MLNavigator - Air-Gapped AI Compliance Automation for Aerospace & Defense

The $125k Audit That Went Wrong

In November 2023, a mid-sized aerospace MRO in Florida prepared for their routine AS9100 surveillance audit. They'd passed six previous audits with only minor findings. Management was confident. Day 2 of the audit, the registrar issued 3 major findings:

Calibration records incomplete for 12 measurement tools
Drawing change control procedures not followed (Rev B parts made to Rev A drawing)
Corrective action tracking system showed 18 overdue actions

Impact:

Certificate suspended pending corrective actions
90-day window to remediate or lose certification
Customer notifications required
$45k in emergency consultant fees
$80k in lost revenue during suspension
Total cost: $125k+ from preventable findings

The shop knew the requirements. They just hadn't implemented them systematically. No one caught the gaps until the auditor walked in. This article is your pre-audit insurance policy—a comprehensive checklist to find and fix issues before auditors do.

Pre-Audit Compliance Checklist

Overall Readiness0%

0 of 22 items completed

AS9100D Requirements

Quality Manual current and accessible

⚠️ Major Finding

Work instructions documented and controlled

⚠️ Major Finding

Calibration records for all measurement equipment

⚠️ Major Finding

Traceability records for all materials

⚠️ Major Finding

Internal audit schedule maintained

Management review records (last 12 months)

Corrective action tracking and closure

⚠️ Major Finding

Drawing change control procedures

⚠️ Major Finding

FAA/PMA Compliance

Current FAA production certificate

⚠️ $10k-$50k fine

Inspection stamps and records current

⚠️ Certificate suspension

Authorized inspector signatures on file

⚠️ Certificate suspension

8130-3 airworthiness tags properly completed

⚠️ $25k+ fine

Supplier approval records maintained

Parts traceability to raw material

⚠️ Certificate suspension

CMMC Level 2

Access control logs for CUI systems

⚠️ Contract disqualification

Incident response plan documented

⚠️ Contract disqualification

Security awareness training records

⚠️ Contract disqualification

Multi-factor authentication enabled

⚠️ Contract disqualification

Configuration management baseline

⚠️ Contract disqualification

Audit logs immutable and retained

⚠️ Contract disqualification

Physical access controls documented

Media sanitization procedures

⚠️ Contract disqualification

Most Common Audit Findings (2024)

• Incomplete calibration records (47% of audits)

• Missing work instructions (38% of audits)

• Inadequate corrective action tracking (52% of audits)

• Non-compliant CUI handling (61% of CMMC audits)

• Drawing change control gaps (35% of audits)

• Incomplete traceability records (44% of audits)

How MLNavigator Helps

MLNavigator automatically maintains audit-ready records for drawing compliance, CUI access controls, and quality documentation. Our immutable logging system ensures traceability for AS9100, FAA, and CMMC audits—reducing preparation time from weeks to days.

Checklist based on AS9100D:2016, FAA Order 8900.1, and CMMC Level 2 requirements.

Understanding Audit Types

Aerospace shops face three primary audit frameworks:

AS9100D: Quality Management System

Who: Aerospace quality management standard (ISO 9001 + aerospace requirements)
Frequency: Initial certification, then surveillance audits every 6-12 months
Who audits: Third-party registrars (accredited certification bodies)
Consequences: Major findings = certificate suspension; lost certification = lost customers

FAA / PMA: Regulatory Compliance

Who: Federal Aviation Administration for production or parts manufacturer approvals
Frequency: Initial approval, then periodic surveillance (announced or unannounced)
Who audits: FAA inspectors
Consequences: Fines $10k-$50k+; certificate suspension; criminal penalties for egregious violations

CMMC Level 2: Cybersecurity Certification

Who: Defense contractors handling Controlled Unclassified Information (CUI)
Frequency: Every 3 years by certified C3PAO assessors
Who audits: CMMC Third-Party Assessment Organizations (C3PAOs)
Consequences: Failed assessment = disqualified from DoD contracts

Each has different focus areas, but overlap significantly on documentation, traceability, and process control.

