EASA Quality Assurance Compliance Auditing - Understanding Findings vs. Observations

Let’s first consider a fundamental difference between ISO 9001-2015 and EASA Regulatory Compliance Audits.  In the ISO world one reason to perform internal audits is to support the continual improvement of the organisation system. Conversely when in EASA compliance audit is carried out it is essentially to support the identification of a non-conformance.

Let’s also consider that the criteria by which we audit is called our audit “standard” Such a standard may in fact be a regulatory requirement driven directly from the Implementing Rule IR or the Acceptable Means of Compliance (AMC).

It may also be a requirement based on the need for compliance with internal documentation, for example any of the following - OPS Manual Part A, EASA Part 145 Maintenance Organisation Exposition (MOE), EASA Part M Continuous Airworthiness Management Exposition (CAMO) or EASA Part 147 Maintenance Training Organisation Exposition (MTOE).  All of the aforementioned documents contain detailed procedures which need to be complied with by the organisation.

Considering Audit Observations 

When we consider Observations during an EASA Audit we should understand that in respect of its own auditors EASA does not permit observations, simplifying the process into a choice between level 1 and level 2.

Essentially EASA does not make observations – why?  The answer is that the focus is on compliance and if compliance is demonstrated this is the point to stop. It is not correct to tell a person who is managing a business area how to do the job in a better way. (even it could be resented)

One description of an observation would be as follows:

An Observation is a statement of fact (or opinion) made during an audit where the audit subject is consider compliant with the “standard” which may be further substantiated by objective evidence and/or with additional auditor’s informational comments, such observation being based on an assessment of either a specific process or situation in relation to the quality system under audit. 

So can we make observations?

The short answer is YES!

However now that we know that EASA does not support observations we should be careful regarding the nature of any observations which are made.

Observations should never be considered a finding.  

Observations should never proscribe an activity we “should” be done rather to identify an activity or task which “may” be done.

The important thing is to ensure a diplomatic engagement and to be careful how we write our observations.

In Summary 

Never forget that as quality auditors it is our job to tell people what is wrong not to tell them what to do. Moreover it is incumbent on us to ensure the auditee not only agrees the issue but knows from where is the requirement for the particular requirement or standard.

Sofema Aviation Services provides more than 30 EASA compliant Quality Audit courses both classroom and online for details please see www.easaonline.com, www.sassofia.com or email office@sassofia.com & easaonline@sassofia.com.