Approved Versus Acceptable Repair Data: How To Make Sure .

Approved VersusAcceptable Repair Data:How to Make Sure YouHave What You NeedClassifying a repair as“major” or “Minor” isbased on the complexityof the repair andthe capability of theoperator.06a e r o q u a rt e r ly   qtr 03 07

by Dale Johnson and Ron Lockhart,Regulatory and Industry Liaison Program Managers,Commercial Aviation ServicesBoeing aims to provide a quick and accurate response to operator requestsfor repair data. However, the escalating operator demand for approved repairdata can mean longer response times and result in operators having airplanesout of service longer than desired. By understanding the different types ofrepair data, applicable regulations, and the process for submitting requestsfor repair data, operators can receive the repair data they need and minimizethe length of time an airplane is out of revenue service.Operators are often faced with a dilemma whendetermining the type of repair data that is neededto meet regulatory requirements. Under the UnitedStates Federal Aviation Administration (FAA)system, repair data can be classified as either“acceptable” or “approved.” In European AviationSafety Agency (EASA) regulations, all repair datashall be “approved.”In addition, a new bilateral agreementbetween the United States (U.S.) and the EuropeanUnion (EU) is refocus ing attention on the issue ofapproved versus acceptable repair data. Manyoperators and mainte nance, repair, and overhaul(MRO) organiza tions in the EU are not familiar with“acceptable” repair data because it is notcommonly allowed by EASA.boeing.com/commerc i a l / a e r o m a g a z i n eThis article defines “acceptable” and“approved” repair data, explains the differencesbetween the FAA and EASA regulations, outlinesthe repair data section of the new bilateralagreement between the U.S. and the EU, andfamiliarizes operators with the most effectiveways to receive the appropriate repair data neededfrom Boeing.data type are summarized in figure 1, and furtherexplained in subsequent sections of this article.Boeing and the FAA expect appropriatelyapproved airline, maintenance, and MRO person nel to assess whether a repair is major or minor,and to use an assessment process preapprovedby their national aviation authority.FAA SYSTEMApproved versusacceptable repair dataBy understanding the type of repair data neededfor each classification of damage, operators canminimize delays and return airplanes to revenueservice quickly. The FAA and EASA definitions ofeach classification of damage and authorized repairOperators under FAA jurisdiction are responsiblefor ensuring that repairs are accomplishedaccording to all applicable regulations underU.S. Code of Federal Regulations 14 CFR Part 43.Airplane repairs of damage can be classified aseither “major” or “minor.” This assessment is07

FAA VERSUS EASAOVERVIEWFigure 1fa a d e f i n i t i o nAlthough the FAA and EASAhave similar definitionsfor what constitutes majorand minor repairs, therequirement for acceptableor approved data is quitedifferent.pa r t 1Major repairs are those thatif improperly done, mightappreciably affect weight,balance, structural strength,performance, power-plantoperation, flight characteristics,or other qualities affectingairworthiness or that; are notdone according to acceptedpractices or elementaryoperations.M a j o r R e pa i rMinor repair is any repair,other than a major repair.m i n o r R e pa i rbased on the scope and complexity of the repairand the experience and capability of the operator.The responsibility for determining whether arepair is major or minor rests with operators, repairstations, and holders of an inspection or mainte nance authorization. Because the classification ofa repair as either major or minor is not a 14 CFRPart 25 requirement, this classification is outsidethe scope of FAA authority delegated to Boeing. Inthe U.S., all operators have authority to useacceptable repair data for minor repairs withoutadditional FAA approval.FAA Advisory Circular (AC) 43-18 describesacceptable data as data acceptable to the FAA08that can be used for maintenance, minor repair,or minor alteration that complies with applicableairworthiness regulations. Acceptable data can beprovided by a type certificate (TC)/supplementaltype certificate (STC) holder or third-party operatoror MRO qualified engineer.FAA AC 120-77 defines approved data as:“Technical and/or substantiating data that hasbeen approved by the FAA” or by an FAA delegatesuch as a FAA-designated engineering represen tative (DER) or FAA-authorized representative (AR).If the operator’s qualified personnel determine thedamage necessitates a major repair, then FAAapproval of the repair data is required. Operatorshave many ways to obtain FAA-approved repair data:Accomplish the repair per the Boeing structuralrepair manual (SRM) because all repairs in theBoeing 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 repairsusing an FAA form 8110-3. Where FAA authorization has been delegated toBoeing under delegation option authorization (14CFR Part 21.231), a Boeing AR may approve theengineering repair data on an FAA form 8100-9. a e r o q u a rt e r ly   qtr 03 07

