Finding closure
Finding and action-item register support for installation approval
Finding register support checks that the finding and action-item register carried into an installation approval reflects real closure rather than a status field set to closed. It is prepared by or for the modifier before the package enters formal review. The work reads each finding's owner, the evidence linked to it, and its recorded state, then tests whether items marked closed actually carry the evidence that closes them. You receive a register health view keyed to closure evidence, a gap assessment naming items closed in status but open in fact, and a closure plan to reconcile the register before submittal.
When this review is needed
- A long project accumulated findings across several review rounds and the register has never been reconciled against its evidence.
- Action items were owned by people who have since moved off the project, and their closures were recorded by others.
- The register drives the go decision for submittal and the team needs to know which closures are real.
- A reviewer is expected to reopen the register and sample closed items, and the project wants the unsupported closures found first.
The problem
A finding register tends to age faster than the evidence behind it. Items get marked closed in a status field the moment someone believes the work is done, before the closing artifact is filed and linked. Ownership shifts as engineers rotate off, and a closure recorded by a new owner may rest on a conversation rather than a document. The register looks healthy because the status column is mostly closed, yet a share of those closures cannot produce the evidence that a reviewer or an auditor will ask for.
What gets reviewed
- Each finding's owner confirmed against someone still accountable for the item
- Evidence links checked so a closed item points to a producible closing artifact
- Closure state reconciled with the evidence rather than taken from the status field
- Items closed in status but lacking evidence isolated as still open
- Findings closed by an accepted rationale checked for a documented, defensible basis
- A closure plan to file, link, or reopen the items that do not reconcile
Scope this review
Tell us the asset, the event, and the evidence in scope, and we will outline a focused first engagement.
Identify what is missing against the means of compliance.
What gets validated
- Every item marked closed points to a closing artifact that can be produced on request
- The recorded owner of each open item is a person still accountable for it
- Closures based on a rationale rather than an artifact state that rationale explicitly
- No finding is duplicated across rounds with one instance closed and another left open
- The register accounts for every finding raised, with none dropped between review rounds
Evidence normally required
- The finding and action-item register as maintained
- The closing artifacts and evidence linked to each item
- The review minutes or correspondence that raised the findings
- Ownership and assignment history for the action items
- Any accepted rationale used to close a finding without an artifact
Common discrepancies
- An item marked closed whose linked evidence cannot actually be retrieved
- A closure recorded by a new owner resting on a conversation rather than a document
- A finding duplicated across rounds, closed in one instance and open in another
- A closure by rationale with no documented basis behind the acceptance
What is at stake
A register that shows closed items which cannot produce evidence is worse than one that honestly shows them open, because it invites a reviewer to sample and find the discrepancy. Once one closure fails to produce evidence, the reviewer widens the sample, and the register's credibility for the whole package erodes. Reconciling it under review, item by item, is far slower than reconciling it once before submittal.
How the work runs
Pull the full register
Assemble every finding across all review rounds with its owner, state, and linked evidence.
Test each closure
Confirm each closed item can produce its closing artifact rather than relying on the status field.
Check rationale closures
Verify findings closed by rationale carry a documented, defensible basis.
Plan the reconciliation
Sequence the items to file, link, or reopen so the register reflects real closure before submittal.
What the buyer receives
- A register health view keyed to closure evidence
- A gap assessment naming each item closed in status but open in fact
- A closure plan to reconcile the register before the package is submitted
Who uses the output
- Certification project managers making the submittal go decision on real closure
- Engineering leads filing or reopening the items that do not reconcile
- Compliance staff who will defend the register when a reviewer samples it
How the work fits into the transaction or program
The register is the project's own account of what still stands between the package and submittal, and it feeds directly into the accomplishment summary. Reconciling it to evidence before review means the summary rests on real closures, and the reviewer's inevitable sample of closed items lands on findings that can produce their proof.
Start with a single asset
Reduce finding cycles by checking the package first.
Jurisdiction-specific considerations
FAA and EASA both track findings and action items to closure through their respective review processes, and the register logic is common. What differs is how findings are raised and formally closed within each authority's process, so the reconciliation confirms each closure would satisfy the process this package runs under rather than assuming a closure accepted in one process carries to the other.
Regulatory limits
The work reconciles the register to its closure evidence and flags unsupported closures. It does not close findings on the authority's behalf, does not accept a closure rationale, and does not make a compliance finding or grant an approval. Formal closure and the compliance determination rest with the authority.
What this review does not cover
- Formally closing findings on the authority's behalf
- Accepting a closure rationale in place of the reviewer
- Any compliance finding or approval tied to the register
Specific to this review
- A status field set to closed is a claim, not evidence, so a register that reads mostly closed tells a reviewer nothing until the closing artifacts can be produced.
- Ownership churn is the quiet driver of false closure, because a closure recorded by someone who inherited the item often rests on handoff notes rather than a filed document.
- Duplicated findings across review rounds are a common trap: one instance gets closed and the other lingers open, and only a reconciliation across rounds catches it.
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. STC application process, certification basis, and continued airworthiness obligations of an STC holder.
RTCA. Environmental qualification test categories and procedures referenced by TSO and equipment qualification.
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. Isn't that a good sign?
Only if each closed item can produce the artifact that closes it. A status field is a claim, and reviewers sample closed items precisely to test that claim. The reconciliation confirms every closure has producible evidence behind it, which is what a mostly-closed register needs before it means anything.
Relevant glossary terms
Related pages
Where this fits
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We will walk through your current state, the records or evidence involved, and a scoped first engagement.
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