Repairs and alterations
Repair and alteration record review against the modification baseline
A repair map lists what has been done to the structure and systems; the modification baseline holds the evidence of what was approved. This review reads each repair and alteration on the map against SB records, STC files, embodiment evidence, effectivity notes, and configuration-control logs to confirm the approved data, disposition, and any recurring requirements are actually on file. It serves configuration managers and fleet engineers preparing a baseline, a heavy-check induction, or a transaction. The deliverable is an exception list of repairs whose approval basis the file cannot produce, each tagged with its likely evidence source.
When this review is needed
- The repair map or dent-and-buckle chart is being adopted into a configuration baseline and each entry needs an approval basis on file.
- A repair interacts with a later modification, and it is unclear whether the repair's approval still holds for the changed configuration.
- Heavy-check planning needs to know which existing repairs carry recurring inspection requirements the program must track.
- A counterparty review is expected to sample structural repairs, historically the richest source of transaction findings.
The problem
Repairs accumulate across operators, shops, and decades, and each one was approved in its own moment: a manual chapter reference here, engineering-approved data there, an authority field approval somewhere else. The repair map records that a repair exists, but the substantiation lives in whichever work package, engineering file, or predecessor operator's archive held it at the time. Later modifications quietly complicate matters further, because a repair approved on the original structure may sit differently once an SB or STC has changed the surrounding configuration.
What gets reviewed
- Every entry on the repair map traced to its approved data: manual reference, engineering approval, or authority acceptance
- Dispositions confirmed as filed for each repair, including temporary repairs and their permanent-fix deadlines
- Recurring inspection requirements extracted from repair approvals and checked against the tracking program
- Repair-to-modification interactions examined where SB or STC embodiment changed the repaired area
- Alterations distinguished from repairs and checked for the approval class each actually required
- Map completeness sampled against work packages, so repairs evidenced in the file appear on the map
Scope this review
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What gets validated
- Each map entry cites approved data that exists in the file and covers the repair as actually performed, including size and location
- Temporary repairs show either a filed permanent disposition or a live deadline the program is tracking
- Repairs in areas later modified carry evidence that the approval basis was reassessed or remains applicable
- Every recurring requirement from a repair approval has a corresponding tracked task with a correct interval
- No work package in the sample evidences a repair absent from the map
Evidence normally required
- The repair map or dent-and-buckle chart with its supporting repair files
- Work packages and embodiment evidence for sampled repairs and adjacent modifications
- SB and STC files affecting repaired areas
- The maintenance program's tracked-task list for repair-driven inspections
- Predecessor operator records where repairs predate current custody
Common discrepancies
- A repair recorded with a bare manual reference where the repair's actual dimensions fall outside that chapter's limits
- A temporary repair that outlived its disposition deadline with no filed extension or permanent fix
- A recurring inspection from a repair approval that never entered the tracking program after a system migration
- Repairs found in work packages that never reached the map, usually from line stations or outstation events
What is at stake
A repair without producible approved data becomes an engineering problem on someone else's schedule: a heavy check finds it and stops, or a buyer's team finds it and discounts, or an authority finds it and asks the question the file cannot answer. Recurring inspection requirements attached to unsubstantiated repairs are the sharpest edge, since missing them is a compliance lapse rather than a paperwork gap. Reconstruction after the fact means re-engineering the repair from measurements, at a cost out of proportion to filing the data correctly the first time.
Move from findings to resolution
Move from findings to a documented resolution path.
How the work runs
Reconcile the map
Establish the working repair population from the map plus a work-package sample that catches unlisted repairs.
Pull each basis
Locate the approved data and disposition for every entry and grade coverage against the repair as performed.
Chase the interactions
Examine repairs in modified areas and extract recurring requirements into a tracking comparison.
Report by exposure
Deliver exceptions ranked by compliance and check-planning impact, with the substantiated annex.
What the buyer receives
- An exception list per repair naming the missing element: data, disposition, reassessment, or tracked task
- A substantiated-repair annex citing the approval basis and file location for each verified entry
- A tracking reconciliation showing repair-driven requirements matched into the maintenance program
Who uses the output
- Configuration managers certifying the repair dimension of the baseline
- Structures engineers prioritizing which unsubstantiated repairs need engineering attention first
- Records and transition teams preparing for heavy-check induction or counterparty sampling
How the work fits into the transaction or program
Repair substantiation closes the loop the other baseline reviews open: AD and SB checks establish what should have been done, while this review establishes that what was done to the airframe along the way is defensible. Its output feeds heavy-check planning directly, since unsubstantiated repairs found at induction are the classic source of unplanned check scope.
Jurisdiction-specific considerations
The FAA frames repair approval through 14 CFR Part 43 and its distinction between major and minor work, with major repairs demanding approved data and specific documentation, while EASA under Regulation 1321/2014 channels repairs through approved data mechanisms with a different major-minor logic. Aircraft that have lived under both systems carry repairs approved under each convention, and a repair correctly approved in one era can lack the documentation the current system's reviewers expect to see, which the review flags as a context exception rather than a defect in the original approval.
Regulatory limits
The review verifies documentation against the repair map. It does not approve repairs or repair data, does not classify work as major or minor on the authority's behalf, does not perform structural assessment, and does not determine continued airworthiness of any repaired area. Engineering and regulatory dispositions remain with the design-approval holders, the operator, and the authority.
What this review does not cover
- Physical inspection or mapping of repairs on the aircraft
- Engineering reassessment or re-approval of repair data
- Creation of new repair records for undocumented damage
Specific to this review
- Repair findings dominate transaction discrepancy lists because every repair is unique, so no status list can vouch for them in bulk the way an AD list vouches for directives.
- The manual-reference shortcut fails quietly: a chapter citation looks complete until someone compares the repair's actual dimensions to the chapter's limits.
- Modification embodiment over an existing repair is a compound event that neither the repair file nor the modification file typically owns, which is exactly why it goes unexamined.
- Outstation and line-maintenance repairs are the most common map omissions, since their paperwork enters the system through a different channel than hangar work.
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
How is this different from a structures engineer reviewing our repairs?
An engineering review judges the repairs technically. This review is documentary: it establishes which repairs can produce their approval basis and which cannot, so engineering effort goes only where substantiation is actually missing. In practice it is the filtering step that makes the engineering review affordable.
Can it cover repairs done by operators we have no relationship with?
The review identifies which repairs trace to prior custody and what evidence should exist for each. Recovery from predecessor operators is a remediation activity, but the exception list is built to support it, naming the era, the likely holder, and the specific document needed.
Relevant glossary terms
Related pages
Where this fits
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