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