General Introduction to Findings
An Audit finding is essentially a non-conformity with a particular standard by performing a visual assessment or to perform a specific measurement it is possible to provide a gap analysis which indicates an issue, which should be resolved to re-establish conformity.
When objections or defects are determined during an audit, the QM and the Business Area Owner / Nominate Person should agree upon corrective actions and/or procedure improvements.(where it can be demonstrated the finding is The decided corrective actions and/or procedure improvements are then to be conveyed to the AM.)
The following is the EASA interpretation of findings :
a) “Level 1 finding” is any non-compliance with EASA Regulations, which could lead to uncontrolled non-compliance’s with applicable airworthiness requirements and could affect the safety of the aircraft.
Level 1 findings are considered most serious and concern any significant non-compliance with EASA regulatory requirements in particular, where it is seen that such non conformities could lower the safety standard and hazards and seriously the flight safety.
b) “Level 2 finding” is any non-compliance with EASA Regulations which is not classified as level one.
Level 2 findings may still be seen to lower the safety standard and possibly hazard the flight safety or may be a non-compliance to the Organisational Procedures.
c) “Level 3 Observation” is any item where it has been identified, by objective evidence, to contain potential problems that could lead to non-compliance. (However to note that it is neither a Level 1 or Level 2 finding means that it does not meet the current criteria to identify it as a “finding”)
How to decide level 1, 2 or 3?
Simply to start at the top and consider whether what you have found MUST be fixed immediately either because of regulatory, contractual or safety requirements – if yes it is a Level 1 finding.
So everything else is now level 2, but how long to rectify? This is negotiable and depends on the seriousness of the issues – it must also be agreed – we should not impose findings rather to encourage the auditee to embrace the finding and to take ownership.
If we do not have any standard or requirement for our “issue” it cannot be a finding and we are typically looking at an observation.
How long is a Typical Period for the Resolution of a Finding?
The above mentioned levels of findings require rectifications by the responsible management personnel within the following time frame:
Level 1 finding immediately
Level 2 finding up to 3 months (depending on nature of finding)
Notification to the Regulatory Authority in regards of changes to the organisation’s activities / approval / location / personnel and whenever an audit finding shows existence of hazard for an aircraft managed (Level 1)
Note regarding findings received from the Regulatory Authority
After receipt of notification of findings of an audit of Regulatory Authority the organisation shall define a corrective action plan and demonstrate corrective action to the satisfaction of Regulatory Authority within a period agreed with Regulatory Authority .
Action will be taken by Regulatory Authority to suspend in whole or part the approval in case of failure to comply within the timescale granted by Regulatory Authority
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