Finding register
Closing STC finding-register items marked closed without closure evidence
This closure work cleans up an STC finding register where items are recorded as closed without evidence that actually answers what was raised. It is run for the modifier when the register shows a finding resolved but the closure rationale, the corrected data, or the reviewer disposition behind it is missing. The work reopens each questionable closure, attaches the evidence that answers the original issue, records the disposition, and assigns a residual-action owner where the finding is only partly resolved. You receive a re-audited finding register, an evidence request list for the hollow closures, and a disposition package where every finding is genuinely closed or explicitly carried.
When this review is needed
- A finding is marked closed but nothing on file answers what it raised.
- Closures were entered in a rush before a milestone without attaching the evidence.
- A reviewer reopened a finding the register showed as resolved.
- A finding was partly addressed and closed as if fully resolved.
The problem
A finding register is the record of every issue raised against the program and how it was answered, and its credibility rests on each closure being backed by evidence. Closures decay when they are entered under milestone pressure: someone marks the finding resolved intending to attach the rationale later, the deadline passes, and the closure stands with nothing behind it. A register full of closed items can be hollow, and because it is the document a reviewer uses to confirm the program dispositioned its issues, a hollow closure is exactly what reopens under scrutiny.
What gets reviewed
- Each finding recorded as closed checked for evidence that answers the original issue
- Closure evidence attached to findings that lacked it
- The reviewer or self-disposition recorded for each closed finding
- Partly resolved findings reopened with a residual-action owner
- The register reconciled so every closure reflects real resolution
What gets validated
- Each closed finding has evidence that directly answers what it raised
- The closure evidence addresses the finding as stated, not a narrower version
- A disposition is recorded for every closed item
- Partly resolved findings carry a residual action and an owner rather than a full-closure mark
- No finding is closed on a status change with nothing attached
Evidence normally required
- The finding register with its current closure states
- The corrected data, rationale, or analysis behind each claimed closure
- Reviewer correspondence and disposition records
- The compliance data the findings were raised against
- Owners available to take residual actions on partial closures
Common discrepancies
- A finding marked closed with no rationale or corrected data attached
- A closure that answers a narrower issue than the finding actually raised
- A partly resolved finding recorded as fully closed
- A closure entered before a milestone that was never substantiated afterward
What is at stake
A finding closed without evidence reopens the moment a reviewer checks it, and a register that fails those checks suggests the program's issue-tracking discipline is unreliable. That prompts a reviewer to reopen closures broadly rather than sample, which stretches the review and can reintroduce findings the program believed settled. A closure with no disposition is also fragile at amendment, when the register has to demonstrate again that every issue was genuinely answered.
Move from findings to resolution
Identify the missing data behind the finding.
How the work runs
Re-audit the closures
Check every finding marked closed for evidence that answers what it raised.
Attach or reopen
Tie closure evidence and disposition to each finding, or reopen the ones that lack it.
Assign residual actions
Give partly resolved findings a residual action and a named owner.
Reconcile the register
Produce a register where every closure reflects real resolution for reviewer disposition.
What the buyer receives
- A re-audited finding register with evidence behind each closure
- An evidence request list for the closures that lack substantiation
- A disposition package where each finding is genuinely closed or carried with an owner
Who uses the output
- Certification leads presenting a register whose closures survive reopening
- Engineering owners supplying the evidence behind hollow closures
- Program managers tracking residual actions on partially resolved findings
How the work fits into the transaction or program
The finding register is the last thing a reviewer reads to confirm the program answered its issues, so its closures have to be real before the finding-closure review begins. This work runs at the end of closure, drawing on the corrected data the other reviews produced, so the register reflects genuine resolution rather than status marks entered under deadline.
Start with a single asset
Confirm each requirement maps to substantiating evidence.
Jurisdiction-specific considerations
Each authority tracks its own findings against a submission, so a finding closed to one authority's satisfaction does not automatically settle a parallel finding raised by another. The re-audit notes where a closure accepted on the primary submission needs its evidence re-presented to answer a corresponding finding on a validating filing.
Regulatory limits
This work attaches evidence and disposition to findings and identifies residual actions. It does not accept a finding on the authority's behalf, judge whether a closure is adequate, approve the modification, or grant the STC. Acceptance of each closure remains the authority's finding.
What this review does not cover
- Producing the corrective analysis or data behind an unclosed finding
- Dispositioning a finding on the authority's behalf
- Any determination that a closure is acceptable
Specific to this review
- Findings closed under milestone pressure are the ones most likely to be hollow, because the closure mark is entered ahead of the evidence that was meant to follow.
- A closure that answers a narrower issue than the finding raised reads as resolved until the finding text and the evidence are compared side by side.
- A register with a few hollow closures moves a reviewer from sampling closures to reopening them broadly, so the cost lands across the whole program.
Sources
U.S. Government (eCFR). Type certificates, STCs (Subpart E), TSO authorizations (Subpart O), PMA (Subpart K), and export airworthiness approvals (Subpart L).
Federal Aviation Administration. FAA type certification process, certification basis establishment, and compliance findings.
European Union / EASA. EASA design and production certification, STCs, ETSO authorizations, and EASA Form 1 release.
Frequently asked questions
Why reopen findings the register already shows as closed?
A closure with no evidence behind it will reopen anyway the moment a reviewer checks it, and it will reopen on the reviewer's terms rather than the modifier's. Re-auditing them in advance lets the program attach real evidence or carry a residual action openly, which is far stronger than a status mark that collapses under a question.
Relevant glossary terms
Related pages
Where this fits
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