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VSG Aviation Safety, Safety Management System

1. Safety	Policy

a. Vision	Services	Group	is	committed	to	implementing	and	maintaining	a	Safety	

Management	System (VSG-SMS)	in	accordance	with	the	purpose	and	intent	of	

the	Federal	Aviation	Administration	sponsored	Aviation	Safety, Safety	

Management	System	(AVSSMS).	The	implementation	of	this	SMS	reflects	a	

commitment	to	safety	not	only	because it	is	an	aviation	best	practice	and	the	

most	effective	method	of	ensuring	the	endurance	and	safety	of	our	equipment	

and	personnel,	but	because	it	is	an	efficient	method	of	optimizing	the	safety	of	

the	National	Airspace	System.	

b. As	part	of	the	VSG-SMS,	a	designated	safety	committee,	which	will	be	defined	in	

this	document, will	regularly	review	company	safety	practices	and	identify	

methods	for	improving	safety	practices	including,	but	not	limited	to,	those	

recommendations	made	by	the	FAA	and	NTSB.

c. The	key	process	by	which	most	safety	related	incidents	could be avoided	or	

mitigated	is	through	a	comprehensive	risk	management	plan.	This	document	

outlines	the	safety	risk	management	strategy	employed	by	all	employees	of	the	

company	and	any	contractors	or	sub-contractors	in	executing	the	VSG-SMS.

d. VSG,	its	employees,	subsidiaries,	contractors	and	sub-contractors	shall,	at	all	

times,	comply	with	all	federal,	state	and	local	statutes	and	regulations	applicable	

to	company	activities.	

e. It	is	the	responsibility	of	all	employees	to	report	violations	of	this	VSG-SMS	or	

any	other	unsafe practices.	Employees	may	report	directly	to	their	supervisor,	

the	company	safety	representative	or	any	member	of	the	executive	

management	team	if	they	encounter	a	seemingly	unsafe	situation.	These	reports	

will	be	treated	completely	in	a	non-retribution	manner	and	employees	are	

assured	that	the	reporting	of	unsafe	conditions	will	under	no	circumstances	be	

detrimental	to	their	employment,	career	progression	or	relationship	within	the	

company.	Whenever	possible,	the	reporting	employee	should	offer	a	suggestion	

to	bring the	unsafe	situation	into	a	state	of	compliance	or	make	

recommendations	for	better	practices.	Safety	is	everyone’s	responsibility.

f. Acceptable	employee	behavior	is	outlined	in	the	company	policy	document	

regarding	employee	dress	and	behavior	and	included	in	the	employee	handbook.	

VSG	expects	its	employees	to	act	in	a	professional	manner	at	all	times	on	the	job	

to	include	refraining	from	behavior	that	may	create	an	unsafe	environment	or	
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condition.	While	all	risk	cannot	be	removed	from	our	operations,	the	

unnecessary	risk	associated	with	certain	unprofessional	behavior	is	unacceptable	

and	will	not	be	tolerated.

g. In	creating	the	VSG-SMS,	all	safety	objectives	should	reflect	the	following	

guidance

i. Ensure	the	safety	of	all	human	participants	in	flight	activity	to	include	

operators,	observers and	bystanders.

ii. Ensure	the	protection	of	real	&	personal	property	to	the	greatest	degree	

possible.

iii. Ensure	the	safety	of	aircraft	and	other	associated	equipment	to	the	

greatest	degree	reasonable.

iv. The	order	of	precedence	for	these	objectives	should	be	preservation	of	

life,	prevention	of	injury,	protection	of	property	and	then	protection	of	

VSG	equipment/aircraft.

h. All	managers	shall	ensure	their	subordinates	review	the	safety	objectives	once	

quarterly	and/or	when	changes	to	safety	policies	or	objectives	are	implemented.	

