Major vs. Minor

(3) Give the aircraft owner a maintenance release signed by an authorized representative of the repair station and incorporating the following information..."

I want to point out one important detail about this exception. This one exception to the requirement to use an FAA Form 337 applies to major repairs only. That being said, if the entity performing the work is a repair station certificated under Part 145 it may elect to provide the aircraft owner or operator a signed copy of the work order in place of the Form 337. It is critically important though, to understand the limitations behind this exception. It is not real clear in the appendix. Regardless of how the major repair is approved for return to service, whether it be by use of the Form 337 or a signed copy of the work order, the work must be performed in accordance with approved data. Take a look at Part 65.

65.95 Inspection authorization: Privileges and limitations

"(a) The holder of an inspection authorization may -

(1) Inspect and approve for return to service any aircraft or related part or appliance (except any aircraft maintained in accordance with a continuous airworthiness program under Part 121 of this chapter) after a major repair or major alteration to it in accordance with Part 43 of this chapter, if the work was done in accordance with technical data approved by the Administrator..."

145.201 Privileges of certificates

"(c) A certificated repair station may not approve for return to service:

(2) Any article after a major repair or major alteration unless the major repair or major alteration was performed in accordance with applicable approved technical data."

There is a misleading statement in the appendix that begs a question. Notice it states, "For major repairs made in accordance with a manual or specifications acceptable to the Administrator, a certificated repair station may..." I have several times approached the FAA with this statement to justify the use of data that has not yet been approved and found in all cases, that is not the intent. Look again at 14 CFR Part 145.201:

145.201 Privileges of certificates

"(c) A certificated repair station may not approve for return to service:

(2) Any article after a major repair or major alteration unless the major repair or major alteration was performed in accordance with applicable approved technical data."

Clearly, a repair station must use approved data for major repairs even when it elects to approve for return to service in accordance with 14 CFR Part 43 Appendix B (b).

I believe the intent of this statement stems from this. Back when this old rule was written, approved data for repairs was rare and the common practice was to use AC 43.13-1A as data to support the repair. You may be surprised to find out that you can still use AC 43.13-1B (revised about five years ago) as approved data for major repairs.

AC43.13-1B Introduction

1. PURPOSE.

"This advisory circular (AC) contains methods, techniques, and practices acceptable to the Administrator for the inspection and repair of nonpressurized areas of civil aircraft, only when there are no manufacturer repair or maintenance instructions. This data generally pertains to minor repairs. The repairs identified in this AC may also be used as a basis for FAA approval for major repairs. The repair data may also be used as approved data, and the AC chapter, page, and paragraph listed in block 8 of FAA Form 337 when:

1. The user has determined that it is appropriate to the product being repaired;
   
   
2. It is directly applicable to the repair being made; and
   
   
3. It is not contrary to manufacturer's data."

I believe this is why Appendix B uses the term accepted rather than approved. What I see as another opportunity for revision. The AC is simply acceptable data and can only be used as approved data under these clearly defined conditions.