Repairs on record
Structural repair records review inside the lease-transition file
Structural repair records carry the longest tail in a transition file, and this review reads them the way the next inspector will. It takes the structural repair map presented in the lease-transition file and tests every mapped repair for the evidence behind it: the damage report, the approved repair data, the accomplishment record, and any repeat-inspection obligation the repair created. Repairs outside SRM limits are checked for a specific approval basis under FAA or EASA rules. The output is an exception list keyed to repair map references that the transition lead can defend at acceptance.
When this review is needed
- A heavy check during the term embodied repairs whose dossiers were left in the check package rather than the transition file.
- The counterparty's survey photographed external doublers that the current repair map does not explain.
- Repairs approved under a previous registry are about to be judged by a different authority's expectations after transfer.
- The incoming CAMO has asked which repairs carry repeat inspections and no single document answers the question.
The problem
Repairs accumulate over an airframe's life across operators and maintenance providers, and the map is only as good as the dossiers behind it. A mapped repair with no drawing, no measured damage, or no approval basis reads at transition as an unapproved repair regardless of how sound the metal is. Worse, the repeat-inspection obligations that some repairs generate live in an operator's tracking system, and they are the item most easily dropped when the aircraft changes hands.
What gets reviewed
- Every entry on the structural repair map traced to its damage report and repair dossier
- Approval basis for each repair, whether an SRM chapter and revision, DER-approved data, or an authority-approved design change
- Accomplishment evidence showing the repair was embodied to the approved data
- Repeat or supplemental inspection requirements generated by repairs, and where they are being tracked
- Repairs surfacing in heavy-check paperwork, photographs, or correspondence that never reached the map
- Interior and secondary structure repairs held in work packages rather than on the map
Scope this review
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What gets validated
- The map reference, dossier, and accomplishment record agree on location, station, and repair description
- SRM-based repairs cite a chapter and revision that actually covers the damage as measured
- Repairs beyond SRM limits carry approved data appropriate to the registry at the time of embodiment
- Repeat-inspection intervals stated in dossiers appear in the maintenance program or tracking extract
- No repair evidenced in source paperwork or survey photographs lacks a corresponding map entry
Evidence normally required
- The structural repair map or damage chart at its current revision
- Repair dossiers including damage reports, approved data, and embodiment records
- Heavy-check packages and work orders from the lease term
- The maintenance program or tracking extract carrying repeat-inspection items
- Transition correspondence, survey reports, and the open-item tracker
Common discrepancies
- A mapped repair whose dossier contains the damage report but none of the approved data it was worked to
- A repeat-inspection requirement stated in a dossier that never entered any tracking system
- Repairs evidenced in heavy-check paperwork that the map does not show
- A repair approved under a prior registry with no assessment of its standing after transfer
What is at stake
Unsupported repairs rank among the most expensive transition findings, because the options narrow quickly: recover data from a shop years after the event, commission new approval work, or concede value in the settlement. A dropped repeat inspection is a different order of problem, an airworthiness process failure the incoming CAMO must resolve before it operates the aircraft, and one that colors how every other record in the file gets read.
Move from findings to resolution
Move from findings to a documented resolution path.
How the work runs
Index the map
List every mapped repair with its location, claimed basis, and dossier reference.
Pull the dossiers
Locate the damage report, approved data, and embodiment record for each repair across the folders.
Chase the obligations
Extract repeat-inspection requirements from dossiers and verify each one is tracked somewhere.
Write the exceptions
Deliver findings keyed to map references, each naming the missing or conflicting element.
What the buyer receives
- A repair-by-repair exception list keyed to map references
- A status table showing approval basis and accomplishment evidence for each mapped repair
- A register of repeat-inspection obligations found in dossiers, with their current tracking status
Who uses the output
- Transition leads answering the counterparty's structural queries with sources rather than assertions
- Incoming CAMO or maintenance-control staff who inherit the repeat-inspection burden
- Asset managers judging whether a structural finding is a records gap or an engineering problem
How the work fits into the transaction or program
This check feeds the wider lease-transition file review and connects sideways to the AD status work, since repairs sometimes constitute or interact with AD terminating action. Findings go onto the open-item tracker; gaps that cannot be closed from the file escalate to engineering for disposition, and the repeat-inspection register goes straight to whoever will run the aircraft's program next.
Jurisdiction-specific considerations
FAA-registered history typically shows approved data through DER-approved packages or, on older aircraft, field approvals, with the SRM serving as approved data within its limits. EASA-side repairs are approved under Part 21 design provisions, often through a design organization's privileges. A repair that was properly approved on one registry can still require review at transfer, because bilateral acceptance between authorities is not unlimited and the receiving CAMO must satisfy its own authority.
Regulatory limits
The review does not approve repairs, does not judge structural adequacy, and offers no engineering disposition or airworthiness determination. It establishes what the file proves about each repair and where the proof stops.
What this review does not cover
- Engineering evaluation or re-substantiation of any repair
- Physical inspection of the airframe or nondestructive testing of repaired areas
- Preparation of new repair approvals or design changes
Specific to this review
- Repair maps and repair dossiers age at different rates: maps get redrawn at heavy checks while dossiers stay buried in the check package, and the link between them is where evidence goes missing.
- A repair inside SRM limits at embodiment can fall outside them at a later SRM revision, and which revision governs the assessment becomes a genuine transition argument.
- Repeat inspections are the most commonly orphaned obligation at operator changes because they live in the tracking system, which does not transfer with the aircraft the way dossiers do.
- Photographic survey reports from earlier transitions often reveal external repairs no current map entry explains, which is why they belong in the input set.
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
A repair looks well made and we have photographs. Is that enough at transition?
Photographs evidence existence, and existence is rarely the dispute. Counterparties test the approval basis and the accomplishment record, because those are what let the repair be relied on for continued operation. A sound repair with no data trail is treated in negotiation much like an unapproved one, which is exactly the outcome this review is meant to prevent.
Relevant glossary terms
Related pages
Where this fits
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