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145.A.95 defines the process for findings raised by the competent authority during audits, classifying them as Level 1 (significant non-compliance that lowers safety standards) or Level 2 (non-compliance that could lower safety standards), and requires the organisation to define and implement corrective action within specified timeframes.
What it means in practice
When the competent authority identifies non-compliance during an audit or inspection, it raises a finding. Findings are classified into two levels. A Level 1 finding indicates a significant non-compliance that lowers the safety standard and seriously hazards flight safety. Level 1 findings require immediate corrective action and may result in full or partial suspension of the approval. A Level 2 finding indicates a non-compliance that could lower the safety standard and could possibly hazard flight safety if not corrected.
The organisation must investigate the root cause of each finding, define appropriate corrective action, and implement it within the timeframe agreed with the competent authority. For Level 1 findings, immediate action is required, and the authority may limit or suspend the approval until the finding is resolved. For Level 2 findings, the corrective action period is determined by the nature of the finding but must not exceed a period defined by the competent authority.
Key requirements
The organisation must have a procedure for receiving, investigating, and responding to findings from the competent authority. Root cause analysis must be performed for all findings. Corrective action must address both the immediate non-compliance and the underlying root cause to prevent recurrence. The organisation must provide evidence to the competent authority that corrective actions have been implemented and are effective.
Failure to address findings within the required timeframe, or failure to implement adequate corrective action, may result in escalation of a Level 2 finding to Level 1, or in enforcement action including suspension or revocation of the approval.
Common compliance gaps
The most common gap is corrective actions that address the symptom rather than the root cause, leading to repeat findings on the same topic. Organisations sometimes submit corrective action plans that consist only of retraining or issuing reminders, without investigating why the non-compliance occurred in the first place. Another frequent issue is failing to close corrective actions within the agreed timeframe, which can lead to escalation and enforcement action.
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