Give an example of a 'level 2 finding' related to the control and calibration of tools under point 21.A.139(b)(1)(vii).

An example is when the organisation could not demonstrate compliance with some elements of point 21.A.145(a) regarding the control register of tools and equipment, as evidenced by some sampled tools physically available in the tool store being missing from the tool control register, or one tool not being correctly identified (e.g., incorrect part number or serial number) in the register.

Provide an example of an 'observation' related to tool calibration that does not constitute non-compliance.

An example is the accumulation of tools in the tool store that have not yet been sent for calibration. This situation may have consequences regarding tool availability and operational capabilities during peak activities, indicating ineffectiveness of the process.

What is an example of an 'observation' that could potentially lead to a 'level 2 finding' if not addressed?

The process for managing the tool control register through dedicated software is not detailed enough, which has the potential to cause a 'level 2 finding'.

According to the guidance, what is the relationship between 'observations' and compliance with the regulation?

Observations may be issued to an organisation that remains compliant with the regulation, while additional input may be considered for continuous improvement. This is in contrast to findings, which are issued for non-compliance.

What are the two specific evidence examples that demonstrate non-compliance with point 21.A.145(a) regarding the tool control register?

The two examples are: (a) some sampled tools physically available in the tool store were missing in the tool control register managed by the organisation; or (b) one tool was not correctly identified (e.g., incorrect part number or serial number) in the tool control register.

In the context of tool control, what does the example about the accumulation of tools not yet sent for calibration illustrate?

It illustrates an 'observation' where the organisation remains compliant but the process is ineffective, potentially affecting tool availability and operational capabilities during peak activities.

GM1 21.B.125(e) and 21.B.225(e) Findings and corrective actions

Q: What is the fundamental difference between a 'level 2 finding' and an 'observation' under point 21.B.125(e)?

A 'level 2 finding' is issued for non-compliance with the regulation, the organisation's procedures and manuals, or the certificate including the terms of approval. An 'observation' may be issued to an organisation that remains compliant with the regulation, while additional input may be considered for continuous improvement.

Navigate / EASA

Ask question Discover more Add to collection

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

ED Decision 2023/014/R

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

(a) ‘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(e)).

The competent authority may decide to issue a ‘level 2 finding’ when the ‘observations’ process is not managed correctly or is overlooked (see points 21.A.125B(c) and 21.A.158(c)).

(b) 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(b)(1)(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:

(a) 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

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

Examples of ‘observations’:

(a) 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).

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

(c) 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).

Details

Source-Title: GM1 21.B.125(e) and 21.B.225(e) Findings and corrective actions, observations View latest amendments

Erulesid: ERULES-1963177438-20333 Compare versions

Domain: Initial airworthiness

Amendedby: Issue 2, Amendment 16

Applicabilitydate: 21 October, 2023

Entryintoforcedate: 21 October, 2023

Regulatorysource: ED Decision 2023/014/R Navigate

Regulatorysubject: Part-21

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

Parentir: 21.B.125 Findings and corrective actions, observations

Origin: EASA

Category: EAR