GM1 145.B.350(f) Findings and corrective actions; observations

CAA ORS9 Decision No. 38

DIFFERENCE BETWEEN ‘LEVEL 2 FINDING’ AND ‘OBSERVATION’

(a) ‘Findings’ are issued for non-compliance with the Regulation, whereas ‘observations’ may be issued to an organisation remaining compliant with the Regulation while additional inputs for the organisation could be considered for continuous improvement.

However, the CAA may decide to issue a ‘level 2’ finding when the ‘observations’ process is not managed correctly or overlooked by the organisation.

(b) Examples to help differentiate between a ‘level 2 finding’ and an ‘observation’ are provided below, based on the provisions for the control and calibration of tools in accordance with point 145.A.40(b).

Example of a ‘level 2 finding’

- The organisation could not demonstrate compliance with some elements of 145.A.40(b) regarding the control register of the tools, equipment and particularly test equipment process as evidenced by:

(1) the fact that some sampled tools physically available in the tools store were missing in the tools control register managed by the organisation;

(2) The fact that one tool has not been correctly identified (e.g. incorrect P/N, S/N) in the tools control register.

Examples of ‘observations’

- Accumulation of tools in the store not sent yet for calibration. This situation could generate some consequences on the availability of tools and operational capabilities during a peak of activities (ineffectiveness of the process).

- The process to manage the tools control register through the dedicated software is not detailed enough (potential to cause a level 2 finding).

- The colour of the ‘unserviceable’ tag of the tools could generate some confusion. The organisation should consider changing the colour of this unserviceable tag to better alert the staff on the particular status of the unserviceable tools (potential improvement).