EASA regulations applicable to repairs can be found in Part 21A (Subpart M) and Part M (M.A 304, 305, 708, 710). In addition, the EASA has published Guidance Material (GM) and Acceptable Means of Compliance (AMC), which provide additional insights into the regulatory requirements of the repair process.
Repairs performed under EASA regulations require approved data for both minor and major classifications (as opposed to repairs performed under FAA regulations. The determination of minor or major classifications for repairs has to be performed by an organization holding an EASA Design Organization Approval (DOA). Operators without an EASA DOA must rely on the EASA directly or contract with an approved DOA organization to classify and approve the repair. There are many different levels of EASA DOA authorizations, ranging from authorization to design and certify major repairs and alterations (i.e. Type Certificate holders) to authorization for approval of minor changes or repairs only.
The EASA regulations allow for various ways to develop and approve repairs:
●Based on the manuals or ICA (e.g. SRMs, Maintenance Manuals, Engine Manuals, etc.) provided by the TC holder or STC holder
● By an approved DOA organization (for minor repairs only)
● By the STC holder or the EASA for minor and major repairs
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:
● 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.
Since 1 May 2011, a bilateral is in force between the US and the EU which consolidates earlier bilateral 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.
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