Approved Versus

Acceptable Repair Data:

How to Make Sure You
Have What You Need

CLASSIFYING A REPAIR AS
“MAJOR” OR “MINOR” IS
BASED ON THE COMPLEXITY
OF THE REPAIR AND
THE CAPABILITY OF THE
OPERATOR.

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by Dale Johnson and Ron Lockhart,
Regulatory and Industry Liaison Program Managers,
Commercial Aviation Services

Boeing aims to provide a quick and accurate response to operator requests

for repair data. However, the escalating operator demand for approved repair
data can mean longer response times and result in operators having airplanes
out of service longer than desired. By understanding the different types of
repair data, applicable regulations, and the process for submitting requests
for repair data, operators can receive the repair data they need and minimize
the length of time an airplane is out of revenue service.

Operators are often faced with a dilemma when This article defines “acceptable” and data type are summarized in figure 1, and further
determining the type of repair data that is needed “approved” repair data, explains the differences explained in subsequent sections of this article.
to meet regulatory requirements. Under the United between the FAA and EASA regulations, outlines Boeing and the FAA expect appropriately
States Federal Aviation Administration (FAA) the repair data section of the new bilateral approved airline, maintenance, and MRO person-
system, repair data can be classified as either agreement between the U.S. and the EU, and nel to assess whether a repair is major or minor,
“acceptable” or “approved.” In European Aviation familiarizes operators with the most effective and to use an assessment process preapproved
Safety Agency (EASA) regulations, all repair data ways to receive the appropriate repair data needed by their national aviation authority.
shall be “approved.” from Boeing.
In addition, a new bilateral agreement
FAA SYSTEM
between the United States (U.S.) and the European
APPROVED VERSUS
Union (EU) is refocusing attention on the issue of ACCEPTABLE REPAIR DATA Operators under FAA jurisdiction are responsible
approved versus acceptable repair data. Many
for ensuring that repairs are accomplished
operators and maintenance, repair, and overhaul
By understanding the type of repair data needed according to all applicable regulations under
(MRO) organizations in the EU are not familiar with
for each classification of damage, operators can U.S. Code of Federal Regulations 14 CFR Part 43.
“acceptable” repair data because it is not
minimize delays and return airplanes to revenue Airplane repairs of damage can be classified as
commonly allowed by EASA.
service quickly. The FAA and EASA definitions of either “major” or “minor.” This assessment is
each classification of damage and authorized repair

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 FAA VERSUS EASA
OVERVIEW
Figure 1

Although the FAA and EASA FA A D E F I N I T I O N

have similar definitions PA R T 1
for what constitutes major
and minor repairs, the
requirement for acceptable
or approved data is quite Major repairs are those that
different. if improperly done, might
appreciably affect weight,
balance, structural strength,
performance, power-plant
M A J O R R E PA I R operation, flight characteristics,
or other qualities affecting
airworthiness or that; are not
done according to accepted
practices or elementary
operations.

Minor repair is any repair,

other than a major repair.

M I N O R R E PA I R

based on the scope and complexity of the repair that can be used for maintenance, minor repair, approval of the repair data is required. Operators
and the experience and capability of the operator. or minor alteration that complies with applicable have many ways to obtain FAA-approved repair data:
The responsibility for determining whether a airworthiness regulations. Acceptable data can be
N Accomplish the repair per the Boeing structural
repair is major or minor rests with operators, repair provided by a type certificate (TC)/supplemental
repair manual (SRM) because all repairs in the
stations, and holders of an inspection or mainte- type certificate (STC) holder or third-party operator
Boeing SRM are FAA approved.
nance authorization. Because the classification of or MRO qualified engineer.
N Apply to the FAA directly.
a repair as either major or minor is not a 14 CFR FAA AC 120-77 defines approved data as:
N Use a DER, who has a “special delegation”
Part 25 requirement, this classification is outside “Technical and/or substantiating data that has
from the FAA, to approve data for major repairs
the scope of FAA authority delegated to Boeing. In been approved by the FAA” or by an FAA delegate
using an FAA form 8110-3.
the U.S., all operators have authority to use such as a FAA-designated engineering represen-
N Where FAA authorization has been delegated to
acceptable repair data for minor repairs without tative (DER) or FAA-authorized representative (AR).
Boeing under delegation option authorization (14
additional FAA approval. If the operator’s qualified personnel determine the
CFR Part 21.231), a Boeing AR may approve the
FAA Advisory Circular (AC) 43-18 describes damage necessitates a major repair, then FAA
engineering repair data on an FAA form 8100-9.
acceptable data as data acceptable to the FAA
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 EASA DEFINITION FA A R E PA I R E A S A R E PA I R
PA R T 2 1 D AT A D AT A

