Repairs & alterations
Major repair and alteration records review
A major repair and alteration records review confirms that each major change to the aircraft is recorded on the right document and backed by the approved data and continued-airworthiness instructions it relies on. It is used by lessors, airlines, and acquisition teams before a return, a sale, or a configuration reconciliation. It covers the recording documents for major repairs and alterations, the approved data behind each one, and any instructions for continued airworthiness the change introduced. You receive a change-by-change status, a list of changes that lack support, and the path to close each gap.
When this review is needed
- A configuration shows alterations that are not matched to an approval basis in the records.
- A return condition requires that each major change carry its approved data and instructions.
- A repair was embodied during the lease and the recording document is missing or incomplete.
- A buyer needs the alteration history substantiated before pricing the airframe.
The problem
Major changes are recorded on a document that should name the approved data and the instructions that come with the change, but in practice the recording document and the approval basis drift apart. A change embodied with no recording document, a document that cites approved data nobody can produce, or an alteration with no instructions for continued airworthiness all leave a configuration that cannot be fully substantiated.
What gets reviewed
- Each recorded major repair and major alteration on the airframe
- The recording document for each change and its completeness
- The approved or acceptable data the change relies on
- The approval basis, whether a field approval, an STC, or other accepted route
- Instructions for continued airworthiness introduced by the change
- The match between the recorded changes and the current configuration baseline
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 major change has a complete recording document with the work described
- The recording document cites approved or acceptable data that can be produced
- The approval basis named is appropriate to the change and present in the records
- Instructions for continued airworthiness exist where the change requires them
- Recorded changes reconcile with the current configuration baseline
- No alteration appears in the configuration without a corresponding recorded change
Evidence normally required
- Major repair and alteration recording documents
- Approved or acceptable data cited by each change
- Approval basis evidence such as field approvals or STC references
- Instructions for continued airworthiness associated with the changes
- Modification and repair status list and the configuration baseline
Common discrepancies
- A major change recorded with no document, or a document missing required content
- Approved data cited on the document that cannot be produced from the records
- An alteration with no identifiable approval basis
- A change that should carry continued-airworthiness instructions but does not
- Configuration that shows an alteration with no corresponding recorded change
- A repair recorded under acceptable data where approved data was required
What is at stake
An alteration without an approval basis can be challenged at a return, force a removal or re-approval, or reduce what the airframe can be sold or re-leased against. Reconstructing approved data and instructions after the embodying organization has moved on is slow and sometimes impossible.
Move from findings to resolution
Move from findings to a documented resolution path.
How the work runs
List the changes
Identify every recorded major repair and major alteration and gather its recording document.
Trace the data
Confirm each document cites approved or acceptable data that can be produced and an appropriate approval basis.
Check instructions
Verify that changes requiring continued-airworthiness instructions actually carry them.
Reconcile configuration
Match recorded changes to the configuration baseline and route each unsupported change to closure.
What the buyer receives
- A change-by-change status covering document, approved data, and instructions
- A list of changes lacking a recording document, an approval basis, or instructions
- A recommended path to substantiate, re-approve, or otherwise close each gap
Who uses the output
- Records and engineering teams substantiating the alteration history
- Asset and acquisition teams pricing an altered airframe
- Continuing-airworthiness staff reconciling configuration before a return
How the work fits into the transaction or program
The review runs inside a configuration or return check and confirms that the major changes carried by the airframe are recorded and supported. It feeds the discrepancy register and the modification section of the records package.
Jurisdiction-specific considerations
An alteration approved under one authority's basis is not automatically valid under another. Where the airframe moves between authorities, the review identifies which changes need a recognized approval basis for the receiving authority rather than assuming the original carries over.
Regulatory limits
The review confirms that major changes are recorded and supported by data and instructions. It does not approve data, issue a field approval or an STC, or make an airworthiness determination on any alteration.
What this review does not cover
- Generating or approving repair or alteration data
- Physical inspection of the repairs or alterations themselves
- Any airworthiness determination on a change's acceptability
Specific to this review
- The recording document and the approval basis are separate artifacts that frequently drift apart, so a complete document citing data nobody can produce is still a gap.
- A major alteration can introduce its own instructions for continued airworthiness, and a change missing those instructions leaves the configuration incompletely supported.
- An alteration visible in the configuration with no recorded change is as much a records gap as a recorded change with no supporting data.
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
What separates a major change from a minor one for this review?
The review follows the classification already applied in the records and the applicable rules, then concentrates on whether each change classified as major carries the recording document, approved data, and instructions that classification calls for.
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.