Executive	management	is	responsible	for	the	support	of	this	VSG-SMS	and	will	

provide	managers	with	the	means	to	disseminate	and	review	safety	objectives	

with	their	team.	

i. The	company	safety	officer	shall	be	appointed by	and	report	to	the	Chief	

Executive	Officer	for	all	safety	related	duties.	The	safety	officer	is	responsible	for	

the	execution	and	monitoring	of	the	VSG-SMS	but	the	executive	management	

team	is	ultimately	responsible	for	its	success	through	their	commitment	and	

support. The	safety	officer’s	duties	include:	

i. Executing	the	VSG-SMS	

ii. Leading	the	annual	review	of	safety	procedures	and	objectives

iii. Receiving	incident	reports	and	conducting	the	ensuing	investigations

iv. Monitoring	operations	for	VSG-SMS	compliance

v. Issuing	warnings	and	letters	of	reprimand	which	become	part	of	an	

employee’s	permanent	record	for	safety	violations

vi. Making	recommendations	for	safety	procedure	improvement
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vii. Reporting	the	overall	condition	of	the	VSG-SMS	and	company	compliance

j. The	safety	committee,	which	includes	at	a	minimum	the	safety	officer,	Chief	

Operating	Officer	and	Director	of	Training,	shall	review	annually	the	statutory	

and	regulatory	applications	to	the	VSG-SMS	to	ensure	its	compliance	with	all	

federal,	state	and	local	requirements.	The	committee	shall	use	the	resources	at	

its	disposal	to	include	in-house	research,	company	counsel,	company	flight	

insurance	representatives	and	any	relevant	government	documents,	notices	or	

websites	to	ensure	compliance	with	up	to	date regulations.

k. The safety	committee	shall	maintain	and	the	safety	officer	shall	implement,	

procedures	to	measure	the	effectiveness	of	the	VSG-SMS.	These	procedures	will	

include	statistics	around	quarterly	reports	of:

i. Number	of	safety	incidents

ii. Incident	investigation	findings	(human,	environmental	or	mechanical	

error)

iii. Number	and	severity	of	safety	violations,	warning	and	reprimands

l. All	incidents	or	accidents	must	be	reported	to	the	safety	officer	following	the	

incident	reporting	guidelines	found	in	the	employee	handbook.	Forms	for	all	

ground	&	air	safety	reports	can	be	found	on	the	company	server.	All	incidents	

shall	be	investigated	by	the	safety	officer.	Depending	on	the	severity	of	the	

incident,	the	safety	officer	may	choose	involve	the	aircraft	manufacturer,	

company	maintenance	or	training	director	for	diagnostic	evaluation	of	the	flight	

telemetry	and	aircraft/vehicle	condition	to	aid	in	the	investigation.	Results	of	the	

investigation,	if	they	lead	to	a	new	finding	regarding	best	practices,	may	be	

incorporated	into	a	technical	advisory	or	service	advisory	distributed	to,	at	a	

minimum,	all	company	flight	operations	and	maintenance	personnel,	but	also	

may	be	distributed	to	the	manufacturer	for	further	dissemination.	The	safety	

officer,	Chief	Operating	Officer	or	company	counsel may	use	their	discretion	on	

whether	wider	dissemination	is	necessary.

Safety Risk Management

m. The	Pilot	in	Command	(PIC)	shall	complete	a	Pre-Flight	Risk	Management	

Worksheet	prior	to	flight	commencement	at	each	operating	location	for	the	day.
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n. This	worksheet	endeavors	to	describe	the	environment	in	which	flight	

operations	will	take	place,	identify	hazards	present	and	use	this	information	to	

analyze	the	level	of	risk	for	any	given	flight.

o. The	worksheet	gives	clear	instructions	on	when	supervisors	or	more	senior	

members	of	the	operations	team	must	give	approval	for	flights	based	on	the	risk	

level.	This	is	meant	to	mitigate	the	risk	of	a	less	experienced	operator	taking	

unnecessary	risks.	

p. Although	a	PIC	is	forbidden	to	fly	if	a	supervisor	or	other	senior	member	of	the	

operations	team	directs	them	not	to	fly	because	of	safety	concerns	or	other	

reasons,	a	PIC	has	the	authority	to	choose	NOT	to	fly, regardless	of	approval	by	

supervisors	or	other	senior	members	of	the	operations	team, if	the	PIC	feels	that	

conditions	are	such	that safe	operation	of	the	aircraft is	impossible	and	that	

flight	would	endanger	the	safety	of	the	crew,	observers,	other	people	or	

property	or	the	VSG-owned	equipment.

q. The	attached	Pre-Flight	Risk	Management	Worksheet uses	figures	based on	the	

safe	operating	characteristics	of	the	Bramor	fixed-wing	aircraft	and	the	Octane	

multi-rotor	aircraft.	If	using	a	different	platform,	this	form	should	be	modified	

according	to	the	operating	handbook	of	that	platform	and	any	applicable	

supplemental	guidance	from	VSG.	
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Pre-Flight	Risk	Management	Worksheet

