IATA Aircraft Lease Guidance

Annex V: Structural Repair File Guidelines
2.2 FAA
Operators under FAA jurisdiction are responsible to ensure that repairs are accomplished according to the
applicable regulations as specified in US Code of Federal Regulations 14 CFR Part 43. As with EASA
regulations, repairs of damage can be classified as either ‘major’ or ‘minor’. The classification of ‘major’ or
‘minor’ is based on the scope and complexity of the repair and the capability of the maintenance provider
which in some instances is also the operator.
Unlike operators in an EASA environment, classification of a major or minor repair can be performed by the
operator itself, repair stations, or holders of an inspection or maintenance authorization. Because the
classification of a repair as either major or minor is not a 14 CFR Part 21 requirement, this classification is
outside the scope of FAA authority delegated to (S)TC holder.
All operators have authority to use acceptable repair data for minor repairs without additional FAA approval.
FAA Advisory Circular (AC) 43-18 describes acceptable data as data acceptable to the FAA complying with
applicable airworthiness regulations that can be used for maintenance, minor repair, or minor alteration.
Acceptable data can be provided by (S)TC holder or third-party operator, or MRO qualified engineer. FAA AC
120-77 defines approved data as: “Technical and/or substantiating data that has been approved by the FAA”.
This also includes an FAA delegate such as a FAA DER or FAA authorized representative (AR). If the
operator’s qualified personnel determines that the damage necessitates a major repair, then FAA approval of
the repair data is required. Operators have several ways to obtain FAA-approved repair data:
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Accomplish the repair per the SRM, because all repairs in the SRM are FAA approved
Apply to the FAA directly
Use a DER who has a “special delegation” from the FAA to approve data for major repairs using an FAA
form 8110-3
Where FAA authorization has been delegated to Boeing under delegation option authorization (14 CFR
Part 21.231), a Boeing AR may approve the engineering repair data on an FAA form 8100-9
2.3 EU-US Bilateral
Since 1 May 2011, a bilateral is in force between the US and the EU which consolidates earlier bilaterals
between the US and individual EU member states. This bilateral arranges the automatic acceptance of
certain repair data (minor/major) regardless of the State of Design of the product from TC/STC holders, or
third party, except repair data on critical components. This means that repair designs that have been
approved or accepted under the US system no longer need a separate approval by the EASA and vice versa,
except for repairs on critical components.
3. Repair File Overview
The obvious goal of the repair summary is to provide the user with clear, accurate, and detailed information of
all actions performed to address damages on the aircraft. Aircraft OEMs provide guidelines for record
keeping of repairs, such as Airbus, which describes the reason and requirements for proper record keeping in
its SRM as follows:
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