Repair and alteration records
Boeing 737 MAX repair approval data records review
This review confirms that the repairs and alterations recorded on a Boeing 737 MAX each rest on approved data the file can produce. It runs during valuation, transfer, or after a heavy check, run by or for the party relying on the repair history. It covers the repair map for the airframe, the damage reports and dispositions behind each repair, the approved data the disposition used, and the return-to-service entry that closed it. You receive an exception list per repair, a source map from the repair map to its approval basis, and a closure plan for the repairs the file cannot yet substantiate.
When this review is needed
- A 737 MAX is in diligence and a buyer will ask for the approved data behind each structural repair.
- A heavy check added repairs and the repair map has to catch up before the file is relied on.
- A repair on the map has a disposition but the approved-data reference behind it is missing.
- The tail is transferring registers and repairs approved on one basis have to be recognized by the receiving authority.
The problem
A repair is recorded as done and signed off, but the value question is whether the data it was done to was approved and whether the file can still show it. On a 737 MAX the repair map may list a repair while the damage report, the disposition, and the approved-data reference that justify it sit in separate packages or have gone missing. A repair that looks closed can rest on data whose approval basis nobody has confirmed, and that surfaces when a buyer or a receiving authority asks to see it.
What gets reviewed
- The repair map reconciled to the repairs the records actually document
- Damage reports and dispositions behind each mapped repair
- The approved data each disposition relied on and its approval basis
- Return-to-service entries closing each repair
- Alterations checked for the approval appropriate to the change
- Repairs added at a recent heavy check reconciled onto the map
Scope this review
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What gets validated
- Each repair on the map traces to a damage report and a disposition
- The data behind each repair carries an approval basis the file can produce
- The return-to-service entry follows from the disposition and the data used
- An alteration is supported by approval appropriate to its effect on the type design
- Repairs from the most recent heavy check are reflected on the current map
Evidence normally required
- The airframe repair map or repair register
- Damage reports and repair dispositions
- The approved data and substantiation behind each repair
- Return-to-service entries for the repairs and alterations
- The most recent heavy-check work package
Common discrepancies
- A repair on the map with a disposition but no approved-data reference behind it
- An alteration recorded without the approval its effect on the type design requires
- A repair added at a heavy check that never made it onto the current map
- A return-to-service entry that does not follow from the data the disposition cites
What is at stake
A repair without a traceable approval basis can force re-substantiation or, in the worst case, removal and rework, which is far more costly than confirming the data up front. An unrecognized repair basis can stall a register transfer, and a repair map that lags a heavy check leaves the configuration understating what the airframe actually carries.
Move from findings to resolution
Move from findings to a documented resolution path.
How the work runs
Reconcile the repair map
Match the map to the repairs the records document and flag anything the map misses.
Trace to disposition and data
Tie each repair to its damage report, disposition, and the approved data behind it.
Confirm the approval basis
Check that the data carries an approval basis producible and valid for this configuration.
Report the exceptions
Deliver the per-repair exception list, source map, and closure plan.
What the buyer receives
- An exception list per repair graded by missing basis, missing data, or map gap
- A source map from the repair map to each repair's approval basis
- A closure plan for the repairs the file cannot yet substantiate
Who uses the output
- Asset managers testing whether the repair history survives diligence
- Engineering deciding how to treat a repair whose approval basis is missing
- Records teams recovering the approved data behind unsupported repairs
How the work fits into the transaction or program
The repair history sits on top of the configuration baseline and feeds the structural picture a transaction and a program both read. This review confirms each repair reaches a producible approval basis, and its exception list drives the substantiation recovery a transfer or a program acceptance depends on.
Aircraft-specific considerations
On the 737 MAX, modification embodiment and configuration control matter as much for repairs as for parts, because a repair to a modified area has to reference data valid for the embodied standard, not the baseline type. Repairs interacting with structural or systems modifications are where the approved-data reference most often points to a superseded basis, so those are checked against the current configuration rather than the as-delivered one.
Jurisdiction-specific considerations
A repair approved under an FAA basis is not automatically recognized when a 737 MAX moves to an EASA register, so the review flags repairs whose approval basis the receiving authority will need restated or validated.
Regulatory limits
This review checks that each repair reaches an approval basis the file can produce. It does not approve repair data, develop substantiation, or make an airworthiness determination on a repair or the aircraft.
What this review does not cover
- Developing or approving repair or alteration data
- Performing or re-performing any repair
- Any airworthiness determination on the repairs or the airframe
Specific to this review
- A repair signed off as complete can still rest on data whose approval basis nobody has confirmed, which is exactly what a buyer asks to see.
- A repair to a modified area must reference data valid for the embodied standard, so the approval basis can be real yet wrong for this configuration.
- A repair added at a heavy check but never reflected on the map leaves the recorded configuration understating the airframe.
Sources
U.S. Government (eCFR). Maintenance recordkeeping content and approval-for-return-to-service requirements, including 43.9, 43.11, and Appendix B.
U.S. Government (eCFR). Records an owner or operator must keep, including total time in service, current status of life-limited parts, and AD compliance.
European Union / EASA. Continuing airworthiness, maintenance records, CAMO responsibilities, and the airworthiness review process in the EASA system.
Frequently asked questions
The repairs are all signed off. Why check the approval data?
A sign-off records that the work was done and returned to service. It does not by itself prove the data it was done to was approved or that the file can still produce that basis. A buyer or a receiving authority will ask for the approved-data reference, and this review finds the repairs where that reference is missing or wrong for the configuration.
Relevant glossary terms
Related pages
Where this fits
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