Sofema Online (SOL) Considers the key difference between Level 1 and Level 2 Findings – Also to consider the role of observations

Understanding the distinction between Level 1 and Level 2 findings is critical for maintaining regulatory compliance and ensuring the safety and integrity of aviation operations.

• While EASA’s framework is focused on clear, actionable findings, organizations should take the initiative to establish strong internal quality systems that proactively identify and address observations before they escalate into formal non-compliances.

• By fostering a culture of continuous improvement—where observations, lessons learned, and best practices are integrated into daily operations—organizations can strengthen resilience, minimize risk, and consistently exceed regulatory expectations.

• EASA, through its regulatory framework (e.g., Part 145, Part CAMO, Part 21, etc.), defines a two-tier classification system for non-conformities identified during audits:

Level 1 Finding:

A serious non-compliance that has an immediate impact on safety or constitutes a significant breach of regulatory requirements. These are considered critical and must be rectified immediately or within a very short timeframe. Common examples include:

• Failure to maintain an effective Safety Management System (SMS)

• Use of unapproved data for maintenance

• Certification of airworthiness without required inspections

Implication: A Level 1 finding jeopardizes the validity of the approval and can lead to suspension, revocation, or restriction of privileges if not addressed urgently.

Level 2 Finding:

A less severe non-conformance that does not pose an immediate safety threat but still represents a failure to comply with regulatory standards. Examples include:

• Incomplete documentation processes

• Minor procedural gaps in training programs

• Failure to fully implement a quality assurance procedure

Implication: Level 2 findings typically require corrective action within a defined timeline (often 3 months), but they do not immediately threaten the approval status.

Why Do Regulators Not Issue "Observations"?

Unlike internal audits or some industry practices (e.g., ISO 9001), EASA does not formally issue "observations" in their audit reports. Here’s why:

• Regulatory Clarity:
EASA’s audit reports focus exclusively on compliance or non-compliance. A finding either constitutes a regulatory breach (Level 1 or 2) or it doesn’t. Introducing a third category like “observation” could create ambiguity about whether action is required.

• No Legal Basis for "Observations":
EASA audits are regulatory assessments, not advisory reviews. Observations are typically informal suggestions for improvement, which regulators are not mandated (or authorized) to provide. Their role is to ensure compliance, not offer best-practice recommendations.

• Accountability and Consistency:
By sticking strictly to findings, regulators ensure consistency across audits. Each non-compliance is clearly defined and must be corrected, while areas without findings are implicitly compliant.

Best Practice: Internal Observations

While EASA does not issue observations, organizations themselves—through internal audits or quality systems—should capture observations as part of continuous improvement. Observations in this context can:

• Highlight potential weaknesses before they escalate into findings

• Encourage proactive risk management

• Support a robust safety culture

Final Thoughts

EASA audits are about compliance vs. non-compliance, with findings classified as Level 1 or Level 2 based on severity and impact.
Observations are not part of EASA's formal audit output—they are left to organizations’ own quality systems to promote best practices and enhancements.
A strong internal audit program, which includes observations, can help organizations go beyond compliance and strive for excellence.

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