The position of person with primary responsibility, or prime person as it's more commonly known, is a safety-critical role pivotal to a Part 102 unmanned aircraft organisation’s success.
So you want to be a prime person? It’s a rewarding position which gives you the opportunity to provide safety leadership and add value to the business.
But it’s not for the faint-hearted.
The role cannot be underestimated and requires commitment to the continual improvement of safety, and commitment to the time it takes to do that properly.
A positive attitude towards communicating, including and importantly with the CAA, is an essential trait in a prime person. Photo: iStock.com/mixetto.
The safety-critical role of a prime person is pivotal to a Part 102 unmanned aircraft organisation’s success.
It’s also a requirement of the civil aviation rules. An organisation cannot become the holder of a Part 102 unmanned aircraft operator certificate without a prime person in place.
A prime person is responsible for all the functions associated with an operation, and they foster the safety culture of the organisation. They exercise an appropriate level of control, direction, and responsibility to ensure the continued safety, and effective running, of the operation.
A prime person may have several employees to assist them to do the work, but they remain responsible for ensuring the work is done and done right.
Prime person responsibilities include:
While not necessarily senior in years, prime persons need to be experienced, skilled, and knowledgeable. They must also have sufficient time, resources, and authority to fulfil their responsibilities.
By their actions and words, the prime person sets the boundaries of acceptable performance for the organisation’s personnel. They have a responsibility to create a positive organisational culture.
A prime person does not need to be an unmanned aircraft pilot, nor do they require aviation experience. BUT they do need a practical understanding of the relevant risks, and to understand relevant aviation concepts to be able to fulfil the role. The prime person’s knowledge will be evaluated during the CAA’s assessment process.
Does your nominee for prime person have the experience, knowledge, and expertise to fully carry out their responsibilities? Do they have the right attitude to complying with the rules? Can they lead by example? Photo: CAA.
As already noted, the nomination, and CAA acceptance, of a suitable prime person is an essential part of certificating an aviation organisation.
Acceptance of a nominated prime person is never automatic, and it’s not uncommon for a prime person candidate to be declined by the CAA.
Often that’s because they, or the applicant (that’s the organisation on whose behalf they are applying), or both, have insufficient understanding of what the role involves.
Being turned down by the CAA is stressful to the candidate, an added cost to the applicant that has put them up for an assessment, and can cause delays in certification.
An applicant can avoid this situation by considering, whether their person nominated:
That last trait is particularly important. It’s not enough for the prime person to say ‘everyone must act safely’. They must be able to demonstrate to the CAA that they live and breathe that.
To that end, a positive attitude towards communicating, including with the CAA, is essential.
When assessing the prime person candidate, the CAA will be considering things like:
The supervisory aspect of the prime person role is critical, so it’s important the nominated candidate can demonstrate how they’re prepared to go beyond simple rule compliance, instead describing how they would raise the safety bar at their organisation.
There are, at the time of publishing this online booklet, 228 Part 102 (Unmanned Aircraft Operator Certification) operators in New Zealand, many of them in the agricultural, surveying, engineering, and film/video industries. Photo: iStock.com/artursfoto.
Nominating a suitable prime person is just one thing an applicant can do to make sure the certification process goes smoothly.
The initial application for a certificate must be accompanied by the nominee’s fit and proper documentation. Who will be nominated prime person is a decision that needs to be made right from the start.
Nominating a new prime person after you have already submitted your Part 102 certificate application because you have changed your mind will cause delays.
The nominee must be employed, contracted, or otherwise engaged to work sufficient hours to fulfil the prime person functions appropriate to the size and scope of the organisation.
If an applicant has no one they can nominate from within their own organisation, they can contract from outside – at least until such time as someone else gains enough experience to apply successfully to be the prime person.
The Civil Aviation Act 2023(external link) is the primary legislation underpinning aviation safety in New Zealand, and a good understanding of its requirements is essential.
The candidate must have an in-depth knowledge of their company’s exposition, and a good working knowledge of the Part 101 and 102 rules, transport instruments and advisory circulars.