Most Common Audit Findings

Based on 2024 industry data, these are the top findings that trigger major non-conformances:

1.
Source:Nqa✓

What auditors look for:

Calibration stickers current on all measurement equipment
Certificates traceable to NIST standards
Recall system ensuring tools don't go past due
Out-of-tolerance procedures (what happens if calibration fails)

Common gaps:

"We sent it out for calibration but don't have the cert"
Tools past due because recall system failed
No procedure for handling out-of-tolerance findings

Fix: Centralized calibration database, automated recall notices, require certs before tool returns to service. MLNavigator helps: Audit logs show which tools were used to measure which features on which parts—enabling retroactive impact analysis if calibration lapses.

2.
Source:Nqa✓

What auditors look for:

Documented procedures for each manufacturing operation
Instructions accessible at point of use
Current revision controlled
Evidence workers trained to current revision

Common gaps:

"We've always done it this way" (undocumented tribal knowledge)
Instructions outdated, workers using newer methods
No training records showing who's qualified

Fix: Document procedures, implement revision control, train and document training. MLNavigator helps: Drawing compliance scanning ensures work instructions reference current drawings.

3.
Source:Nqa✓

What auditors look for:

CARs (Corrective Action Requests) opened for all NCRs
Root cause analysis documented
Corrective actions implemented and verified
CARs closed in timely manner

Common gaps:

Overdue CARs (opened but never closed)
Root cause = "operator error" (not acceptable—what process allowed the error?)
No verification that corrective action actually worked

Fix: CAR tracking system with automated reminders, management review of overdue CARs. MLNavigator helps: Immutable logs provide evidence for root cause analysis (which drawing, which engineer, which adapter version).

4.
Source:Nqa✓

What auditors look for:

CUI identified and marked
Access controls enforced
Audit logs showing who accessed what
Encryption in transit and at rest

Common gaps:

No systematic identification of CUI
Shared passwords, no access control
No logging of CUI access

Fix: CUI identification training, role-based access, immutable logging. MLNavigator helps: Enforces access control on engineering drawings, logs all CUI access with timestamps and user IDs.

5.
Source:Nqa✓

What auditors look for:

Only current revision drawings used
Change control process documented
Obsolete drawings removed from circulation
Parts traceable to drawing revision

Common gaps:

Old revision found on shop floor
No system preventing use of obsolete drawings
Parts made to wrong revision

Fix: Electronic drawing distribution, obsolete drawings purged, revision verification at start of production. MLNavigator helps: Flags rev mismatches at upload, logs show which revision scanned for each part.

6.
Source:Nqa✓

What auditors look for:

Material certs for all raw materials
Heat lot traceability
Sub-tier supplier approvals
Test reports retained

Common gaps:

"We know we got the cert, but can't find it"
Material used before cert arrived
No system ensuring cert retained with job

Fix: Require cert before material released to production, centralized cert repository.

Pre-Audit Preparation Timeline

6-8 Weeks Before Audit

Run internal audit: Find your own findings before auditor does
Review open CARs: Close overdue actions or document delays
Verify calibration status: Ensure no past-due tools
Check document control: Confirm current revisions in use

4 Weeks Before Audit

Train staff: Ensure everyone knows what auditor might ask
Update quality manual: Reflect current processes
Organize records: Calibration certs, training records, CARs
Mock audit: Have someone unfamiliar with your system review records

2 Weeks Before Audit

Final walk-through: Check for obvious issues (obsolete drawings, expired cal stickers)
Briefing: Remind staff to answer only what's asked, be honest, don't volunteer extra info
Assign escorts: Designate who will accompany auditor

Day of Audit

Opening meeting: Understand scope, special focus areas
Stay calm: Findings aren't personal; they're opportunities to improve
Take notes: Document auditor comments for corrective action
Closing meeting: Understand findings, ask for clarification if needed

How to Respond to Findings

Major Finding

Definition: Absence or complete breakdown of a system required by the standard
Timeline: Usually 90 days to correct
Response:
1. Immediate containment (stop the nonconforming activity)
2. Root cause analysis (why did it happen)
3. Corrective action (fix the system)
4. Verification (prove the fix works)
5. Documentation (provide evidence to auditor)

Minor Finding

Definition: Isolated lapse or minor deviation
Timeline: Address by next audit
Response:
1. Investigate
2. Correct the specific instance
3. Check for systemic issue (is it really isolated?)
4. Document correction

Observation (Not a Finding)

Definition: Potential area of concern, not yet a nonconformance
Timeline: No formal deadline, but wise to address
Response: Consider it a warning; fix before it becomes a finding next audit

Common Auditor Questions and How to Answer

"How do you ensure only current drawings are used?"

