Defects and dispositions
Non-routine card closures in an import and export records package
Every non-routine card in the package records a defect the aircraft actually had, and an importing authority reads them for exactly that reason. This review reconciles the non-routine register against the cards themselves, confirms each closure carries a disposition and corrective action, and traces repair-related closures to their approval basis. Timed for import, export, or registry-change preparation, it completes before the authority reads the file. The transition lead receives an exception list showing which closures the source evidence supports and which need work.
When this review is needed
- The last heavy check generated a large non-routine volume and the closures were never independently read.
- Structural or repair-related non-routines exist whose approval basis must satisfy the importing authority.
- Register and card set came out of different systems and their counts have never been reconciled.
- Deferred non-routines were carried out of a check and their trail into the deferral log is uncertain.
The problem
Non-routine cards are written under check-time pressure by whoever found the defect, and closed under delivery pressure by whoever ran out of runway. Dispositions get abbreviated, corrective actions point at repairs documented somewhere else, and cards deferred at check exit scatter into other systems. The register that summarizes all of this is only as honest as the reconciliation nobody has done.
What gets reviewed
- Register-to-card reconciliation across the checks in scope, in both directions
- Closure quality on each sampled card: disposition stated, corrective action identified, certification present
- Repair-related non-routines traced to drawings, SRM references, or engineering approvals
- Part replacements arising from non-routines, followed into the component and release records
- Non-routines deferred at check exit, followed into the deferral or open-items system
- Cross-references from non-routine cards into logbook entries and damage records
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
- Every register line resolves to a physical or scanned card, and every card appears on the register
- Sampled closures state what was found, what was done, and under what data, with a valid certification
- Repairs raised through non-routines carry an approval basis appropriate to their classification
- Parts changed under non-routines trace to release certificates in the component records
- Deferred non-routines reappear in the deferral log with matching identity and limits
Evidence normally required
- The non-routine register for each check in scope
- The complete non-routine card sets, with attachments and referenced work orders
- Repair dossiers or engineering approvals referenced by non-routine closures
- The deferral log and open-items list current at package assembly
- Component change records and release certificates tied to non-routine part replacements
Common discrepancies
- A closure marked complete whose card contains no corrective action, only the defect description
- Repairs referenced by non-routines with no drawing, dimension record, or approval attached
- A card deferred at check exit that never landed in the deferral system
- Replaced parts named in closures with no matching release certificates in the component file
What is at stake
Non-routines are where an authority review shifts from checking status to probing substance. A closed defect without a visible fix invites the question of whether the aircraft still carries it, and that question arriving after the export application is filed costs far more than the same question answered in the package. Unresolved structural non-routines can hold a registry change until an engineering answer exists.
Move from findings to resolution
Move from findings to a documented resolution path.
How the work runs
Reconcile the counts
Match register lines to cards and cards to register lines for every check in scope.
Sample for substance
Read closures with weight on structural, repair, and late-check items.
Follow the threads
Trace repairs to approvals, parts to releases, and deferrals into the open-items system.
Deliver the exceptions
Report each unsupported closure with its evidence gap and the party positioned to fill it.
What the buyer receives
- A reconciled register annotated with the evidence state of every closure
- An exception list ranked by authority sensitivity, structural and repair items first
- A trace file linking repair-related non-routines to their approval documents or to the gap
Who uses the output
- Transition leads judging which findings must close before the authority filing
- Engineering and CAMO staff resolving repair-basis questions the review surfaces
- The importing operator's records team inheriting the open items after transfer
How the work fits into the transaction or program
The non-routine review pairs with the task-card check: routine cards prove planned work, non-routines prove what the aircraft revealed along the way. Its repair findings flow into the structural repair map review, and its deferral findings into the deferred maintenance review, so the three are usually sequenced together in the package build.
Jurisdiction-specific considerations
Both FAA and EASA frameworks require that maintenance records describe the work performed, but they diverge on repair-data acceptance: data approved for one registry may need a recognized acceptance route for the other. Non-routines that spawned repairs are therefore read twice, once for closure quality and once for whether their approval basis travels to the destination registry.
Regulatory limits
This is an evidence review, and its boundaries are strict: it makes no judgment on whether a defect was correctly dispositioned from an engineering standpoint, issues no repair approvals, and offers no airworthiness determination. Engineering adequacy and acceptance sit with the design and maintenance organizations and the authorities.
What this review does not cover
- Engineering re-evaluation of dispositions or repair designs
- Physical inspection to confirm defects were rectified
- Rework of the maintenance provider's register or card records
Specific to this review
- Count mismatches between register and cards are the fastest completeness screen available, and running it in both directions catches different failure modes.
- Non-routines most likely to block a transfer are the quiet structural ones closed by reference to a repair that was never separately documented.
- Cards raised in the last days of a check show measurably weaker closures than early ones, a pattern experienced reviewers sample for deliberately.
- An importing authority that finds one weak closure tends to request the entire register history, which converts a card-level problem into a package-level one.
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
The check was released to service, so were the non-routines not already accepted?
The release covers the work performed under the maintenance organization's approval at the time. A registry change puts the records in front of a different authority applying its own review habits, and a closure that passed unremarked at check exit can still fail as evidence at import.
Relevant glossary terms
Related pages
Where this fits
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