GM1 21.B.125(f) and 21.B.225(f) Findings and corrective actions; observations

CAA ORS9 Decision No. 40

DIFFERENCE BETWEEN A ‘LEVEL 2 FINDING’ AND AN ‘OBSERVATION’

  1. ‘Findings’ are issued for non-compliance with the regulation, with the organisation’s procedures and manuals, or with the certificate including the terms of approval, whereas ‘observations’ may be issued to an organisation that remains compliant with the regulation,while additional input to the organisation may be considered for continuous improvement (see points (1), (2), and (3) of point 21.B.125(f)).

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

  2. Examples to help differentiate between a ‘level 2 finding’ and an ‘observation’ are provided below, based on the requirements for the control and calibration of tools in accordance with point 21.A.139(d)(2)(vii).

Example of a ‘level 2 finding’:

The organisation could not demonstrate compliance with some elements of point 21.A.145(a) regarding the control register of the tools and equipment, as evidenced by the fact that:

  1. some sampled tools that are physically available in the tool store were missing in the tool control register that is managed by the organisation; or

  2. one tool was not correctly identified (e.g. incorrect part number or serial number) in the tool control register.

Examples of ‘observations’:

  1. Accumulation of tools in the tool store, which have not been yet sent for calibration. This situation may have some consequences regarding the availability of tools and the operational capabilities during a peak of activities (ineffectiveness of the process).

  2. The process for managing the tool control register through the dedicated software is not detailed enough (potential to cause a ‘level 2 finding’).

  3. The colour of the ‘unserviceable’ tag of the tools may generate some confusion. The organisation should consider changing the colour of that unserviceable tag to better alert its staff to the particular status of the unserviceable tools (potential improvement).