Part 102 is a performance-based set of rules, which is different to many prescriptive civil aviation rules. The candidate must understand how Part 102 enables 102 operators.
Some other fundamental requirements for the nomination of a prime person are found in the Act:
Section 13 General requirements for aviation participants(external link)
Section 75 Grant or renewal of aviation document (external link)
Section 80 Fit and proper person test(external link)
In the era of mobile phones and internet meetings, a prime person can spend time away from the base of operations. But the CAA expects they’ll exercise visible leadership and allocate an appropriate amount of time to on-site activities. Photo: iStock.com/sanjeri.
Anyone thinking about taking on the role of prime person should assess whether they have the time to do justice to the role.
In asking that question of themselves, if the honest answer is ‘no’, they will need a plan to free up the time needed, or nominate someone else, before their application is submitted to the CAA.
Since people often hold multiple roles in an organisation, or multiple roles within industry, the CAA needs to be satisfied the candidate will have enough time to be effective. For instance, if not full-time on site, will they spend enough time there? Will they dedicate enough time to do the job properly? The CAA needs to be confident that not only is the candidate capable, but that they’ll dedicate sufficient time to their responsibilities.
A prime person doesn’t have to be on site all the time. In the era of mobile phones and internet meetings, a certain amount of time can be spent away from the base of operations.
But it can be harder to promote a positive safety culture, when supervising and monitoring an organisation remotely. It’s expected the prime person will exercise visible leadership and allocate an appropriate amount of time to on-site activities.
Section 77 of the Act(external link) requires the prime person to satisfy the fit and proper person test.
At their interview, a prime person candidate needs to describe to the CAA – among other things – the time they intend to dedicate to the role, and how they’ll manage other commitments that could potentially interfere with it. Photo: iStock.com/Wasan Tita.
To help establish that, the CAA assesses a nominated person’s capability and capacity to successfully carry out the role. This is usually done by conducting a formal interview with the candidate to establish their competence to perform the prime person role and to ensure the continuing safety of the operation.
Following an initial review and discussion of the candidate’s qualifications and experience, the candidate will be expected to:
The CAA will consider the information that was provided about the candidate, how the candidate performed during the interview, and complete any follow-up, that’s required before providing the candidate with the results.
Either the prime person candidate will be assessed as:
Note: A formal interview may not be required if the person has already been assessed previously for a similar role.
A prime person’s ability to effectively carry out the role will continue to be monitored by the CAA. It’s not a box tick every five years. Photo: iStock.com/MTStock Studio.
The CAA is always interested in the ongoing ability of the prime person to do their job.
A prime person is expected to keep themselves up-to-date with professional development, with rule changes, and with changes to their company’s exposition. They’re encouraged to attend user group meetings or relevant professional gatherings. They need to stay ahead of the game.
It would be a mistake for a newly appointed prime person to think they were now ‘through the gate’ and become complacent. Attitude is demonstrated through behaviour, so a prime person must constantly illustrate that they are positive, proactive, and constructive.
Their ability to effectively carry out the role will continue to be monitored, as will their ability to meet the fit and proper person requirements. It’s not a matter of a box tick every five years.
A good prime person can be trusted by the CAA to get on the phone to the Authority to discuss any concerns they have about their organisation. The expectation is that they will communicate openly and honestly with the CAA, bringing any issues to the CAA's attention in a timely manner. The CAA will be interested to hear what they’ve done, or intend to do, to address the issues in terms of corrective or preventative actions.
They must also demonstrate leadership skills. Rather than asking, ‘How does this person’s leadership skills contribute to the organisation’s bottom line?’ the CAA asks, ‘How does this person’s leadership skills contribute to developing an effective safety culture?’
Because a certificated organisation’s prime person must be named in their exposition, if that person changes, then the exposition must be updated too.
The CAA must be formally notified if an organisation intends to change its prime person, as the new person must be acceptable to the Director. This is done by applying for an amendment using this form:
We recommend that if you’re a prime person leaving an organisation, you make sure you receive written acknowledgement from that organisation, of your intended departure date.
It may also be appropriate to let the CAA know that you’re moving on.
Main photo: iStock.com/Tlillico.