easa definitionfa a r e pa i re a s a r e pa i rpa r t 2 1d at ad at aAll other repairs that arenot minor.Approved data from the FAAor FAA designee — designatedengineering representative (DER)or authorized representative (AR)Approved by EASA orEASA design organizationapproval (DOA)Acceptable data fromthe operator ortype certificate (TC) /supplemental typecertificate (STC) holderApproved data by EASA orEASA DOA; or acceptabledata from the TC/STC holderor third party*(Ref. EASA GM 21A.91 andGM 21A.435[a])A minor repair is one thathas no appreciative effect onthe mass, balance, structuralstrength, reliability, operationalcharacteristics, noise, fuelventing, exhaust emissions,or other characteristicsaffecting the airworthinessof the airplane.* Acceptable data developed under the FAA system for a minorrepair will be automatically approved by EASA under thepending U.S.-EU Bilateral Aviation Safety Agreement.EASA SYSTEMEASA regulations (Commission Regulation Euro pean Community [EC] 2042/2003 Annex I Part M)require “approved” data for both minor and majorclassifications of airplane repairs. This policy is incontrast to the FAA system that requires “approved”data for major repairs only and “acceptable” datafor minor repairs.Additionally, EU operators under EASA regu lations cannot make determinations of minor ormajor for repairs unless they hold an EASA designorganization approval (DOA). EU operators withoutboeing.com/commerc i a l / a e r o m a g a z i n ean EASA DOA must rely on EASA directly or con tract with an EASA-authorized DOA holder to havethe repair classified.There are different levels of EASA DOAauthorization. For example, Basic DOA allows theholder to classify major or minor repairs andapprove minor repairs only. A TC/STC holder withan EASA DOA can also approve both major andminor repairs.Regulations similar to EASA’s are beingadopted by global national aviation authoritiesoutside the EU, including Australia and India.U.S.-EU BILATERAL AVIATIONSAFETY AGREEMENTBoth the FAA and EASA continue to work toharmonize regulations with joint principles andprocesses. To minimize the impact to operatorsresulting from two distinct repair data approvalsystems, a special interim provision from theU.S.-EU Bilateral Aviation Safety Agreement wasreleased on April 1, 2007.Amending the Implementation Procedures forAirworthiness (IPA) in existing Joint AviationAuthorities (JAA) bilateral agreements between theU.S. and six EU member states (France, Germany,09

Boeing Repair SketchSTA410-2 TriplerSTA420-1 DoublerSTA4306 EQUAL SPACES– 7.50STA4403.05S-2R3.05(LNSPL -251)3.60 SEC1.80XF FNCRBL5.001.20 (TYP).60 (TYP) .40 (TYP).40 (TYP)2 EQ SPS (TYP) XF FNCX2G 3N (8 PLACES)C(CSK IN-619) BSC .98 SEEIBIIC12XF FNC.49XF FNCSTA4507 EQUAL SPACES– 8.75.901.80S-11B9-25SCALE 1/2FND,Stagger fastenersthese areas Antenna cutout Trimout1. Sample repair design forfuselage skin cracks2. Operator layout ofrepair design103. Operator repairdoubler installationa e r o q u a rt e r ly   qtr 03 07

Example of a wing sparchord repair.Example of a wing sparweb splice repair.boeing.com/commerc i a l / a e r o m a g a z i n e11

structures 8110-3/8100-9requests versus fleet size(707, 727, 737, 747, 757, 767, 777)Figure 2 8110-3/8100-9 Fleet 02059250000199219992006The number of requests for approved repair data via anFAA form 8100-9 for 707, 727, 737, 747, 757, 767, and777 airplanes has increased nearly sixfold since 1992,a rate disproportionate to the growth in the size of theworldwide Boeing fleet.12a e r o q u a rt e r ly   qtr 03 07