The sUAS Guide 2016 Q1 Update | Page 22

4.2 Means-of-Compliance for Manufacturers to Show that Small UAS Meet the Performance-Based Safety Requirement 4.2.1 Manufacturer’s Declaration To demonstrate that a small UAS qualifies for Category 2, 3, or 4 operations over people, the ARC recommends that the manufacturer of the UAS be required to declare (self-certify) that the small UAS meets industry consensus standards for operation over people. This recommendation is the outcome of a robust discussion that also considered, and rejected, two alternatives: (1) FAA certification of conformity with standards; and (2) mandated third-party certification (such as by an independent laboratory). The consensus view was that FAA certification would be impractical and too slow to keep up with the rapid pace of technology development, and thus this method of certification was unanimously rejected. The ARC also concluded that mandatory third-party laboratory certification would impose an unnecessarily high burden in light of the simple type of test that is contemplated (a drop test measuring impact energy transfer). The ARC was unanimous in recommending manufacturer self-certification for Categories 1, 2, and 3. There was also consensus for self-certification for Category 4. 4.2.2 Category 1 Means-of-Compliance To demonstrate that a small UAS qualifies for Category 1 operations over people, the ARC recommends that the manufacturer of the UAS be required to: (1) label the retail product packaging of the small UAS with either the actual weight of the small unmanned aircraft or a general statement that the small unmanned aircraft weighs 250 grams or less; or (2) declare that the small unmanned aircraft weighs 250 grams or less and submit that declaration to the FAA in a form and manner acceptable to the FAA. 4.2.3 Category 2 Means-of-Compliance To demonstrate that a small UAS qualifies for Category 2 operations over people, the ARC recommends that the manufacturer of the UAS be required to: (1) declare that the small UAS meets applicable industry consensus performance standards for operation over people; (2) submit that declaration to the FAA in a form and manner acceptable to the FAA; and (3) label the product or product retail packaging in accordance with industry consensus standards. 4.2.4 Category 3 Means-of-Compliance To demonstrate that a small UAS qualifies for Category 3 operations over people, the ARC recommends that the manufacturer of the UAS be required to: (1) declare that the small UAS meets applicable industry consensus standards for operation over people; (2) submit that declaration to the FAA in a form and manner acceptable to the FAA; and (3) label the product or product retail packaging in accordance w