Repair file, US-bound
Repair approval records review before an EASA to FAA transfer
Repairs performed and approved during EASA operation rest on Part-21 design approvals, SRM authority, and CAMO dispositions, and a US-side reviewer reads that file with different reference points. This review goes through the damage reports, repair dispositions, approved-data references, and return-to-service entries, together with the repair map, and asks whether each repair can be shown as resting on data acceptable in the FAA system. A records specialist runs it before the package reaches the buyer or the FAA-side reviewer. It produces a substantiation map for the repair file, a gap list, and document requests for the design organizations and shops holding the missing approvals.
When this review is needed
- A US buyer's audit team has begun matching the repair map to substantiation documents and finding open references.
- Structural repairs were approved through an EASA design organization and the approval sheets were never collected into the aircraft file.
- The dent-and-buckle chart, the repair map, and the logbook disagree about how many repairs the airframe carries.
- The N-registration timeline is fixed and repair substantiation is the file with the most unknowns.
The problem
Under EASA operation, a repair's paper trail often ends at a design-organization approval reference: a number in a disposition, with the substantiation held by the organization that issued it. That is normal European practice and a problem at transfer, because the US-side reviewer wants to see the data or a recognizable approval, and the design organization has no continuing duty to the aircraft's next owner. Meanwhile repairs recorded against SRM authority need chapter-and-figure specificity that busy line entries rarely captured.
What gets reviewed
- Repair map and dent-and-buckle chart reconciled with logbooks and work orders into one repair inventory
- Each repair's approval basis identified: SRM within limits, design-organization approval, or STC-associated repair data
- Design-organization approval references chased to the actual substantiation sheets or minor-repair classifications
- Return-to-service entries checked for the data reference and revision actually used
- Allowable-damage items verified as within limits at the recorded dimensions and location
- Repairs interacting with AD-mandated structural inspections cross-checked against the AD file
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What gets validated
- Every repair on the map carries a substantiation reference a US reviewer can evaluate, at minimum the approving document itself
- Design-organization approvals in the file identify the organization, approval number, and applicability to this serial number
- SRM-based repairs cite chapter, figure, and the revision in force at accomplishment
- Damage dimensions recorded at disposition sit within the limits of the data cited
- Repair count and locations agree across the map, the chart, and the structural inspection history
Evidence normally required
- Repair map and dent-and-buckle chart as currently maintained
- Damage reports, repair dispositions, and CAMO assessment records
- Design-organization approval sheets and repair substantiation data where held
- Work orders, task cards, and return-to-service entries for repair events
- Structural AD and inspection records that reference repaired areas
Common discrepancies
- Dispositions citing a design-organization approval number with no copy of the approval or its data in the aircraft file
- Repairs recorded as within SRM limits with no dimensions noted, making the claim unverifiable
- A repair map missing items the dent-and-buckle chart records, usually from line-station events
- Minor-classification decisions that a US reviewer would revisit given the repair's size or location
What is at stake
Every repair the file cannot substantiate invites three bad outcomes: a document chase against an organization with no obligation to respond quickly, an engineering re-substantiation effort under transaction deadlines, or a physical re-evaluation of the repair itself. Structural items are the slowest to resolve, and an unresolved major repair can hold the buyer's acceptance even when the rest of the records are clean.
How the work runs
Unify the repair inventory
Merge map, chart, logbook, and work-order data into a single numbered repair list.
Attach substantiation
Chase each repair to its data: SRM reference with dimensions, approval sheet, or associated STC data.
Assess US-side readability
Flag repairs whose evidence a FAA-side reviewer cannot evaluate as delivered, ranked by significance.
Issue the requests
Deliver the substantiation map, gap list, and requests to design organizations and shops.
What the buyer receives
- A substantiation map covering every repair and alteration in the inventory
- A gap list ranked by structural significance and expected recovery difficulty
- Document requests addressed to the design organizations, shops, and prior operators holding substantiation
Who uses the output
- Records teams closing the repair file before the buyer's audit
- Asset managers sequencing which repair questions to resolve versus negotiate
- The incoming US operator's engineering support reviewing inherited repairs
How the work fits into the transaction or program
The repair strand of an EASA to FAA transition runs alongside the modification-status review, and the two share a boundary: alterations misfiled as repairs and repairs embedded in modification embodiments surface in both. Its document requests target design organizations with long response times, so it starts early, and its output feeds the master gap list the transaction team negotiates from.
Start with a single asset
Confirm the status list matches the underlying evidence.
Jurisdiction-specific considerations
In the EASA system, repair designs are approved under EU 748/2012 by design organizations or through SRM authority, with continuing-airworthiness records held under EU 1321/2014. The US framework reaches the same safety intent through 14 CFR Part 43 and its approved-data requirements, and it has no direct slot for a bare European approval reference. Acceptance at transfer therefore turns on producing the substantiation itself or an approval trail the FAA-side reviewer recognizes, which is exactly the evidence this review verifies exists.
Regulatory limits
The review is documentary. It does not approve repair data, reclassify repairs, direct any physical inspection, or determine airworthiness. Whether a given repair is acceptable on the US register is decided by the responsible persons and authority in that system; the review's role is to establish what evidence they will have in front of them.
What this review does not cover
- Physical inspection or nondestructive testing of repaired structure
- New repair-design engineering or re-substantiation analysis
- Warranty or liability claims against organizations that performed the repairs
Specific to this review
- Design-organization approval references are the defining gap in EU-operated repair files at transfer; the approval exists, but the aircraft file holds only its number, and retrieval depends on an organization with no duty to the new owner.
- Undimensioned allowable-damage entries cannot be defended later; without recorded size and location, the within-limits claim rests on the memory of whoever wrote the line.
- Repairs discovered on the chart but absent from the map usually date to line-station blend-outs, and their paperwork is the hardest class to recover.
- Cross-checking the repair file against structural AD inspections pays twice: it validates the repair record and catches directives whose inspection zones a repair has altered.
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.
U.S. Government (eCFR). Export airworthiness approval requirements and special requirements of an importing authority.
European Union / EASA. EASA design and production certification, STCs, ETSO authorizations, and EASA Form 1 release.
Frequently asked questions
The dispositions cite EASA design-organization approvals. Is that enough for the FAA side?
A citation alone rarely is. The reviewer needs to evaluate the repair against data, so the file should hold the approval sheet and, for significant repairs, the substantiation behind it. Requesting those documents while the design organization is still responsive to the current operator is far easier than after the aircraft changes hands.
Relevant glossary terms
Related pages
Where this fits
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