Part 2 of DRONELIFE’s Exclusive Series: The Human Edge: People, Perception, and the Future of Drone Operations
As commercial drone operations become more complex, regulators around the world are working to address new safety challenges. Much of that effort has focused on aircraft, airspace, and beyond visual line of sight (BVLOS) operations. Increasingly, however, attention is turning to another critical factor: the people operating these systems.
In Part Two of this exclusive DRONELIFE guest series, transportation and aviation experts Aloha Ley and Giovanni Carnaroli examine how aviation authorities in the United States, Europe, the United Kingdom, Australia, Japan, and ICAO are approaching human factors in drone operations, and what commercial operators can learn from those evolving standards. (See Part 1 here.)
The following article appears as submitted by the authors.
A Global Patchwork: How Regulators Are (and Aren’t) Addressing Human Factors
By Aloha Ley and H. Giovanni Carnaroli
The regulatory landscape for UAS human factors is, in a word, nascent. Aviation authorities worldwide have invested enormous effort in airspace integration, remote identification, BVLOS frameworks, and vehicle certification. The human being operating the aircraft has received considerably less formal attention, though 2025 and 2026 have brought notable movement.
United States: FAA and the Growing Data Mandate
The FAA’s approach to UAS human factors remains primarily embedded within Part 107’s general airman fitness standards, it’s the same “fit for flight” framework applied to crewed aviation, rather than in drone-specific physiological or cognitive requirements. However, FAA-sponsored research programs, including the 2025 Annual Report from the ASSURE UAS Center of Excellence, are pushing toward more data-driven insight into how operator behavior and workload patterns affect safety outcomes in the National Airspace System. That report, covering November 2024 through December 2025, analyzed UAS traffic patterns, regulatory compliance, and collision risk with an unprecedented combination of detection and surveillance tools, and explicitly flagged “areas needing continued attention,” including operations near heliports where human decision timing is most critical.
The FAA Civil Aerospace Medical Institute (CAMI) has historically been the most rigorous domestic source of applied human factors research for aviation. As commercial UAS operations scale, CAMI’s cognitive load and aeromedical research methodologies are increasingly being applied to remote pilot contexts, particularly around fatigue thresholds and attention management in extended BVLOS operations, which remain a frontier for both technology and human performance standards.
Europe: EASA, SORA, and the Human in the Loop
The European Union Aviation Safety Agency has been more explicit in building human-factors considerations into its operational risk frameworks. EASA’s June 2026 revision of its Easy Access Rules for Unmanned Aircraft Systems incorporates the SORA 2.5 package (the Specific Operations Risk Assessment methodology developed by JARUS), which requires operators to conduct structured risk assessments that, in principle, account for operator competency and operational context, including workload and environmental conditions.
EASA’s Operational Safety Objectives (OSOs) within SORA specifically address “Remote Crew Training and Competency” and “Remote Crew Conditions,” creating at least a regulatory skeleton on which human factors requirements can be built. The challenge is enforcement and standardization: SORA is a risk assessment tool, not a prescriptive human performance standard. What constitutes adequate operator fitness remains largely at the discretion of member states and individual operators.
United Kingdom: The IMSAFE Framework in Practice
The UK Civil Aviation Authority has taken a more practitioner-oriented approach, widely promoting the IMSAFE checklist — originally a manned aviation pre-flight self-assessment tool — as a standard reference for drone operators across all operational categories. IMSAFE evaluates: Illness, Medication, Stress, Alcohol, Fatigue, and Eating/Hydration. UK drone safety guidance explicitly states that fatigue impairs cognitive function, reaction time, decision-making, and situational awareness, and that “pilots who are fatigued should not operate.” It is a blunt but effective starting point for a culture shift that the broader industry has been slow to embrace.
Asia-Pacific: Emerging Standards, Accelerating Complexity
Australia’s Civil Aviation Safety Authority (CASA) and New Zealand’s CAA have published manned aviation fatigue guidelines that serve as reference frameworks for drone operators managing multi-day commercial deployments, particularly relevant in the agricultural mapping and infrastructure inspection sectors where consecutive days of intensive flying are common. Japan’s Ministry of Land, Infrastructure, Transport and Tourism (MLIT) continues to develop UAS-specific guidance as Level 4 autonomous operations (flights over people without visual observers) expand. As the Asia-Pacific region scales its commercial drone ecosystem, the absence of standardized human-factors requirements is emerging as a material safety gap.
ICAO: Setting the Global Floor
The International Civil Aviation Organization has been working to establish baseline human-factors guidance for RPAS operations that member states can adapt. ICAO’s efforts have focused on integrating UAS operator requirements into the broader framework of Annex 1 (Personnel Licensing) and Annex 19 (Safety Management), including Fatigue Risk Management Systems (FRMS). The challenge is that ICAO standards are non-binding, and the diversity of UAS platforms (from 250-gram consumer craft to heavy-lift commercial systems) makes prescriptive global standards exceptionally difficult to define.
Regulatory Human-Factors Comparison: Key Jurisdictions
| Jurisdiction | Primary Authority | Human Factors / Fatigue Framework | Drone-Specific Standards |
| United States | FAA (Part 107) | General airman fitness standards; CAMI research programs; FRMS encouraged for complex ops | Developing; ASSURE research informing future rulemaking |
| European Union | EASA / SORA 2.5 | OSOs address crew training, competency, and conditions within risk assessments | Moderate; operator-led SORA risk assessment includes human factors elements |
| United Kingdom | UK CAA | IMSAFE checklist promoted; fatigue guidance explicit for commercial ops | Guidance-based; Specific Category ops expected to address fatigue |
| Australia | CASA | Manned aviation FRMS guidelines adapted for drone multi-day deployments | Reference frameworks available; prescriptive rules still maturing |
| Japan | MLIT | Developing; Level 4 autonomous ops driving new human-machine interface standards | Early stage; significant expansion expected 2026-2028 |
| Global (ICAO) | ICAO Annex 19 | FRMS integration into Safety Management Systems; non-binding guidance for member states | Framework only; national implementation varies widely |
Sources: FAA ASSURE Report 2025; EASA EAR for UAS June 2026; UK CAA drone safety guidance; CASA documentation; ICAO Annex 19.
Lessons from the Field: What Military UAS Got Right — and What It Got Wrong
The commercial drone industry stands on the shoulders of military UAS operations that, for decades, grappled with exactly the human-factors challenges that civilian operators are now encountering at scale. The lessons are instructive, and cautionary.
Early U.S. military research on platforms like the MQ-1 Predator and MQ-9 Reaper identified a specific constellation of cognitive requirements for effective UAS operators: rapid and accurate information processing, the ability to divide attention across multiple simultaneous inputs, strong visual acuity and spatial perception, robust working memory, pattern-recognition under uncertainty, and the motivational and moral resilience to operate in high-consequence environments remotely. These findings, developed by researchers including Dr. Wayne Chappelle of the USAF School of Aerospace Medicine, established that the “right stuff” for drone pilots was distinct from but no less demanding than that of manned aircraft pilots — simply differently configured.
The military also learned, expensively, that human factors do not diminish with experience. High operator tempo, multiple missions per day, extended shift lengths, and the psychological dissonance of conducting lethal operations from an air-conditioned trailer, produced fatigue-related performance degradation that technical training alone could not address. The response, over time, was the adaptation of Crew Resource Management (CRM) principles, originally developed for multi-crew commercial aviation — to single-operator and small-team UAS environments.
“The most dangerous assumption in drone operations is that removing the pilot from the aircraft removes the human risk. It doesn’t. It relocates it.”
CRM for One: Adapting Crew Resource Management to Single-Operator UAS
Crew Resource Management (CRM) is the discipline of optimizing how crews use all available resources, including information, equipment, and people to ensure safe and effective operations. In commercial aviation, CRM is mandatory training for cockpit crews. For drone operators, particularly the majority who operate as single-person crews (NASA ASRS data indicates 58% of UAS reporters operate as single-person crews), the challenge is adapting CRM principles to an environment where there is no co-pilot to catch your errors, no flight engineer to monitor your systems, and no shared fate to keep everyone in the loop.
Forward-thinking UAS training programs are beginning to address this by incorporating structured pre-flight briefing protocols, mission risk assessments, defined task priorities, and go/no-go decision frameworks that effectively replicate the error-checking function of a two-person crew within a single operator’s cognitive workflow. The checklist is the CRM proxy. Used rigorously, it externalizes cognitive load by offloading sequential verification tasks from working memory to a physical or digital document, preserving mental bandwidth for dynamic in-flight decision-making.
Coming Next: Building Safer Drone Operations
Regulations are only one piece of the puzzle. In the final installment of The Human Edge, Ley and Carnaroli examine how enterprise operators are managing fatigue across large drone fleets, how artificial intelligence is helping reduce cognitive workload, and the practical tools organizations can use today to improve safety before regulations require them. See Part 1 of the series here.

