TSO finding closure
Closing findings marked closed without evidence that answers them
This helps equipment suppliers whose finding register carries items marked closed that no evidence actually resolves. A specialist reads each closed finding against the issue it raised and the evidence attached to it, and separates the findings that are genuinely answered from those closed by assertion, by a response that misses the point, or by a fix that left a residual action nobody tracked. The work is done during the program, before a reviewer reopens a finding the register calls closed. You receive a closure brief listing findings that are not truly resolved, an evidence request list for what each still needs, and a disposition package with closure evidence, a reviewer-facing disposition, and an owner for every residual action.
When this review is needed
- A reviewer reopens a finding the register marks closed because the response did not answer the issue.
- Findings were closed to hit a milestone with a note that promised evidence that never followed.
- A finding was closed by a fix that created a residual action nobody assigned.
- The register shows a high close rate but the closure column holds statements rather than evidence.
The problem
A finding register is only as honest as its closure column, and closure columns fill up under milestone pressure with statements that read like resolution. A finding gets marked closed with a promise of evidence to come, or with a response that addresses a nearby concern instead of the one raised, or with a fix that quietly spawned a new action that never made it onto anyone's list. The register then reports a program in control while carrying findings that a reviewer can reopen with a single question, and reopened findings arrive with less schedule left than when they were first raised.
What gets reviewed
- Every finding marked closed read against the issue it originally raised
- Closures separated into evidence-backed, assertion-only, off-point, and fixed-with-residual
- The closure evidence for each finding checked to confirm it answers the specific issue
- Residual actions left by a fix identified and assigned to an owner
- A reviewer-facing disposition drafted for each finding that reads against the original issue
- A reconciled register where every closed finding has evidence and every residual has an owner
What gets validated
- Each closed finding has evidence that answers the specific issue it raised, not an adjacent one
- Closures that promised future evidence either have it now or are reopened
- A fix that created a residual action has that action logged and owned
- The disposition for each finding reads coherently against the original wording of the issue
- The register's closed count reflects findings that would survive a reviewer reopening them
Evidence normally required
- The finding register with its closure column and status history
- The evidence attached or referenced against each closed finding
- The original finding text so closures can be read against the real issue
- The change and action records that show what each fix actually did
- Any reviewer comments that reopened or questioned a closure
Common discrepancies
- A finding closed with a note promising evidence that never arrived
- A response that addressed a nearby concern rather than the issue raised
- A fix that resolved the finding but created a residual action nobody owns
- A closure column holding a statement of intent rather than an evidence reference
What is at stake
A finding closed without evidence is worse than an open one, because it hides work that still has to happen behind a green status. When a reviewer reopens it, the schedule that assumed it closed is already spent, and the supplier is answering an old finding on a new deadline. A register full of soft closures also costs credibility: once a reviewer catches one closure that does not hold, they audit the rest, and the close rate the program reported stops meaning anything.
Move from findings to resolution
Identify the missing data behind the finding.
How the work runs
Read closures against issues
Take every closed finding and read its closure against the specific issue it originally raised.
Sort the closures
Separate evidence-backed closures from assertion-only, off-point, and fixed-with-residual ones.
Own the residuals
Assign an owner to every residual action and identify the evidence each unresolved finding still needs.
Reconcile the register
Deliver a register where closures are evidence-backed and residuals are owned, with a disposition package.
What the buyer receives
- A closure brief listing findings the register calls closed that are not truly resolved
- An evidence request list for what each unresolved finding still needs
- A disposition package with closure evidence, a reviewer-facing disposition, and a residual-action owner per finding
Who uses the output
- Certification leadership seeing the real close state behind the register's status
- Engineering leads producing the evidence the soft closures still owe
- Program management retiring residual actions before a reviewer surfaces them
How the work fits into the transaction or program
This audits the finding register against the issues it claims to have closed, sitting between finding response and the compliance submittal. It converts a status column into evidence-backed closures with owned residuals, so the register the supplier presents survives a reviewer reopening any line of it.
Start with a single asset
Confirm each requirement maps to substantiating evidence.
Jurisdiction-specific considerations
FAA and EASA both expect a finding to be closed by evidence that resolves the issue, and both can reopen a closure they judge unsupported. The check is authority-neutral, though a finding raised by one authority is dispositioned to that authority's original wording, since the issue as raised is what the closure has to answer.
Regulatory limits
The work assesses whether closures are supported and drafts dispositions for the reviewer. It does not close findings on the authority's behalf, does not determine airworthiness, and does not decide that a finding is resolved; the authority accepts or reopens each closure.
What this review does not cover
- Performing the engineering fixes that some findings require to close
- Negotiating finding closure or disposition with the authority
- Producing the underlying evidence a soft closure still owes
Specific to this review
- A soft closure is more dangerous than an open finding, because it hides remaining work behind a status that says nothing is left.
- Findings closed to hit a milestone tend to carry a promise of later evidence, and that promise is the first thing to check.
- A fix can close a finding and open a residual action in the same stroke, and the residual is the part that gets lost.
- One reopened closure makes a reviewer audit the whole register, so the close rate is only credible if it survives spot reopening.
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
Our register shows almost everything closed. Why review it?
A high close rate only means the status column is full, not that the evidence behind it holds. Findings closed under milestone pressure often carry a promise of evidence, a response that misses the issue, or a fix that spawned an untracked residual. Reviewing the register against the original issues is what confirms the closures would survive a reviewer reopening them, which is when a soft closure costs you schedule.
Relevant glossary terms
Related pages
Where this fits
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