EASA Aircraft Repair Design and Record Keeping Considerations – Ref 21.A.447

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Requirements are driven by EASA Part 21 Regulatory requirements

Introduction – New Major Repair

Relevant substantiation data associated with a new major repair design and record keeping should include:

» The identification of the damage and the reporting source;
» The major repair design approval sheet identifying the applicable specifications and references of justifications;
» The repair drawing and/or instructions and scheme identifier;
» The correspondence with the holder of the type certificate (TC), supplemental type certificate (STC), or auxiliary power unit European technical standard order (APU ETSO) authorisation, if its advice on the design has been sought;
» The structural justification (static strength, fatigue, damage tolerance, flutter, etc.) or references to this data;
» The effect on the aircraft, engines and/or systems (performance, flight handling, etc., as appropriate);
» The effect on the maintenance programme;
» The effect on airworthiness limitations, the flight manual and the operating manual;
» Any weight and moment changes; and
» Special test requirements.

Introduction – Minor Repair

Relevant minor repair documentation includes

» The identification of the damage and the reporting source;
» The repair drawing and/or instructions and scheme identifier;
» Additional items from the above list as required.
» If the repair is outside the approved data, a justification for the classification is required.

Note 1: Special consideration should be given to repairs that impose subsequent limitations on the part, product or appliance (e.g. engine turbine segments that may only be repaired a finite number of times, the number of repaired turbine blades per set, oversizing of fastener holes, etc.).

Note 2: Special consideration should also be given to life-limited parts and critical parts, notably with the involvement of the TC or STC holder when deemed necessary under 21.A.433(a)(4).

Note 3: Repairs to the engine or APU critical parts would normally only be accepted with the involvement of the TC holder.

Repair Source Information Requirements

For each repair, all relevant design information, drawings, test reports, instructions and limitations possibly issued in accordance with point 21.A.443, justification for classification and evidence of the design approval, shall:

» Be held by the repair design approval holder at the disposal of the Agency; and
» Be retained by the repair design approval holder in order to provide the information necessary to ensure the continued airworthiness of the repaired products, parts or appliances.

Relevant substantiation data associated with a new major repair design and record keeping should include:

» The identification of the damage and the reporting source;
» The major repair design approval sheet identifying the applicable specifications and references of justifications;
» The repair drawing and/or instructions and scheme identifier;
» The correspondence with the holder of the type certificate (TC), supplemental type certificate (STC), or auxiliary power unit European technical standard order (APU ETSO) authorisation, if its advice on the design has been sought;
» The structural justification (static strength, fatigue, damage tolerance, flutter, etc.) or references to this data;
» The effect on the aircraft, engines and/or systems (performance, flight handling, etc., as appropriate);
» The effect on the maintenance programme;
» The effect on airworthiness limitations, the flight manual and the operating manual;
» Any weight and moment changes; and
» Special test requirements.

Further to the record-keeping requirements appropriate to or associated with the quality system, all relevant design information, drawings and test reports, including inspection records for the article tested, shall be held at the disposal of the Agency and shall be retained in order to provide the information necessary to ensure the continued airworthiness of the article and of the type-certificated product in which it is fitted

» All documents produced to establish and justify the flight conditions shall be held by the holder of the approval of the flight conditions at the disposal of the Agency and competent authority and shall be retained in order to provide the information necessary to ensure the continued airworthiness of the aircraft.
» All documents associated with the issue of permits to fly under the privilege of approved organisations, including inspection records, documents supporting the approval of flight conditions and the permit to fly itself, shall be held by the related approved organisation at the disposal of the Agency or the competent authority and shall be retained in order to provide the information necessary to ensure the continued airworthiness of the aircraft.

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