Part of what makes aviation safe is the extensive system of checks and oversight designed to ensure that work is performed in accordance with approved standards and subjected to the necessary level of scrutiny. Beyond compliance with OEM manuals, repairs may also require review and approval by the applicable aviation authority.

Although serving similar purposes, each aviation authority applies its own framework for the approval and recording of structural repairs, particularly for repairs not covered within the SRM.

Here are some key examples of forms* you may need to check across different authorities.

FAA (United States)

Under FAA, FAA Form 337 (Major Repair and Alteration (Airframe, Powerplant, Propeller, or Appliance)) is the most commonly used for documenting major repairs and major alterations. 

An important part of the repair approval process is the use of approved technical data. FAA Order 8300.16 includes a useful overview of the repair and alteration data approval process. 

Alternative approval routes may also be obtained through authorized designees such as Designated Engineering Representatives (DERs) or Organization Designation Authorization (ODA) holders, including organizations such as Boeing, which requires either Form 8110-3 or 8100-9 as applicable.

• FAA Form 8110-3 – Statement of Compliance with Airworthiness StandardsCommonly associated with technical data approval made under Designated Engineering Representatives (DERs).

• FAA Form 8100-9 – Statement of Compliance with Airworthiness StandardsCommonly associated with technical data approval made under an ODA holder’s authorized procedures.

  
  

EASA

Under EASA, repairs are approved under Part 21 Subpart M – Repairs, which defines repair classifications, approval requirements, and applicable privileges. Unlike the FAA framework, EASA does not use a direct equivalent to FAA Form 337.

Instead, repair approvals are handled through Minor or Major Repair Design Approvals, either directly through EASA or under Design Organisation Approval (DOA) privileges.

Aside from regulatory approvals, OEM-approved non-SRM structural repairs are also commonly supported through manufacturer approval documents, such as:

• Repair Design Approval Sheet (RAS) for Airbus

• Structural Repair Approval Sheet (SRAS), or equivalent, for ATR
  

As with the major aviation authorities, other countries also employ their own repair approval and recording systems.

Indonesia and Malaysia provide good examples of how local authorities may adopt concepts similar to FAA or EASA frameworks while maintaining their own procedures, forms, and approval structures.

DGCA Indonesia

In Indonesia, repair and modification approvals are administered by the Directorate General of Civil Aviation (DGCA). Common forms encountered include:

• Form No. 43-337 – Return to Service Embodiment of Alteration or Major RepairUsed to record alterations or major repairs performed on aircraft, airframes, powerplants, propellers, appliances, or spare parts. As implied by its numbering and structure, the form is conceptually similar to FAA Form 337.

• Form No. 21-09 – Application for Approval of Modification and Major Repair

These forms are generally accessible through the Indonesian Ministry of Transportation aviation platform.

CAAM Malaysia

In Civil Aviation Authority of Malaysia (CAAM), repairs are managed under the Malaysian airworthiness framework, which broadly follows a major/minor repair classification concept similar to EASA. Depending on the organisation’s privileges, certain minor approvals may be handled under Design Organisation Approval (DOA) privileges. A document you can reference to for CAAM is the Civil Aviation Guidance Material – 8106.

Common CAAM forms include:

• CAAM/AW/8104-02 – Application for Approval of the Design of Major Modification and Major Repair

• CAAM/AW/8104-03 – Application for Approval of the Design of Minor Modification and Minor Repair

• CAAM/AW/8104-04 – Statement of Compliance – STC / Modification / Repair

  
  

Additional Things to Note

• Different documents serve different purposes

Approval data, return-to-service records, and release certificates each serve different functions within the repair process. Depending on applicability, supporting release documentation such as EASA Form 1 or FAA Form 8130-3 may still be required.

• Check the applicable authority and latest revision

Always confirm the requirements of the aircraft’s applicable authority and use the latest approved forms and procedures. Regulatory forms, guidance materials, and approval processes are periodically revised.

Summary

While the underlying objective remains the same, each aviation authority applies its own framework for the approval, substantiation, recording, and release of repairs. Understanding the distinction between repair approval data, return-to-service documentation, and release certification is essential when reviewing aircraft records, particularly for non-SRM or major structural repairs.

This remains only a surface-level overview, and the latest applicable regulations, guidance materials, and bilateral acceptance arrangements should always be reviewed. Additionally, where repairs incorporate or interface with STCs, the corresponding STC approval, validation, and supporting documentation processes must also be considered.

Reference:

https://www.faa.gov/sites/faa.gov/files/aircraft/air_cert/design_approvals/dah/use_of_previously_approved_data.pdf 

https://www.easa.europa.eu/en/document-library/application-forms#certification 

https://www.caam.gov.my/wp-content/uploads/2021/10/CAGM-8106-Design-of-Repairs.pdf