Repairs and approved data
Structural repair records across the shop-visit source file
Every repair a shop embodies needs three things on file: the damage it addressed, the approved data it was worked to, and the inspection that closed it. This review walks the structural repair map produced at the visit and tests each mapped repair against the source package for those three anchors. It is done at closeout, for the quality or asset manager who has to accept the file. Each repair that cannot show its data or its closure comes back as a written exception with the missing element named.
When this review is needed
- The visit generated structural findings and the repair map has grown by dozens of entries.
- Repairs were worked to SRM chapters at the limit of their applicability and the substantiation must be on file.
- A DER approval or major-repair data package was used and its presence in the file needs confirming.
- The next operator's records audit will sample repairs, and unsupported entries would stall acceptance.
The problem
During a heavy visit, repairs are dispositioned fast: an inspector writes up the damage, engineering assigns data, the mechanic works the card, NDT closes it. The repair map gets assembled afterward from whatever the cards say. When a mapped repair lacks its drawing reference, its approval basis, or its closing inspection record, nobody notices at the time because the structure itself is sound. Only a critical read of the file exposes the gap, and closeout rarely includes one.
What gets reviewed
- Every entry on the repair map traced to a non-routine card and damage report
- Approved data references checked: SRM chapter and revision, DER data, or design-organization approval
- Repairs at or beyond SRM limits verified to carry an engineering disposition
- NDT and close-up inspection records matched to the repairs they cleared
- Repair categorization checked for any repetitive-inspection obligation it creates
- Map coordinates and descriptions verified against the card so the repair can be relocated on the aircraft
Scope this review
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What gets validated
- Each mapped repair cites approved data valid at the revision in force when the work was done
- The damage description on the card falls within the applicability of the data cited
- NDT reports in the file cover the inspection method and area the data required
- Repairs classified as major carry the corresponding approval and, where FAA rules apply, the Form 337 trail
- No card in the file describes a worked repair that is absent from the map
Evidence normally required
- The structural repair map or dossier as delivered at closeout
- Non-routine cards and damage reports from the visit
- Engineering dispositions, DER packages, or design-organization approvals used
- NDT reports and inspection sign-offs
- The SRM revision status applicable during the visit
Common discrepancies
- Mapped repairs citing an SRM chapter whose limits the recorded damage exceeds
- A repair worked to engineering data that never made it into the closeout file
- NDT closure recorded generically with no tie to the specific repair location
- Cards describing repairs the map does not carry, leaving the map incomplete as a configuration record
What is at stake
A repair without its approval basis on file is treated by any future reviewer as an unapproved repair until proven otherwise. That single classification can hold an aircraft out of a transaction while data is reconstructed, and reconstructing DER or design-organization substantiation years later is slow and sometimes impossible. Interior and hidden repairs are the worst case: the evidence in the file is all there will ever be without opening the structure again.
How the work runs
Reconcile map to cards
Match every map entry to its non-routine card and flag orphans in both directions.
Verify the data basis
Check each cited approval against the damage recorded and the revision in force.
Confirm closure
Tie NDT and inspection records to the specific repairs they cleared.
Issue the register
Report exceptions with a recovery path while the shop can still act.
What the buyer receives
- A repair-by-repair exception register naming the missing anchor for each finding
- A reconciled repair map annotated where the file supports each entry
- A prioritized recovery list for data still obtainable from the shop before the aircraft departs
Who uses the output
- Quality managers holding the closeout package open until exceptions clear
- Lessor representatives who must defend the repair record at the next transition
- CAMO and reliability staff tracking repairs that carry repetitive inspections
How the work fits into the transaction or program
The repair map created at a shop visit becomes the aircraft's structural history for every later transaction. Verifying it against the source cards while the shop's engineers and inspectors are still assigned to the aircraft is the only cheap moment to fix it; afterward, each exception becomes a records-recovery project of its own.
Start with a single asset
Confirm release certificates and component traceability are complete.
Jurisdiction-specific considerations
FAA files distinguish major repairs, which bring Form 337 and field-approval or DER data expectations under 14 CFR 43 Appendix B. EASA files under EU 1321/2014 lean on design-organization approvals and the Part-145 work report instead. The review applies whichever documentation logic governed the visit, and flags repairs approved under one system that the receiving jurisdiction will read differently.
Regulatory limits
The review examines documentation, never structure. It does not judge repair adequacy, approve data, classify damage, or determine airworthiness. Findings state what the file fails to evidence so the responsible organizations can supply or reconstruct it.
What this review does not cover
- Engineering evaluation of repair design or residual strength
- Physical inspection, NDT, or access opening
- Negotiation of repair acceptability with a purchaser or lessor
Specific to this review
- The repair map is usually compiled by a different person than the one who dispositioned the repairs, which is where citation errors enter.
- SRM revisions roll during long visits; a repair valid against the revision at induction can read as out-of-limits against the revision at closeout, and the file must show which applied.
- Repairs that create repetitive inspections are a double exposure, since the repair record and the resulting maintenance-program task both have to survive review.
- A missing damage report is often recoverable from the inspector's findings log for weeks after closeout, then effectively never.
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
What happens when a repair's approved data cannot be found?
The exception names the repair, the data cited, and who last held it. Recovery usually starts with the shop's engineering files or the DER of record. If nothing surfaces, the operator has a documented basis for pursuing new substantiation rather than a silent gap discovered by a buyer.
Relevant glossary terms
Related pages
Where this fits
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