22 Degrees South Aviation
Drone Consulting and Auditing
This can be a tough nut to crack. For this document, we seriously recommend that you use a consultant that knows what they are doing. Else, you might lose a lot of time in your application because the CAA will just send it back if it is wrong, every time.
If you are planning to do this on your own, you need to understand that the ROM is there to provide clear procedures to the CAA of how you plan to do drone operations. It is not supposed to be a document that copies the text of Part 101!
Part 101.04.4(2)(b) requires an operator to “ensure that each observer has completed the training prescribed by the operator and as approved by the Director in their operations manual.”
It means that your ROM should contain clear procedures in a training program for Observers.
It is not sufficient to just have text in the ROM that states for instance: “We at ABC drone company ensure that our observers are trained before they are used”.