Airworthiness finding level and safety severity guidance

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

This page provides guidance for airworthiness approved organisations with regard to what would be a potential level 1 finding. Also providing transparency about the use of a Civil Aviation Authority (CAA) Airworthiness classification system to assist in differentiating findings regarding 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 and so on.

The lists below of possible Level 1 findings against each approval type is in line with the UK CAA procedures and guidance. This is not an exhaustive list, there may be other circumstances which warrant a level 1 classification.

Part 145 & Part-CAO maintenance approval

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 the Civil Aviation Authority (CAA) 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).

Close Part 145 & Part-CAO maintenance approval

Part 147 Maintenance training approval

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).

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

Close Part 147 Maintenance training approval

Part M Subpart G/Part-CAMO / Part-CAO Continuing Airworthiness Management approval

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 an un-approved mod, un-recorded defects, an un-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 / Management 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).

Close Part M Subpart G/Part-CAMO / Part-CAO Continuing Airworthiness Management approval

Part 21 Subpart G production approval

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).

Close Part 21 Subpart G production approval

Safety severity classification

The classification of findings allows the Civil Aviation Authority (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 used, 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.