Repair-substantiation diligence
Structural repair records review against data-room evidence
This review takes the structural repair map a seller posts and asks whether the data room substantiates each mapped repair. For a sampled set it hunts down the originating damage report, the repair data and its approval basis, and any repeat-inspection obligations the repair created. It is run for buyers and lessors while the data room is live. Findings return as exception entries graded by the strength of each repair's paper.
When this review is needed
- The dent and buckle chart shows repairs the index has no engineering files for.
- A repair predates the seller's ownership and its approval basis was never handed over.
- Anything repaired near or beyond SRM limits needs its specific approval located before pricing.
- The next heavy check will inspect repaired areas and the repeat-inspection basis must be established first.
The problem
Repair maps record that metal was worked; they do not record why the repair was acceptable. The substantiation, an SRM chapter within its limits, an FAA Form 8110-3, a repair design from the type certificate holder, or EASA-approved data, lives in engineering folders that survive operator changes and archive migrations poorly. Sellers post the chart because it is one document; the several dozen files behind it are what the buyer actually needs.
What gets reviewed
- The repair map or dent and buckle chart reconciled with damage reports and non-routine records in the room
- Sampled repairs traced to their repair data and its approval basis
- Applicability of SRM-based repairs checked against the chart's dimensions and locations
- Repeat-inspection or supplemental-inspection obligations identified and matched to the program records
- Interactions with AD-mandated structural inspections flagged for the AD review
- Undocumented chart entries and unmapped repairs in the records logged in both directions
Scope this review
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What gets validated
- Each sampled repair cites data that was approved or acceptable for that damage, location, and size
- Dimensions and locations on the chart match the engineering documents behind them
- Repairs classified as within SRM limits actually fall inside the cited chapter's applicability
- Repeat inspections created by repairs appear as tracked tasks in the program records
- Chart revision history is coherent, with additions traceable to dated damage events
Evidence normally required
- The structural repair map or dent and buckle chart, all posted revisions
- Damage reports, non-routine cards, and repair engineering files in the uploads
- Approval documents such as FAA Form 8110-3 sign-offs or EASA-approved data references
- The maintenance program task list, for repeat-inspection cross-checks
- Q&A access for locating engineering files the index hides
Common discrepancies
- Chart entries with no engineering file anywhere in the uploads, especially from earlier operators
- Repairs marked as SRM-standard whose recorded size exceeds the cited chapter's limits
- A repeat-inspection requirement stated in the approval and absent from the task list
- Records of repaired damage that never made it onto the posted chart
What is at stake
A repair without an approval basis gets treated at the next check as damage: inspected, engineered, possibly redone. Missed repeat-inspection requirements can unravel the compliance story retroactively, and a chart that undercounts repairs, discovered at redelivery, converts into pricing disputes with no seller left at the table.
Move from findings to resolution
Move from findings to a documented resolution path.
How the work runs
Reconcile the chart
Compare all posted chart revisions with damage reports and non-routine records to fix the repair population.
Pull the substantiation
Locate repair data and approval basis for each sampled repair, including dimension and location checks.
Follow the obligations
Identify repeat-inspection requirements and confirm the program records carry them.
Grade the population
Report each sampled repair's documentary strength with exceptions for the deal schedule.
What the buyer receives
- A repair-by-repair substantiation grade across the sample
- Exception schedule entries with engineering-file references and exposure notes
- A repeat-inspection reconciliation for the buyer's CAMO or program review
Who uses the output
- Structures engineers advising the purchase or lease decision
- The buyer's continuing-airworthiness team loading repeat inspections into its program
- Deal leads pricing repair risk or drafting conditions for missing substantiation
How the work fits into the transaction or program
Structural repair review draws inputs from the non-routine closure review, where many repairs originate, and pushes outputs to the maintenance program check, which must carry the repeat inspections. On aging aircraft it also anchors conversations about the structural sampling and corrosion-control history the next check will price.
Jurisdiction-specific considerations
Acceptable approval routes differ: US repairs may rest on FAA-approved data, including DER sign-offs on FAA Form 8110-3 or FAA Form 337 major-repair records, while EASA-world repairs reference approved data under Part-21 and are executed under Part-145. Work executed in one regime on an aircraft now bound for the other deserves early scrutiny, because acceptance of the basis is never automatic.
Regulatory limits
The review evaluates documentation, never the structure itself. It makes no airworthiness determination, approves no repair data, performs no damage assessment, and does not substitute for the engineering judgment of design approval holders and authorities.
What this review does not cover
- Physical inspection or NDT of repaired areas
- Engineering development of substantiation for undocumented repairs
- Negotiating repair acceptance with the destination authority
Specific to this review
- A chart redrawn at each heavy check can silently drop entries the earlier revision carried, so all posted revisions get compared, never only the newest.
- Repairs from the aircraft's first decade are the least documented and the most likely to sit under later paint and later repairs, compounding at survey time.
- An approval that imposes repeat inspections effectively edits the maintenance program; if the program review does not know about it, both records are wrong.
- External repair counts from a physical survey and internal counts from the records rarely match on aging aircraft, and the direction of the mismatch matters commercially.
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 chart says every repair is within SRM limits. What is left to verify?
The classification itself. Within-limits is a claim about dimensions, location, and the cited chapter's applicability, and sampled charts regularly contain repairs whose recorded size or zone falls outside the chapter invoked. Verifying the claim against the engineering documents is the core of the review.
Relevant glossary terms
Related pages
Where this fits
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