❌ Bad answer: "Our engineers know to check."
✅ Good answer: "We have a controlled drawing server. Engineers download drawings via ADIS, which verifies current revision. Obsolete drawings are purged from the system. Audit logs show which revision was used for each job."

"What happens if calibration fails?"

❌ Bad answer: "Hasn't happened."
✅ Good answer: "Our procedure (QP-07) requires notification to Quality Manager, quarantine of parts measured since last good calibration, and disposition decision (scrap, rework, or 100% re-inspect). Last occurrence was documented in CAR 2024-023."

"How do you prevent unauthorized access to CUI?"

❌ Bad answer: "We have passwords."
✅ Good answer: "MLNavigator enforces role-based access control. Only authorized engineers can view CUI drawings. Access is logged with user ID and timestamp. Logs are immutable per CMMC AU-9. I can show you the logs."

"What's your root cause analysis process?"

❌ Bad answer: "We figure out what went wrong."
✅ Good answer: "We use 5-Whys or fishbone diagrams per procedure QP-14. Root cause must identify a process gap, not blame an individual. Example: CAR 2024-015 identified lack of work instruction as root cause for machining error. We created the instruction, trained operators, and verified with 3-month follow-up."

Penalties for Non-Compliance

AS9100 Certificate Suspension

Loss of customer approvals
Inability to bid on new work
Existing contracts at risk
Emergency re-certification costs: $20k-$50k

FAA Fines and Suspensions

$10,000-$50,000 per violation
Certificate suspension (no production until reinstated)
Criminal penalties for willful violations
(
Source:Faa✓
))

CMMC Failed Assessment

Disqualified from bidding on DoD contracts
Loss of existing contract renewals
Must remediate and re-assess (6-12 month delay)
Competitors gain market share

How MLNavigator Accelerates Audit Readiness

MLNavigator's built-in compliance features address common audit findings:

Immutable Audit Logs

Every drawing upload logged with timestamp, user ID, revision
Logs BLAKE3-hashed (tamper-proof)
Satisfies AS9100 4.2.3, CMMC AU-2/AU-3/AU-9

Access Control

Role-based permissions on CUI drawings
Satisfies CMMC AC-2, AC-3

Drawing Revision Control

Flags rev mismatches at upload
Ensures current revisions used
Satisfies AS9100 8.5.1, FAA production approval requirements

Corrective Action Support

Root cause analysis data (which drawing, which issue)
Historical error patterns
Satisfies AS9100 10.2

Instead of scrambling to find evidence during an audit, MLNavigator provides:

Pre-built reports for auditors
Exportable logs for compliance review
Traceability from drawing to part to shipment

Related Compliance Resources

For deeper dives into specific compliance frameworks:

Why Most Defense Suppliers Aren't Ready for CMMC 2.0 - Full CMMC Level 2 preparation guide.
CMMC Level 2 Compliance: 110 Controls by 2026 - Complete control breakdown and timeline.
Engineering Drawings: The Hidden Compliance Risk - How drawing errors trigger audit findings.

Conclusion

Audits don't have to be stressful. The shops that struggle are those that:

Wait until the week before to prepare
Lack systematic documentation
Rely on tribal knowledge instead of documented processes

The shops that sail through audits:

Run internal audits quarterly
Address findings immediately
Use tools like MLNavigator for automated compliance

Use the interactive checklist above to assess your readiness. If you're checking off 90%+ of items, you're in good shape. If you're below 70%, start fixing gaps now—don't wait for the auditor to find them. The cost of non-compliance ($125k+ in the Florida example) far exceeds the cost of preparation. And in many cases, the tools you deploy for compliance (like MLNavigator) also improve efficiency and reduce CoPQ—creating a double ROI. Your next audit is coming. The question is whether you'll be ready.