All other repairs that are Approved data from the FAA Approved by EASA or
not minor. or FAA designee — designated EASA design organization
engineering representative (DER) approval (DOA)
(Ref. EASA GM 21A.91 and
, or authorized representative (AR)
GM 21A.435[a])

ics,

ot

A minor repair is one that Acceptable data from Approved data by EASA or
has no appreciative effect on the operator or EASA DOA; or acceptable
the mass, balance, structural type certificate (TC) / data from the TC/STC holder
strength, reliability, operational supplemental type or third party*
characteristics, noise, fuel certificate (STC) holder
venting, exhaust emissions,
or other characteristics
affecting the airworthiness
of the airplane.

* Acceptable data developed under the FAA system for a minor

repair will be automatically approved by EASA under the
pending U.S.-EU Bilateral Aviation Safety Agreement.

EASA SYSTEM an EASA DOA must rely on EASA directly or con- U.S.-EU BILATERAL AVIATION
tract with an EASA-authorized DOA holder to have SAFETY AGREEMENT
EASA regulations (Commission Regulation Euro- the repair classified.
pean Community [EC] 2042/2003 Annex I Part M) There are different levels of EASA DOA Both the FAA and EASA continue to work to
require “approved” data for both minor and major authorization. For example, Basic DOA allows the harmonize regulations with joint principles and
classifications of airplane repairs. This policy is in holder to classify major or minor repairs and processes. To minimize the impact to operators
contrast to the FAA system that requires “approved” approve minor repairs only. A TC/STC holder with resulting from two distinct repair data approval
data for major repairs only and “acceptable” data an EASA DOA can also approve both major and systems, a special interim provision from the
for minor repairs. minor repairs. U.S.-EU Bilateral Aviation Safety Agreement was
Additionally, EU operators under EASA regu- Regulations similar to EASA’s are being released on April 1, 2007.
lations cannot make determinations of minor or adopted by global national aviation authorities Amending the Implementation Procedures for
major for repairs unless they hold an EASA design outside the EU, including Australia and India. Airworthiness (IPA) in existing Joint Aviation
organization approval (DOA). EU operators without Authorities (JAA) bilateral agreements between the
U.S. and six EU member states (France, Germany,
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 BOEING REPAIR SKETCH

-2 Tripler
STA STA STA STA STA
410 -1 Doubler 420 430 440 450
6 EQUAL SPACES 7 EQUAL SPACES
– 7.50 3.05 3.05 – 8.75

S-2R (LNSPL -251) XF FN

C
3.60 SEC
XF FN 1.80 X2G 3N (8 PLACES)
C C (CSK IN-619)

1.20 (TYP) SEE

RBL + + ++ + + + + + + + + + + + + + + + +++ + IBIIC12
5.00 .60 (TYP) + + ++ +++ +
+ + ++ + + + + + + + + + +.98 +
BSC
+ + + + +++ +
.40 (TYP) XF FN
.40 (TYP) .49 C
2 EQ SPS (TYP) XF FN .90
C 1.80

S-1

+ +
+ +
+ +
1B9-25
SCALE 1/2 + +
FND,
+ +
Stagger fasteners
these areas Antenna cutout Trimout

1. Sample repair design for

fuselage skin cracks

2. Operator layout of 3. Operator repair

repair design doubler installation

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Example of a wing spar
chord repair.

