Root Cause Analysis and Corrective Action Plans for EASA Findings, With a Worked Example

Two names, two training dates

Finding F-02, Level 2. Contrary to 145.A.35(d), ExampleMRO could not demonstrate that all certifying staff received recurrent training in each 2-year period. Of 12 certifying staff records sampled on 3 March 2026, two showed the last recurrent training completed on 11 November 2023 and 20 January 2024. Both staff held current certification authorisations and signed certificates of release to service in February 2026.

Under 145.A.95, ExampleMRO now owes three things: the root cause(s) of, and contributing factor(s) to, the non-compliance; a corrective action plan; and a demonstration of implementation that satisfies the authority, within the period agreed with it. The analysis asks why the system let two authorisations outrun their training, not who forgot. The plan separates correction, corrective action and preventive action, gives each an owner, a date and its evidence, and, under the AMC, goes for acceptance before it is implemented.

Finding levels and the agreed period are in EASA Level 1 and Level 2 findings.

Key facts

• 145.A.95 and CAMO.A.150: identify root cause(s) and contributing factor(s), define a corrective action plan, demonstrate implementation to the competent authority's satisfaction.
• Those actions are performed within the period agreed with the competent authority.
• ORO.GEN.150 and ORA.GEN.150 ask for the root cause, without naming contributing factors, plus the plan and the demonstration.
• AMC1 145.A.95: the plan covers correction, corrective and preventive actions, and goes for acceptance before it is effectively implemented.
• GM1 145.A.95: ask why, not who or what; a simple, linear model may miss important factors.
• GM1 ORO.GEN.150 defines correction, corrective action and preventive action separately.

What 145.A.95 and CAMO.A.150 require

Point (1) names contributing factors alongside root causes, so a one-line cause answers only part of it. Point (3) gives the last word to the authority: an action your own system marks complete has not yet satisfied the authority. Points (b) and (c) are covered in the findings levels guide.

A CAMO has the same duties in CAMO.A.150, with the period agreed under CAMO.B.350 and no observations point.

Correction, corrective action and preventive action

AMC1 145.A.95 gives the plan its parts and its order.

AMC1 CAMO.A.150 adds the word containment.

The Air Ops guidance, GM1 ORO.GEN.150, defines the three action types in one place.

In the plan below, C-lines are corrections, CA-lines corrective actions and PA-lines preventive actions.

The sequence the rules set

Read together, 145.A.95 and AMC1 145.A.95 give this order:

1. Notification of findings.
2. Immediate corrections, depending on the issues.
3. Root cause(s) and contributing factor(s).
4. The plan: correction (correction/containment, in the CAMO wording), corrective and preventive actions, and their planning.
5. The plan submitted for acceptance before it is effectively implemented.
6. Implementation after acceptance.
7. Within the agreed period, the authority told the plan is complete and sent the evidence it asks for.
8. Implementation demonstrated to the authority's satisfaction.

Not in that text: checking later that the action worked. Corrective action is there to "prevent recurrence" (GM1 ORO.GEN.150(b)); step 6 below checks that it did.

What the root cause analysis has to show

GM1 145.A.95 says what the analysis is for.

GM1 CAMO.A.150 gives a CAMO the same two points under "CAUSAL ANALYSIS" and adds, in point (c), that a system description of the organisation "will support both effective causal (reactive) and hazard (proactive) analyses". In practice:

• Ask why, not who. "Technician error" answers who.
• Go deep, then wide. GM1's example of a simple, linear model is a fault tree; the 5 whys is a single chain too. Follow the chain, then sweep the factor types GM1 lists.
• Distrust quick fixes. If every action repairs the sampled records, the plan treats the symptom.

Worked example, step 1: read the finding

ExampleMRO is fictional, and so are its dates, headcounts and internal settings such as the 90-day look-ahead. Only the 2-year period comes from the rule.

The finding cites 145.A.35(d).

Requirement: recurrent training in each 2-year period. Evidence: two of twelve sampled records, with dates. Effect: both people kept certifying. Staff outside the sample are unchecked; checking them is the extent check. The authorisation rules are in the certifying staff guide.

Step 2: contain and correct before you analyse

• 3 March, exit briefing. The quality manager suspended both certification authorisations until recurrent training was done.
• 4–5 March. The training manager checked all 46 certifying and support staff. One more person's 2-year period would end on 28 March; they were booked for 19 March.
• 12 March. Both staff completed recurrent training; authorisations reinstated on 13 March.
• By 20 March. An uninvolved certifying engineer reviewed the 23 releases the two had signed after their periods ended. No technical discrepancy was found; the review was recorded against each work order.

These corrections deal with the non-compliance and its effects, and go into the plan as completed items with evidence.

Step 3: find the root cause

Method: 5 whys, then a sweep across the factor types in GM1 145.A.95. It is one method among several; no rule quoted here prescribes one. Every answer is checked against a record.

