentional or unintentional rule-breaking (procedural drift).
A LOSA in SAR identifies how the crew manages the transition from a standard launch to an emergency find. Does the communication between the RPAS crew and the ground search teams break down? Are checklists abandoned when the target is spotted? By observing these "natural" behaviors, SAR organizations can refine their Crew Resource Management (CRM) training to ensure safety isn't sacrificed for speed.
3. Hot Spot Firefighting (Wildfire Ops)
Operating RPAS in support of wildfire suppression is perhaps the most complex environment in Canadian aviation. You have high heat, heavy smoke (IMC conditions), multiple manned assets (helicopters and air tankers) in the same airspace, and intense pressure.
LOSA in this "Hot Spot" environment captures the "Why" of Coordination. If an RPAS enters a restricted "no-fly" zone during a retardant drop, FDM records the location breach. LOSA, however, might reveal that the crew was distracted by a malfunctioning radio or that the air-to-air coordination frequency was so congested they couldn't announce their position.
The "Whys" vs. The "Whats": Complementing FDM
Dr. Baron emphasizes that LOSA is the perfect partner to Flight Data Monitoring. In the RPAS world, we have more data than we know what to do with—telemetry, signal strength, battery cycles, and GPS accuracy are all logged.
However, FDM cannot see the Human-Machine Interface (HMI).
Imagine an RPAS landing with dangerously low battery levels. FDM shows the percentage at touchdown. The LOSA observer, however, notes that the pilot was struggling with a complex menu on the GCS to find the battery telemetry screen, or that the crew was arguing about the landing site's suitability. The fix isn't a better battery; it’s a redesigned GCS interface or better CRM training.
The Threat and Error Management (TEM) Framework
The backbone of LOSA is the TEM framework. In Canadian RPAS operations, we categorize these as follows:
External Threats
Environmental: Sudden "Anabatic" winds in the Rockies, icing at low altitudes, or solar flares affecting GPS.
Operational: Rapidly changing NOTAMs or "pop-up" manned aircraft in uncontrolled airspace.
Errors
Procedural: Skipping a pre-flight sensor calibration.
Communication: Misunderstanding a command from the Visual Observer (VO) or Air Traffic Control.
Tactical: Miscalculating the return-to-home (RTH) battery buffer against a headwind.
Undesired Aircraft States (UAS)
This is the "Red Zone"—low battery, altitude excursions, or flying outside the approved BVLOS corridor. LOSA helps us understand how a pilot navigates from a Threat to an Error and, eventually, back to safety (or into an incident).
Why Canadian RPAS Operators Need LOSA Now
1. Insurance Benefits
As Dr. Baron highlights, insurance companies view LOSA very favorably. In the emerging Canadian BVLOS market, insurance premiums are a significant OpEx. Demonstrating a "Predictive" safety culture through LOSA can lead to substantial premium reductions, as it proves the operator is managing risk, not just reacting to it.
2. Regulatory Compliance and Beyond
Transport Canada’s move toward more integrated airspace requires operators to demonstrate "Equivalency" to manned aviation safety standards. Implementing a LOSA program puts an RPAS operator on the same professional footing as a major airline.
3. Evidence-Based Training
Instead of generic training, LOSA allows Canadian operators to build Evidence-Based Training (EBT). If LOSA data shows that crews at a specific SAR base consistently struggle with "Lost Link" procedures in mountainous terrain, the training department can develop a specific simulator module for that exact scenario.
Implementing LOSA: The Road Map
For a Canadian RPAS company to implement LOSA, they should follow the ACG (Aviation Consulting Group) methodology:
Preparation: Define the scope (e.g., "All Level 1 Complex operations in Ontario").
Observer Training: Select senior pilots to be observers. They must be trained to observe without interfering—the "fly on the wall" technique.
Data Collection: Conduct observations over a set period (e.g., 50 missions).
Data Analysis: De-identify the data and look for patterns.
Targeted Action: Update Standard Operating Procedures (SOPs), checklists, or GCS hardware based on the findings.
Integrating a LOSA program isn't just a "nice-to-have" safety philosophy; for serious Canadian operators, it is a structural component of their regulatory identity. For organizations conducting Level 1 Complex and BVLOS operations, the Remotely Piloted Aircraft Operational Certificate (RPOC) is the legal foundation of their authority to fly.
To move beyond the minimum requirements of CARs 901.102, LOSA should be formally codified within your RPOC Manual.
Integrating LOSA into the RPOC Framework
The most effective way to ensure LOSA is performed consistently is to embed it directly into the Safety Management System (SMS) section of your manual. Specifically, LOSA protocols should be detailed under:
Section: Safety Management System (SMS)
Subsection: Proactive Safety Data Collection (LOSA)
Scope: Define that 100% of BVLOS and Level 1 Complex missions are eligible for random LOSA observations.
Observer Qualifications: Specify that observers must be "Qualified Persons" who have completed LOSA-specific training from a recognized provider (like ACG).
Data Protection: Explicitly state the "Non-Punitive" clause—that data collected during a LOSA cannot be used for disciplinary action against the crew, ensuring the integrity of the "Normal Operations" data.
Section: Flight Operations – Training & Evaluation
While the above Section deals with the data, the Section should address how that data is used.
Subsection 5.8: Evidence-Based Training (EBT): State that LOSA findings will be reviewed quarterly by the Chief Pilot to adjust the training syllabus for Level 1 Complex maneuvers and BVLOS contingency procedures.
Why This Matters for TC Certification
When Transport Canada (TC) reviews an RPOC application for BVLOS or Complex ops, they are looking for Safety Assurance. By including LOSA in your manual, you are telling the regulator:
We monitor the "Why": We don't just wait for an incident to occur; we observe our pilots during routine flights to catch "procedural drift" before it leads to an accident.
Standardization: In SAR or Firefighting, "heroic" deviations from SOPs are common. Codifying LOSA in the RPOC manual provides a formal mechanism to identify these deviations and bring the team back to the standard.
Audit Readiness: Having a LOSA section in your RPOC manual creates a clear audit trail. When a TC inspector asks how you manage "Human Factors" in BVLOS, you can point directly to your LOSA data sets.
By making LOSA a "Manualized" requirement, it ceases to be an optional exercise and becomes a core part of the organization's DNA, proving to both regulators and clients that you operate at the highest level of aviation professionalism.
NOTE: KR Droneworks has include LOSA into ALL of its Generic RPOC Suite of Manuals, where applicable - available though our website.
We have also created a LOSA Observation Checklist designed specifically for the RPAS environment. This tool focuses on Threat and Error Management (TEM)
Applicability: Level 1 Complex / BVLOS / SAR / Firefighting Ops. This is available FREE OF CHARGE . Simply email KR Droneworks at: kr.droneworks@gmail.com to receive your free copy today.
Conclusion: Predictive is the Ultimate Proactive
In the words of Dr. Baron, "With LOSA, you are being predictive—which is the ultimate form of proactive safety!"
For the Canadian RPAS industry to move from experimental to essential, we must embrace tools that look beyond the hardware. Whether you are flying a multi-million dollar BVLOS platform for pipeline inspection or a thermal-equipped drone for a SAR mission in the Yukon, the human in the loop remains the greatest variable.
LOSA doesn't just watch the pilot; it watches the system. By understanding the "why" behind the errors in our most complex operations, we can build a future where RPAS are not just "safe enough," but are the safest assets in the Canadian sky.
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