Turn Audit Prep From Panic to Routine

Get an audit readiness assessment and see how MLNavigator provides automated compliance evidence.

Request Audit Readiness Review

The $125k Audit That Went Wrong

Calibration records incomplete for 12 measurement tools
Drawing change control procedures not followed (Rev B parts made to Rev A drawing)
Corrective action tracking system showed 18 overdue actions

Impact:

Certificate suspended pending corrective actions
90-day window to remediate or lose certification
Customer notifications required
$45k in emergency consultant fees
$80k in lost revenue during suspension
Total cost: $125k+ from preventable findings

Pre-Audit Compliance Checklist

Overall Readiness0%

0 of 22 items completed

AS9100D Requirements

Quality Manual current and accessible

⚠️ Major Finding

Work instructions documented and controlled

⚠️ Major Finding

Calibration records for all measurement equipment

⚠️ Major Finding

Traceability records for all materials

⚠️ Major Finding

Internal audit schedule maintained

Management review records (last 12 months)

Corrective action tracking and closure

⚠️ Major Finding

Drawing change control procedures

⚠️ Major Finding

FAA/PMA Compliance

Current FAA production certificate

⚠️ $10k-$50k fine

Inspection stamps and records current

⚠️ Certificate suspension

Authorized inspector signatures on file

⚠️ Certificate suspension

8130-3 airworthiness tags properly completed

⚠️ $25k+ fine

Supplier approval records maintained

Parts traceability to raw material

⚠️ Certificate suspension

CMMC Level 2

Access control logs for CUI systems

⚠️ Contract disqualification

Incident response plan documented

⚠️ Contract disqualification

Security awareness training records

⚠️ Contract disqualification

Multi-factor authentication enabled

⚠️ Contract disqualification

Configuration management baseline

⚠️ Contract disqualification

Audit logs immutable and retained

⚠️ Contract disqualification

Physical access controls documented

Media sanitization procedures

⚠️ Contract disqualification

Most Common Audit Findings (2024)

• Incomplete calibration records (47% of audits)

• Missing work instructions (38% of audits)

• Inadequate corrective action tracking (52% of audits)

• Non-compliant CUI handling (61% of CMMC audits)

• Drawing change control gaps (35% of audits)

• Incomplete traceability records (44% of audits)

How MLNavigator Helps

Checklist based on AS9100D:2016, FAA Order 8900.1, and CMMC Level 2 requirements.

Understanding Audit Types

Aerospace shops face three primary audit frameworks:

AS9100D: Quality Management System

Who: Aerospace quality management standard (ISO 9001 + aerospace requirements)
Frequency: Initial certification, then surveillance audits every 6-12 months
Who audits: Third-party registrars (accredited certification bodies)
Consequences: Major findings = certificate suspension; lost certification = lost customers

FAA / PMA: Regulatory Compliance

Who: Federal Aviation Administration for production or parts manufacturer approvals
Frequency: Initial approval, then periodic surveillance (announced or unannounced)
Who audits: FAA inspectors
Consequences: Fines $10k-$50k+; certificate suspension; criminal penalties for egregious violations

CMMC Level 2: Cybersecurity Certification

Who: Defense contractors handling Controlled Unclassified Information (CUI)
Frequency: Every 3 years by certified C3PAO assessors
Who audits: CMMC Third-Party Assessment Organizations (C3PAOs)
Consequences: Failed assessment = disqualified from DoD contracts

Each has different focus areas, but overlap significantly on documentation, traceability, and process control.

Most Common Audit Findings

Based on 2024 industry data, these are the top findings that trigger major non-conformances:

1.
Source:Nqa✓

What auditors look for:

Calibration stickers current on all measurement equipment
Certificates traceable to NIST standards
Recall system ensuring tools don't go past due
Out-of-tolerance procedures (what happens if calibration fails)

Common gaps:

"We sent it out for calibration but don't have the cert"
Tools past due because recall system failed
No procedure for handling out-of-tolerance findings

2.
Source:Nqa✓

What auditors look for:

Documented procedures for each manufacturing operation
Instructions accessible at point of use
Current revision controlled
Evidence workers trained to current revision

Common gaps:

"We've always done it this way" (undocumented tribal knowledge)
Instructions outdated, workers using newer methods
No training records showing who's qualified

Fix: Document procedures, implement revision control, train and document training. MLNavigator helps: Drawing compliance scanning ensures work instructions reference current drawings.

