The FAA has been working on a clear definition of what is major and what is minor when it comes to repairs for several years. A Major-Minor working group is trying to gain a consensus on a flow chart including "No, No-Go" questions that will guide us to the correct decision. As months continue to pass while we wait for clear guidance, aircraft continue to be repaired and we continue to make our best decision on the magnitude of the repair. I want to discuss the major repair issue this month and attempt to draw some clarity with the information that we do have.
Major or Minor? Who decides?
FAR Part 43.9 (a) appears to put the decision in the hands of the "person performing the work". Part 43.9 spells out the documentation requirements for all types of maintenance, except scheduled inspections. The last portion of that rule makes reference to the documentation means (which we will discuss later) and places the responsibility of proper documentation in the hands of the repairer. Keep in mind, the person authorized to perform a major repair is no different than a person authorized to perform a minor repair and or maintenance work. The difference lies in the authority to approve the major repair. Ref. FAR Part 65. The technician or repair station performing the work has to decide whether the repair is major or minor and, when appropriate, call in an appropriately rated inspector to approve the repair.
How do I decide?
There are two places to go within the regulation to get input for making the determination between Major and Minor Repair. First, FAR Part 1 "Definitions and Abbreviations" has a very broad definition for "Major Repair" leaving much to the best judgment of the repairer. Secondly, FAR Part 43 - Appendix A actually lists the types of repairs in different categories that are, according to the administrator, major repairs. Each list in the appendix (although outdated) is fairly detailed and should be reviewed carefully when making the decision. While looking to the regulation to make determination ask yourself, "Is there any way that someone else could look at this repair and the rule and consider it a major repair?" If there is, figure that someone will and complete the appropriate paperwork.
There are two important distinctions to consider when discussing major Vs minor repairs.
1. The data/instructions used to perform the repair.
2. Documentation of the repair in the aircraft's maintenance records.
However, neither of these distinctions should enter into the decision as to whether or not the repair is major.
Calling a repair a minor repair because you could not find "Approved Data" for the repair is a common trap. It is also the reason to consider how you will perform the repair after you have determined the extent of the repair and whether or not it is major.
What is Approved Data?
Once you know you are making a major repair, you must use approved data for the repair. The best reference for finding what is considered Approved Data today is FAA Airworthiness Inspector's Handbook 8300.10, (Volume 2, Chapter 1, Section 1, paragraph 5., A., (9)). The Approved Data used must be referenced in the documentation of major repairs. It is important to note that some data many believe to be approved is not. For example: Airframe, Engine and Propeller manufacturer's manuals are not approved unless specifically called out as "FAA Approved".