Aloha Ley is a nationally recognized transportation leader, founder of eNoLux, and creator of the Syntara Path Architecture — a human-centered systems philosophy for moving individuals and organizations from fragmentation to synchronization. With more than 30 years of service across the U.S. Department of Transportation, including roles as Chief of Staff, Senior Advisor, and Director of Safety at the FAA, FTA, and Office of the Secretary, she has shaped national aviation safety policy, Safety Management Systems (SMS) standards, and public-sector innovation. Aloha’s thought leadership explores the intersection of AAM, SMS, safety culture, human factors, human dignity, counter human trafficking, and next-generation mobility systems. LinkedIn: www.linkedin.com/in/aloha-ley

H. Giovanni Carnaroli is a nationally recognized transportation technology executive and former Deputy Chief Information Officer (CIO) of the FAA, with more than 30 years of federal leadership spanning digital transformation, cybersecurity, and advanced aviation systems. A licensed commercial airplane and helicopter pilot (single- and multi-engine, land and sea, instrument) and FAA Part 107 UAS pilot, Giovanni currently works in Airworthiness, bringing rare operational depth to his strategic perspectives on drones, AAM, and low-altitude systems.
LinkedIn: www.linkedin.com/in/giovanni-carnaroli
The Human Edge is a DRONELIFE exclusive series. All statistics and research cited reflect findings available as of July 2026. DRONELIFE does not make or receive payment for guest posts.


Miriam McNabb is the Editor-in-Chief of DRONELIFE and CEO of JobForDrones, a professional drone services marketplace, and a fascinated observer of the emerging drone industry and the regulatory environment for drones. Miriam has penned over 3,000 articles focused on the commercial drone space and is an international speaker and recognized figure in the industry. Miriam has a degree from the University of Chicago and over 20 years of experience in high tech sales and marketing for new technologies.
For drone industry consulting or writing, Email Miriam.
TWITTER:@spaldingbarker
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