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Airworthiness finding level and safety severity guidance

Regulation, policy and guidance for UK airworthiness approval holders

  • UK Airworthiness Approval holders provide services in accordance with Commission Regulation (EU) No 1321/2014 or 748/2012 implementing rules.

    This page provides guidance for airworthiness approved organisations with regard to what would be a potential level 1 finding. Also provides transparency with regard to the use of a CAA Airworthiness classification system to assist in differentiating findings with regard to their safety impact (whether it’s a level 1 or 2).

    Guidance

    Classifying Findings can be a challenge especially where the regulation does not provide any examples to support the making of a determination, in some situations a judgement is necessary. For instance, if there is no accountable manager available (one of the criteria) the CAA may need to investigate further to understand the underlying situation; such as, what are the related risks, are there mitigating measures in place bridging the gap until a manager will become available, etc.
    The list of possible Level 1’s is in line with EASA’s expectations. This is not an exhaustive list, there may be other circumstances which warrant a level 1 classification.

  • Part 145 & Part M Subpart F maintenance organisation

    Working outside scope of approval

    • Fabrication of primary structural elements without TCH approval or iaw approved data
    • Carrying out maintenance / mods / repairs to non-approved data
    • Systemic breakdown of calibration control
    • Systemic breakdown of maintenance standards
    • Knowingly releasing aircraft with incomplete / incorrect maintenance
    • Falsifying of work packs
    • Lack of Accountable Manager
    • Lack of Nominated Postholder (where no deputy is defined within exposition or where no suitable temporary arrangements can be approved in an interim basis)
    • Failure to respond to within the agreed timescales 
    • Denied access (after 2 written requests)
    • Repeat significant finding
    • Failure or ineffective Quality System (multiple significant findings across various areas of an organisation at medium or High safety severity indicating a breakdown of the control and/or monitoring of the organisation's compliance and adherence to its procedures and safety policies).

    Part 147 Maintenance training organisation

    • Non-adherence to approved examination procedures (consider remote / additional sites)
    • Significant non-compliance with the training process
    • Inadvertent / intentional exposure of the question data base (cheating)
    • Lack of process control of the Certificates of Recognition 
    • Lack of Accountable Manager
    • Lack of Nominated Postholder (where no deputy is defined within exposition or where no suitable temporary arrangements can be approved in an interim basis)
    • Failure to respond within the agreed timescales
    • Denied access (after 2 written requests)
    • Failure or ineffective Quality System (multiple significant findings across various areas of an organisation at medium or High safety severity indicating a breakdown of the control and/or monitoring of the organisation's compliance and adherence to its procedures and safety policies).

    Note:  failure to complete the rectification of any L1 finding within 3 days shall result in revocation, suspension or limitation [147.B.130(a)]

    Part M Subpart G CAMO

    • Working outside scope of approval
    • AD non-compliance (inadequate control / deliberate)
    • Significant AMP shortfalls
    • Mandatory tasks (CMR / AD / LLP)
    • Repair repeat inspections
    • ICA's for STC's
    • Inappropriate / lack of a reliability system
    • Insufficient / incompetent key personnel
    • Systemic breakdown of continuing airworthiness management
    • Inadequate maintenance planning & control (variations of CMR / AD / LLP tasks)
    • Operating aircraft with a; non-approved mod, un-recorded defects, a non-airworthy condition
    • Arranging maintenance to be carried out by unapproved organisation
    • Inappropriate management of significant repetitive defects
    • Any action intended to mislead the authority
    • Lack of Accountable Manager
    • Lack of Nominated Postholder (where no deputy is defined within exposition or where no suitable temporary arrangements can be approved in an interim basis)
    • Repeat denied access 
    • Failure to respond to within the agreed timescales
    • Repeat significant finding
    • Failure or ineffective Quality System (multiple significant findings across various areas of an organisation at medium or High safety severity indicating a breakdown of the control and/or monitoring of the organisation's compliance and adherence to its procedures and safety policies).

    Part 21 Subpart G production organisation

    • The organisation cannot demonstrate that an item is in conformity with approved design data and is safe to fly
    • Design data not available
    • Manufacturing processes not iaw approved data 
    • Incorrect / damaged tooling not iaw approved data

    The organisation is not adequate to support the approval or part thereof due to:

    • Lack of Accountable Manager
    • Lack of Nominated Postholder (where no deputy is defined within exposition or where no suitable temporary arrangements  can be approved in an interim basis)
    • Competence of staff
    • Escalation of level 2 findings
    • Failure to respond within the agreed timescales 
    • Denied access (after 1 written request)
    • Repeat significant finding
    • Failure or ineffective Quality System (multiple significant findings across various areas of an organisation at medium or High safety severity indicating a breakdown of the control and/or monitoring of the organisation's compliance and adherence to its procedures and safety policies).

    Safety severity classification

    The classification of findings allows the CAA to focus on those findings which affect safety, this then provides a basis which the time scales for a finding to be closed can be defined. For high safety severity findings time for closure will be typically less than 30 days but can be shorter depending on the safety impact.

    Safety severity Definition Example of safety classification
    A.3 Airworthiness Directives    		 Example of safety classification
    B.3 Mass and Balance (M&B) 
    High  The effectiveness of a safety barrier has been significantly reduced. (Level 1 or Level 2 finding with a significantly reduced response time)  Failure to comply with an Airworthiness Directive within its required timescales. An error on the weighing report or schedule that has an effect on the basic M&B index used, that could lead to the aircraft being operated beyond its M&B envelope. 
    Moderate  The effectiveness of a Safety Barrier has been potentially reduced.  Airworthiness Directive not evaluated and/or controlled (forecasted). But the compliance date has not been exceeded.  An error on the weighing report or schedule that has a minor effect on the basic M&B index iused, that could not lead to the aircraft being operated beyond its M&B envelope. 
    Low  No direct effect on safety  Airworthiness Directive complied with, but incorrectly recorded in the continuing airworthiness records.  An error (typo) on the weighing report or schedule that does not affect the basic M&B index used.

     

     

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