Date: PIC: Location:

CRM	Risks 3 2 1

Crew	Rest	prior	to	duty <6hrs 6-8hrs >8hrs

Crewmembers	ill? Yes No

PIC	experience <50hrs 51-100hrs >100hrs

Mission	type No	notice Routine Training

CRM	Sub-Total

Environmental	&	Terrain	Risks 3 2 1

Visibility <1sm 1-3sm >3sm

Clouds OVCST SCT CLR

Wind	conditions >7	m/s 4-7	m/s <4	m/s

Heat	(leave	blank	in	winter/fall) >100F 90-99F <90F

Cold (leave	blank	in	summer/spring) <35F 35-44F >45F

Launch/Land	area <100yd 100-150yd >150yd

Obstacles	within	0.5nm	(height) >400ft 150-399ft <150ft

Population	Density Urban Suburban Rural

Topography Mountain Hilly Flat

Environmental	&	Terrain	SubTotal

Risk	Management	Total

If	CRM	sub-total	is:

<8;	proceed 8+;	requires	supervisor	approval

If	Environmental	sub-total	is:

<16;	proceed 16+;	requires	supervisor	approval

If	Risk	Management	total	is:

<24;	proceed 24-28;	requires	supervisor >28	requires	Dir,	Flight	Ops

This	information	is	accurate	to	the	best	of	my	knowledge.	______________________

PIC	Signature
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2. Safety	Assurance

a. While	safety	is	everyone’s	responsibility,	the	company	safety	officer	is	the	

primary	point	of	contact	for	all	safety	related	questions	within	the	company.	This	

officer	is	also	responsible	for	continually	monitoring	the	company’s	activities	and	

ensuring	compliance	with	safety	policy.	The	company	safety	officer	sits	as	a	

member	of	the	safety	committee	as	described	in	section	1.b.	and	3.b. of this	

document. The	safety	officer	shall	submit	a	safety	compliance	report	quarterly	to	

the	safety	committee	and	the	CEO.

b. The	VSG	safety	committee	shall	consist	of	no	less	than	three	(3)	individuals	to	

include	the	company	safety	officer,	a	Director	or	equivalent	from	the	Operations	

division, and	a	member	of	the	senior	executive	team	(C-level).	The	safety	

committee	shall	be	responsible	for	reviewing	current	company	safety	policy,	the	

VSG-SMS,	safety	records	and	reports	to	determine	if	the	company	is	operating	

under	ideal	safety	practices.	The	committee	will	use	current	practices,	industry	

standards	and	federal,	state	and	local	statutes/regulations	to	decide	if	changes	

or	amendments	to	current	practices	need	to	be	implemented.	The	committee	

shall	meet	twice	annually	to	review	the	company	safety	policy	and	may	be	called	

to	special	session	to	address	immediate	safety	concerns.

c. It	is	the	responsibility	of	all	employees	to	report	violations	of	this	VSG-SMS	or	

any	other	situation	that	appears	unsafe.	Employees	may	report	directly	to	their	

supervisor,	the	company	safety	officer	or	any	member	of	the	executive	

management	team	if	they	encounter	a	seemingly	unsafe	situation.	These	reports	

will	be	treated	completely	in	a	non-retribution	manner	and	employees	are	

assured that	the	reporting	of	unsafe	conditions	will	under	no	circumstances	be	

detrimental	to	their	employment,	career	progression	or	relationship	within	the	

company.	Whenever	possible,	the	reporting	employee	should	offer	a	suggestion	

to	bring	the	unsafe	situation	into	a	state	of	compliance	or	make	

recommendations	for	better	practices.	Safety	is	everyone’s	responsibility.

d. All	incidents	or	accidents	must	be	reported	immediately	as	outlined	in	the	

Operator	Handbook.	

i. The	first	priority	is	to	assess	injury	to	any	people	and	take	appropriate	

steps	to	treat	the	injury.	The	next	priority	is	to	assess	damage	to	non-VSG	

property.	The	on-scene	responder	should	then	secure	and	document	the	

accident	site,	notify	the	company	safety	officer	and	the	flight	operations	

supervisor.	
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ii. Accident	investigations	may	be	carried	out	in	the	field,	by	analysis	of	

flight	telemetry,	interviewing	the	witnesses	or	any	combination	of	the	

above.	It	is	crucial	for	the	PIC	to	secure	and	evidence	(including	flight	

telemetry,	pre-flight	worksheets	and	any	other	documents)	for	proper	

investigation	into	the	incident.

