What is the fundamental difference between a 'level 2 finding' and an 'observation' under GM1 145.B.350(f)?

A 'finding' is issued for non-compliance with the Regulation, whereas an 'observation' may be issued to an organisation that remains compliant with the Regulation but where additional inputs could be considered for continuous improvement.

Give an example of a 'level 2 finding' related to the control register of tools under point 145.A.40(b).

An example is when the organisation could not demonstrate compliance with some elements of 145.A.40(b) regarding the control register, as evidenced by some sampled tools physically available in the tools store being missing from the register, or one tool not being correctly identified (e.g., incorrect P/N, S/N) in the register.

Provide an example of an 'observation' related to tool calibration that could affect operational capabilities.

An example is the accumulation of tools in the store not yet sent for calibration, which could generate consequences on the availability of tools and operational capabilities during a peak of activities, indicating ineffectiveness of the process.

What 'observation' is given about the colour of the 'unserviceable' tag for tools?

The colour of the 'unserviceable' tag could generate confusion, and the organisation should consider changing the colour to better alert staff on the particular status of unserviceable tools, as a potential improvement.

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

Q: Under what circumstances may the competent authority issue a 'level 2 finding' related to the 'observations' process?

The competent authority may decide to issue a 'level 2 finding' when the 'observations' process is not managed correctly or is overlooked.

Q: What is an example of an 'observation' regarding the tools control register software that could potentially lead to a level 2 finding?

An example is when the process to manage the tools control register through the dedicated software is not detailed enough, which has the potential to cause a level 2 finding.

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

ED Decision 2022/011/R

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

(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).

Details

Source-Title: GM1 145.B.350(f) Findings and corrective actions, observations View latest amendments

Erulesid: ERULES-1963177438-20122 Compare versions

Domain: Continuing airworthiness

Aircraftuse: Used by licensed air carrier (LAC), Used by private operator or for limited operations

Aircraftcategory: Complex motor-powered aircraft (CMPA), Non-complex motor-powered aircraft (non-CMPA)

Applicabilitydate: 2 December, 2022

Entryintoforcedate: 11 May, 2022

Registrystate: EU-registered, Non-EU registered

Regulatorysource: ED Decision 2022/011/R Navigate

Regulatorysubject: Part-145

Typeofcontent: GM to IR (Guidance material to implementing rule)

Parentir: 145.B.350 Findings and corrective actions, observations

Origin: EASA

Category: EAR