The chain misses the question the finding raises: why did the authorisations stay in use? The sweep finds it.

The safety manager, who has no role in training, peer-reviewed the analysis. What went into the response:

• Root cause 1: the training due list depended on one named person, with no deputy or escalation, so no bookings were made during that person's absence (October 2025 to February 2026).
• Root cause 2: the authorisation process did not use the recurrent training due date, so an authorisation stayed usable after training fell outside the 2-year period.
• Contributing factors: the two marked in the table.

Weak and strong root cause statements

A strong statement names a condition in the system, points at a record and tells you what to change.

Step 4: write the corrective action plan

Every cause has an action. Every action has one owner, a date and evidence that it happened, not that it was discussed.

Step 5: implementation, evidence and closure

• 20 March. Plan submitted: C1–C3 completed with evidence, CA1–PA2 planned.
• 27 March. The authority accepted the plan; CA1–PA2 started after that.
• 30 April and 29 May. Corrective and preventive actions implemented.
• 2 June. ExampleMRO told the authority the plan was complete and sent the evidence.
• 16 June. The authority confirmed the finding closed.

Build the evidence pack from the evidence column. A revised procedure proves a document changed; the May due list, issued on time with a 90-day horizon, proves the process ran.

Step 6: check that it worked

The check was set when the plan was written: 15 September 2026, after five monthly cycles. The pass criteria were fixed in advance:

• no authorisation in use past its training due date (all 46 checked);
• every monthly list out by the 5th working day, or escalated and issued by the deputy (all five);
• everyone due within 90 days booked.

The result on 15 September: 46 of 46 current. Four of five lists on time; the July list went out on the 7th working day, issued by the deputy after the escalation fired. Three people due, all booked. ExampleMRO judged the action effective.

No rule quoted here requires a separate effectiveness review. It is how you show the corrective action did what GM1 ORO.GEN.150 says it is for. Where the follow-up sample sits in next year's plan is in the audit programme guide.

What inspectors and auditors typically send back

Patterns from practice, not rule text:

• a root cause that restates the finding or names a person;
• corrections only, with nothing changed in the process;
• "Quality department" as owner, "ASAP" or "ongoing" as the date;
• evidence of a meeting or an email, not of the changed process running;
• no extent check beyond the sampled records;
• actions implemented before acceptance, other than immediate corrections.

Where AI helps in preparing a plan, and where it stops, is in Using AI to Prepare an Aviation CAP for Review.

Air operators and aircrew organisations

Operators have ORO.GEN.150.

The Easy Access Rules also print a point (d), on informing contracted ground handling organisations, marked as applicable from a later date. It is not in force on 25 September 2026 and is not quoted here. Its AMC, AMC1 ORO.GEN.150(b), keeps the effects of the non-compliance in the plan.

Aircrew organisations under Part-ORA have ORA.GEN.150.

Both texts ask for the root cause and do not name contributing factors. The sweep still finds what a single cause misses.

Doing this in Avioverse

The same sequence works for findings from your own compliance monitoring audits. In Avioverse they live in Audits, and each finding card states: "Internal finding grade: follow your organisation’s procedure. Authority-issued deadlines are separate."

Mark closed stays unavailable until the handling is on record, and what is missing is listed above the button. Level 1 and Level 2 findings need the Actual root cause with its Root cause classification, the Corrective/preventive action plan and the Implemented actions and evidence. Level 1 also needs the Immediate containment decision.

Closing also needs a risk decision: Create new, Link existing or No risk assessment. "No risk assessment" needs a written rationale; a linked risk assessment has to be finalised first.

The auditee answers without an account. Share with auditee creates a link, protected by a passphrase by default, which you send yourself. Their drafts stay private until they send them. Accept actions does not close the finding. In a team audit the Independent reviewer closes it, after declaring independence, and cannot be anyone who raised, edited or is assigned the finding.

Verification comes after closure, with its own status. Schedule verification sets the date of the effectiveness check, with a reminder on the finding's task. Record verification asks "What did you verify, and did it work?". Not required records that none is planned. The status reads Verification scheduled, Verification done or Verification not required.

The product checks that each item and decision is on record. Judging whether the root cause is right, and whether the finding should close, stays with the people doing the work. Creating an auditee link needs the Pro plan. The full walk-through is in Aviation Audit Software: From Checklist to Closed Finding.

Where to read it yourself

Every citation was checked against the EASA Easy Access Rules for Continuing Airworthiness (Regulation (EU) No 1321/2014, 2025-09-02 revision), Air Operations (Regulation (EU) No 965/2012, 2026-03-27) and Aircrew (Regulation (EU) No 1178/2011, 2025-11-25). Each rule has a page in the Avioverse regulation library with its AMC and GM: 145.A.95, CAMO.A.150, ORO.GEN.150 and ORA.GEN.150.

Next in this series: the compliance monitoring audit programme for Part-145 and CAMO.