Repairs and alterations
Repair and alteration substantiation review in the continuing-airworthiness file
This review tests whether every repair and alteration the record set acknowledges is backed by approved data and a proper disposition in the continuing-airworthiness file. It is run for CAMO and maintenance leadership when the repair history must survive scrutiny: dent-and-buckle reconciliations, airworthiness reviews, or a counterparty's structures engineer at redelivery. Each entry on the repair map is traced to the substantiation that approved it, whether an SRM reference, DER-approved data, an STC, or an authority field approval. Repairs that stand in the history without their approval basis come back as a located, described exception list.
When this review is needed
- The dent-and-buckle chart and the repair file are being reconciled for the first time in years.
- A redelivery condition requires substantiation for every repair above SRM limits.
- An alteration was found on the aircraft that no record explains.
- Airworthiness-review preparation has flagged repair entries citing data nobody can produce.
The problem
Repairs accumulate over an airframe's life in layers: line-station blends, heavy-check doublers, and one-off engineering dispositions, each approved under whatever mechanism was fastest at the time. The repair map records that something was done; the approval that made it legitimate lives in a different file, often at a different organization. Time strips the connection until the map is a list of assertions.
What gets reviewed
- The repair map or dent-and-buckle record against repair files held in the CAMO archive
- Approval basis for each mapped repair: SRM chapter, engineering order, DER data, STC, or field approval
- Alterations and modifications recorded in the file against their approval and embodiment evidence
- Repairs categorized against damage limits, and whether the categorization is documented
- Repetitive-inspection requirements generated by repairs, traced into the maintenance program
- Repairs inherited from prior operators and the substantiation transferred with them
Scope this review
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What gets validated
- Every mapped repair cites an approval basis, and the cited document exists in the file at the referenced revision
- Repairs exceeding published SRM limits carry engineering approval rather than an SRM citation alone
- Approved data effectivity covers this serial number and the configuration at the time of repair
- Repair-generated repetitive inspections appear in the maintenance program with correct thresholds and intervals
- The physical record set, photographs and sign-offs, matches the repair the approval describes
Evidence normally required
- The current repair map or dent-and-buckle chart
- Repair and alteration files from the CAMO archive, including engineering orders and dispositions
- The maintenance program task list, for repair-driven inspections
- Heavy-check packages where major repairs were embodied
- Prior-operator repair documentation received at transition
Common discrepancies
- Mapped repairs citing an engineering order the file holds only as a request, never as an approved issue
- SRM references pointing at revisions that no longer permit the repair as performed
- Repair-generated inspections that never entered the maintenance program, leaving intervals silently missed
- Doubler installations visible in photographs but absent from the map entirely
What is at stake
A repair without approved data behind it gets read by reviewers as an unapproved repair, whatever its actual engineering quality. That reading can hold up a redelivery, trigger an authority finding, or force new engineering assessment of old work, with the aircraft's schedule hostage to a structures queue.
Move from findings to resolution
Move from findings to a documented resolution path.
How the work runs
Reconcile map and file
Compare the repair map to the repair archive in both directions to establish the true population under review.
Trace each repair to its approval
Locate the SRM citation, engineering order, or other approval basis and confirm it exists at the referenced revision.
Check effectivity and follow-on tasks
Verify the approved data covered this serial number and that repair-generated inspections entered the maintenance program.
Separate retrieval from engineering
Report each exception as recoverable paper or as a gap that only a new engineering assessment can close.
What the buyer receives
- A repair-level exception list separating missing substantiation from wrong or expired substantiation
- A reconciliation of the repair map against the file, with unmapped and unfiled items in both directions
- A remediation route for each exception: retrieval, re-approval, or engineering review
Who uses the output
- CAMO managers clearing repair exposure ahead of reviews and transitions
- Structures and engineering staff scoping re-approval work where data is truly gone
- Redelivery teams answering a counterparty's repair-substantiation demands
How the work fits into the transaction or program
The repair review runs against the same CAMO file as the AD, LLP, and release-document reviews but reaches further into engineering territory, since its exceptions often need a structures decision rather than a document retrieval. Its output pairs naturally with a physical survey: the map is proven against the file here, and against the airframe there.
Jurisdiction-specific considerations
Under 14 CFR Part 43, major repairs and alterations must be performed to approved data and documented accordingly, and 91.417 keeps those records with the aircraft. Regulation (EU) 1321/2014 places equivalent duties on EASA operators, with the CAMO responsible for holding repair substantiation. Aircraft that moved between systems often carry repairs approved under one framework being read under the other, and the review flags where that translation is doing load-bearing work.
Regulatory limits
The review establishes what substantiation the file holds for each repair. It does not approve repairs, generate or validate engineering data, classify damage, or determine that any repair or the aircraft is airworthy.
What this review does not cover
- New engineering analysis or repair design
- Physical mapping or NDT of the airframe
- Liaison with the type-certificate holder for repair approvals
Specific to this review
- Repair records are the one CAMO-file domain where an exception often cannot be cured by finding paper: if approved data never existed, engineering has to be done, on today's rules.
- The map and the file fail independently, so both directions matter: mapped repairs with no file, and filed repairs missing from the map.
- Repair-driven repetitive inspections are the highest-consequence defect class, because a missing document becomes a missed inspection interval.
- Photographs taken at embodiment are frequently the only evidence tying a specific doubler to a specific approval, which makes image legibility a records issue rather than a nicety.
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 aircraft has repairs from an operator that no longer exists. What then?
The review marks those exceptions as non-retrievable and routes them to engineering review rather than a document chase. In practice a structures engineer assesses the repair as found, against current data, which is slower but produces substantiation that stands on its own.
Relevant glossary terms
Related pages
Where this fits
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