Non-routine evidence
Non-routine closure records review for airlines ahead of a transaction
Non-routine cards carry the burden of proof at a transaction because each one records a defect someone found and someone else decided how to clear. This review takes the non-routine registers from an airline aircraft's recent checks and verifies that every closed card holds the full chain: the defect description, the engineering disposition or approved data that authorized the fix, the corrective action performed, and the final sign-off. Fleet and records teams run it in the months before a sale or lease return, while the operator can still reach the engineers and shops involved. Findings land as a register-keyed exception list with a recovery route per item.
When this review is needed
- A lease return is scheduled and the lessor's review team is known to sample non-routines heavily.
- Aircraft are being marketed for sale and heavy-check non-routine counts run into the hundreds per visit.
- Structural or repair-related non-routines exist whose approved-data references have never been centrally verified.
- A previous redelivery in the fleet generated non-routine findings and the same check packages are about to be reviewed again.
The problem
During a heavy check, non-routines close under production pressure: the fix gets done, the card gets signed, and the disposition that authorized it lives in an engineering email, a repair-design file, or the MRO's own system. Months later the card says closed, the register says closed, and the authorizing document is nowhere in the operator's records. Repairs are the sharpest case, because a counterparty will ask which approved data covered the repair and whether it was categorized correctly, and the answer has to come from paper, not memory.
What gets reviewed
- Non-routine registers from the checks in scope reconciled against the physical or scanned card sets
- Each closed card verified to contain defect, disposition, corrective action, and certifying sign-off
- Repair-related non-routines traced to the approved data and, where applicable, the repair approval record
- Deferred non-routines matched to MEL or deferral records and their eventual clearance
- Cards raised but voided or duplicated identified and their register entries corrected
- Cross-references between non-routines and the routine cards that raised them verified
Scope this review
Tell us the asset, the event, and the evidence in scope, and we will outline a focused first engagement.
Send a representative, redacted record set and we will scope the review.
What gets validated
- Register line counts reconcile to card counts, with voids and duplicates explained
- No card is signed closed while its corrective-action block is blank or refers to a document not on file
- Repair dispositions cite approved data valid for the aircraft and damage location
- Deferred items show authorized deferral and a closure record inside the allowed interval
- The sign-off on each sampled card belongs to a person or organization authorized for that task at that time
Evidence normally required
- Non-routine registers and card sets for the checks in scope
- Engineering disposition files, repair approvals, and referenced approved data
- Deferral and MEL records covering the same period
- The damage-and-repair chart or dent-and-buckle record for cross-checking structural items
- Lease return conditions or the sale agreement's records standard
Common discrepancies
- Closed structural cards whose disposition exists only in the MRO's system, never delivered to the operator
- Corrective-action text reading 'repaired IAW engineering' with no traceable engineering reference
- A deferral that expired before the closure record that eventually cleared it
- Register entries for cards that were voided on the floor but never annotated, inflating the open count
What is at stake
Every non-routine that cannot show its disposition becomes a question mark against the aircraft's repair history. At redelivery, unresolved repair documentation regularly escalates into damage-and-repair survey disputes and holds the aircraft on the ground past the return date. In a sale, buyers price the uncertainty or demand indemnities, and the operator ends up paying for work it actually performed correctly but cannot evidence.
Move from findings to resolution
Move from findings to a documented resolution path.
How the work runs
Reconcile the registers
Match every register line to a card and account for voids, duplicates, and deferrals.
Open the closures
Verify defect, disposition, corrective action, and sign-off on each card in the sample.
Chase the dispositions
Trace repair and engineering references to documents actually held in the operator's records.
Hand over the plan
Deliver the exception list with recovery owners and deadlines aligned to the transaction date.
What the buyer receives
- An exception list keyed to register line numbers with the missing element named per item
- A repair-documentation subset flagged for the damage-and-repair review that follows
- A recovery plan identifying which items need the MRO, which need engineering, and which need re-issue
Who uses the output
- Fleet-management and redelivery teams clearing items before the lessor's reviewers arrive
- Engineering and CAMO staff recovering dispositions from their own and the MRO's archives
- Transaction counsel assessing what the records condition can actually be certified against
How the work fits into the transaction or program
Non-routine review runs after the routine task-card check and feeds two downstream efforts: the damage-and-repair survey, which relies on the repair subset being documented, and the redelivery or sale exception schedule. Doing it early matters more here than anywhere else in records preparation because recovery paths run through third parties whose retention clocks are already ticking.
Jurisdiction-specific considerations
Repair documentation expectations diverge across regimes. Work under the FAA framework turns on whether data was acceptable or approved and on the major-repair paperwork trail where applicable, while EASA-governed repairs point to design-approval routes under Part 21. An aircraft crossing regimes at sale needs its repair-related non-routines readable in the receiving regime's terms, which the review flags item by item.
Regulatory limits
The review establishes documentary completeness of closed non-routines. It does not approve repairs, reclassify damage, issue engineering dispositions, or determine airworthiness. Where a disposition is missing, the review names the gap; producing valid engineering remains with the design and maintenance organizations involved.
What this review does not cover
- Physical inspection of repairs or structural survey of the aircraft
- Producing new engineering dispositions or repair approvals
- Negotiating redelivery compensation for items that cannot be closed
Specific to this review
- Non-routines are the highest-yield sample for a counterparty reviewer because a single card exposes defect handling, engineering authority, approved data, and certification practice at once.
- MRO document retention often runs on shorter internal clocks than the operator assumes, so dispositions recoverable today can be purged before the transaction closes.
- Corrective-action wording that references an engineering order without a number is the most common single defect and also the cheapest to fix while the check's engineering log still exists.
- A voided card left unexplained on the register reads to a reviewer as a missing card, which costs credibility beyond the item itself.
- Cabin and corrosion items closed by parts replacement are quick wins; structural repair items dominate recovery effort, so triage by class before chasing items in register order.
Sources
U.S. Government (eCFR). Maintenance recordkeeping content and approval-for-return-to-service requirements, including 43.9, 43.11, and Appendix B.
Federal Aviation Administration. FAA guidance on making and keeping maintenance records and acceptable recordkeeping practices.
European Union / EASA. Continuing airworthiness, maintenance records, CAMO responsibilities, and the airworthiness review process in the EASA system.
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.
Frequently asked questions
Should the damage-and-repair survey wait for this review?
Run this first. Survey teams work far faster when each structural non-routine already has its disposition and approved data located, and gaps found here often change which repairs the survey must physically verify.
Relevant glossary terms
Related pages
Where this fits
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