iii. The	intent	of	accident	investigations	is	not	to	assess	blame	but	rather	to	

determine	the	contributing	factors	and	make	changes	to	policies	and

procedures,	training	or	operations	to	mitigate	the	risk	of	these	types	of	

incidents	occurring	in	the	future.

iv. The	safety	officer	shall	be	responsible	for	completing	a	detailed	incident	

report	for	any	Class	B	or	higher	incident	(refer	to	VSG	Incident	

Classification	System)	and	shall	decide	if	immediate	action	is	required	to	

mitigate	future	risks.	If	immediate	attention	is	required,	a	special	meeting	

of	the	safety	committee	may	be	called.	If	not	required,	the	report	shall	be	

included	in	the	quarterly	safety	report.
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3. Safety	Promotion

a. VSG,	its	officers,	management	and	shareholders	all	deem	safety	to	be	a	top	

priority	for	the	business.	Safety	is	important	to	the	company	and	its	managers	

not	only	because	of	the	high	value	VSG	places	on	its	personnel’s	safety	and	that	

of	other	people’s	property,	but	also	because	safe	operations	lead	to	lower	

maintenance	and	repair	costs,	higher	employee	morale	and	more	effective	

overall	operations,	as	well	as	the	safe	integration	of	unmanned	aircraft	into	the	

U.S.	NAS.	The	commitment	to	safety	by	the	senior	executive	management	team	

is	clear	and	actively	supported	at	all	times	through	clear	and	regular	

communication	and	training.

b. Company	safety	policy	is	communicated	quarterly in	a	formal	fashion,	and	

regularly	in	an	informal	fashion, by	the	company	safety	officer	as	well	as	during	

required	annual	safety	training.	The	annual	safety	training	is	a	requirement	for	

all	employees,	contractors	and	sub-contractors.	New	employees	receive	training	

on	the	company’s	safety	policies	and	procedures	within	30	days	of	hire,	

regardless	of	position	or	capacity.	Amendments to	company	safety	policies	are	

disseminated	to	all	personnel	immediately	after	publication.

c. The	regular	reports	to	the	senior	executive	management	team	of	safety	statistics	

and	issues	reaffirms	the	company’s	dedication	to	safe	operations.	The	tracking	of	

these	statistics	and	their	use	in	shaping	safety	policy	is	essential	to	VSG’s	

commitment	to	continued	safety	improvement.

d. The	safety	officer	and	other	members	of	the	safety	committee	(as	detailed	in	

3.b.)	shall	be	senior	personnel	in	the	company	who	have	demonstrated	the	

competency	required	to	fulfill	such	an	important	role.	The	safety	officer	shall	be	

a	senior	UAS	operator	with	a	minimum	of	500	hours	total	flight	time	and	a	strong	

history	of	safe	operations.	This	individual	will	be	required	to	complete	an	

accident	investigation	training	course	as	well	as	demonstrate	a	thorough	

understanding	of	VSG-SMS	and	VSG	safety	policy	and	procedures.	

e. The	safety	officer	is	responsible	for	making	budget	recommendations	to	the	

various	operations	directors	for	safety	related	issues.	The	company	is	committed	

to	allocating	appropriate	resources	to	safety	programs,	training	and	equipment.	

This	allocation	of	resources	includes	budgeting	time	off	for	“safety	days”	and	

additional	continuing	training	to	improve	and	reinforce	personnel	safety	

practices.
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f. The	safe	operation	of	unmanned	systems	is	a	great	concern	to	VSG.	The	

company	is	committed	to	cooperating	with	the	FAA,	other	governmental	entities	

and	private	industry	to	ensure	that	the	safety	best	practices	and	lessons	learned	

are	shared	and	implemented	whenever	possible	to	foster	a	safer	overall	air	

environment	and	to	build	and	maintain	the	reputation	of	unmanned	aircraft	

systems	and	the	aviators	who	operate	them.

This publication outlines the official VSG-SMS and is considered the source document for 

safety policy structure within Vision Services Group. In the event of any conflict between 

this document and FARs or CFRs, user should follow the FAR/CFR. Any questions or 

concerns related to this document or its contents should be addressed to the office of the 

Chief Executive Officer, Vision Services Group, LLC. –CAO: 06/01/2014