Major/Minor Repairs Q&A
Q: We are a certificated repair station. Can we create our own methods, techniques and practices acceptable to the Administrator, even if those procedures are not reflected in the manufacturer’s maintenance instructions?
A: Yes, but remember that you must obtain approval of that technical data when the work will result in a major repair or alteration.
Q: What constitutes “approved data” in support of a major repair or alteration?
A: In Chapter 12 of its Aviation Maintenance Technician Handbook, the FAA indicates examples of approved data as AD Notes, STCs, TCDS’s, DAS specific authorizations, DER specific delegations, and FAA-approved manufacturer service bulletins.
Q: Who may approve technical data supporting a major repair?
A: The Administrator, or an appropriately authorized Designated Engineering Representative (DER). A DER is a representative of the Administrator with the ability to approve technical data supporting a major repair or alteration.
Q: We are performing major repairs according to the manufacturer’s maintenance manual. Does the manufacturer’s maintenance manual have to be approved by the FAA in order to use it for accomplishing major repairs?
A: No. The FAA addressed this issue several years ago in its response to a consistency and standardization initiative request. Major repairs can be accomplished using a manufacturer’s maintenance manual that was developed from previously approved technical data; there is no need for separate FAA approval of the data substantiating the manual, which contains the methods, techniques and practices acceptable to the agency for performing the work.
Q: I am a repair station, what paperwork do I need to complete for a major repair or alteration?
A: 14 CFR part 43 Appendix B generally requires that major repairs and alterations be recorded on Form 337. However, paragraph (b) creates an exception to the use of the 337 for recording major repairs. The exception allows a repair station performing such (note that this exception applies only to repairs, not alterations) in accordance with a manual or specification acceptable to the Administrator to use the customer’s work order in lieu of a 337. To review the additional requirements for the exercise of this exception, see Appendix B.
Q: Where do I send my Form 337?
A: When executing a 337, one copy should go to the aircraft owner, and the other should be sent to the FAA Aircraft Registration Branch, AFS-750, P.O. Box 25504, Oklahoma City, OK 73125-0504. Alternately, if using the electronic form 337, you must sign up for an account through your local FSDO to obtain access to the electronic filing system. (See FAA website for detailed instructions on eForm 337)
Q: I am a certificated mechanic with both an airframe and powerplant rating. Can I approve a major repair for return to service?
A: Not unless you also have an inspection authorization (See 14 CFR § 65.95(a)).