3.
Source:Nqa✓

What auditors look for:

CARs (Corrective Action Requests) opened for all NCRs
Root cause analysis documented
Corrective actions implemented and verified
CARs closed in timely manner

Common gaps:

Overdue CARs (opened but never closed)
Root cause = "operator error" (not acceptable—what process allowed the error?)
No verification that corrective action actually worked

4.
Source:Nqa✓

What auditors look for:

CUI identified and marked
Access controls enforced
Audit logs showing who accessed what
Encryption in transit and at rest

Common gaps:

No systematic identification of CUI
Shared passwords, no access control
No logging of CUI access

Fix: CUI identification training, role-based access, immutable logging. MLNavigator helps: Enforces access control on engineering drawings, logs all CUI access with timestamps and user IDs.

5.
Source:Nqa✓

What auditors look for:

Only current revision drawings used
Change control process documented
Obsolete drawings removed from circulation
Parts traceable to drawing revision

Common gaps:

Old revision found on shop floor
No system preventing use of obsolete drawings
Parts made to wrong revision

6.
Source:Nqa✓

What auditors look for:

Material certs for all raw materials
Heat lot traceability
Sub-tier supplier approvals
Test reports retained

Common gaps:

"We know we got the cert, but can't find it"
Material used before cert arrived
No system ensuring cert retained with job

Fix: Require cert before material released to production, centralized cert repository.

Pre-Audit Preparation Timeline

6-8 Weeks Before Audit

Run internal audit: Find your own findings before auditor does
Review open CARs: Close overdue actions or document delays
Verify calibration status: Ensure no past-due tools
Check document control: Confirm current revisions in use

4 Weeks Before Audit

Train staff: Ensure everyone knows what auditor might ask
Update quality manual: Reflect current processes
Organize records: Calibration certs, training records, CARs
Mock audit: Have someone unfamiliar with your system review records

2 Weeks Before Audit

Final walk-through: Check for obvious issues (obsolete drawings, expired cal stickers)
Briefing: Remind staff to answer only what's asked, be honest, don't volunteer extra info
Assign escorts: Designate who will accompany auditor

Day of Audit

Opening meeting: Understand scope, special focus areas
Stay calm: Findings aren't personal; they're opportunities to improve
Take notes: Document auditor comments for corrective action
Closing meeting: Understand findings, ask for clarification if needed

How to Respond to Findings

Major Finding

Definition: Absence or complete breakdown of a system required by the standard
Timeline: Usually 90 days to correct
Response:
1. Immediate containment (stop the nonconforming activity)
2. Root cause analysis (why did it happen)
3. Corrective action (fix the system)
4. Verification (prove the fix works)
5. Documentation (provide evidence to auditor)

Minor Finding

Definition: Isolated lapse or minor deviation
Timeline: Address by next audit
Response:
1. Investigate
2. Correct the specific instance
3. Check for systemic issue (is it really isolated?)
4. Document correction

Observation (Not a Finding)

Definition: Potential area of concern, not yet a nonconformance
Timeline: No formal deadline, but wise to address
Response: Consider it a warning; fix before it becomes a finding next audit

Common Auditor Questions and How to Answer

"How do you ensure only current drawings are used?"

"What happens if calibration fails?"

"How do you prevent unauthorized access to CUI?"

"What's your root cause analysis process?"

Penalties for Non-Compliance

AS9100 Certificate Suspension

Loss of customer approvals
Inability to bid on new work
Existing contracts at risk
Emergency re-certification costs: $20k-$50k

FAA Fines and Suspensions

$10,000-$50,000 per violation
Certificate suspension (no production until reinstated)
Criminal penalties for willful violations
(
Source:Faa✓
))

CMMC Failed Assessment

Disqualified from bidding on DoD contracts
Loss of existing contract renewals
Must remediate and re-assess (6-12 month delay)
Competitors gain market share

How MLNavigator Accelerates Audit Readiness

MLNavigator's built-in compliance features address common audit findings:

Immutable Audit Logs

Every drawing upload logged with timestamp, user ID, revision
Logs BLAKE3-hashed (tamper-proof)
Satisfies AS9100 4.2.3, CMMC AU-2/AU-3/AU-9

Access Control

Role-based permissions on CUI drawings
Satisfies CMMC AC-2, AC-3

Drawing Revision Control

Flags rev mismatches at upload
Ensures current revisions used
Satisfies AS9100 8.5.1, FAA production approval requirements

Corrective Action Support

Root cause analysis data (which drawing, which issue)
Historical error patterns
Satisfies AS9100 10.2

Instead of scrambling to find evidence during an audit, MLNavigator provides:

Pre-built reports for auditors
Exportable logs for compliance review
Traceability from drawing to part to shipment

Related Compliance Resources

For deeper dives into specific compliance frameworks:

Why Most Defense Suppliers Aren't Ready for CMMC 2.0 - Full CMMC Level 2 preparation guide.
CMMC Level 2 Compliance: 110 Controls by 2026 - Complete control breakdown and timeline.
Engineering Drawings: The Hidden Compliance Risk - How drawing errors trigger audit findings.

Conclusion

Audits don't have to be stressful. The shops that struggle are those that:

Wait until the week before to prepare
Lack systematic documentation
Rely on tribal knowledge instead of documented processes

The shops that sail through audits:

Run internal audits quarterly
Address findings immediately
Use tools like MLNavigator for automated compliance

Turn Audit Prep From Panic to Routine

Get an audit readiness assessment and see how MLNavigator provides automated compliance evidence.

Request Audit Readiness Review

How to Survive Your Next Audit

The $125k Audit That Went Wrong

Pre-Audit Compliance Checklist

AS9100D Requirements

FAA/PMA Compliance

CMMC Level 2

Most Common Audit Findings (2024)

How MLNavigator Helps

Understanding Audit Types

AS9100D: Quality Management System

FAA / PMA: Regulatory Compliance

CMMC Level 2: Cybersecurity Certification

Most Common Audit Findings

1. Source:Nqa✓

2. Source:Nqa✓

3. Source:Nqa✓

4. Source:Nqa✓

5. Source:Nqa✓

6. Source:Nqa✓

Pre-Audit Preparation Timeline

6-8 Weeks Before Audit

4 Weeks Before Audit

2 Weeks Before Audit

Day of Audit

How to Respond to Findings

Major Finding

Minor Finding

Observation (Not a Finding)

Common Auditor Questions and How to Answer

"How do you ensure only current drawings are used?"

"What happens if calibration fails?"

"How do you prevent unauthorized access to CUI?"

"What's your root cause analysis process?"

Penalties for Non-Compliance

AS9100 Certificate Suspension

FAA Fines and Suspensions

CMMC Failed Assessment

How MLNavigator Accelerates Audit Readiness

Immutable Audit Logs

Access Control

Drawing Revision Control

Corrective Action Support

Related Compliance Resources

Conclusion

Turn Audit Prep From Panic to Routine

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Continue Reading

CMMC Level 2‑aligned architecture: 110 Controls by 2026

Offline AI vs. Cloud AI: Why Air-Gapped Intelligence Wins in Defense

Staying Audit-Ready in Aerospace: How MLNavigator Supports the AS9100D Cycle

How to Survive Your Next Audit

The $125k Audit That Went Wrong

Pre-Audit Compliance Checklist

AS9100D Requirements

FAA/PMA Compliance

CMMC Level 2

Most Common Audit Findings (2024)

How MLNavigator Helps

Understanding Audit Types

AS9100D: Quality Management System

FAA / PMA: Regulatory Compliance

CMMC Level 2: Cybersecurity Certification

Most Common Audit Findings

1. Source:Nqa✓

2. Source:Nqa✓

3. Source:Nqa✓

4. Source:Nqa✓

5. Source:Nqa✓

6. Source:Nqa✓

Pre-Audit Preparation Timeline

6-8 Weeks Before Audit

4 Weeks Before Audit

2 Weeks Before Audit

Day of Audit

How to Respond to Findings

Major Finding

Minor Finding

Observation (Not a Finding)

Common Auditor Questions and How to Answer

1.
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