Engineering substantiation
Approval and substantiation records review
An approval and substantiation records review traces each engineering disposition on the aircraft back to the data that justifies it, so repairs and changes rest on substantiation that can actually be produced. It is used by lessors, airlines, and acquisition teams before a return, a sale, or a deep records review. It covers engineering orders and dispositions, the substantiation behind them, the approval route claimed, and how each ties to the recorded work. You receive a disposition-by-disposition status, a list of approvals with thin or missing substantiation, and the path to close each one.
When this review is needed
- A repair disposition cites substantiation that has never been filed with the records.
- A deep records review needs each engineering approval tied to producible justification.
- A non-routine finding was dispositioned during the lease and the basis is unclear.
- A buyer wants the engineering basis confirmed before relying on prior dispositions.
The problem
An approval signature records that a disposition was accepted, but the substantiation that should justify it, the analysis, the test reference, the approved repair data, is often summarized in a single line and never attached. A disposition that names substantiation nobody can locate, or an approval route that does not fit the disposition, leaves the engineering basis asserted rather than demonstrated.
What gets reviewed
- Engineering orders and dispositions applied to the aircraft
- The substantiation each disposition relies on and whether it can be produced
- The approval route claimed and its fit to the disposition
- Non-routine findings and how each was dispositioned and justified
- The link between each disposition and the recorded work that embodied it
- Consistency between the disposition, the substantiation, and the configuration result
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
- Each disposition names substantiation that can be produced from the records
- The substantiation actually supports the disposition it is cited for
- The approval route claimed is appropriate to the type of disposition
- Non-routine findings show a dispositioned and justified resolution
- Each disposition links to the recorded work that carried it out
- The disposition, its substantiation, and the resulting configuration agree
Evidence normally required
- Engineering orders and disposition records
- Substantiation data such as analyses, test references, or approved repair data
- Approval route references for each disposition
- Non-routine finding and resolution records
- Work records that embodied the dispositions
Common discrepancies
- A disposition citing substantiation that cannot be located in the records
- Substantiation on file that does not actually support the disposition claimed
- An approval route that does not fit the type of disposition made
- A non-routine finding closed without a recorded justification
- A disposition with no link to the work that embodied it
- A disposition, substantiation, and configuration result that disagree
What is at stake
A disposition with thin or absent substantiation can be challenged at a return, require re-substantiation or removal, or reduce confidence in the wider engineering record at a transaction. Recreating analysis or recovering test data years later is costly and frequently not feasible.
Move from findings to resolution
Move from findings to a documented resolution path.
How the work runs
Collect dispositions
Gather the engineering orders and dispositions applied to the aircraft and the substantiation each one cites.
Locate substantiation
Confirm the cited analysis, test reference, or approved data can be produced and that it supports the disposition.
Check the route
Verify the approval route fits the disposition and that non-routine findings carry a recorded justification.
Route gaps to closure
List dispositions with thin or mismatched substantiation and recommend re-substantiation or re-approval.
What the buyer receives
- A disposition-by-disposition status with the substantiation for each noted
- A list of approvals with thin, missing, or mismatched substantiation
- A recommended path to re-substantiate, re-approve, or otherwise close each gap
Who uses the output
- Engineering teams confirming prior dispositions are defensible
- Records teams assembling the substantiation package for a review
- Acquisition teams gauging confidence in the engineering record
How the work fits into the transaction or program
The review runs beneath a repair-and-alteration or deep records review and tests whether the engineering decisions behind the changes are actually justified. It feeds the engineering findings into the discrepancy register.
Jurisdiction-specific considerations
An approval route accepted by one authority does not guarantee the disposition is accepted by another. Where the aircraft crosses authorities, the review flags dispositions whose basis would need to be recognized or re-established for the receiving authority.
Regulatory limits
The review confirms that approvals are backed by substantiation that can be produced and is internally consistent. It does not generate substantiation, grant any approval, or make an airworthiness determination on a disposition.
What this review does not cover
- Producing analyses, test data, or approved repair data
- Granting or signing any engineering approval
- Any airworthiness determination on a disposition's acceptability
Specific to this review
- An approval signature records acceptance, while the substantiation that justifies it is a separate artifact that is frequently summarized and never attached.
- Substantiation that exists but does not actually support the disposition cited is a finding, because the approval then rests on unrelated data.
- A non-routine finding closed with no recorded justification leaves the disposition asserted rather than demonstrated, regardless of the signature.
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). Type certificates, STCs (Subpart E), TSO authorizations (Subpart O), PMA (Subpart K), and export airworthiness approvals (Subpart L).
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.
European Union / EASA. EASA design and production certification, STCs, ETSO authorizations, and EASA Form 1 release.
Frequently asked questions
How does this differ from a major repair and alteration records review?
A repair and alteration review confirms each major change is recorded on the right document with an approval basis. This review goes a layer deeper into whether the engineering dispositions, including non-routine resolutions, are backed by substantiation that can actually be produced.
Relevant glossary terms
Related pages
Where this fits
Talk to an engineer who has done this work
We will walk through your current state, the records or evidence involved, and a scoped first engagement.
Walk through your situation with an engineer who has done this work.