Repair data at export
Repair and alteration approval data review for MRO teams at export
This review prepares an MRO's repair and alteration records to stand behind an aircraft leaving the registry. It verifies that every entry on the repair map connects to a damage report, a disposition, approved data, and a return-to-service entry, and that the approval basis of each repair is one the destination side can accept. Records specialists perform it during export airworthiness preparation, ahead of the certificate request. Quality leadership receives a verified repair map, a register of substantiation gaps, and a worksheet showing the approval basis claimed for each repair.
When this review is needed
- An export is scheduled and the repair map has never been reconciled against the damage charts behind it.
- Older repairs cite approval references that nobody has tried to produce in years.
- Alterations were embodied under one authority and the destination side will re-read their basis.
- A buyer's structures reviewer is expected to walk the airframe against the map during the export survey.
The problem
Repairs accumulate over an airframe's life under whatever approval route was expedient at the time: within published structural repair manual limits, under delegated engineering approval, or through data accepted by a single authority. The repair map that summarizes them is maintained separately from the substantiation, and the two drift apart. Export review is where a foreign authority or buyer walks the map against the aircraft and the data, and every unlinked entry becomes the MRO's problem to explain.
What gets reviewed
- The repair and alteration map reconciled against dent-and-buckle or damage-chart records
- Damage reports and dispositions behind each mapped entry
- Approved data references: SRM chapters, delegated approvals, STC provisions, or authority-accepted data
- Return-to-service entries closing each repair in the aircraft records
- Alterations with ICA obligations, confirming the instructions entered the maintenance program
- Repairs whose approval basis is authority-specific and needs re-reading for the destination
Scope this review
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What gets validated
- Every mapped repair cites data that is producible, rather than merely referenced
- Within-limits SRM repairs actually fall inside the cited chapter's limits for location and size
- Delegated or authority approvals name the aircraft or repair they cover
- Each repair has a return-to-service entry signed under an appropriate approval
- No damage record exists without a corresponding disposition and map entry
Evidence normally required
- The current repair and alteration map or listing
- Damage reports, dent-and-buckle charts, and disposition records
- Approved data packages, delegated approvals, and STC documents
- Logbook and work-order entries returning each repair to service
- Prior heavy-check packages where older repairs were recorded
Common discrepancies
- Map entries citing SRM chapters whose limits the repair exceeds on measurement
- A delegated engineering approval referenced by number but missing from the records
- Alterations embodied years ago whose ICA never reached the maintenance program
- Damage chart marks with no traceable disposition anywhere in the records
What is at stake
A repair without producible approved data is read as an unapproved repair, whatever the quality of the work underneath the skin. That reading can strand the export until engineering data is regenerated, and regeneration for an old repair often costs more than the original repair did.
How the work runs
Reconcile the map
Cross the repair map against damage charts and check packages to find unmapped or undispositioned entries.
Pull substantiation
Assemble data, approvals, and return-to-service entries for every mapped repair.
Grade the basis
Assess each approval basis for producibility and destination acceptability.
Register and resolve
Issue the gap register and drive engineering and archive requests before export review.
What the buyer receives
- A verified repair map with each entry's substantiation status
- A substantiation gap register naming the missing document per entry
- An approval-basis worksheet flagging repairs that need destination-side reassessment
Who uses the output
- MRO quality leadership presenting the records at export review
- Structures or engineering liaison staff resolving data gaps
- The exporting owner's team negotiating findings with the receiving side
How the work fits into the transaction or program
Repair substantiation runs alongside the rest of the export records effort but has the longest engineering tail, since regenerating data involves people outside the records organization. The verified map also protects the MRO after export, because it fixes what was substantiated at handover.
Start with a single asset
Confirm release certificates and component traceability are complete.
Jurisdiction-specific considerations
A repair approved through one authority's delegation system is not automatically approved data under another; bilateral agreements govern what transfers and what needs revalidation. Under 14 CFR Part 43 the performance and approval rules frame US-side repairs, while EASA-side acceptance runs through Regulation 1321/2014 mechanisms, and the worksheet marks each repair against the system it must satisfy next.
Regulatory limits
The review verifies records and approval references. It does not approve repair data, perform engineering assessment of any repair, inspect structure, or decide destination-side acceptability, which rests with the receiving authority.
What this review does not cover
- Non-destructive testing or physical survey of repairs
- Generating or revising engineering substantiation
- Filing the export certificate application
Specific to this review
- The damage chart and the repair map are maintained by different processes, and export reviews find their disagreements before anyone else does.
- Within-limits claims fail on measurement more often than on paperwork, so cited limits are checked against recorded dimensions, never chapter references alone.
- An STC alteration is incomplete as a record until its ICA shows up in the operating program; the installation paperwork alone does not close it.
- Old repairs with lost data are recoverable more often through the original approving engineer's retained files than through the operator's archive.
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
The repairs were all signed off when performed. Why would they fail export review?
Sign-off proves return to service under the rules in force at the time and place. Export review asks a different question: can the approval data behind each repair be produced now and accepted by the destination authority? Records that answered the first question routinely fall short on the second.
Relevant glossary terms
Related pages
Where this fits
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