Safety Center · Close Calls · NASA ASRS
ACN 2361807What the Reporter Described
Report 1 | Narrative: During a review of my UAS records; I discovered that I had inadvertently conducted commercial small UAS operations while my recurrent training was overdue by approximately two months. At the time of the operations; I believed my Remote Pilot recurrent training status was current and that I had a reminder system in place to alert me before expiration. After reviewing my records; I realized the reminder had either failed or was not properly configured; which caused the lapse to go unnoticed.The flights conducted during this period were completed normally and safely; with no injury; property damage; airspace conflict; loss of control; or known hazard created.
Once I discovered the issue; I immediately stopped conducting commercial UAS operations until the recurrent training requirement was corrected. I then completed the required recurrent course and updated my records.The primary contributing factor was overreliance on a single reminder system instead of actively verifying pilot currency before each commercial UAS operation. As a corrective action; a new UAS credential and training verification SOP was introduced.
This SOP requires confirmation of Remote Pilot currency before accepting or conducting any commercial UAS mission; periodic review of pilot credentials; redundant calendar reminders for recurrent training deadlines; and documentation of credential status in the mission file.Additionally; as an extra safety and compliance measure; we will complete the FAA ALC-515 recurrent training course annually; even if the regulatory recurrent training interval allows a longer period.
This annual review will help ensure continued familiarity with current Part 107 requirements; operating limitations; airspace procedures; and UAS safety responsibilities.This issue was unintentional and was corrected immediately upon discovery. The lesson learned is that currency requirements must be verified through a formal process; rather than relying only on memory or a single automated reminder.
Report 1 | Synopsis: Part 107 UAS pilot reported inadvertently flying without having met Remote Pilot recurrent training requirements.