Example of a wing spar

web splice repair.

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 STRUCTURES 8110-3/8100-9
REQUESTS VERSUS FLEET SIZE
(707, 727, 737, 747, 757, 767, 777)
Figure 2

= 8110-3/8100-9

= Fleet Size

12500 12500

12006
10000 10000

9252
7500 7500
8083

7817
7588

7373
6624
6071

5000 5000
5240
4375

2500 2500
2932
2376
2289
2070
2059

0 0

1992 1999 2006

The number of requests for approved repair data via an

FAA form 8100-9 for 707, 727, 737, 747, 757, 767, and
777 airplanes has increased nearly sixfold since 1992,
a rate disproportionate to the growth in the size of the
worldwide Boeing fleet.

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 The data suggests
that operators may not
fully understand the
regulatory requirements
that dictate approved
versus acceptable data.

Italy, Netherlands, Sweden, and the United The aging of the airplane fleet alone does not model service letter “BCA Review and Delegated
Kingdom), this provision clarifies the mutual appear to explain this significant increase in opera- Approval of Airplane Structural Repair and
acceptance of repair data between the FAA and tor requests. The data suggests that operators may Modification Data” (e.g., 737-SL-51-027-E). Using
EASA. This allows acceptable structural repair data not fully understand the regulatory requirements this process helps ensure that all the information
from TC / STC holders under the FAA system to be that dictate approved versus acceptable data, or needed to evaluate the repair design is available
automatically approved by EASA. are asking for approved data for nonregulatory and can be efficiently processed.
Although this means Boeing will continue to purposes, such as for records to support future
provide an 8100-9 approval for major repairs, an EU airplane ownership transfer. There is also a higher
SUMMARY
operator and MRO in those six EU member states demand for approved data from EU member states
can now use Boeing acceptable data for minor repairs than the rest of the world.
Boeing strives to provide accurate and responsive
without additional EASA or EASA DOA approval. The increased demand challenges Boeing
fleet support to operator requests for repair data.
A new bilateral agreement between the U.S. Delegated Compliance Organization resources,
By understanding applicable regulations, using the
and the EU is planned to be signed in the near resulting in extended — and often unnecessary —
Boeing SRM, and following established procedures,
future, allowing implementation of the mutual airplane downtime.
operators can receive the information they need
acceptance of repair data by all EU member states.
efficiently, reducing airplane downtime. The value
HOW OPERATORS CAN GET THE DATA of structural repairs contained in the Boeing
GROWING DEMAND THEY NEED FROM BOEING SRM is that they are available for immediate use
FOR APPROVED DATA by the operator and are approved by both the
Boeing encourages all operators and MROs to FAA and EASA.
During the last 15 years, Boeing has seen a use the Boeing SRM whenever possible, because For more information, please contact your
significant increase in demand for approved all repairs in the SRM have been approved by local Boeing Field Service representative or Dale
structural repair data requests from operators, the FAA. Additionally, operators and MROs should Johnson at dale.r.johnson2@boeing.com or Ron
while the number of Boeing airplanes in the familiarize themselves with FAA AC 120-77, Lockhart at ronald.j.lockhart2@boeing.com.
fleet has remained somewhat level (see fig. 2). which provides guidance for minor deviations
This increase primarily involves Boeing 707, 727, from allowable damage limits in the SRM and
737, 747, 757, 767, and 777 airplanes. The other manufacturer’s service documents resulting
demand for approved structural repair data for in greater applicability to more repairs.
the Douglas fleets — DC-8, DC-9, MD-80/90, Finally, when submitting a request to Boeing for
DC-10, MD-11, etc. — has remained relatively either acceptable or approved repair data, follow
steady during the last several years. the process contained in the appropriate multi-

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