Medical Drones Saga In Ghana – An Aviation Safety Risk Perspective And Way Forward

On 31 May 2016, I penned an article on drones in Ghana titled: Integrating-Unmanned-Aircraft-System-(UAS) into Ghana’s Airspace (Modern Ghana, 2016) and here was a direct quote from that article-

“There has been the perennial challenge of getting essential vaccines and drugs to some remote areas in Ghana due to non-navigable water-bodies and un-motorable roads and that may be an area where UAS may suffice. The Community-based Health Planning and Services (CHPS) initiative, a national policy promulgated encouraging District Health Management Teams throughout Ghana to take steps toward instituting community-based health care, could benefit tremendously from the use of UAS in the distribution of drugs, vaccines, tissue and blood samples and health educational materials”

It was therefore interesting to hear that the Ghana government through the Ministry of Health and Zipline have signed an agreement to implement this initiative suggested in 2016. The move by government to deliver medical supplies with these UAS (aka drones) has received mixed public response, with several people questioning the cost the country may have to incur. As stated in my previous article, the regulatory oversight for flight operations in Ghana will fall squarely within the gambit of the Ghana Civil Aviation Authority (GCAA). The Director-general of GCAA is on record to have stated that “Now we have big players like Zipline coming in, they are working with the Civil Aviation Authority. We visited their premises, we are on a joint committee to take them through certification of the drones they will use for their operations,” (Ghana web, 2018). The Ghana Health Service (GHS) has also described the drone delivery of medical supplies as the most efficient and cost-effective means of reaching under-served areas in the country.

From a flight operations and safety management perspective, there are some concerns that needs to be addressed before the entire project will be deemed safe in the airspace of Ghana. The first and biggest challenge of these drone operations in suggested operational areas such as Suhum is the risk of collision with manned aircraft. Suhum, lies in a major airway (descent path for flights) from Kumasi to Accra and there is the potential for collisions with manned aircraft. I can surmise that these drones may not have Automated-Dependent Surveillance-Broadcast (ADS-B) or transponder capabilities to alert or warn pilots of manned aircraft on collision course. Since these Zipline drones are potentially going to operate Beyond Visual Line of Sight (BVLOS) over populated areas and un-populated areas, there should be standardized procedures and guidance on telemetry coverage, lost -link communication, detect-and -avoid etc.

Most of these drone operations may warrant Very High Frequency (VHF) contact with Air Traffic Services of the various airports or aerodromes within that area to help sequence and provide separation services for manned aircraft and from these drones if they inadvertently fly in controlled airspace. Unfortunately, because VHF communication is line of sight and can be potentially attenuated by high terrain and other land features, communication on the ground between the drone pilot and Air Traffic Controllers can be impeded.

A realistic example may be the rotary-wing operations of the Ghana Airforce and some mining companies who have helicopters that sometimes fly at low altitudes (Sometimes below 500 feet above ground level) to remote areas which may be out of VHF range or ATS control. The Ghana Airforce conducts medical evacuations, national security support activities, and passenger transport for government officials using these helicopters. The mining company helicopters also transport gold bullion from mining areas located sometimes within the operational areas of these drones. They may be susceptible to risk of collision with these drones. There are also high-tension pylons and communication towers that may pose collision hazards for these drones and in the case of a collision with high tension cables on these power pylons, power supply to an entire community may be interrupted not discounting the risk of fire.

Does the GCAA have historical or industry -based safety data on collisions between drones and manned aircraft in Ghana or have they done comprehensive safety risk analysis of the integration of drones into our airspace? Research on the damage risk posed to manned aircraft by UAS has been clearly established (Gregg, 2018) and suggests that reported encounters between manned aircraft and unmanned aircraft worldwide is on the rise. The study suggests that that all of the most dangerous encounters (those close enough to require evasive maneuvers on the part of manned aircraft) occurred at altitudes greater than 400’ AGL, or within 5 miles of an airport.

The University of Dayton Research Institute has been conducting several trials to determine the damage a drone really poses to an aircraft. Their findings show that drone strikes can be much worse than bird strikes as the mass of the drone mostly stays in tact during the impact leading to greater damage. Safety risk posed by inadvertent collision of these drones with high rise fuel farm tanks and chemical facilities cannot be under-estimated and could potentially be catastrophic with loss of human lives and assets.

Will GCAA as part of the certification process, ensure that there a mobile command vehicles and observers to ensure safe telemetry between drones and human operators? What are the modalities to ensure that errant drones don’t collide with buildings and high-rise properties as they traverse their delivery circuits? What will be the operational environment under which these drones will operate (time of day, visibility minima, maximum range, maximum altitudes, speed and finally frequency of simultaneous deployments)? There should be safety assurance criteria on loss of telemetry data and detect -and -avoid strategies for these drone operations.

The use of drones for these health -related operations may have benefits but should not be the only end to a means. It should rather supplement the existing supply chain infrastructure for medical logistics. What is the essence of using drones to supply critical medical necessities if the receiving centers don’t have the requisite infrastructure to safely store these medications and vaccines? A holistic approach of ensuring that foundational health infrastructures are consolidated are the best and then these auxiliary methods of using drones can be deployed in times of emergencies and needs basis.

There should be tentative agreement between the GCAA and the operators on performance standards for Detect and Avoid and Command links, the level of technical integrity drones will need to demonstrate, how these platforms will be certified. There are requirements for pilot qualifications and equipment standards outlined in the GCAA Directives Part 28 (2016) and hopefully the specifications will be adhered to. Pilots of these drones must have the same basic responsibilities as pilots of manned aircraft for the operation of the drone in accordance with the rules of the air, laws, regulations and procedures of Ghana.

It will also be prudent for the GCAA ensure that Zipline conduct their operations on a “proving basis” for about 6 months in which relevant operational and safety data will be collected and analyzed to ensure that safety performance metrics established are met. Continuous improvement strategies and monitoring can then be done after the proving period. The initial phase must be done in a “controlled setting” ensuring that risk involving collisions with manned and static infrastructure on the ground are assessed, effective controls implemented, and improvements made.

Kwasi Adjekum, Ph.D., CSP
Professor of Aviation and Aerospace Sciences
University of North Dakota School of Aerospace Sciences

Relevant References:
Gregg, P. (2018) Risk in the Sky? https://udayton.edu/blogs/udri/18-09-13-risk-in-the-sky.php

Ghana Civil Aviation Directives Part 28
https://www.modernghana.com/news/695321/integrating-unmanned-aircraft-system-uas-into-ghanas-airs.html